TXX-6676, Forwards Rev 0 to QA Dept Procedure Nqa 3.07-1.01, Technical Audit Program & Rev 3 to Engineering Assurance Program Engineering Functional Evaluation,Comanche Peak Steam Electric Station
| ML20238F022 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/08/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20238F024 | List: |
| References | |
| TXX-6676, NUDOCS 8709150345 | |
| Download: ML20238F022 (8) | |
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Log # TXX-6676
=' 9 File # 10004 nlELECTRIC September 8, 1987 wmim c. counsa becutive Vkt President
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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 TECHNICAL AUDIT PROGRAM AND ENGINEERING FUNCTIONAL EVALUATION Gentlemen:
The Corrective Action Program and its results will be significant factors in our request to the NRC for an operating license for CPSES.
Because of that important role, TV Electric has implemented significant measures to provide added levels of confidence that the Corrective Action Program is conducted effectively.
Those measures are the TV Electrical Technical Audit Program and the Stone and Webster Engineering Corporation Engineering Functional Evaluation. Although the programs were initiated for the primary purpose _of providing oversight of design validation activities, both programs also address additional matters. Attached for your information is a copy of the program document and an executive summary for each of those programs.
In 1985 the TU Electric Quality Assurance Department commenced its technical oversight of engineering services contractors as part of its vendor audit
-activities. The Technical Audit Program which has been underway since January 1987 is an outgrowth of that initial oversight effort and represents a significant expansion of the scope, depth, and intensity of technical oversight activities.
The Technical Audit Program is conducted under the TV Electric Quality Assurance Program and is headed by the Supervisor, Technical Audits who reports to the Director of Quality Assurance via the Manager of Quality Assurance.
The Technical Audit Program focuses on the Corrective Action Program as a whole, emphasizes technical rather than programmatic assessments, and embodies both vertical and horizontal concepts.
This approach results in indepth technical evaluations of significant portions of the Corrective Action Program by highly qualified and experienced personnel.
In addition to oversight of design validation activities, the Technical Audit Program will evaluate Project actions related to Comanche Peak Response Team recommendations and Project commitments resulting from the Comanche Peak Response Team's conduct of the Issue Specific Action Plans.
The Technical Audit Program in level of effort, qualifications of personnel, and depth of review is a significant activity.
8709150345 070908 PDR ADOCK 05000445 Of A
PDR MM North Obsc Stnet LB 61 Dallas, Texas 73201
4 TXX-6676
- September 83 1987
- Page 2 The' Engineering Functional Evaluation.which'has been underway since May 1987 is modeled after similar Stone and Webster Engineering Corporation efforts at other nuclear power plants within the recent past. The Engineering Functional.
' Evaluation is conducted under the Stone and Webster Engineering Corporation Quality Assurance Program and is headed by a Program Manager who reports to
- the Stone and Webster Engineering Corporation Chief Engineer, Engineering Assurance.
The Engineering' Functional Evaluation employs a vertical ~ slice approach in the evaluation of the Containment Spray System, Control Room HVAC System, and Safeguards Building.
This approach results in indepth evaluations
- of significant portions of these subjects by a team of highly qualified and experienced engineers.
In addition to' oversight of design validation
. activities, the Engineering Functional Evaluation will evaluate the utilization of design data in the testing, maintenance, and operations.
programs, and will evaluate the controls that will assure that the design is maintained throughout the life of the plant. The Engineering Functional Evaluation in level of effort, qualifications of personnel, scope, depth, and -
documentation'is comparable to other integrated design inspections and verification efforts conducted on other plants.
Concerns identified during the conduct of the Technical Audit Program and the Engineering Functiona1' Evaluation are independently initiated by the audit /
evaluation teams, fully documented, and sent to the appropriate portion of the engineering organization for evaluation and determination.of cause, extent of condition, and corrective and preventive actions.
Responses are evaluated for acceptability by team members and followup evaluation is performed to verify implementation of corrective actions..
The Technical Audit Program and the Engineering Functional Evaluation compliment each other and collectively provide a design oversight and review effort that is unprecedented in the nuclear industry, and reflect'TU Electric's approach in going beyond minimum requirements. These oversight efforts are. coordinated to maximize coverage and share experiences that may indicate a need to emphasize specific review activities. This coordination effort includes at least monthly meetings between the Stone and Webster Engineering Corporation Chief Engineer, Engineering Assurance and the TV Electric Director of Quality Assurance and members of their staffs.
' Additionally, monthly briefings of the status of each program are jointly provided to the Comanche Peak Response Team Senior Review Team and the TV Electric Vice President of Engineering and Construction.
We invite the staff to review the Technical Audit Program and the Engineering Functional Evaluation and their implementation. We will notify the staff of any significant changes in the scope of these programs. We will make available to the staff the Technical Audit Program audit reports and the final Engineering Functional Evaluation report.
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. September 8, 1987..
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Should you: desire. additional:information on these programs, please contact me..
Very truly.yours b
W. G. Counsil
' RSB/mlh-Attachment
- Enclosure Attachments:
- 1.
Executive Summary - Technical Audit Program 2.-
Executive' Summary
' Engineering Functional Evaluation.
3.
Technical Audit Program'-(NQA 3.07-1.01, Rev. 0)
..'4. ; Engineering Functional Evaluation (87-EA-047/EA306, Rev. 3)
- c Mr. C. I. Grimes Mr. H. 'E. Schierling.
- Mr R..D. Martin, Region IV Resident Inspectors, CPSES (3).
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_ to TXX-6676 September 8, 1987 Page 1 of 2 EXECUTIVE
SUMMARY
TECHNICAL AUDIT PROGRAM i
The Technical Audit Program is an integral part of the TV Electric Quality Assurance Program. This program was established to (1) assure the technical i
and programmatic effectiveness of the Corrective Action Program, and (2) provide oversight of Project actions in response to actions recommended to the Project by the Comanche Peak Response Team and commitments made by the Project to the CPRT as a result of the conduct of the Issue Specific Action Plans (ISAPs).
The Technical Audit Program achieves these objectives by means of a comprehensive series of technical audits using personnel technically qualified in and independent of the areas being audited.
The Technical Audit Program is executed in a planned and documented manner to provide objective evidence of completion of the planned scope and depth of the program. The Technical Audit Program utilizes the TV Electric Quality Assurance Audit Program procedures to plan, schedule, execute, report, i
followup, and close technical audits. Audits utilize checklists to guide the conduct of each audit. The audit teams are comprised, as appropriate, of i
experienced, senior level engineers and analysts with demonstrated expertise in specified technical disciplines such as:
Seismic and Stress Analyses; Fluid Systems Design; Equipment Qualification; Hazards Analyses; Instrumentation and Control Logic, Circuitry Design and Electrical Power Systems Analyses; Nuclear Construction; and Startup Testing.
Audits of the Corrective Action Program are planned to cover discrete elements or phases of the eleven scopes of design validation activities from design basis document development through as-built reconciliation of the physical plant with the final validated design. Audits are scheduled to examine i
specific elements of work as the work progresses at the locations where principal portions of the work are being accomplished. Audits are planned to provide a vertical as well as horizontal examination of the design validation process.
Audits of Project actions in response to actions recommended to the Project by the CPRT and commitments made by the Project to the CPRT as a result of the conduct of the ISAPs will focus primarily on those commitments which the CPRT views as mandatory.
The scope of the Technical Audit Program is being covered in two modules:
o Conduct of Corrective Action Program 1
o Project Implementation of ISAP Recommendations / Commitments j
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___________________O to TXX-6676 September 8, 1987 Page 2 of 2 The Conduct of Corrective Action Program Module will determine if the:
o Design validation procedures are available and adequate.
o Design basis documents are developed and reconciled with licensing commitments and reflect operating / performance requirements under normal and upset. conditions.
o Generic Technical Issues are correctly reflected in associated Design Validation Packages and are correctly incorporated into design f
procedures and specifications, and satisfactorily implemented in the validation program.
o Design drawings, specifications, calculations and analyses are
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validated in accordance with established design criteria and reflect proper inputs, reasonable assumptions, control of interfaces, correct analytical methods including computer programs, and produce reasonable results.
o Third-party. Discrepancy Issue Reports are resolved.
o The "as-built" or "as-installed" status of CPSES is considered in the design validation process.
o hequired design modifications are developed and implemented, and the impact of modifications on interfacing design activities is addressed.
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Post Construction Hardware Validation Program implementation demonstrates technical acceptability of existing installations as compared to design requirements.
o Final reconciliation of existing CPSES systems, structures and components with the final approved design is accomplished.
The Project Implementation of ISAP Recommendations / Commitments Module will, for each recommendation / commitment deemed mandatory by the CPRT, assure that the:
o Responsible Project party has captured it in a formal control system.
o Resolution actions as approved by the CPRT are effectively implemented.
o Corrective actions have been completed and documented.
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In summary, the Technical Audit Program is a significant effort to provide an added level of confidence that the Corrective Action Program is conducted effectively and that the mandatory corrective actions relating to CPRT-identified issues are implemented.
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. Attachment 2 to TXX-6676 l
September 8, 1987
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EXECUTIVE
SUMMARY
ENGINEERING FUNCTIONAL EVALUATION
- The Engineering Functional Evaluation (EFE) is a four part program for performing an independent, in-depth technical evaluation of the Corrective Action Program for CPSES to provide additional assurance that the arogram is effectively implemented. The EFE also includes an evaluation of tie TU Electric design control program to provide additional assurance that appropriate measures are in place for maintaining the design basis during plant operation. The scope of the EFE is being covered in the following four modules:
o Design Completion Activities o
Design Data Utilization - Testing
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' Design Data Utilization - Maintenance and Operations o
Operating Plant Design Control The first' three modules. represent the indepth technical evaluation of selected systems and structures..The systems and structure selected for evaluation are the Containment Spray and Control Room HVAC Systems and associated electrical and control' systems, and the Safeguards Building. They were selected based on their complexity and nuclear grade classification, and because they. involve representative' design activities being conducted by a portion of the design organization. The last module is primarily a programmatic assessment of the process that TU will use to maintain the design during operation of the plant.
The EFE is performed in a formal, preplanned, and fully documented manner to-provide objective evidence of completion of the planned scope and depth of the evaluation and to provide complete records of results and conclusions. The EFE uses a vertical slice approach which results in significant portions of the selected systems and structures being reviewed in great detail The Engineering Functional Evaluation is organized on a discipline approach with the following disciplines represented on the Evaluation Team:
Electrical, Equipment Qualification, Engineering Mechanics (Piping Systems & Supports),
Engineering Mechanics (Mechanical), Engineered Safeguards, Radiation Protection, HVAC, I&C, Power, Materials, and Structural.
The methods utilized in the evaluation process are summarized below:
o Evaluation Plan - The detailed Evaluation Plan describes the purpose, scope, depth and the approach to the evaluation. The plan is a comprehensive document which describes the specific systems and structures selected for evaluation, and describes the engineering activities selected for evaluation for each engineering discipline.
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' Attach' ment'2 to TXX-6676 September 8, 1987-
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o! ' Evaluation Team - The Evaluation Team is comprised of experienced-engineers having 'significant specific experience in the activity being evaluated.
The team is composed of approximately 25 individuals with representation from EBASCO, IMPELL, and SWEC.- None of the team has
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previous design responsibility at CPSES..The team.is headed by a
. Program Manager who reports to the SWEC Chief Engineer, Engineering.
Assurance..
o Detailed Planning - The Evaluation Team developed detailed Review Plans (Checklists) of attributes to be evaluated.
The Review Plans are structured to provide a logical vertical-approach for verifying that' regulatory requirements and design bases as specified in the license application are correctly implemented in the design and physical plant.
For-the evaluation of the operating plant design control program, Review Criteria Documents have been developed which describe the controls that would be expected to exist in a program to maintain the design basis of the plant.-
o' Conduct of the Evaluation - Review Plans are fully annotated by_ team members to document the' results of the evaluation. Concerns identified are documented as formal Action Items and are provided to the appropriate portion of the engineering organization for evaluation and determination of cause, extent of condition, and corrective and l preventive actions.
Responses are evaluated for acceptability by team members and followup evaluation is performed to verify implementation of' indicated' actions, o
_ Reporting - At the conclusion of the evaluation, a summary of the results of the evaluation and overall conclusions concerning the adequacy and implementation of the corrective action processes will be reported.
' The Design Completion Activities Module evaluation will determine if:
o The design is consistent with and supports the FSAR and other licensing commitmerits (including system function, and compliance with documents committed to in the FSAR, valid design practices, Design Basis Documents, and NSSS/ vendor requirements and criteria).
o' Technically adequate calculations are available to support the design.
o Diagrams, specifications, drawings and vendor documents are technically complete and consistent with each other, o
Design changes and modifications are technically adequate and are consistent with licensing commitments, o
implementation of resolutions to known industry problems are technically adequate.
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o Documentation packages are technically adequate, verifiable and support the as-constructed condition.
o Inter-discipline interfaces are adequate.
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o Post construction hardware validations adequately assess the as-i installed condition.
The vertical slice approach is carried through in the Design Data Utilization Modules evaluation to verify the utilization of validated design data in the i
testing, maintenance, and operations programs.
The depth of this portion of the EFE is illustrated by the following example topics:
o Appropriate periodic or surveillance testing is to be performed consistent with licensing commitments or engineering data.
o Tests have been performed using the latest design requirements or dispositioned as no further testing being required.
o Setpoints have been properly incorporated into the surveillance and calibration reports.
o Maintenance procedures have been developed utilizing requirements from licensing commitments, Design Basis Documents, design and procurement specifications, Codes and Standards, and manufacturer requirements.
o Post-maintenance testing verified that the system is capable of meeting design basis requirements and is therefore ready for return to
- service, o
Operating procedures (i.e., system, general plant, abnormal and emergency) affecting the safe operation of the system being evaluated have included appropriately validated requirements from plant licensing commitments, Design Basis Documents, design and procurement specifications, Codes and Standards, and manufacturer requirements.
o System modifications have been reflected in operator instructions and training.
-The Operating Plant Design Control Module evaluation will determine the completeness of the engineering procedural system with respect to those i
activities requiring engineering involvement. The purpose of this module is to establish confidence that TV Electric Comanche Peak Engineering has the l
appropriate controls in place to maintain the design basis during operation of the plant.
In summary, the EFE is a significant independent design evaluation effort comparable in method, depth, and documentation to a typical design evaluation, with an expanded scope to include the testing, maintenance, and operations and operating plant design control areas.
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