TXX-6712, Forwards Executive Summary of post-const Hardware Validation Program Engineering Evaluation Methodology,Per 870729-30 Public Meeting.Program Validates Final Acceptance Attributes for safety- & Selected nonsafety-related Hardware

Forwards Executive Summary of post-const Hardware Validation Program Engineering Evaluation Methodology,Per 870729-30 Public Meeting.Program Validates Final Acceptance Attributes for safety- & Selected nonsafety-related Hardware

ML20238E942
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)
References
TXX-6712, NUDOCS 8709150301
Download: ML20238E942 (8)

Text

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- -- Log # TXX-6712 F9 .~~

File # 10004

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TUELECTRIC September 8, 1987 twum w nucm

. 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 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)

ENGINEERING EVALUATION METHODOLOGY

REFERENCE:

1) TV Electric Letter TXX-6631 from W. G. Counsil '

to the NRC dated August 20, 1987

2) TV Electric Letter TXX-6675 from W. G. Counsil to the NRC dated August 28, 1987 Gentlemen:

l At the public meeting on July 29 and 30, 1987, between TV Electric and the NRC, TV ElectMc presented the Post Construction Hardware Validation Program (PCHVP) as the element of TU Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related and selected non- ,

safety related hardware. TU Electric indicated that this validation of attributes defined in an attribute matrix, developed from the validated design specifications, would be implemented via physical validations (Quality Control Reinspection / Engineering Walkdowns) or engineering evaluations. Discussions at the public meeting of this methodology focused on the engineering evaluations. These discussions indir.ated to TV Electric that additional

) detail with respect to the conduct of engineering evaluations during the PCHVP might be beneficial to the NRC staff.

TU Electric is submitting the attached executive summary of the engineering r evaluation methodology that will be implemented during the conduct of the PCHVP. The information in this executive summary is intended to supplement and expand upon information provided to the NRC staff at the public meeting and via the above referenced letters submitted to the NRC staff subsequent to the public meeting.

If you have any questions in this regard, please do not hesitate to ask.

Very truly yours, ON45 l PDR W. G. Counsil Q

RSB/mlh h g Attachment ,

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-- , 7 t-TXX-6712 September 8, 1987 Page 2 c - Mr. C. I. Grimes Mr. H. E. Schierling Mr. R. D. Martin, Region IV-Resident Inspectors, CPSES (3)

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.' EXECUTIVE

SUMMARY

OF THE POST CONSTRUCTION HARDWARE G3<, '

" VALIDATION PROGRAM ENGINEERING EVAU!ATION METHODOLOGY \ J

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The Post Condrection Hardward Validstico Program (PCHVP) is that -

yM element 1 o? TU Electric's Corrective fttion Program.(CAP) which validates' '

3' tb finhl,adceptance attributes for. safety-felated and selected non- /

sa The PCHVP meets Tegulatory requirements and ,

i h g(ety glated hardw9.re. bean, developed ti be consistent with'the high sta J erg]1ence expected by TU Electric. ,

Th$ initial-input parameters to the PCHVP are condakned in the~

installation specifications. .The installation specifications implement the licensing commitments and design criteria ofJthe Design Basis Documents. (DBDs),'which were developed during the' CAP contractors' Design Validation process, r d  ;.

r s Final acceptance i$spect16n, requirements identhied in tue validated

. installation specifications were-used to devdp the PCHVP attribute ,',

matrix. ' This matrix is a complete set of fin'al acceptance attributes', "

identified for instalied hardware, \

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The PCHVP by either physical validations (not discussed in thiv, y'

• r executive summary) or through an engineering evaluation methodology, h 8

- assures that each of the. attributes defind in the attributednatriv, in

• ' 6 validated. This arogram will provide reassable assurance thahthe e validated 4 sign las been effectively implucentedj for safety-felate.f.t and '

., selected non-safety related hsrdware. '., , N l 4 .

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j 3 Jh0 PCHVP engineering evaluation is procedurally. controlled telgui6eiths '

responsible engineer through the evaluation of ehh item on the 4 ' .

attribute matrix to be dispositioned by the engineding evalc.ation f i method. Dispositions of'cach attribute will be clearly documented. If

the technical disposition of the final acceptance attribute is "not >

n acceptable" or the attribute cannot be dispositioned based on available  ! /1 information, an alternate plan consisting of additional evaluatichs, l testing, inspections /walkdowns or modification as necessary will be _lj developed to demonstrate.and document the a ceptability of the U..

attribute. The proceWre controlling this engineering evaluation is 4 /

currently (available on site for NRC staff review. The purpose of the .

J' . Executive ' Summary is to provide, for the,E st.aff's review, sufficier.t-

/, detail tezadequately describe the engineering evaluation method of:

,a validation. ' Quality Control reinspection / engineering walkdowns are >  ;

e controlled by the appropriate Field Verification Method and are not described here,in. , q

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Attachment to TXX-6712 September 8, 1987 Page;2 of 6 2.0 DETAILS-Figure 1.' astrates the process that is being used in the PCHVP engine' .ng evaluations. Each attribute identified in the attribute

11 atrix is dispositioned. Appropriate aspects of the engineering, quality, and oversight. organization are involved in this disposition.

Recommendations from the Comanche Peak Response' Team (CPRT) effort

. comprise a significant portion of this evaluation. A major component of the CPRT program has been the reinspection of a comprehensive,.' random.

sample of existing hardwt re ring an independently derived set.of inspection attributes. The reinspection was performed and the results evaluated by third party personnel per Appendix E to the CPRT Program Plan (submittal. from TU Electric via letter TXX-6540 from W. G. Counsil.

to the NRC dated June 25,1987). The scope of the reinspection covered 100$ of the then final quality accepted installed hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished product). These populations were sample reinspected to at least a 95/5 confidence level on an attribute basis per Appendix D to the CPRT Program Plan.

Corrective action recommendations were made to the TV Electric project based on the evaluated findings when a) a Construction Deficiency existed, b) an Adverse Trend existed, or c) an Unclassified Trend i existed,. all as defined per Appendix E to the CPRT Program Plan.

The PCHVP assures that all CPRT recommendations are properly dispositioned.

Figure 1 illustrates that, during the engineering evaluation of a given ll attribute from the PCHVP' attribute matrix, the initial task of the responsible engineer is to determine if any of the following statements are true:

a. The attribute was recommended for reinspection by the CPRT.

b. Design Validation resulted in a change to design (e.g., any design document, Corrective Action Request (CAR), Significant Deficiency Analysis Report (SDAR), etc.) or acceptance attribute that is more stringent than the original acceptance criteria.

c. Design Validation resulted in new work, including modificJion to existing hardware.

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L . Attachment to TXX-6712 September 8, 1987 j,

. Page 3 of 6 1 1

If the CPRT had no recommendations and items b or c, above, do not ~1 apply, the attribute under consideration will be accepted. 'This conclusion 1s justified by.the comprehensive coverage of the CPRT reinspection and the consistently conservative evaluation of each finding from both a statistical-and adverse trend perspective. The i attribute "*ix is then updated to indicate that neither engineering-1 walkdown-nor quality control reinspection of the attribute is necessary.

A completed _ evaluation package is prepared and forwarded to the Comanche Peak Engineering-(CPE) organization for concurrence. The evaluation -

package is vaulted after CPE concurrence is obtained. a If any'of the.three statements are true, it 'is assumed that the final-acceptance attribute must be further evaluated as follows:

2.1 Determine Attribute Accessibility The responsible engineer will determine if the attribute is accessible as defined in the implementing procedure. If the attribute is accessible, a field validation of the item's J

acceptability will be performed and documented in'accordance with an approved Field Verification Method (FVM).

4 If.the responsible engineer' reaches the conclusion that the i attribute is inaccessible, an engineering evaluation will be {

conducted by technical disposition of available information.

After completing the attribute accessibility review, the l responsible engineer will update the attribute matrix as necessary 1

to reflect the results of that review.

2.2 Technical Disposition '

l The responsible engineer identifies the data to be considered i during the subsequent technical disposition process. Examples of such items used in this disposition may include, but are not s . limited to:

o Historical Documents (e.g. Specifications, Procedures, Inspection Results);

o External Source issues.

o Construction Practices; o Quality Records; o Test Results; I o Audit Reports; o Authorized Nuclear Inspector (ANI) Records; o Surveillance Reports;

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Attachment to TXX-6712 September 8, 1987 Page 4 of 6-l L o NCRs, DRs, SDARs and CARS; o Reinspection conducted to date; o Results of Third Party Reviews; o Purchasing Documents; o Construction Packages; and o Receipt Inspections.

After compiling the data identified as pertinent to the attribute, the technical disposition will be. performed. The actual steps and-sequence of. actions required for each technical disposition will differ;. however, the tangible results from each technical

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disposition will be consistent. These results will include as a minimum:

a. a written description of the attribute;

b. a written justification by the responsible engineer and approved by the responsible engineer's management for acceptance of the attribute;

c. a written explanation of the logic utilized to conclude that the attribute need not be field validated;

d. a chronology demonstrating that the attribute has not been significantly altered by redesign; e, all documents viewed to support the disposition; and

f. concurrence of the acceptance of the attribute's validity by CPE.

If the responsible engineer concludes that the data evaluated represents evidence of the attribute's acceptability, the conclusion will be documented in an Attribute Evaluation Report.

The report and supporting documentation will be reviewed and approved by CPE Management and vaulted. If the responsible engineer determines that the data reviewed does not provide evidence of the attribute's acceptability, the Attribute Evaluation Report will explain why the attribute cannot be validated and recommend an alternate course of action. The alternate course of action may take various forms; such as, making the attribute accessible and reinspecting it, or testing to support the attribute's acceptability. This alternate plan, after approval by CPE Management, will be implemented to validate the attribute.

Attachment to TXX-6712 September 8, 1987 l Page 5 of 6

'3.0

SUMMARY

l The process above describes a comprehensive process by which each attribute in the PCHVP attribute matrix is validated to the validated design. The TV Electric Quality Assurance Technical Audit Program will audit the PCHVP. This audit program is complemented by the Engineering. }

Functional Evaluation being performed by an independent team comprised of Stone and Webster, Impell and Ebasco engineering personnel working under the Stone and Webster QA Program and subject to oversight directed by the CPRT's Senior Review Team.

This combination of audit and independent oversight provides assurance that the PCHVP has been effectively implemented.

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I. Attachment to TXX-6712 l September.8, 1987 Page 6 of 6 FIGURE 1 PCHVP ENGINEERING ___________

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