View source for IA-86-454, Submits Update of 860408 Schedule for Remaining Work Needed on Sser 13 for Comanche Peak Program Plan.Related Info Encl

{{Adams
| number = ML20215B816
| issue date = 04/09/1986
| title = Submits Update of 860408 Schedule for Remaining Work Needed on Sser 13 for Comanche Peak Program Plan.Related Info Encl
| author name = Trammel C
| author affiliation = NRC
| addressee name = Calvo J, Shao L
| addressee affiliation = NRC
| docket = 05000445, 05000446
| license number = 
| contact person = 
| case reference number = FOIA-86-272, FOIA-86-454
| document report number = NUDOCS 8610090113
| package number = ML20197E251
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 320
}}

=Text=
{{#Wiki_filter:,     - - _ _ _ _ _
(?          'o                         UNITED STATES
                     ^,^
8                n             NUCLEAR REGULATORY COMMISSION g              .g                     WASHINGTON, D. C. 20555 l                                  April 9, 1986
          %, . . . . . p                                                                                         .
NOTE T0:   J. Calvo L. Shao FROM:      C. Trammell

==SUBJECT:==
REMAINING WORK FOR COMANCHE PEAK PROGRAM PLAN (SSER #13) -
UPDATE #2 This is an update of my note dated Tuesday, April 8.
Current work needed is outlined below (as of c.o'b. Tuesday, April 8):
Item                     Action Needed                            Person l
Section 1                Final comments, if any, from             Mizuno                .
(INTR 0)                 OELD needed.
Section 2                Statistical affidavit has                Saffell                    i (QOC)                    been approved and issued. This           Lurie                      l section can now be finalized.                                       ;
Target'date is 4/11/86.                                             ;
Section 3                Complete rewrite under way. To           Calvo DAP                      be finalized 4/11/86. Will               Knox                       ;
include a description of SWEC            Nevshemal                  l program and its overview by CPRT;                                   i and Ebasco/Impell/ANC0 programs and CPRT overview (cable trays and conduitsupports).
Section 4                Response to ELD coments needed.           Gilray CPRT QA                  Estimated response date to be             Spraul provided 4/9/86.
Appendix C               Comments on DSAPs X and XI               Calvo needed.                                  Knox Nevshemal C. M. TrammelI cc:   H. Denton          D. Terao                  F. Miraglia D. Eisenhut        C. Haughney              D. Crutchfield' T. Novak           J. Gilray                G. Imbro V. Noonan          J. Spraul                T. Ankrum E. Marinos         J. Knox                  G. Mizuno D. Jeng            D. Lurie                  L. Chandler A. Vietti-Cook     B. Grimes 8610090113 861003 PDR    FOIA GARDE 86-272        PDR c+- W -

o Document Name:
CP SSER 13 PAGES I-V Requestor's ID:
ORDAZ Author's Name:
Trammel Document Comrcents:
Abstract, Table of Contents, Contributors, Acronyms & Abbrev Q/pll        !   /       .i      A              '(
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LIST OF PRINCIPAL CONTRIBUTORS NRC Staff                           Consultants / Organization D. Jeng                             R. Hookway         TES*
L. Shao                             J. Flaherty        TES E. Marinos                          J. Malone          TES J. Calvo                            J. Cragin          TES S. Hou                              D. Landers         TES J. Knox                             J. Rivard          TES                                  I E. Tomlinson                        R. Ciatto          TES D. Terao                            E. Solla           TES A. Vietti-Cook                      R. Masterson       EAS
                                  ~
D. Norkin                           V. Ferrarini       EAS J. Gilray                           P. Chen            ETEC
                                                                                                        ]
V. Noonan                           E. Thompson        ETEC 41.L-B. Grimes                           B. Saffell         Battelle          p    .y,'/ '/ '
C. Early                            C. Hofmayer~       BNL , y /        I-C. Hale                             N. Rivera           in' dependent S. Phillips                         M. Yost            EG&G T. Westernan                        L. Stanley          ZYTOR.
I. Barnes                           R. Philleo          independent J. Milhoan                          C. Huaghney         COMEX C. Tramell                          P. Keshishian       independent J. Nevshemal       WESTEC 1
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            *Teledyne Engineering Services 03/27/86                                   iii                 Comanche Peak SSER 13 l
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           "~ implements the .CPRT's seIf-initiated. portion of the QOCIFor a more complete description of the ISAPs, see pages 5 through 9 of Appendix B to the CPRT Program Plan, Revision 3. For a list of the ISAPs, see Attachment 1 to ff                  Appendix B to the CPRT Program Plan, Revision 3.
l      \'
i l                  Discipline Specific Action Plans (DSAPs). The DSAPs address specific CPSES l                   design issues regarding the adequacy of either the design or the design f           ( process which have been identified by external sources or by the CPRT as a result of other evaluations] Certain DSAP tasks also implement the CPRT's self-initiated design evaluations. Other DSAPs, encompassing piping and pipe supports and cable tray and conduit supports, entail a significant level of
;                   engineering reanalysis, and are being performed for the CPSES Project by l                  engineering organizations that were not responsible for the original design.
CPRT third-party personnel will review the analytical process and the design criteria for these major reanalysis efforts.           For a more complete description of the DSAPs, see pagei 5 through 15 of Appendix A to the CPRT Program Plan,
;                   Revision 1.
i 1.4 Purpose of the CPRT In this section the staff relates the. purpose of the CPRT, as described on pages 2 through 6 of Revision 3 to the Program Pian.
The CPRT is now charged with resolving issues so that it can advise TUEC i                   management whether there is- reasonable assurance that the CPSES has been designed, constructed, and tested such that it can be operated safely. To 1
accomplish this goal, the CPRT has three objectives:
(1) The CPRT will evaluate each External Source issue relating to design adequacy, hardware quality, and testing. The CPRT will then determine
!                         the rfature of any safety-significant deficiencies and the necessary                                                   i corrective action. Accomplishment of this objective by the CPRT is intended to provide TUEC with reasonable assurance that there are no undetected and ungorrected safety-significant deficiencies associated r                         with any of the External Source issues.
i t
04/08/86                                1-5                                CP SSER 13 SEC. 1

                            )W              jW -ff W                                         p                                      l1           -
Y []f Y             f/)?h_                 ,a           h                             Ll   fl jL        E The CPRT expects that deviations in this special set will seldom be
                       ~
           /                           sa'fety-significant by themselves.
(6) Safety-Significant Because of the importance of this term, the descrip-tion presented below is a virtual quote from the language of Appendix E, Revision 1 of the CPRT Program Plan. Safety-significant is defined to                                       e
 ;                                     mean that the identified discrepancy, if uncorrected, would result in the
                           )f l[           _ loss of capability of the affected system, structure or component to i             perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train or                                     <
structure level. This definition, which is employed in the CPRT. Program for purposes of sample expansion, is more restrictive (conservative) than                                   -
Jg                  b f that usually applied to the term " safety-significant" for regulatory p)N rr' dl purposes or in comon parlance, in that it ignores redundancies that do p"p g                               exist in real lif.p. Identification of a deficiency as " safety-f                             significant" for purposes of the CPRT Program, therefore, is not equiva-lent to a statement that, in fact, the deficiency, if uncorrected, would
 ,                                     have resulted in unsafe operation.
(7) Adverse Trend. A trend is a set of related discrepancies having attributes that reflect commonality. Examples of possible commonalities i                                      include:
o     The individual, group of individuals or organization performing the j                                            activity.
o     The program requirements, procedures or controls governing the performance of the safety-related activity.
A trend is considered to be adverse if it is determined that the
!                                      identified pattern or commonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected area, population or stratum. Adverse trends are also referred to as programmatic deficiencies.
(8)'Rootcause. A root cause is considered to be the fundamental event or l                                      decision that was the most likely causa of the identified problem.
t 04/08/86                                    1-9                                       CP SSER 13 SEC. 1 i

            '..                                                                                            O L&
                                                                                                           .lf
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,           }l        o     All deviations, which include items that fail to meet current                        ,1 l                           licensing commitments, are tracked, evaluated, and classified as to lJ                          safety-significance. - g              gb(af       , ' ' ll                  NI i
                                                                 '   W/
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    ._ l              o     Deviations are evaluated to determine if an adverse trend exists.
i.j o     If TUEC should detennine that the issue need resolution by changing a licensing comitment, they will submit an FSAR amendment requesting the staff's review and approval of the change.
l                                                                                                          U.)/
1.6 CPRT Products: Evaluations, Corrective Action, and Reports.
In accomplishing its activities, the CPRT will conduct or initiate four types of. actions to resolve identified problems:
o Determination.of Root Causes o Evaluation of Generic Implicatio_ns i
o Initiation and Oversight of Corrective Action i
o Documentation of Results in Reports The first two of these actions constitute important evaluations that the CPRT intends to use to fully resolve identified problems and to bound the safety-significance of the associated deviations. The staff's understanding and evaluation of these actions are described below (see pages 2'and 7 through
!                9 of Revision 3 to the CPRT Program Plan for TUEC's discussion of these l               actions).
I                (1) Deterinination of Root Causes. The CPRT recognized that the specific issues identified by External Sources may be representative of more
;                      fundamental, underlying concerns. Accordingly, the CPRT has committed to evaluate each issue, even if the issue is nonsafety-signficant.
i                    Root causes will be investigated and determined where possible for all adverse trends of deviations, design observations, and all deficiencies
{
04/08/86                              1-11                       CP SSER 13 SEC. I
 =--                      -                               ..   -      - - .        _ . - - . - . - - .

                         ' The sample size for each population which is part of the construction adequacy
 ;                           review program is targeted by the CPRT in Appendix D to meet:a 95/5 confidence
 !                           level. This confidence: level is used by the CPRT as a means for detecting programmatic or systematic deficiencies. For each work activity of interest, a minimum sample size of 60 will be taken.                                                      If no safety-significant deficiencies are found in the sample, the work activity is j                           accepted.        If a deficiency is found, the sample is expanded. For a single
 ;                        ' sample expansion, the sample would be increased to 95 and the work activity is I                            accepted only if the total number of deficiencies does not exceed one. As
!                           noted.in Attachment 4 to Appendix D of the Program Plan and confirmed by the-Applicant in a meeting with the staff on March 18, 1986, only one_ sample                                     ,                                   ;             _
expansion will be made prior to performing a 100% reinspection or reevaluation                                                                                     ).
.                            of an attribute, stratum, or population as conditions dictate. Provisions are a                          provided in Appendix D for 100% reinspection or review of a population.                                                        If the                                 '$
items from the samples contain no safety-significant deficiencies, and there are no apparent adverse trends of nonsafety-significant deviations, no further                                                                                   \)'
l                           reinspections or documentation reviews would be required.                                                  Ifasampleisfounk                                   -,
{                            to contain one or more safety-significant deficiencies, or if there is evidence #
j                            of an adverse trend, the sample would be expanded and additional reinspections/, )
i                            documentation reviews conducted. All safety-significant deficiencies will be analyzed for root cause and generic implications in conjunction with these expanded reinspection / documentation reviews and will be consistent with the process used to establish the HWAs.
l                          A results report will be prepared documenting the results of the self-initiated evaluation program. Anyinformationthatmayple related to design adequacy                  .                                                                    7 j                           which is identified during implementation of this ISAP will be referred to CPRT
<                                                                                                                   /                                                                    2 personnel responsible for implementation of the DAP.
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2.3 Staff Evaluations 1
The staff reviewed the applicable sections of the Program Plan and each individual ISAP including the ISAP describing the self-initiated evaluation program for the purpose of ascertaining if the CPRT's construction adequacy program can accomplish'its stated objectives (See CPRT Program Plan, Appendix l                            B, Page 2). In addition to the review of each individual ISAP, on-site audits i
n 04/02/86                                                            2-5                                CP SSER 13 SEC. 2 9
                ._..______--m--_          - - , - , _ , . , . ,,.._m.. , _ _ _ _ _ , , . , , . _   ..__.___.,,.-.,7     _..~___.m._            ,.,__.m._ _ , . . , - _ , . - . , , - _ ,

t Civil / Structural Issues M2No.7,.._NEUSScd Y M N Y I.c Electrical Conduit Supports Mf/
Description This ISAP addresses actions required by SSER No. 8, Civil and Structural cen e                  A Category 14,-a11egation-AE-17 xenf            g on the installation of nonsafety-related conduit supports for conduit two inches in diameter or less in seismic Category I areas of the plant. No evidence could be found by-the TRT that substantiated the k         adequacy of the installation, or in demonstrating that their failure would not
                <h adversely affect the function of safety-related components or cause injury to plant personnel.
Staff Comments The general scope and methoodology contained in this ISAP is responsive to 4             concerns raised by the staff.             However, in clarifying the disposition of rejects i
s',                   identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Sections 4.1.2.1 and g
              'e,            Section 4.1.2.5 of ISAP I.c.          The intent of this statement relative to sample
    /        V1              expansion and compliance with Appendix D of the Plan is unclear.
t         /
:    lC                      Clarification and/or justification of the statement in Section 4.1.2.1 and I
h                  4.1.2.5 is needed.
II.a Reinforcing Steel in the Reactor Cavity li v
Description N
'i
    ~fs                       ThisISAPaddressesactionsrequiredb$,ASSER s                   earnwrt v                   No. 8, Civil'and Structural
< s.                          Category 6,<atlegation-AC-38,-oga documented occurrence in which reinforcing l0h                            steel was omitted from a Unit I reactor cavity concrete placement between the i                           812-foot and 819-foot-1/2-inch elevations. Although the omission was If4(
documented, 3ustification su,po, ting the engineering conclusion to "use as is"
; 3.(9 E                           was not available.
1 03/31/86                                           B-14                                       CP SSER 13 APF.B

Staff Comments The general scope and methodology contained in this ISAP is responsive to the concerns raised by the staff. However, the plan should address the corrective actions to be taken if some structural members are deficient when reinforcing steel was omitted. Fur,thermore, the logic diagram in the attachment to the y                     ~hid g r                       .n .. -                                                 %                                Th
     ~              ISAP is=inco/sr+sV  rrect. Theisecond:                      vertical = branch-at the_.lef-                      nd-the s-shaped
                                                         *                                                       -:1 G
* branch near the upper right hand corner gshould-be-deleted.                                                                  g'g (,
  .U J+hdiyr:w.
y tM1 e;$< Y Y II.c Maintenance of Air Gap Between Concrete Structure                                                       ), opp 4M 3 AdM472
                                                                                                                                  '0 UI%         W p'W% nw" A ?d                  / ~$ *''***''!*
                                                                                                                                   ^
Description
                                                                                                                              %f&d,Wat5ml$4M/                       c   ~
Ih This ISAP addresses actions required b SSER No. 8 ' Miscellaneous-Category                     where the TRT            n n.uA       um Wm ident.ified:TUEC?o                             a.a D. yunulu,, <w                         ,a.du u.m um aw mxo b;/
s lack-of-control-of'--debr.is                    in-critical-spacings
               /co nbejiix     _rw,ei w .1n e r9 a n20mponentsTand/o tween
                                                        . m reyic.
s tructure s . TUEC had not adequately demonstrated coinpliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which required separation of Seismic Category I buildings to prevent interaction during an earthquake.
Staff Comments g          The action plan is responsive to concerns raised by the staff. However, the                                                                                            '
b            flow diagram given in the ISAP should be clarified. There is no indicatio frl' where item              profile o M s-built condition _for_ selected-rotofoam-form-work 9                 areas and -for seletted metal form work-areas, and the staff does not understand / designation C,.-
k raj e/ igd" % c7[JA II.e Rebar in the Fuel-Handling Build ng
\                               .
Description This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 15 pallegatTmi~AC-15,)4(anallegedinstanceofunauthorized
(-                   f 03/31/86                                                                  B-15                                                   CP SSER 13 APP.B l
l
_      -     - . - . -         ---     , . _ _ _ , , . . - _ _             _ , - . _ _ _ _ _ _ _ _ , , ,       -._      _    y   . , . . . - - _ -    . , , , , _ . -

s cutting or rebar in the Fuel-Handling Building due to the depth of core drilling.
Staff Comments The approach described in this ISAP is responsive to concerns raised by the staff. However, the plan should address corrective actions to be taken if cut rebar produces an unacceptable structural member. Furthermore, the logic diagram given in the ISAP is incorrect, in that there are no arrows r^anar +=d=
Aa the lower right-hand box.                                              M O
O 03/31/86                                   B-16                          CP SSER 13 APP.B

1 Document Name:
CP SSER 13 APP. C                                                              )
                                                            .                              1 Requestor's ID:
ORDAZ Author's Name:
Trammell I
Document Comments:
April 1, 1986 l
9

                                 .                                                                                                                          \
l l
Appendix C     PROGRAMMATIC CONCERNS                                           ,
i                                                                                                                                                         j j'
Description of Concern The evaluation process defined in Appendix E does not provide sufficient detail on safety-significant evaluation. This concern is primarily related to the fact that safety-significant evaluations of discrepancies are currently underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern in the DAP are piping and cable trays
;                                  and their supports.) Until this revised information becomes available as                                            ,
                                   " plant record documentation" then the safety-significance evaluation process              .
cannot be completed. Any evaluations made using existing documentation must                 .
y    g be revisited when the new documentation becomes available. The major reason for this is that TUGC0 11,as elected to perform extensive reanalysis of piping,                                  w cable trays and their supports which could result in hardware modification                                        h related to optimization or deficiencies or, different design documents and j                                  values which fom the basis for the safety-significant evaluation. Based on                               N       f this, the staff feels that safety-significant evaluation and the potential for scope expansion must be based on final plant documentation. This position does i
not preclude the fact that existing issues which led to the current reanalysis                                  !
I of piping and cable trays must be evaluated for root cause and generic implication to assure that programmatic deficiencies do not extend beyond the boundaries covered by the reanalysis efforts.                                                     J'          l Action Required                                                                            'f i                                                                                                                                 d i
The CPRT must provide procedural direction or instruction to ensure that safety-significant evaluation of discrepancies related to the self-                               4[ * -
initiated design or construction program and the potential for scope expansion must include evaluation using final plant documentation. This f'
;                                                                                                                                           l does not preclude the fact that existing issues must be evaluated _for                                ;
[                                                                                                                           ,
,                                   root cause and generic implication [ During implementation the staff will
!                                   confirm that this action has been accomplished.
i i
i 04/08/86                                C-1                            CP SSER 13 APP. C

        ~
l i
Description of Concern                                               ,             )
This concern is related to the fact that safety-significant evaluations
                      .must be performed using Code or Regulatory approaches. That is, the techniques used and the extent of the evaluation must address each criterion which formed the basis for the original design. For example, the use of g                   actual material properties versus Code defined material properties could be
! }- j                  acceptable but.does not preclude the fact that all evaluations comitted to in d                   the FSAR must be addressed in order to establish margins on all segments of 5                   the acceptance criteria. Actual material properties (if higher than Code minimums) may be of value in evaluating primary stresses and functionality but.
,i do little to change the fatigue margin. .This concern is not limited to Design.
*<                      discrepancies but includes Construction discrepancies for which safety-significance is determined through the use of Design evaluations.
j                       Action Required n1
,s i0                 The CPRT must provide procedural direction or instruction to ensure that the v
is                 techniques used and the extent of the evaluation addresse,es each criterion which formed the basis for the original design. During implementation the staff will confirm that this action has been accomplished.                        ,
Description of Concern There is a lack of discussion in the Plan on the approach to be used in root    _
j                        cause and generic implication. detemination. /I n order to understand any CPRT ]
                    ; proposed evaluation, the Plan needs to define the tems " root cause" and
{
:                        " generic implication." This 'is critical, since the depth and breadth of the
                  -      root cause evaluation will be a function of the CPRT understanding of these i
g/The staff anticipates that the CPRT will consider the following, as a minimum, in determining the root cause of deficiencies:
}
 ;    e           wrih
                  'gywy, e     p.
l%
  \     llo             u P1 04/08/86                                C-2                 CP SSER 13 APP. C o-                              _        __                       _ . _ _ _ _ _

Personnel Process Procedures Design (as it effects construction)
Materials Management Action Required A
The Program Plan must be revised to provide those-definitions-or-the-CPRT sharl-1-issue procedural direction / instruction to ensure that persons performing these evaluations have commonality in their understanding of the factors that '
                                                                                                                    ~
affect the determinations. During implementation the staff will confirm that this action has been accomplished.
Description of Concern Another area of staff concern is related to Adverse Trending. The discussion in Appendix E is general in nature and uses a set of examples to define the process by which a set of items could create a pattern for concern. The examples given are related to a design process. The approach used by the CPRT is to evaluate HDAs rather than to review the design process. The concern is that evaluation of HDAs may not provide the appropriate information for trending as
   .          defined in Appendix E.
Action Required The Program Plan must provide that the design process as well as Homogenous Design Activities will be reviewed to determine an adverse trend. During implementation the staff will confirm that this action has been accomplished.
t 04/08/86                                    C-3                       CP SSER 13 APP. C

4-i - . .                      .
Description of Concern-Revision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirmation of implementation and responsibilities of the CPRT and the CPSES Project. The only major' comment the staff has is related to the timing of SRT approval of CPRT RTL determination of the adequacy of correction actions defined by the CPSES Project. Appendix H provides two alternatives, a
j approval on an ongoing basis as corrective actions are developed, or, approval as part of the Action Plan Results Report approval process.
The staff feels that the SRT should approve or disapprove corrective actions on an ongoing basis as they are developed. This action should follow that of the CPRT RTL. It is fel't that this would keep the SRT more in line with
:                             CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES project involved in lengthy discussions when the RTL does not agree with the proposed corrective action.
!                             Action Required Appendix H must be revised to state clearly that the SRT will review and approve / disapprove all co,rrective actions on an ongoing basis, subsequent to
         .                    approval by the CPRT-RTLS. During implementation the staff will confirm that V
this action has been accomplished.
Description of Concern The staff is concerned with a number of observations concerning interfaces as follows:
The definition of interfaces provided in Appendix F establishes measures fod the identification and control of design and construction interfaces and for coordination among the CPRT participant organizations. The availability of matrices will provide each affected organization the specific areas and items 04/08/86                                 C-4                CP SSER 13 APP. C

of information that must be executed and controlled. There are a number of areas where. interface between various CPRT organizations and CPSES Project 4
organizations is defined.        In some cases, the interface appears to be dupli-cative and prime responsibility is not defined. It is important that prime responsibility for interface control be defined to assure that involved organi-
.!                              zations understand who is responsible for establishing, executing and controlling the interface. The following are staff observations on the individual matrices provided in Appendix F.
: 1. QA/QC-RTL and RTL to Unit 1 and Unit 2 Assistant Project General Managers (APGMs). Responsibility for 50.55(e) reportability is assigned to the              -
>                                     TUGC0 Project per Appendix H of the Plan.                                           -
: 2. DAP-RTL to SWEC. 1.nformation on root-cause analyses, generic implications,
!                                     Evaluation Reports and Results Reports is provided to SWEC for "Information" when pertaining to the SWEC scope. Since this information could impact l                                     the SWEC analysis effort, it should be provided for " Action by SWEC."
Since DAP is auditing SWEC activity, this matrix should address those items associated with that effort, including Corrective Action.
: 3. DAP-RTL to Other Design Organizations.      Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports should be provided for " Action" to EBASCO and Impe11, who are reanalyzing l
cable trays and supports. The CPRT may find it more appropriate to I
develop a separate matrix for the cable tray and support effort
!                                     activities of EBASCO and Impell.
l
!                                4. RTLs to CPSES Project. Action Plans are designated as both " Info" and
                                      " Action" by Project. It is the staff's understanding that Action Plans are provided to the CPSES Project for information only.
: 5. SWEC to Interfacing Organizations. Design- and construction-related concerns found during walkdown and document reviews should require action by DAP and QOC RTLs. That action should include evaluation of the l
l 04/08/86                                  C-5                  CP SSER 13 APP. C

deviation in the same manner as if it were discovered as part ,of the CPRT self-initiated program. Loading from the piping system should be provided to QOC through the DAP since this information may be needed for safety-significance evaluation.
: 6. Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and DAP-RTL and EBASC0/
Impell and Interfacing Organizations.
Action Required The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT.
activities provided the concerns are satisfactorily resolved as follows:
(1) Define the organization with prime responsibility for duplicative interfaces.
(2)   Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports should be provided to SWEC, EBASCO and Impell since it could impact their reanalysis effort.
(3) Design- and construction-related concerns found during SWEC, EBASCO or Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action."
(4) Loading from the piping system to equipment, structures, penetrations, etc., should be provided to 00C through the DAP for use in safety-signficant evaluations.
(5) Interface details (or matrices) should be provided for Other Design Organizations and DAP-RTL and for EBASC0/Impell and Interfacing Organizations.
i              04/08/86                                 C-6                                CP SSER 13 APP. C

(6) The CPRT auditing of SWEC activities involves interfaces which should be defined.
(7) Define more clearly CPSES project responsibility for action plans and 50.55(e) reportability.
The concerns related to 50.55(e) and to Action Plan responsibility in the RTL to CPSES Project Matrix are editorial in nature and can be confirmed during the implementation phase of the plan. Additionally, during implementation the staff will confirm that the other above noted actions have been accomplished.
9 M
5 5
I
(
l l            04/08/86                                                                            C-7     CP SSER 13 APP. C l   ..       _ . _ _ _ _ _ _ _ _ _ _ . - _ _ - - _ _ _ _ . _ _ _ - . - _ . _ . . . _ _ . _ _ _ .               _

o    . c k
u wf                     -
d {NDSAP VIII,*CPRT                            w        Overview SP (f_Af my MM-P
                                                                                                  #" ^
Description of Concern                   '
                                                                   ., (4G3/dMuIMM N 8 N
j.
order for TERA to perfonn an integrated review of major concrete and ' steel
    ' N. ,              structures in a manner consistent with their comitments referenced in the                          s
                                                                                                                            /
o NN
* d"                  NRC Office of Inspection and Enforcement (IE) Inspection Report 50-445/85-17                       Ti
            'J and 50-446/85-14, Appendix 2,pageA-4,unigue_loadingdeterminationsmu_st_be      i            )      {
dEl performed _for_the referenced _ buildings (i.e., auxiliary building, fuel storage                              jf N
d       j building, containment building and other portions of selected buildings). DSAP                          g; jg5 VIII Section 4.3.2.1, load Determination, indicates that only the auxiliary / ,
electrical buildings will be reviewed. This is inconsistent with TERA's commit-             3 (i
{(                ment and in fact precludes the performance of a thorough review.                            g
      $y'                                                     A '/)NTd& 9wt             b)
Y                 Action Required                       '~
                                                                           .,,fh,       ['                          ?S  'C
                                                                                                                           )%
    + }s                                                                                                             9j TERA should review other buildings than those listed in DSAP VIII, Section                           .
          %              4.3.2.1 Load Determination.                                                              j      ((
y; Description of Concern Thermal loadings or expansion considerations must be considered in the i                        evaluation of the reactor building internal structure since this is a l       -                fundamental design consideration (e.g., to mitigate the effects of thermal expansion). DSAP VIII, Section 4.3.2.1, does not address thermal considerations and should be revised accordingly.
Action Required DSAP VIII, Section 4.3.2.1 should be revised to include thermal load considerations for reactor building internal structure.
l 04/08/86                                            C-8                CP SSER 13 APP. C

Description of Concern                                               .
The NRC inspection report (Appendix 7, item 4, page A-216) discusses embedment load tracking. The TERA response indicates that final design loads will be coordinated with the civil / structural discipline (e.g., to confirm that building designs are consistent with the final design loads). Section 4.3.2.1 of DSAP VIII doesn't discuss this and should be revised accordingly.
Action Required DSAP VIII, Section 4.3.2.1 should be revised to address how original building .
  ~
design loads are reconciled with the final design loads.                       ,
O i
04/08/86                               C-9                   CP SSER 13 APP. C

fy.
                                                                                       ,n   .n #l,lLf.J t
c1
                           -                                                          %,           > p,,'/ a.
                  'DSAP VIII - Civil / Structural. Including Cable Tray / Condu                       '
                                                   ~~                       -
Description of Concern         _
fus. Mn/(hy;;hh7%pf!! e
             !        The(testing program may generate design and acceptance criteria which do not comply with FSAR commitments.
Action Required j
If the FSAR comitments are not met, the proposed acceptance criteria must be identified for approval by the staff prior to implementation.                   ,
Description of Concern Inconsistencies exist be" tween the DAP, DSAP VIII and Impell-Ebasco project instructions. The inconsistencies involve the statements describing the methodologies that may be used to evaluate the cable tray supporth In the DAP            M ttisstatedthattheestablishedEbascomethodologieswillbeuhedwhilethe
        /             DSAP allows the use of Impell and Ebasco de, sign procedures. Further in the DSAP it is stated that only two methods of dynamic analysis will be used in analysis,/designverificationofcabletraysupports. The Impell project instructions, however, permit the use of time history methods, overlap methods and multi-level response spectrum methods in addition to the two methods l
referred to in the DSAP.
i l                     Action Required i
1AU i                     During implementation the-staff will-confim-that these inconsistenciesgbe
          /
I      /              resolved and the appropriateness of the above methodology demonstrated to the
!                     staff.
i Description of Concern The staff is concerned with the lack of prescriptiveness of review checklists used for the third parg review. In general, the checklists define the review       ><
Y 04/08/86                               C-10                  CP SSER 13 APP C l
L

         ~.
scope by listing criteria and commitments for which the implementation will be verified in the review, but do not indicate the design considerations which must be accounted for in verifying that the commitments were met.
Action Required The checklists need to be more prescriptive with respect to all design criteria to be met.
1 Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection Report Nos. 50-445/85-17,50-446/85-14 indicates areas in which specific review
    ~
checklists need to be expanded or clarified with respect to subject content.    ,
Description of Concern The staff evaluation of the third-party activities for the review of project activities and corrective actions is based on audits performed at the offices of the CPRT third-party (TERA).                  ,
At the time of this audit, Revision 3 of the Program Plan had not yet been issued. Revision 2 of the Program Plan was not definitive in stating the third-party activities for the cable tray / conduit program. This program was undergoing a major rewrite which now clearly defines the role of the third l
i party.
Action Required The staff generally agrees with the Program Plan with respect to the i            third-party activities in the cable tray / conduit area; however, a complete j            evaluation will be made after the staff completes its audit of the details of
!            the third party review of the project actions.
4 1
1 l
04/08/86                                  C-11                CP SSER 13 APP. C

I Description of Concern                                                 .
The staff review of the validity of identified HDAs and design activities not enveloped by the HDAs identified a concern with the HDA criteria for homogeneity.
HDAs are required to have common design or analysis approach / methodology or mechanics in design implementation such that meaningfully different complexities or considerations are not contained within that design activity.
However TERA had not obtained formal documentation pertinent to the Gibbs and Hill design / analysis methodology and approach. Such documentation              -
(instructions and procedures) is normally utilized to establish design process.
control and thereby establish uniformity of technical approach in the execution of engineering,for a project.
The Civil / Structural Phase 3 Scope Validation document, including the HDAs identified within, is based on such items as the plant engineering documents       '
available at Gibbs and Hill, TERA interviews.with project personnel, and the engineering experience of TERA personnel in nuclear power plant design.
A review checklist, DAP-E-PM-001, dated October 27, 1985 states that, on a programmaticlevel,(1)organizationalanddesigncontrolprocesschanges withinGibbsandHillhavenotaffectedtheidentifiedHDAsand(2)therehave been no changes to design methodology over time at Gibbs and Hill such as to affect the the identified HDAs. These TERA conclusions are based on discussions with Gibbs and Hill rather than review of design control procedures, design methodology, etc.
TERA apparently recognizes that other homogeneous design activities (HDAs) may exist and that some currently so defined may in fact not he homogeneous since it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Posse 3 Scope i       .
Val.idation, Civil / Structural" that in the review effort there will remain an en,'"... search for substantive differences in criteria category, design considerations, approach, or methodology in the design process."
l i
C-12                 CP SSER 13 APP. C
(               04/08/86

                    ,. ( g p ur[b /? Y NAki W Gd b b S UU                       P   5M#Y
(,
The team identified potential HDAs not identified by TERA such as ,the design                   g of the annualar structural steel normally inside the containment, the
.               auxiliary building structural steel, foundation overturning design, the design                   g of walls for tornado missiles and the effect of Category II buildings on                     S @,
l-Category I buildings.                                                                          fh qN Due to the above uncertainty as to documented design methodology, there is a                   9h
 ;              related question on sample sizes.                                                            \
kh indicated that for the auxiliary building and the. fuel building           '
* 2D
               %       n                      .                   .w as.mu
                                      .w.
five (.5) slab and five (5) wall calculations will be g selected at-random for               (x y%  '
design review Then.another_ set of ten (10) calculations-will-be-selected             .
                                                                                                           .]
               -either randomly or-based on any' findings from~the previous-ten-(-10). Such'a          .          4 sample may not be valid if all these calculations were by one individual, if therewerefifteen(15)jndividualsdoingindependentdesignsforslabsand walls without any design process / methodology guidance beyond the FSAR l
criteria. If there were no controls within the Gibbs and Hill organization.
l l
for establishing homogeneity in design approach and methodology, one must j               compare individual engineers and designers completing similar tasks. Forthis
)               situation, the actual homogeneity that exists can apparently only be established as the design review progresses.
j               To the degree that TERA relies on HDA populations as the basis for review                           i sample selection, the staff plans to evaluate whether the review sample is representative of the design process for that population and whether the population is homogeneous.
4 i
Action Required
;               The staff generally agreed with the third-party conclusions that certain checklists adequately cover HDAs. Exceptions to this are addressed in detail l_
l               inAppendix12oftheNRCOfficeofInspectionandEnforcement(IE) Inspection i               Report Nos. 50-445/85-17,50-446/85-14 which was transmitted to the Applicant j               in a letter from J. M. Taylor to W. G. Counsil dated January 21, 1986. Staff j               approval of the CPRT Program Plan is contingent upon acceptable resolution of the staff concerns and staff coments on the review checklists provided in the ll               IE Inspection Reports.
04/08/86                                 C-13                       CP SSER 13 APP. C l

              .                                                                                               +
L i    ,,
DSAP IX - Staff Comment (Third-Party Review)                                    .
The staff requires the following items to be adequately completed in order to determine the acceptability of the piping and supports discipline specific
;               actionplanrelatedtothethird-party (TERA) actions:
i               Description of Concern i
It was not evident that a process existed for' identifying discrepancies (or deviationhinexternalsourceissuesbySWECinviewofthefactthathardware
!      .        modifications may be made to piping and supports irrespective of the corrective j               actions required for safety-significant problems.                                         -
!               Action Required              ,,
i l              A root cause/ generic implication evaluation should be performed for all hard-ware modifications in order to document the reasons for such modifications.
i i
Description of Concern In the staff review of the checklists to be used by the third-party (TERA) in their overview of the SWEC piping and supports program, only one of three checklists were completed.
l l               Action Required
!               Provide the checklists to be used for the overview of the SWEC piping analysis implementation and pipe support design implementation.
]
Description of Concern 3
 !        . The staff review of the third-party overview of the SWEC construction /as-built
!               program found that no third-party procedures were available at the time of the l               staff audit.
l 4               04/08/86                                   C-14                  CP SSER 13 APP. C

    ~
4 Action Required                                                                  .
Provide the procedure to be used for the third-party overview of the SWEC construction /as-built activities.
Description of Concern The self-initiated review of the AFW system does not fully address the inter-face with the SWEC piping reanalysis program.
   .             Action Required The third-party should include a portion of the AFW system in their review of
.                the SWEC piping and pipe. supports requalification effort.                                          ,
1
]
4 1
i i
I 04/08/86                              C-15                             CP SSER 13 APP. C

                        .       .. . . - . . -          - . .             .-      _-   . -       - = _ . _-      . - _ _ _ _
4 I
i DSAPIX-StaffComments(Project /SWECActions]                                                              '
 ;      .                 The staff requires the following items to be adequately completed in order to determine the acceptability of the piping and supports discipline specific action plans related to Project (SWEC) actions:
I Description of Concern i
i The major technical details of the piping and supports requalification program                         ;
are provided in Comanche Peak Project Procedures (CPPP-5, 7, 8, 9, 10 and 15).
{                         The staff has not yet completed our review of these procedures. However, based j*                        on preliminary findings, the staff identified a concern that the design               ,
criteria in CPPP-7 is not totally consistent with the CPSES FSAR licensing comitments.
Action Required The acceptability of the CPRT Program Plan is contingent upon acceptable
,                         resolutions of technical concerns identified'in our review of the Comanche Peak l                         Project Procedures including consistency between FSAR licensing commitments and the design criteria in CPPP-7.
{
l-                        Description of Concern There is a lack of information in the CPRT Program Plan which explains the l                         process used to assure the adequacy of the as-built data used in the SWEC piping reanalysis effort.
l                                                               '
l                         Action Required                                                                                        I l
* l                         Provide a description of the process followed by the various activities in the
!                         Construction Adequacy Program and in the SWEC program for the evaluation of' as-built discrepancies including the interfaces among ERC, SWEC, and TUGC0 l                         projects and the applicable procedures used in the process.
f 04/08/86                                   C-16                  CP SSER 13 APP. C l

                             ._            _.     ._ _.   ._=_ _              _     _.___          _    ___ ._. _   __
                            ~
l
  !                            Description of Concern                                                ,
 }                              In our review of the as-built process and interfaces between the Construction
^
AdequacyProgramandSWEC,thestafffoundthatjeviation, reports (DR's) issued by ERC are not transmitted to SWEC. However, all DR's are transmitted to TUGC0
 !                             projects for initiating an NCR and only those NCR's dispositioned as "use-as-i is" will be transmitted to SWEC.
1 Action Required j                      -
1 l,                             Address the need for SWEC to review the DR's for the impact of construction      .
 '                             deviations identified by the construction adequacy program on the piping          .
reanalysis effort.
i 4
j                              Description of Concern
!                              As a result of the as-built walkdown performed under CPPP-5, deviations were               ;
l                               found in one of the four attributes (i.e. val.ve and strut orientation) result-ing in a 100 percent reinspection of that attribute. However, the staff noted I'                              that CPPP-5 did not expand its scope to address other as-built attributes (e.g.
I                               pipe run geometry, clearances including those at floor and wall penetrations, l                               embedments,andpipeattachments)whicharealsorequiredtobeexaminedunder IE Bulletin 79-14.
I Action Required Provide a justification for not reverifying the as-built attributes which were            ,
5                               excluded under CPPP-5.
j Description of Concern The staff is concerned that the design criteria and procedures used in the SWEC piping and support reanalysis might be impacted by as-built plant conditions which are not reflected in the design documents used by SWEC.
l l
I i
!                               04/08/86                                 C-17                CP SSER 13 APP. C I   .     . - - - , . _ . .                   . -

a Action Required                                                      ,
Provide the basis for assuring that all as-built conditions which can adversely affect the acceptability of the piping reanalysis program will be identified and corrected.
.                    Description of Concern It appears to the staff that therejs no evaluation of root cause or generic implication or adverse trend assoc (ted with the as-built deviations identified in the SWEC as-built walkdowns. Furthermore, there does not appear to be a       .
procedure or process for the evaluation of the resulting desi[ deficiencies or SWEC-identifiedconstructiondeficienciesper10CFR50.55(e).
                                                  ~
Action Required i                   Address the need for a program for ensuring that the results of the SWEC walk-downs will be adequately evaluated for root cause/gentric implications and' adverse trends and that design and construction deviations identified as a j                    result of SWEC walkdowns will be properly evaluated per 10 CFR 50.55(e).
Description of Concern The staff review of CPPP-10 finds that a final design document which estab-lishes the system design input must be prepared and satisfactorily reviewed by the staff.
Action Required Prepare a final document compiling all operating modes and system loading conditions.
.l 04/08/86                                 C-18               CP SSER 13 APP. C

Description of Concern                                                           ,
The scope ~of the Class 5 piping systems includes only those Class 5 piping systems within the boundaries of ASME Class 2 and 3 piping stress problems.
Action Required Justify excluding the remaining Class 5 piping systems from the SWEC scope.
Description of Concern The Comanche Peak Project Procedure for the requalification of small bore               ,
piping (CPPP-15) is not yet available for staff review.                                  -
                                               ~
Action Required The CPPP-15 should be completed and issued for staff review.
Description of Concern The staff has not yet completed its review of the resolutions to the special technical issues.
Action Required The acceptability of the CPRT Program Plan is contingent upon acceptable resolutions of the special technical issues.
l l
t 04/08/86                               C-19                   CP SSER 13 APP. C

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         = = , -                                                  p' 7 R    stor's ID:                                        -
Author's Name:
Trammel Ab       ,      Contents, Contributors, Acron   &, Abbr RV%        -
d U               / erd k %
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1L            aqd 6      4
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ABSTRACT Supplement 13 to the Safety Evaluation Report related to operation of the Comanche Peak Steam Electric Station, Units 1 and 2 (NUREG-0797), has been prepared by the Office of Nuclear Reactor Regulation of the U.S. Nuclear The facility is located in So     vell County, Texas, Regulatory Commission.
This supplement approximately 40 miles southwest of Fort Worth, Texas.
presents the staff evaluation of the Comanche Peak Response Team Program Plan which was formulated by the applicant to resolve various construction and design issues raised by the Atomic Safety and Licensing Board, allegers, NRC inspections of various types, and Cygna Energy Services while conducting its independent design assessment.
Subject to acceptable resolution of the items identified in the evaluatinn, the NRC staff concludes that the CPRT Program Plan will provide an acceptable assessment of design and construction adequacy when implemented.
i                 Comanche Peak SSER 13 03/27/86

TABLE OF CONTENTS I
P, ale 1
ABSTRACT............................................................
iii CONTRIBUTORS........................................................
iv ACRONYMS AND ABBREVIATIONS..........................................
1-1 1.0 INTR 000CTION...................................................
1.1 Background................................................
1.2 SSER Purpose , Scope, Organization. . . . . . . . . . . . . . . . . . . . . . . . .
1.3 CPRT Terminology..........................................
1.4 Purpose of CPRT...........................................
1.5 Problem Identifj eation and Cl assi fication. . . . . . . . . . . . . . . . . sSm/wn.hs; 1.6 CPRT Products 1 Corrective Action, and Reports. . . . . . . . . . . . .
1.7 Overall        Conclusion........................................                                        2-1 2.0 CONSTRUCTION         ADEQUACY..........................................
2.1 External Source          Issues....................................
2.2 Sel f-I ni ti a ted P rogram. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.3 Staff      Evaluation..........................................
3-1 3.0 DESIGN      ADEQUACY................................................
3.1    xterna Source I es...... ....... .........                                                     .
If-Init ted Prog m....... ........ ......... ......
          .2 3 CP Overs            t - Spec 1 Proje s (SWEC, Ebasco,                                   ell)..
: 3. Staf         aluat      ........ ........ ........
4-1 4.0 CPRT QUALITY ASSURANCE PR0 GRAM.... ............................
5-1

==5.0   CONCLUSION==
APPENDIX A - Identification of the components of the CPRT Program Plan, including Appendices ISAPs and                                                     A-1 DSAPs by Revision Number...............................
APPENDIX B - Items to be addressed by Applicant during the                                                         B-1 implementation phase of certain ISAPs..................
APPENDIX C - Items to be addressed by Applicant during the                                                         C-1 implementation phase of certain DSAPS..................
LIST OF FIGURES Figure 4.1 - CPRT Organization Figure 4.2 Figure 4.3 ii                               Comanche Peak SSER 13 03/27/86

7-LIST OF PRINCIPAL CONTRIBUTORS I
Consultants / Organization NRC Staff R. Hookway                          TES*
D. Jeng J. Flaherty                         TES L. Shao TES E. Marinos                                        J.Malon/Sovt.
J. Calvo                                          J. Cragin                            TES D. Landers                           TES S. Hou J. Knox                                           J. Rivard                            TES E. Tomlinson                                     R. Ciatto                            TES D. Terao                                          E. Solla                             TES A. Vietti-Cook                                    R. Masterson                          EAS D. Norkin                                         V. Ferrarini                          EAS P. Chen                               ETEC J. Gilray E. Thompson                           ETEC V. Noonan B. Saffell                            Battelle
                             -B. Grimas C. Early                                          C. Hofmayer                           BNL N. Rivera                              independent C. Hale M. Yost                                EG&G
              -               S. Phillips L. Stanley                             ZYTOR T.Westerhkn R. Philleo                             independent I. Barnes C. Huaghney                           COMEX J. Milhoan P. Keshishian                          independent C. Tranmell J. Nevshemal                          WESTEC
                                *Teledyne Engineering Services l
iii                                    Comanche Peak SSER 13
                           . 03/27/86

F ACRONYMS AND ABBREVIATIONS A/E          Architect / Engineer ANSI         American National Standards Ins;itute ASLB         Atomic Safety and Licensing Board ASME         American Society of Mechanical Engineeers ASTM         American Society for Testing & Materials B&R          Brown & Root C/S          Civil / Structural CAP          Construction Adequacy Program CASE         Citizens Association for Sound Energy CAT         Construction Appraisal Team CPRT        Comanche Peak Response Team CPSES        Comanche Peak Steam Electric Station CTCS         Cable Tray & Conduit Supports DAP          Design Adequacy Program DSAP         Discipline-Specific Action Plan ERC Evaluation Research Corporation ESI          External Source Issues FSAR        Final Safety Analysis Report G&H          Gibbs & Hill HDA         H mogenous Design Activities A cT%fy up n    HVAC om6 eati@Mnoso    Wod., Ventilation & Air C6nditioning I&C         Instrumentation & Control IAP          Independent Assessment Program INPO         Institute of Nuclear Power Operations ISAP        Issue-Specific Action Plan LOCA        Loss-of-Coolant Accident NRC         Nuclear Regulatory Commission NSSS         Nuclear Steam Supply System PSAR         Pre,liminary Safety Analysis Report QA           Quality Assurance QAP         Quality Assurance Program                            ,
QC          Quality Control iv                   Comanche Peak SSER 13 03/27/86
                                                                                         )

QE           Quality Engineering QOC Quality of Construction & QA/QC Adequacy Program RIV          Region IV RPVRI        Reactor Pressure Vessel Reflective Insulation RTL          Review Team Leader SER         Safety Evaluation Report SET         Special Evaluation Team SIT         Special Inspection Team SRT         Senior Review Team SSE Safe Shutdown Earthquake SSER        Supplemental Safety Evaluation Report SWEC Stone & Webster Engineering Corporation TERA         Tera Corporation THE          TUGC0 Nuclear Engineering TRT         Technical Review Team TUEC Texas Utilities Electric Company TUGC0 Texas Utilities Generating Company UT Ultrasonic Testing v                 Comanche Peak SSER 13 03/27/86

       ._ _ _ . .                                - _ . - . . .. .                        _ __ . ._ _. ... -._--_, _. ..         . .._ . .         . . _        . _ _ ~ _ .                      .          . _ .
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;.                                                           CP SSER 13.SEC. 1.
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Author's Name:                                                                                                                                       ;
                                                           - Trammel                                                                                                                                              1 1
i                                                             Document Comments:
['
Comanche Peak SSER 13 Introduction                                                                                                                  !
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==1.0 INTRODUCTION==

1.1 Background                                                                                              .
i On March 12, 1984, the U.S. Nuclear Regulatory Commission's (NRC's) Executive Director for Operations established a program to assure that technical concerns and allegations related to. Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a As a means of executing coordinated and integrated manner by the NRC staff.
its assigned responsibilities, the NRC formed a Technical Review Team (TRT).
representing the following disciplines:
o     Electrical / Instrumentation o     Civil / Mechanical o     QA/QC o     Protective Coatings o     Testing Programs o     Miscellaneous The TRT initiated a series of onsite inspections and evaluations in July 1984, and documented the results of these activities in five supplements to j
the Comanche Peak Safety Evaluation Report (NUREG-0797, Safety Evaluation l             Report related to the operation of the CPSES, Units 1 and 2 Supplements i
7-11). Prior to publication of these Supplemental Safety Evaluation Reports (SSERs), the staff issued letters on September 18, 1984 November 29, 1984, and January 8,1985, sumarizing the principal issues that required resolution.
In response to the concerns and issues identified by the TRT, Texas Utilities Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the TUEC initially submitted its CPRT purpose of addressing all TRT concerns.
21, 1984, Program Plan on October 8, 1984, and issued Revision 1 on November to respond to comments on the initial version that were received from the NRC staff during meetings on October 19 and 23, 1984.
The initial version and Revision 1 of the Program Plan were written prior to the publication of SSERs 7 through 11, which collectively provided over 1,000 1-1                                          CP SSER 13 SEC. 1
               '04/08/86

pages of the staff's evaluation of the several hundred allegations of design and construction inadequacies. Following publication of the detailed staff evaluations contained in these SSERs and with the recognition of the need to resolve outstanding issues raised by groups other than the TRT, TUEC submitted Revision 2 to the CPRT Program Plan on June 28, 1985. Revision 2 greatly expanded on the earlier revisions and provided an extensive corrective action program to be undertaken by TUEC to resolve outstanding issues from a variety of sources.
In letters dated August 9,1985 and September 30, 1985, the staff provided comments on Revision 2 to the CPRT Program Plan. TUEC specifically addressed these staff comments in a {{letter dated|date=November 22, 1985|text=letter dated November 22, 1985}} and followed with Revision 3 to the CPRT Program Plan, dated January 27, 1986. Revision 3 has been supplemented by submissions in letters from TUEC on January 31, February 7, and two letters on February 28, 1986. With these submissions and the anticipated receipt of one additional item involving hot functional testing, TUEC has completed its description of its planned correctiNaction         x program, the CPRT Program Plan. This Program Plan is intended to describe the program that will address all NRC concerns and demonstrate an adequate level of quality of the design and construction of the CPSES.
1.2 SSER 13 Purpose, Scope, and Organization 1.2.1 CL Purpose  Y and Scope f
l      The purpose of SSER 13 is to describe the NRC staff's evaluation of the CPRT Program Plan, Revision 3 dated January 27, 1986 and supplemented on January 31, February 7 and February 28, 1986, and to document the staff's approval of that plan, subject to the coments contained in this evaluation.
This SSER documents the staff's evaluation and conclusions regarding the CPRT l
Program Plan and supporting appendices, except for the individual action plans contained in Appendix "C". These action plans are the subject of the staff's ongoing evaluation and inspection during the CPRT's implementation phase.      As the CPRT ~ issues reports describing the implementation of each action plan, the staff will conclude its evaluation of these plans.
1-2                    CP SSER 13 SEC. 1 04/08/86

1.2.2 Z"           Organization                                                                        ,
SSER 13 contains 5 sections and 3 appendices. Section 1.0 is the Introduction, which describes the background and purpose of the CPRT, intro-duces key terms associated with the CPRT, describes the CPRT process for identifying and evaluating problems and for ensuring proper corrective action.
Section 2.0 describes the staff's evaluation of the CPRT's Quality of Construc-tion and QA/QC Adequacy Program; Section 3.0 describes the staff's evaluation of the Design Adequacy Program.      Section 4.0 contains the staff's evaluation of the CPRT's quality assurance program; Section 5.0 describes the staff's conclusions regarding the CPRT program. Appendix A is a complete listing of the individual sections of the CPRT Program Plan that have been reviewed by the staff. This listing includes the appropriate revision for each section.
Appendices B and C contain those items the staff has requested TUEC to address during the implementation phase of the CPRT.
Unlike the programs for resolving design and construction issues, the CPRT Program Plan does not contain a separate overall plan that applies to the individual testing action plans. For this reason, the staff has not included a separate section in this SSER describing its evaluation of the CPRT's testing program.
The staff's evaluation of testing issues is ongoing and will continue during the CPRT's implementation phase. The staff will conclude its final evaluation of these testing issues, when the CPRT has finished its assessment and has documented its results.
1.3 CPRT Terminology The CPRT effort has its own nomenclature, some of which is introduced here to aid the reader.
The CPRT essentially consists of two parts--one part relates to CPSES design The first two adequacy and the other part relates to construction adequacy.
terms describe these parts.
1-3                                CP SSER 13 SEC. 1 04/08/86

Design Adequacy Program (OAP). The DAP is that portion of the CPRT Program that resolves issues pertaining to design adequacy.
Quality of Construction and Quality Assurance /Ouality Control (QA/QC)
Adequacy Program (QOC). This program is the portion of the CPRT that resolves
                 ' issues related to the adequacy of the CPSES construction QA/QC program and the
* The CPRT Program Plan uses the acronym QOC adequacy of installed hardware.
when referring to this program.                                                      ?'
This combined  !
Collectively, the DAP and the QOC constitute the CPRT Program.
program resolves issues from the two types of sources:
f External Source issues. These issues arose from sources external to TUEC.            I
: 1) the TRT; 2) the Atomic Safety and Licensing Board
* These sources include:
(ASLB) proceeding on the CPSES operating license; 3) the NRC staff's Supplemental Safety Evaluation Reports (SSERs); 4) the staff's Construction I                Appraisal Team (CAT) and Special Investigation Team (SIT) reports;
: 5) applicable Inspection Reports issued by the NRC's Region IV (RIV) office; and 6) the Cygna Energy Services Independent Assessment Program (IAP).
The CPRT is conducting a self-initiated Self-Initiated Evaluation.                                                     For evaluation of the CPSES quality of construction and adequacy of design.
l                   construction, this effort involves a sainple reinspection of hardware that is representative of the activities and processes used in the construction of            ,
In the design area, the effort involves safety-related aspects of the plant.
reviews of designs that are representative of the aggregate A/E design scope relative to design criteria, disciplines, processes and organizations used in the design of the safety-related aspects of the plant.
4 The CPRT Program Plan contains two types of action plans to resolve
,                                                                                 These action plans l
individual issues in the construction and design areas.
are:
i Issue Specific Action Plans (ISAPs). The ISAPs address specific CPSES construction QA/QC issues regarding either hardware or aspects of the QA/QC-An additional ISAP program that have been identified by external sources.
I4                      CP SSER 13 SEC. 1 i
04/08/86                                                                          -

For a more complete implements the CPRT's self-initiated portion of the QOC.
description of the ISAPs, see pages 5 through 9 of Appendix B to the CPRT Program Plan, Revision 3. For a list of the ISAPs, see Attachment 1 to Appendix B to the CPRT Program Plan, Revision 3.
Discipline Specific Action Plans (DSAPs). The DSAPs address specific CPSES design issues regarding the adequacy of either the design or the design process which have been identified by external sources or by the CPRT as a result of other evaluations. Certain DSAP tasks also implement the CPRT's self-initiated design ev.aluations. Other DSAPs, encompassing piping and pipe supports and cable tray and conduit supports, entail a significant level of engineering reanalysis, and are being perfomed for the CPSES Project by engineering organizations that were not responsible for the original design.
CPRT third-party personnel will review the analytical process and the design criteria for these major reanalysis efforts. For a more complete description of the DSAPs, see pages 5 through 15 of Appendix A to the CPRT Program Plan, Revision 1.
1.4 Purpose of the CPRT In this section the staff relates the purpose of the CPRT, as described on
  ~
pages 2 through 6 of Revision 3 to the Program Plan.
!                t arged with resolving issues so that it can advise TUEC
                                                                                            /
l     TheCPRTfis managemfnt whether there is reasonable assurance that the CPSES has been f                                                                                        To designrjj, constructed,andftestedsuchthatitcanbeoperatedsafely.
accomplishthisgoal,theCPRThasthreeobjectives:
(1) deCPRTwillevaluateeachExternalSourceissuerelatingtodesign a'equacy, d        hardware quality, and testing. The CPRT will then determine the nature of any safety-significant deficiencies and the necessary i
corrective action. Accomplishment of this objective by the CPRT is intended to provide TUEC with reasonable assurance that there are no undetectet and uncorrected safety-significant deficiencies associated wi th any of the External Source issues.
1-5                          CP SSER 13 SEC. 1 04/08/86 l

(2) The CPRT will investigate and attempt to determine the root cause of each safety-significant deficiency and any adverse trends from nonsafety-The CPRT will analyze the significant deviations or design observations.
generic implications of each root cause that is found in order to deter-mine the extent of any additional construction, design, or testing activities that might be deficient for the same reasons. The definitions
                                                    ^
of these terms are discussed in Se ction 1.5 below. Accomplishment            y of this objective by the CPRT is intended to provide TUEC with a full resolution of each External Source issue and to fully bound the safety-significant implications of identified deviations.
(3) Although the External Source issues are numerous, they are not inclusive of all aspects of design and construction activities associated with the CPSES. The CPRT recognized the need for additional evaluations in certain areas in order to be able to make conclusive statements regarding CPSES design adequacy and construction quality. Accordingly, the CPRT developed a third objective to conduct a self-initiated evaluation of CPSES design adequacy and construction quality. In the design area, the self-initiated evaluation entails reviews of designs that are representa-tive of the collective Architect-Engineer design scope. This design evaluation will examine design criteria, disciplines, processes, and In organizations used in design of safety-related aspects of the plant.
the construction area, the self-initiated evaluation consists of a sample reinspection of installed hardware, which represents work processes used during safety-related construction activities. Accomplishment of this third objective will further enhance the CPRT's ability to advise TUEC management that there is reasonable assurance. that the CPSES has been designed and constructed such that it can be operated without undue risk to public health and safety.
As can be sehn from a review of the earlier background section and from statements frn the CPRT Program Plan such as that on page 4 of Revision 3, the Program Plan has not been nor will it become a static document. By its very nature, the implementation of the DAP, the QOC and the associ-ated DSAPs and ISAPs, along with the root cause and adverse trend evalua-tions, the determination of generic implications, the collective 1-6                    CP SSER 13 SEC. 1 04/08/86

significance evaluations, and the initiation of corrective action is intended to combine to produce a program that is iterative, flexible, and adequately controlled. The CPRT is a dynamic, responsive organization that is undertaking a comprehensive evaluation and corrective action program that is described in the CPRT Program Plan, which is itself subject to change as the program unfolds. The staff considers this flexible yet controlled approach to the CPRT to be acceptable.
There are four reasons why the staff has concluded that the CPRT's methods for modifying the Program Plan are satisfactory:
The CPRT has already successfully used this approach to appropriately (1)                                                                 For expand the Program Plan to suit its developing evaluation.
instance, new or expanded Appendices have been added on program QA, interface control, and corrective action. In addition, a new ISAP has been added to evaluate and improve craft training.
(2)
The CPRT Program's expandability ensures that new issues will be resolved using a consistent approach.
l (3)    During the evaluation process, as new perspectives become apparer.t to the CPRT, the Program's inherent approach can adapt to focus attention and resources on important issues. This approach greatly enhances the overall effectiveness of CPRT corrective action.
l (4)
The flexibility in the CPRT Program ensures effective incorporation of lessons learned from the evaluation process.
The staff, therefore, approves the CPRT's methods for modifying the Program Plan, as described in the {{letter dated|date=January 27, 1986|text=January 27, 1986 letter}} from W. G. Counsil to V. S.
Noonan (CPRT-207), transmitting Revision 3_of the CPRT Program Plan.
1.5 Problem Identification and Classification 1
There are four key aspects of the CPRT Program:
(1) identification; (2)
In this classification; (3) evaluation; and (4) correction of problems.
1-7              CP SSER 13 SEC. 1 04/08/86 i
                                     -r __- _ _

section, the staff summarizes the methods chosen by the CPRT to classify identified discrepancies. For a detailed discussion of discrepancy classifi-cation, see pages 1 through 4 of 13 of Appendix E, Revision 1, to the CPRT Program Plan.
In Appendix E, the CPRT has described five different sets of definitions that are used to classify problems, which are subject to evaluation by the CPRT. These five different sets apply to the DAP, the QOC, the test programs ISAPs, and the QA/QC portion of the CPRT. The staff's understanding of these and other key terms, which have nearly universal applicability to all CPRT activities, are described below:
(1) Discrepancy. The term discrepancy is used to convey any problem eligible for consideration by the CPRT. This term encompasses the largest set of potential problems and carries no special meaning about the nature, importance, or potential safety impact of the potential problem.
3                  A deviation is a verified failure to meet a licensing commit-(/) Deviation.
ment, to meet a regulatory requirement, or to properly install hardware.
Not all discrepancies may turn out to be deviations, since not all identified problems turn out to be actual failures to meet a requirement, comitment, or installation specification.
:         (/) Design Observations. The term observation has meaning only for the DAP l
portion of the CPRT Program. Each design discrepancy that is determined not to constitute a verified failure to meet a design commitment or specification will be classified as a design observation.
(4) Deficiency. A deficiency is a deviation that has been evaluated as having safety-significance, a term that is defined below. Very few deviations are expected by the CPRT to be classified as deficiencies, since the CPRT expects that few will be detemined to have safety-significance.
(5) Programmatic Deficiency. If a set of deviations is evaluated as having an adverse trend, then a programatic deficiency is said to exist.
1-8               CP SSER 13 SEC. 1 04/08/86

The CPRT expects that deviations in this special set will seldom be safety-significant by themselves.
(6)   Safety-Significant Because of the importance of this term, the descrip-tion presented below is a virtual quote from the language of Appendix E.
Revision 1 of the CPRT Program Plan. Safety-significant is defined to                                                                         '
mean that the identified discrepancy, if uncorrected, would result in the loss of capability of the affected system, structure or component to                                                                          ,
perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train or This definition, which is employed in the CPRT Program structure level.
for purposes of sample expansion, is more restrictive (conservative) than that usually applied to the term " safety-significant" for regulatory purposes or in common parlance, in that it ignores redundancies that do Identification of a deficiency as " safety-exist in real life.
significant" for purposes of the CPRT Program, therefore, is not equiva-lent to a statement that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.
A trend is a set of related discrepancies having (7) Adverse Trend.
attributes that reflect commonality. Examples of possible commonalities include:
o The individual, group of individuals or organization performing the activity.
o        The program requirements, procedures or controls governing the performance of the safety-related activity.
A trend is considered to be adverse if it is determined that the identified pattern or comonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected area, population or stratum. Adverse trends are also referred to as programatic deficiencies.
(8) Root Cause. A root cause is considered to be the fundamental event or decision that was the most likely cause of the identified problem.
1-9                       CP SSER 13 SEC. 1 04/08/86
                           . _ ,             ,        , - , - - . _ ,,._,__,_,.-_~.__---.e____ ,_  , _ , _ - , - _ , - .   , , _ , . , , _ _ _ _ - - - - _ _ ,

Where possible, the CPRT will determine root causes for safety-significant deficiencies and for adverse trends of deviations and design observations.
(9) Generic Implications. Generic implications are the potential products of evaluations of safety-significant deficiencies or adverse trends of deviations that demonstrate whether these problems represent isolated occurrences, generic weaknesses within a particular area, or programatic weaknesses.
Appendix E to the Program Plan describes the CPRT's method for classifying problems. The staff finds the CPRT's problem classification system to be acceptable for the following three reasons:
                 /) The definitions of the different classes of problems to be encountered
                        'are sufficiently clear that the CPRT should be able to satisfactorily implement the classification of identified problems and the NRC staff should be able to readily inspect the CPRT's implementation of this problem classification system.
k I
(/{ The CPRT's problem classification system includes an adequate framework to address problem classification in that the system addresses all possible categories of problems that could be encountered.
                    +
([ The staff finds that the classification process, which is intended to track identified problems through an evaluation sequence from discrepancy through deviation to safety-related deficiency, is a logical process that
'                           should be suitable for satisfactory implementation by the CPRT and for independent inspection by the NRC staff.
Initially, the staff had expressed concern regarding the CPRT's ability to adequately identify items that were not in compliance with licensing commitments. The staff is now satisfied with the CPRT's intentions in this area, as described in- Revision 3 to the Program Plan, for the following reasons:
5 A
1-10          CP SSER 13 SEC. 1 04/08/86

o       All deviations, which include items that fail to meet current licensing commitments, are tracked, evaluated, and classified as to safety-significance.
o       Deviations are evaluated to determine if an adverse trend exists.
W           S o        If TUEC should detemine that the issue needgresolution by changing    XA a licensing comitment, they will submit an FSAR amendment requesting the staff's review and approval of the change.
1.6 CPRT Products: Evaluations, Corrective Action, and Reports.
In accomplishing its activities, the CPRT will conduct or initiate four types of actions to resolve identified problems:
o Determination of Root Causes o   Evaluation of Generic Implications o    Initiation and Oversight of Corrective Action o    Documentation of Results in Reports The first two of these actions constitute important evaluations that the CPRT intends to use to fully resolve identified problems and to bound the The staff's understanding safety-significance of the associated deviations.
and evaluation of these actions are described below (see pages 2 and 7 through
''  9 of Revision 3 to the CPRT Program Plan for TUEC's discussion of these actions).
(1) Determination of Root Causes. The CPRT recognized that the specific I           issues identified by External Sources may be representative of more fundamental, underlying concerns. Accordingly, the CPRT has committed to evaluate each issue, even if the issue is nonsafety-signficant.
l l
Root causes will be investigated and determined where possible for all adverse trends of deviations, design observations, and all deficiencies I
1-11                    CP SSER 13 SEC. 1 04/08/86

identified through the CPRT Program. Such determinations will assist the CPRT in identifying potential generic implications, establishing appropri-ate expanded scopes of review and defining appropriate corrective actions.
ISAPs and DSAPs include tasks that will determine where possible the root causes of identified deficiencies. These tasks are oriented both at specific testing of any initial root cause hypotheses and more general exploratory efforts that will lead to formulation and testing of new root cause hypotheses as the action plan is implemented.
Investigation of a deficiency into the probable cause initially may In some cases, these suggest many possibilities as contributing causes.
If the investigation can be narrowed down to one most likely candidate.
shows no further possibilities, the CPRT plans to define the " root cause" as the event or decision which is the most likely cause of the identified deficiency. This process may, for example, lead to a finding that the However, if further I      deficiency was due to errors in the instructions.
investigation in the same area shows similar errors, it may be determined that the author of the instructions was the real " root cause." Discovery of the second, more extended root cause is intended to enable correction of the wider-ranging situation and to lead to greater assurance that there are no undetected and uncorre'cted safety-signficiant deficiencies associated with the causes of any deficiencies or adverse trends identi-fied by the External Source issues.
The staff has examined the CPRT's description of their intended methods for detemining root causes and finds that the CPRT's description, although brief, is acceptable. At this stage in the CPRT process, few issues have been fully enough resolved to provide the CPRT with enough examples of safety-significant deficiencies or adverse trends to imple-ment a root cause evaluation process. Nonetheless, the CPRT has provided an ample commitment to evaluate root causes as the Program progresses.
The staff will continue its evaluation of the root cause detirmine.tfon process during the CPRT implementation phase.
1-12       CP SSER 13 SEC. 1 04/08/86

(2) Evaluation of Generic Implications.
At such time as the root causes of safety-significant deficiencies or adverse trends of non-safety-significant deviations have been determined, an evaluation will be performed to identify any associated potential generic implications. The CPRT maintains that such evaluations will enable them to determine whether the deficiencies or deviations represent isolated occurrences, generic weaknesses within a particular area, or generic weaknesses that are programmatic in nature.
The CPRT has stated that the results of these evaluations, in conjunction with assessments of the safety-significance of the deviations, will enable them to define expanded scopes for review and to identify correc-tive actions for both the specific deficiency and for prevention of repetition of the same types of deficiencies.
The staff has examined the CPRT's description of their intended methods for detemining the generic implications of each root cause and finds that the CPRT's description, although brief, is acceptable. At this stage in the implementation of the CPRT Program Plan, the root cause determinations have not progressed sufficiently to permit meaningful
        ~                    detemination of generic implications. However, the CPRT has provided an adequate commitment to detennine the generic implications of each found root cause as the Program progresses. The staff will continue its evaluation of generic implications evaluations during the CPRT implementation phase.
(3)         Initiation and Oversight of Corrective Action.
The third action involves TUEC's methods for correcting identified problems and the CPRT's methods for overseeing and, in some cases, concurring in problem correction. Appendix H, Revision 0, of the CPRT Program Plan contains TUEC's description of this corrective action process.
TUEC has structured its action to vest primary responsibility for imple-mentation of corrective action with the CPSES Project rather than the 1-13      CP SSER 13 SEC. 1 04/08/86

                                                                                ._=                   .. -
l CPRT.
Because of the special nature of this program, TUEC has internally i
required that corrective actions by the Project for all safety-significant deficiencies and certain categories of deviations must be acceptable to the CPRT.
The CPRT is responsible for transmitting all deviations and deficiencies to the CPSES Project for evaluation and disposition in accordance with Project procedures for processing non-conformances.
For each deviation or deficiency identified by the CPRT, the CPSES Project is responsible for perfonning 10 CFR 50.55(e) reportability evaluations and for defining appropriate corrective actions. The CPSES Project is also responsible for obtaining CPRT concurrence in the defined corrective actions for:
o     Each safety-significant deficiency identified by the CPRT o     Each programatic deviation or programatic deficiency identified by the CPRT o      Each design deviation identified by the CPRT that involves a l
failure to meet FSAR criteria or comitments, other licensing comitments, or the regulations 4
o      Each deviation identified by the CPRT that has been determined by the CPSES Project to meet the reportability criteria set forth in 10 CFR 50.55(e).
In the event of disputes between the CPSES Project and the CPRT regarding the adequacy of corrective action, TUEC has described a process for resolution of'such disputes on page 3 of 8 of Appendix H to the CPRT Program Plan, Revision 0. The staff finds this described process for resolution of disputes to be acceptable.
1-14     CP SSER 13 SEC. 1 04/08/86

In order to verify that the CPSES Project's program for implementing corrective actions is being effectively implemented, the CPRT is respon-sible for performing confirmatory overviews of the implementation of certain corrective actions. These confirmatory overviews are intended to accomplish the following objectives:
o      To ensure that the corrective actions for each programmatic deviation and programmatic deficiency have been effectively implemented.
o     To ensure that the corrective actions for each specific safety-significant deficiency have been effectively implemented.
o      To ensure that the corrective actions for each specific design deviation that involves a failure to meet FSAR and licensing commitments have been effectively implemented.
o       To ensure that the corrective actions for each specific deviation that meets the reportability criteria of 10 CFR 50.55(e) have been effectively implemented.
The CPRT will perform these overviews using design reviews, document reviews, and independent reinspection and inspection witnessing.
The staff has determined that TUEC's method for implementing corrective l
action and the CPRT's comitment to independently concur and overview f                   key aspects of that corrective action to be acceptable for the following three reasons:
(1) Deviations and deficiencies will be tracked, dispositioned, and l
closed in an auditable system, TUEC's non-conformance report (NCR) j 1                          system.                                In addition, the CPRT's tracking system for deviations l                          ensures that TUEC will generate an NCR for each deviation.
l-l 1-15                                                                               CP SSER 13 SEC. 1
{           04/08/86

(2) The prime responsibility for corrective action and records associated therewith will reside with the organizational entity that will acquire operational control of the facility upon issuance of an Operating License. The staff concludes that it is important that the eventual facility operator controls, implements, and is responsible for this corrective action.
(3) Even though the CPRT will not implement the corrective action resulting from its various evaluations, the CPRT will retain a sufficient level of concurrences and confirmatory overview of TUEC's corrective action for important deviations that the CPRT can ensure the adequacy of corrective action and can ensure the credibility of this Program.
(4) Documentation of Results in Reports .
The fourth action entails documentation of the results of the CPRT's efforts in a set of reports.
The CPRT has described several types of reports that will document the products of its activities. The principal types of reports that the CPRT will provide include:
o     Results Reports.
Each ISAP and each DSAP will produce a Results Report. Each Results Report will at a minimum identify the safety-significant deficien-cies and programmatic deficiencies, their resolution, any root causes and generic implications and their resolution and any recom-mendations for progransnatic improvements to abate the potential for reoccurrence. The CPRT overview of corrective action implementation required by Appendix H will either be included in the Results Report or a supplement to the Results Report.
4 1-16                         CP SSER 13 SEC. 1 04/08/86

The DAP will also produce third-party CPRT Results Reports concur-
               \
ring in the criteria, the processes used and the implementation of the piping and pipe support and cable tray and conduit support        .
design verification efforts.
o     Collective Evaluation Reports.
In the Quality of Construction and QA/QC Adequacy, Design Adequacy, and Testing Program Adequacy areas, the results of the various activities will be collectively evaluated to ensure that potentially safety-significant trends implicit in the collective data but not apparent from the activity specific results are not overlooked.
These collective evaluations will be separately reported in Collective Evaluation Reports.
The Collective Evaluation Report relating to the adequacy of the QA/QC Program will include the identification of necessary improve-ments to future CPSES construction activities and to future plant operations. The Collective Evaluation Report relating to the quality of installed hardware will include identification of the corrective actions necessary to resolve safety-significant hardware deficiencies.
The Collective Evaluation Report relating to the DAP will be called f
the Final Design Adequacy Program Report and will include identifica-tion of improvements needed for future CPSES design activities and identification of corrective actions needed to resolve safety-significant design deficiencies.
o    Collective Significance Report.
A collective significance evaluation will focus on the integrated impact of the identified deficiencies, both specific and program-matic, on the design, construction and testing of CPSES. This evaluation will be conducted by the Senior Review Team (SRT), which 1-17                    CP SSER 13 SEC. 1 04/08/86

consists of a senior TUEC line manager and senior industry consult-ants and which has been established with overall responsibility for the development and implementation of the CPRT Program. The CPRT h
pf Program Director is an ex-offici t member of the SRT.                                  _
The staff finds that the CPRT's description of methods for documenting the results of their efforts in Results Reports Collective Evaluation Reports, and the Collective Significance Report to be acceptable for the following reasons:
(1) These reports, if produced as described in the Program Plan, will give TUEC and the NRC staff sufficient basis for reaching a conclusion about t
the adequacy of the design and construction of the CPSES.
(2) Although the Program Plan description of the Collective Evaluation Reports and the Collective Significance Report is briefer than the description of the Results Reports, the description is considered adequate. The collective evaluations that will support these reports can only begin in earnest when the CPRT has completed the bulk of the i
examinations needed to resolve each ISAP and DSAP. At that time, the respective issues will have become sufficiently understood so that the
* implications of each issue can be properly evaluated. The staff will inspect the CPRT's implementation of these collective avaluations during the implementation phase of the Program.
1.7 Overall Conclusions In SSER 13, the staff approves the CPRT Program Plan and finds reasonable assurance that, if implemented subject to the comments identified in this evaluation, the CPRT Program Plant will provide sufficient information to ensure that the CPSES has been designed, constructed, and tested in a manner that it can be operated without undue risk to public health and safety.
2 .
1-18                        CP SSER 13 SEC. 1 04/08/86
    .,,p. , _ _ - . -  -_,.,--__,-.,_-,__._,,-_______-r,,         .-,c=  -e w- -
e, 'g-.-- -- -                ---,.-w - - ------    **w---+--

The staff concludes, based on its evaluation in this SSER, that Revision 3 of the CP8T Program describes an acceptable process for resolving all currently identified design, construction and QA/QC and testing external source issues and for conducting a self-initiated evaluation evaluation of the design and the quality of construction for all safety-related systems and components.
That process is also an acceptable framework for the evaluation and resolution of any future issues which may arise.
9 8
1 19                     CP SSER 13 SEC. I 04/08/86

a Document Name:
CP SSER 13 SEC. 2 Fequestor's ID:
ORDAZ Author's Name:
Trammel Document Comments:
Comanche Peak SSER 13 Section 2 i
f 1                                                        ,
s

2.0 QUALITY OF CONSTRUCTION The adequacy of the construction QA/QC program and the quality of construction performed within the scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC with responding to and resolving these concerns. This section of the SSER documents the staff evaluation of the CPRT-formulated program (QOC Program) to evaluate questions concerning construction QA/QC and the adequacy of installed hardware.
The CPRT's objectives for the QOC Program are to identify and resolve all of the construction and QA/QC'related external source issues, assess in an inte-grated fashion all identified safety-significant deficiencies and to make a statement about the adequacy of construction at CPSES. The CPRT's program has the following three components:
: a.      Identification and resolution of external source issues,
: b. Root cause evaluation and generic implication assessment for each identified safety-significant deficiency or trend of nonsafety-significant deviations, and
: c. Self-initiated reinspection and documentation review of a representative sample of QC accepted safety-related work activities.
The objective of the staff's evaluation is to ascertain if the CPRT Program Plan describes a framework and process for accomplishing the three components listed above. Subsequent sections of this SSER address both the CPRT-proposed In performing this evalua-process and the staff's evaluation of this process.
tion the staff conducted document reviews and audits for the purposes of understanding the details of the QOC Program process, determining whether an auditable trail existed, and to provide assurance that the proposed process was adequate to meet the Program Plan objectives.
                                            '2-1                         CP SSER 13 SEC. 2 04/02/86

2.1    External Source Issues Concerns regarding the adequacy of the CPSES construction QA/OC program and the adequacy of the constructed safety-related hardware have been raised by a number of sources external to TUEC and are referred to as External Source Issues (ESIs). The QOC has established two components to resolve and bound the safety-signif'icant implications of any ESI deficiency in either the hardware or the CPSES QA/QC construction program. First, the CPRT will evaluate each external source issue by determining the scope of any safety-significant hardware deficiencies and the corrective actions necessary to resolve them.
engineer-This process included reinspection of hardware, documentation review, ing analysis and evaluation, assessment of TUEC corrective action programs and an evaluation of data collected from other CPRT review team action plans.
Second, the CPRT will determine the root cause of each discovered safety-significant deficiency or trend of nonsafety-significant hardware deviations.
They will analyze the generic implications of each root cause in order to determine the extent of any additional hardware that mig'at be deficient for the same programmatic reasons and to determine if changes need to be ia ongoing programs to prevent recurrence in the future (further details of this second component are explained and evaluated in Section 1.5 of this SSER).
Issue-specific actions plans (ISAPs) describe the CPRT plan for resolving each of the external source issues. All construction QA/QC issues whether of a hardware nature or a QA/QC programmatic concern, will be the subject of an ISAP. A single ISAP VII.c also describes the process and methodology for hich the CPRT's self-initiated hardware reinspection and documentation review w The results report prepared for each ISAP is discussed in Section 2.2 below.
Should additional issues be documents each individual issue evaluation.
identified by either other external sources or the CPRT, a new ISAP would be prepared for resolution of the new issue or an existing ISAP will be expanded CPRT proposes to integrate as confirmed in revision 3 of the Program Plan.                                      l and collectively evaluate the findings from their external source issue eva ua-k          t te-tions with the results of the self-initiated program in order to ma e a si a ment about construction quality at the Comanche Peak Steam Electric Stat on.
2-2                  CP SSER 13 SEC. 2 04/02/86

Three reports will be prepared in addition to the individual action plans results reports to document the results of the integrated evaluation. Two collective evaluation reports will be prepared to address the adequacy of the construction QA/QC program and the quality of installed hardware. Finally, a summary report will integrate the results of the two collective evaluation reports and state the CPRT's conclusions regarding the quality of construction and the QA/QC program at Comanche Peak plant. Any information that may be related to design adequacy which is identified during implementation of this ISAP will be referred to CPRT personnel res jonsible for implementation of the DAP.
To assure that all issues / concerns from External Sources are addressed, the CPRT will develop a matrix that provides a cross-reference between each issue /
concern and the action plan (s) that addresses it. This matrix will also serve as an aid in the collective evaluation process. The matrix format will present information such that valid concern can be tracked to the appropriate criteria of 10 CFR 50, Appendix B, and/or hardware area, and tracked to the ISAP govern-ing the concern.
2.2 Self-Initiated Program The self-initiated evaluation of construction adequacy is described in ISAP VII.c. This action plan describes the proposed CPRT reinspection and documen-tation review of a representative sample of completed and QC-accepted safety-related construction work activities performed at Comanche Peak. The objective of this effort is to provide additional confidence that there are no unidentified safety-significant concerns related to the quality of construction of the l
hardware at Comanche Peak. The CPRT's Plan consists of a reinspection of a f
l representative sample of safety-related construction work which has been l
l         inspected and accepted by CPSES QC for Units 1, 2 and their common areas, supplemented by a review of related documentation for uninspectable hardware l         attributes. Construction activities are organized into three disciplines as follows:
i               o    Civil / Structural o    Electrical, and o    Mechanical / Piping 2-3                CP SSER 13 SEC. 2 04/02/86

The methodology for the self-initiated construction adequacy review consists of establishing' reasonably homogeneous populations of construction work activities by reviewing applicable drawings and specifications, codes and standards, work and inspection procedures and by identifying organizations and crafts who performed the work. The populations are then sampled and evaluated by means of physical reinspections of safety related attributes and documentation reviews of uninspectable attributes. The results of these evaluations with conclusions drawn will be documented in an action plan results report.
The self-initiated
                                                                    -r   ted hardware into review begins with the categorization of all safet   (.H              ich samples can be populations made up of homogenous work activitiesg or drawn for evaluation. Population and work process descriptions are prepared for each construction category. The population description describes the boundaries of the population while the work activity describes the process Attributes required to install or construct a certain category of hardware.
associated with each work activity are established based upon the provisions of installation and inspection procedures and/or specifications used for installa-tion of the subject hardware. For each population, two random samples will be selected in accordance with the procedure in Appendix D of the Program Plan.
The first sample is derived from the total population while the second sample (which is essentially an expansion of the first) is drawn from that portion of the total population which is defined by the CPRT as having greater importance to safety. In parallel with the sample selection, checklists and inspection procedures are developed from the attributes used to characterize each work process. Both inspection and documentation review checklists are developed Verification packages are then assembled for from the Quality Instructions.                                                      Any i
each sample item to facilitate an inspection or documentation review.
i     deviations identified as a result of a reinspection or a documentation review are documented in a Deviation Report which will then be evaluated to determine In addition, all deviations are the safety-significance of the deviation.
An action plan results report collectively evaluated for adverse trends.
f      documenting the overall results of the inspections for all populations is the vehicle for documenting the results and evaluations of this ISAP.
l I
2-4                           CP SSER 13 SEC. 2 i       04/02/86 I

The sample size for each population which is part of the construction adequacy review program is targeted by the CPRT in Appendix D to meet a 95/5 confidence level. This confidence level is used by the CPRT as a means for
* detecting programmatic or systematic deficiencies. For each work If no activity of interest, a minimum sample size of 60 will be taken.
safety-significant deficiencies are found in the sample, the work activity is accepted. If a deficiency is found, the sample is expanded. For a single sample expansion, the sample would be increased to 95 and the work activity is As accepted only if the total number of deficiencies does not exceed one.
noted in Attachment 4 to Appendix D of the Program Plan and confirmed by the Applicant in a meeting with the staff on March 18, 1986, only one sample expansion will be made prior to performing a 100% reinspection or reevaluation Provisions are of an attribute, stratum, or population as conditions dictate.
If the provided in Appendix D for 100% reinspection or review of a population.
items from the samples contain no safety-significant deficiencies, and there are no apparent adverse trends of nonsafety-significant deviations, no further If a sample is found reinspections or documentation reviews would be required.
to contain one or more safety-significant deficiencies, or if there is evidence of an adverse trend, the sample would be expanded and additional reinspections/
documentation reviews conducted. All safety-significant deficiencies will be analyzed for root cause and generic implications in conjunction with these expanded reinspection / documentation reviews and will be consistent with the process used to establish the NWAs.
l l
A results report will be prepared documenting .he results of the self-initiated evaluation program. Any information that may be related to design adequacy which is identified during implementation of this ISAP will be referred to CPRT personnel responsible for implementation of the DAP.
2.3 Staff Evaluations I     The staff reviewed the applicable sections of the Program Plan and each individual ISAP including the ISAP describing the self-initiated evaluation program for the purpose of ascertaining if the CPRT's construction; adequacy program can accomplish its stated objectives (See CPRT Program Plan, Appendix B, Page 2). In addition to the review of each individual ISAP, on-site audits 2-5                  CP SSER 13 SEC. 2 04/02/86
\

of the documentation being prepared in support of external source issue reso-lution and of the self-initiated evaluation program were performed for the These audits also purpose of developing an understanding of the CPRT process.
served to establish that the Applicant was documenting construction adequacy evaluation activities in sufficient detail to permit audit now or in the future.
Review of the construction adequacy program plan has been accomplished by teams of NRC staff and consultants. External source issue review have been RT organized in a manner similar to the NRC's Technical Review Team and include the following disciplines,
: a. Electrical and instrumentation issues
: b. Testing program issues
: c. Mechanical and piping issues and miscellaneous issues
: d. Civil and structural issues
: e. QA/QC issues Many of the individuals responsible for reviewing the scope methodology and implementation of the external source ISAP's were members of NRC's Technical Review Team.
Review of the self-initiated evaluation program is accomplished by a multidisciplinary team encompassing most of the disciplines addressing external source issues. This team has reviewed the methodology for the self-initiated program and has audited the safety related hardware populations.
The scope of each ISAP contained in Revision 3 of the Program Plan has been reviewed by the staff for the purpose of comparing its content with that required by the Issue Specific Action Plan Format (Attachment 3 to CPRT The format Program Plan) and its scope with the issue requiring resolution.
required by the CPRT describes the elements of the ISAP process'and includes:
: a. Description of the issue
: b. Actions identified by the NRC
: c. Background l
: d. CPRT Action Plan l
l l
2-6                 CP SSER 13 SEC. 2 j             04/02/86

The ISAP Format also provides guidance for the development of the CPRT Action 9
Plan. For example, the approach to resolution, the required tasks, and assess-
 >                    ment for' potential generic implications must all be included in the CPRT Action Plan. Also, applicable procedures, responsible organizations, personnel qualification, and acceptance and decision criteria must be addressed in each ISAP to comply with the CPRT's specified ISAP Format. Further, implementation of an ISAP is to be in accordance with the CPRT's Quality Assurance Program and the status of each ISAP will be monitored through the CPRT Program Records with-documentation provided in a Results Report. Based upon the assessment of the ISAP format, which essentially describes the CPRT's process for resolving issues, the staff finds that this process contains the elements necessary for systematically addressing issues raised by external sources, as well as any specific issues which may be identified by the CPRT or other external sources in the future. The CPRT acknowledges in Revision 3 to its Program Plan that the scope of its activities will be revised as appropriate. This commitment provides the staff with additional assurance that the CPRT will appropriately.
address and resolve any other construction and QA issues which may be raised in the future.            The staff finds the individual ISAPs are generally responsive to the issues based on the staff's technical review of each ISAP, since they adhere to the ISAP format and address the specific concerns by means of a systematic approach to resolution. Specific comments are provided in Appendix B to this SSER.
The staff reviewed the CPRT's process for their self-initiated program includ-ing their sampling program to determine if it would accomplish its . stated objectives.         This review which included on-site audits examined the homogeneous work activities to develop an understanding of the CPRT's self-iuitiated i
program, to ensure that an auditable trail existed and to determine if the same procedure was being applied to all disciplines. The audits did not address the implementation of the reinspections and the document reviews. The staff found the documentation of the populations to be compatible with the CPRT's Plan described in ISAP VII.c and found the development of the inspection checklists and the documentation associated with this process to be consistent for all populations. The staff further found that the documentation was adequate to i
ensure that this process could be audited in the future. The basis, descrip-tions, items list, and work activity definition for most populations was 2-7                                       CP SSER 13 SEC. 2 04/02/86
   , , , , - r--x.,y-         7.._., ---.,v.   - ,,, ,- ..,, ---.,-_y -_._- _ ,     ,%+--. . _ - -____,_--_.-e.,,--c.,.          ,._.,,_._--.--.+,or.-n 3,,.rrr--- -.--.

reviewed and found to be acceptable since they properly addressed the concept of homogeneity and were documented to enable evaluation of the work activities and their accompanying attributes.
f The sampling procedure is based on assumptions that characterize a binomial population (i.e. acceptable or not acceptable). These assumptions include, among others: (1) homogeneity of items within a work activity; (2) random selection of sample items from a work activity; (3) ability to classify an item as either acceptable or deficient with certainty; (4) the number of items in the work activity is essentially infinite. The homogeneity of the various work activities, required by Assumption 1, is determined and justified by engineer-ing considerations. Homogeneity is a necessary attribute for a population if conclusions based on a sample of a population are to be valid for the entire population. If the population of interest is found to be non-homogenous, the work activity boundaries are redrawn and samples are selected at random from the respective work activities.
The selection of the items from the NWAs is made through a random Since all popula-sampling procedure described in Attachment 2 of Appendix D.
tions developed for the self-initiated program are finite, all sample sizes will be larger than required because of Assumption 4. The 95/5 assurance level i
was selected by the Applicant as a criterion to allow a quantification of the quality of the work activity performance wrthout having to reinspect each and every individual item. From a strict probabilistic view, the sampling plan stated in Appendix D offers less than 95 percent assurance, primarily because of the Plan's associated expansion. A plan which allows no expansion (i.e.,
l accept the work activity only if zero deficiencies are found in a sample size of 60) actually cffers 95.4 percent assurance that no more than 5 percent of the items in the work process are unacceptable. If one expansion is allowed, the assurance level is 93 percent.                           On the other hand, the 95/5 level of assurance is only an arbitrary target value and somewhat smaller assurance (at least 90/5) is in the staff's judgement considered acceptable for this application.              Moreover, there are many factors that would further enhance this assurance. Some of these factors are:
2-8                           CP SSER 13 SEC. 2 04/02/86 d
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: 1. As previously noted in this subsection, the initial sample is supplemented by a second sample drawn from that portion of the population having greater importance to safety.
: 2. The sampling scheme assumes (assumption 4) that the size of the work activity is infinite. For small groupings of work activities, the sample size is considerably larger than need be and hence the associated assurance is understated.
: 3. The sampling assurance is increased when a de.ficiency is identified and repaired. For categories involving a small number of work activities this increase may be very significant.
: 4. When a deficiency is identified, the CPRT Plan calls for further sampling. This activity increases the sample size, generally giving a still greater assurance.
The CPRT's self-initiated program for evaluation of construction adequacy commits to performing root cause evaluations and generic implication assess-ments of safety significant deficiencies and adverse trends of non-safety significant deviations. In addition, adverse trends will be investigated to identify trend boundaries and to determine the affect of the trend on other
  . areas if aFPlicable. Closed external source issues will be considered in the root cause and generic implication evaluations.
The staff considers that the CPRT's self-initiated program for evaluation of construction adequacy to be acceptable because it:
a)      is a structured process which complies with the CPRT's ISAP Format b)      employs an appropriate procedure for assuring homogenous populations for sampling by the use of HWAs.
l f
!          c)       employs e conventional sampling process accepted in the, industry.
l 2-9           CP SSER 13 SEC. 2 04/02/86

d)   establishes a targeted level of assurance by the 95/5 criterion which should be sufficient to identify programmatic deficiencies.
e)   provides for a 100 percent reinspection of a population if two or more deficiencies of the same type are detected in the minimum initial sample.
f)    requires root cause evaluation and generic implication assessments of both safety significant deficiencies as well as adverse trends of non-safety significant deviations and g)   is documented in a manner suitable for audit now and in the future.
2.4 Conclusions The staff concludes, based on its evaluation described above, that Revision 3 of the CFRT Program documents an acceptable process for resolving all currently identified construction and QA/QC external source issues and for conducting a self-initiated evaluation of the quality of construction for all safety related systems and components. That process is also an acceptable framework for the evaluation and resolution of any future issues which may arise.
l                                                                                                                                     ;
l l
I 2-10                                               CP SSER 13 SEC. 2
,                    04/02/86

Document Name:
CP SSER 13 SEC. 3 Requestor's ID:
ORDAZ Author's Name:
Trammel Document Comments:
9

Document Name:
CP SSER 13 SEC. 4 Requestor's ID:
MARIGGIO Author's Name:
Trammell Document Comments:
Comanche Peak SSER Input 3/26/86
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Document Name:
F                        CP SSER 13 SEC. 5 Requestor's ID:                        .
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Trammel i
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i Comanche Peak SSER 13 5.0 Conclusion 1_
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5.0 Conclusion The NRC staff evaluated the CPRT's Program Plan and finds it'to be comprehen-sive in scope and structured to address all existing issues and any future issues which may be identified by external sources. The Program Plan also contains the Applicant's commitment to a set of self-initiated programs intended to assess the adequacy of design and construction of the Comanche Peak Steam Electric Station. Finally, the CPRT Program Plan provides a commitment on the part of the Applicant to resolve staff concerns and demonstrate overall plant safety.
The staff's evaluation of the Program Plan included reviews and audits of the self-initiated programs intended to evaluate design and the design adequacy and construction of the CPSES. The staff. finds these self-initiated programs to be appropriate mechanisms for evaluating design and construction quality.
Further, the implementation and results of these programs are being documented in sufficient detail to permit current and future in-depth review should this be necessary.                Implementation of these programs will be audited until completion of these activities with results to be documented in a future SSER.
Staff acceptance of the self-initiated programs is intended to indicate that an acceptable process has been proposed; an acceptable framework provided for its implementation; and a commitment made to document this process, its results and Further, the staff's conclusions in a manner amenable to future audits.
evaluation finds the issue-specific and discipline-specific action plans generally responsive to external source issues identified at this time.
The Applicant has indicated that sampling as used in the CPRT program is intended to ensure that a systematic approach is used in the resolution of specific issues and in the execution of the self-initiated evaluation. The staff finds that the Applicant's general sampling approach is acceptable.
Specific application of sampling will continue to be reviewed and audited by the staff during the implementation of the program. The staff notes that some I   areas have already been identified for 100 percent reevaluation such as piping and cable trays and conduit supports. The staf f concurs with the ,, Applicant's intent to completely reevaluate these areas.
5-1                            CP SSER 13 SEC. 5 04/01/86

Finally, although concerns are noted in this report, the staff finds the Plan appropriate and acceptable for its intended application. Because the CPRT Program Plan is the Applicant's framework for completely addressing all currently identified issues and is the mechanism for the identification, evaluation, and resolution of any future issues, the Applicant should resolve the staff concerns in a future plan revision.
I j
5-2                     CP SSER 13 SEC. 5 04/01/86

   ~ -
O Document Name:
CP SSER 13 APP. A Requestor's ID:
ORDAZ Author's Name:
Trammell Document Comments:
Identification of all Components of CPRT' Program Plan l
1 f
l i
l 1
1-i i-i i
I

I-Appendix A - Identification of all Components of the CPRT Proaram Plan, includina Appendices. ISAP's and DSAP's by Revision Number i
Although reference is made in this evaluation to " Revision 3" of the CPRT Program Plan, this document actually consists of numerous documents, each.with its own revision number. In addition, " Revision 3" is considered to include four additional letters received after Revision 3 was issued on January 27, 1986. Therefore, for purposes of this assessment, Revision 3 is considered to consist of the basic Revision 3 submittal of January 27, 1986, plus the follow-ing:    1) Appendix D, CPRT Sampling Approach, submitted on January 31, 1986; 2)
Appendix E, CPRT Procedure for Classification, Evaluation, and Tracking of Specified Design or Construction Discrepancies Identified by the CPRT, sub-mitted on February 7, 1986; 3) the Testing Issue - Specific Action Plans (ISAPs), submitted on February 28, 1986*, and 4) Appendix G, Overview Quality Team, submitted on February 28, 1986.
          ' Identified below is the revision number for each appendix, ISAP, DSAP, and attachment contained in Revision 3 of the CPRT Program Plan as of the date of this evaluation.
* ISAP III.a.1 was not included.
4 O
1 I
i I
6 CPSSER 13 App A.
A-1 03/26/86

Revision QA/QC ISAPs I.d.1       QC Inspector Qualifications                                                   2 I.d.2       Guidelines for Administration of QC Inspector Test                                                                2 I.d.3       Craft Personnel Training                                                      0 VII.a.1      Material Traceability                                                         1 VII.a.2      Non-Conformance and Corrective Action System                                                                 1 VII.a.3     Document Control                                                              1 VII.a.4     Audit Program and Auditor Qualification                                       1 VII.a.5     Periodic Review of QA Program                                                 1 VII.a.6     Exit Interviews                                                               1 VII.a.7     Housekeeping and System Cleanliness                                            1 Fuel Pool Liner Documentation                                                  1 VII.a.8 On-Site Fabrication                                                            1 VII.b.1 Valve Disassembly                                                              1 VII.b.2 VII b.3     Pipe Support Inspections                                                       1 Hilti Anchor Bolt Installation                                                 1 VII.b.4 VII,b.5    DELETED VII.c       Construction Reinspection / Documentation Review Plan 1 DSAPs i                               VIII                       Civil / Structural Discipline Specific Action Plan                                         1
;                                 IX                       Piping and Support Discipline Specific
'                                                          Action Plan                                         1 X                        Mechanical Systems and Components Discipline Specific Action Plan                     1 XI                      Electrical /I&C Systems and Components Discipline Specific Action Plan                     1 A-4                  CPSSER 13 App. A.
03/26/86

I Component Title                            Revision Program Plan                                     3 Appendix A               Design Adequacy Program Plan                      1 Appendix B               Quality of Construction and QA/AC Adequacy Program Plan                       3 Appendix C               Action Plans Electrical ISAPs I.a.1         Heat-Shrinkable Cable Insulation Sleeves          4 I.a.2         Inspection Reports on Butt-Splices                4 I.a.3         Butt-Splice Qualification                         4 I.a.4         Agreement Between Drawings and Field Terminations                                      4 I.a.5         NCRs on Vendor Installed Amp Terminal Lugs        4 I.b.1         Flexible Conduit to Flexible Conduit Separation                                        4 I.b.2         Flexible Conduit to Cable Separation              4 I.b.3         Conduit to Cable Tray Separation                  4 I.b.4         Barrier Removal                                   4 Civil / Structural ISAPs   '
Electrical Conduit Supports                       3 I.c II.a           Reinforcing Steel in the Reactor Cavity           3 II.b          Concrete Compression Strength                      3 II.c          Maintenance of Air Gap Between Concrete Structures                                        3 II.d           Seismic Design of Control Room Ceiling Elements                                          3 II.e          Rebar in the Fuel Handling Building               3 l
l l
A-2                  CPSSER 13 App. A.
03/26/86

Revision Testing ISAPs III.a.1                      Hot Functional Testing (HFT) Data Packages III.a.2                     JTG Approval of Test Data                           3 III.a.3                      Technical Specification for Deferred Tests          3 III.a.4                      Traceability of Test Equipment                     4 III.b                         Conduct of the CILRT                               4 III.c                          Prerequisite Testing                              4 III.d                          Preoperational Testing                            4 IV.                            Reserved for Protective Coatings, however, SSER-9 declassified protective coatings and negated the need for a protective coatings ISAP. Paint quali'ty concerns are being addressed under the Quality of Construction Program.
Mechanical ISAPs V.a                            Inspection for Certain Types of Skewed Welds in NF Supports                                     2 V.b                            Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports                   2 V.c                           Design Consideration for Piping Systems between Seismic Category I and Non-Seismic Category I Buildings                               2 V.d                            Plug Welds                                        2 V.e                            Installation of Main Steam Pipes                  2 VI.a                           Gap between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall                                       2 VI.b                           Polar Crane Shimming                              2
* ISAP III.a.1 was not included 03/26/86                                                  A-3                  CPSSER 13 App. A.

                                                   .s.            ._
Revision f
QA/QC ISAPs                                                                            .
2 I.d.1           QC Inspector Qualifications 1.d.2           Guidelines for Administration of QC 2
Inspector Test Craft Personnel Training                                        0 I.d.3 Material Traceability                                           1 VII.a.1 VII.a.2         Non-Conformance and Corrective 1
Action System 1
VII.a.3         Document Control 1
VII.a.4         Audit Program and Auditor Qualification Periodic Review of QA Program                                   1 VII.a.5 1
VII.a.6         Exit Interviews 1
VII.a.7         Housekeeping and System Cleanliness 1
VII.a.8         Fuel Pool Liner Documentation 1
VII.b.1         On-Site Fabrication 1
VII.b.2         Valve Disassembly 1
VII.b.3         Pipe Support Inspections 1
VII.b.4         Hilti Anchor Bolt Installation VII.b.5         DELETED VII.c           Construction Reinspection / Documentation Review Plan 1 DSAPs VIII         Civil / Structural Discipline Specific 1
Action Plan IX           Piping and Support Discipline Specific 1
Action Plan X            Mechanical Systems and Components 1
Discipline Specific Action Plan XI          Electrical /I&C Systems and Components 1
Discipline Specific Action Plan A-4                 CPSSER 13 App. A.
03/26/86

Revision 1
I Appendix D                                       CPRT Sampling Approach Appendix E                                       CPRT Procedure for Classification, Evaluation, l
and Tracking of Specified Design or Construction Discrepancies Identified by 1
the CPRT 1
Appendix F                                       CPRT Interfaces 0
Appendix G                                       Overview Quality Team 0
Attachment 1: CPRT Third-Party Quality Assurance Program Attachment 2:           Management Program Plan for the QA/QC 4
Review Team Attachment 3:           Design Adequacy Review Team Quality 0
Assurance Program Attachment 4: Verification of Issue-Specific Action Plan                                                                                               ,
0 Working Files Appendix H CPRT Procedure for the Development, Approval, and Confirmation of Implementation of 0
Corrective Actions W
l CPSSER 13 App. A.
A-5 03/26/86
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Document Name:
CP SSER 13 APP.B Requestor's ID:
ORDAZ Author's Name:
CTrammell Document Comments:
O

Appendix B -       Items to be addressed by Applicants during the implementation phase of certain ISAPS This Appendix discusses only those ISAPs concerning which the NRC staff has comments. These should be addressed by the Applicants during the implementation phase of each ISAP. The NRC staff has no comments on the remaining ISAPs which are acceptable for implementation as su'o mitted.
The NRC staff will examine the Applicants' response to these comments as part of its inspection program for the CPRT Program Plan implementation of all ISAPs.
B-1                              CP SSER 13 APP.8 03/31/86

Electrical / Instrumentation Issues and Control Systems and Components T
I.a.1              Class 1E Heat Shrinkable Cable Insulation Sleeves Description Heat-shrinkable insulation sleeves are required for uninsulated butt splices, 480-volt and 6.9 kv motor terminations, at cable reduction splices,and at electrical penetration assembly cable connections. The NRC concern as noted in SSER No. 7, Electrical and Instrumentation Categories 1 and 6, centered on the lack of awareness by craft' and inspection personnel as to where the sleeves should be installed and the high percentage of missed or improperly documented inspections requiring witnessing.
Staff Comment This ISAP is adequate to establish the accuracy and completeness of documentation records for the heat shrinkable sleeve issue with respect to completed construction items since it commits to retraining after revision of the applicable procedures. However, since the cause of the concern has been identified as inadequate personnel training, additional
  , training along with revised procedures must be provided and the ISAP should be expanded to include provisions for inspecting future electrical construction to ensure the effectiveness of the additional training and procedure revision.
I.a.2           Inspection Reports on Butt Splice Inspection Reports Description QC inspection reports for 12 butt splices were found to be deficient in one or more respects as noted in SSER No. 7, Electrical and Instrumentation Category
: 1.           Nine reports used a post-installation inspection form instead of a witnessing-type inspgetion form.
Six of these nine reports did indicate that installation of the heat shrinkable sleeves had been witnessed, but did not indicate that such witnessing was required. The other three of these nine B-2                          CP SSER 13 APP.8 03/31/86

forms did not indicate that installation of the splices had been witnessed.
The remaining three reports using the correct form indicated that witnessing of the installations of heat shrinkable sleeves was not applicable (or required). the NRC recommendation was that all QC inspections requiring witnessing for splices be performed and properly documented, and that all but splices be identified on design drawings and physically identified within the appropriate panels.
Staff Comments This ISAP is unsatisfactory both in its approach and in the lack of quantita-tive commitments for inspection and pullout testing of existing butt splices because it presumes that they are satisfactory rather than demonstrating their adequacy. The ISAP should be revised to state explicitly the number of butt splices to be inspected and pullout tested, to identify the approach to resolution of documentation deficiencies and to identify each butt splice.
I.a.3   Butt Splice Qualification Description On a limited basis as described in FSAR Amendment 44, the practice of butt splicing cable conductors in panels has been permitted subject to:
(1) adequate provisions in installation procedures to verify the operability of circuits using butt splices; (2) qualification of the wire splices for anticipated service conditions, and (3) staggering of the splices so that they are not adjacent to or pressing against one another in the same wire bundle.
In addition, reinspection of all existing butt splices was to be accomplished using adequate installation and inspection procedures. As noted in SSER No.
7, Electrical and Instrumentation Category 1, circuits containing butt splices were to be tested, and retested if reworked, during plant preoperational and star, tup tests to assure their operability.
8-3                         CP SSER 13 APP.B 03/31/86

i Staff Comments                                                                      ,
4                                                                                                                                                                                                                 I Since all butt splices in various panels will be inspected to assure that no butt splice touches another one within a wire bundle and rework splices in nonconforming wire bundles will be reworked, this ISAP for butt splice qualifi-cation is adequate to address this issue. However, functional operability of those circuits containing butt splices must be demonstrated by the proposed use of circuit continuity checks.
I.b.1            Flexible Conduit Separation Description 1
;                                                                    Industry criteria, such as IEEE Std. 384-1974, have established minimum separation distances to be maintained-between redundant safety-related cables and between safety-related and nonsafety-related cables within control room Lesser separation panels and cable spreading room termination cabinets.
distances may be justified if supported with engineering analysis of the
'                                                                      involved circuits and components. The TRT, as noted in SSER No. 7, Electrical and Instrumentation Category 3, observed that flexible conduits containing l                                                                      safety and nonsafety cables within these panels were in direct physical I                                        ~
contact, and could not find evidence that analyses had been performed to
+
justify this deviation from requirements in the industry standards.
4 Within main control room panels, for example, flexible conduit identified with one separation division (orange color) has been bundled together with flexible conduit identified with the redundant separation division (green color). In this instance, a technical justification for the lack of one inch separation i
distance between conduits containing safety-related circuits has not been provided.
A reinspection of all panels containing redundant safety-related conduits or both safety-related and nonsafety-related conduits was required to either l
correct each violation of the separation criteria or to demonstrate by
-                                                                            analysis the acceptability of the conduit as a barrier.
i 8-4                                          CP SSER 13 APP.B 03/31/86
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Staff Comments I
Since conformance of internal panel cables and conduits to applicable industry separation criteria is required by this ISAP, 'it is responsive to the issue of adequate separation of flexible conduits in main control' room panels and vertical panels in an acceptable manner. However, it does not specifically In address the issue of SERVICAIR flex in areas outside the main control room.
Sections 3.0 and 4.1.5 of this ISAP the Applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installa-tions. For any installations outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be determined on a case-by-case basis. The staff will find this acceptable and responsive to the action items stated in SSER 7 on confirmation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc. ,
containing two or more Class 1E and non-class 1E circuits.
I.b.2    Flexible Conduit to Cable Separation Description This particular NRC concern as noted in SSER No. 7, Electrical and Instrumen-tation, Category 3, is similar in many respects to ISAP 1.b.1 regarding the accomplishment of minimum separation distances between flexible conduits within main control room panels and vertical panels. In ISAP 1.b.2, the TRT identi-fled twenty-one cables within four panels where the minimum separation distance of 6 inches specified in industry standards had not been maintained relative to SERVICAIR flexible metal conduits containing safety-related cables.
NRC required that a reinspection be performed of main control room panels, other panels located in the control room, and panels located in other areas of the plant where cables and flexible conduit had been used. TUGC0 was requested to either correct any separation criteria violations in these panels or demonstrate that the flexible metal conduit was an adequate barrier in i
8-5                         CP SSER 13 APP.B 03/31/86

accordance with IEEE Std. 384-1974.               If the flexible conduit could not be shown to be a suitable barrier, a minimum separation distance of 6 inches was                                        ,
to be maintained between cables and flexible conduit within the panels. In addition, drawings and related documents were to be revised to indicate the                                     .
revised minimum separation distances.
Staff Comments Since conformance of internal panel cables and conduits to applicable industry separation criteria is required, this ISAP is adequate for assuring compliance with minimum separation requirements for main control room panels and vertical panels.
The ISAP, however, does not explicitly address the issue of SERVICAIR flex in areas outside the main control room. In Sections 3.0 and 4.1.5 of the Action Plan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installations outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be determined on a case-by-case basis. The staff will find this acceptable and responsive to the action items stated in SSER 7 on conformation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc.
containing two or more Class 1E circuits, or Class 1E and non-Class 1E circuits. Also, in Section 4.5.1 of the ISAP, the acceptance criteria is stated as " testing and/or analysis". This is inconsistent with the other sections of the plan which describe testing and analysis, combined, as the means of demonstrating the adequacy of SERVICAIR flex as a barrier, and is therefore not acceptable.
I.b.3           Conduit to Cable Tray Separation Description A minimum separation distance of one inch between an enclosed rigid conduit and open ladder type cable trays was established by Gibbs & Hill in specification 2323-ES-100; however, the Gibbs & Hill analysis supporting 8-6                                  CP SSER 13 APP.B 03/31/86

this separation criterion was neither referenced in the FSAR nor reviewed by the NRC for acceptability. IEEE Std. 384-1974 requires the installation of a                         I barrier between a conduit and an open cable tray unless greater minimum separation distances are maintained or are otherwise justified by an engineering analysis. The TRT, as noted in SSER No. 7. Electrical and Instrumentation Issues, Category 3, requested that the Gibbs & Hill analysis                        -
supporting the one inch separation distance be submitted for NRC review in sufficient detail to permit an independent evaluation of the establishment of this criterion.
Staff Comments Since this ISAP commits to compilation, review, and approval of the applicable documentation to support the one inch minimum separation distance between rigid conduits and open cable trays, and submittal of this material for NRC independent review, this ISAP is responsive to concerns raised by the staff.
The plan is therefore, acceptable. Final resolution of this issue, however, is contingent on the staff review and acceptance of the engineering justification analysis. In the event the justification is found not acceptable, the ISAP will have to be expanded to cover conduit and cable tray modifications committed to in Section 4.6 of this plan.
I.b.4  Barrier Removal Description As noted in SSER No. 7, Electrical and Instrumentation, Category 3, the TRT inspection of auxiliary feedwater panel CP1-EC-PRCB-09, found two barriers Within panel used to separate redundant devices and cables missing.
CP1-EC-PRCB-03, field wiring was not separated by the minimum separation distance of 6 inches.
B-7                                     CP SSER 13 APP.B 03/31/86

Staff Comments Since this ISAP commits to correction of two identified separation violations,             f it is responsive to concerns raised by the staff for main control room panels.
To assure that existing separation violations have been detected in a timely manner, the physical inspection portion of the ISAP should be expanded to include the cable spreading room termination cabinets and safety-related                   ,
instrument racks located throughout the plant. In addition, Section 4.5 of the plan is not acceptable. The applicant should explain what is meant by meeting "the intent" of IEEE-384 and Regulatory Guide 1.75 requirements, and why this is acceptable. In the absence of an adequate explanation, the applicant should commit to " meet" the requirements of the above documents.
8-8                    CP SSER 13 APP.B 03/31/86

Testina" Issues I
III.a.1 Hot Functional Testing Revision 3 of this ISAP has not been provided by the applicant.
9 0
8-9           CP SSER 13 APP.B 03/31/86
    , _ . - - , , , . , - , ,     --_,-.-_.,,,__-,____,,-,.m.,,m.....-.,,.m.v._._-,,__~____,,--.1-,.m-,.--,.,-_,         , ,_~ ,-----,-_._.,v_-       - - - - .

Mechanical and Pipina Issues V.a Inspection of Certain Types of Skewed Welds in NF Supports Description This ISAP addresses actions required by SSER No. 10, Mechanical and Piping Category 3, allegation AQW-73, concerning the failure of TUEC to provide documentation that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., ' interfaces of curved sections).
Staff Comments The staff conducted an evaluation of the CPRT Program Plan for ISAP V.a and found the action plan to be generally responsive to the issues raised since the plan addressed inspection methods, procedure revisions, and reinspections.
The staff, however, requires assurance that the root cause of the issue and its generic implications are properly addressed, independent of whether any safety significiant deficiencies are found. The staff perceives the root cause and generic implication aspect of this issue as important, since the inspection
      , techniques for skewed welds had been addressed previously by TUEC, thus suggesting potential generic implications.
In addition, the response by the CPRT to Item 1 of the staff letter of September 30, 1985 concerning ISAP V.a requires further explanation concerning the intent of procedure QI-QAP-11.1-28 with respect to the inspection of skewed welds.
1
                                                         '8-10                             CP SSER 13 APP.B 03/31/86

V.b    Improper Shortening of Anchor Bolts in Steam Generator (SG) Upper Lateral Supports                                                                                i Description This ISAP addresses actions required by SSER No. 10, Mechanical and Piping Category 18, allegations AB-12 and AQB-3, concerning anchor bolts in the steam generator upper lateral support that may have been shortened during instal-                             '
lation without proper authorization to less than the length shown on the design drawings. TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations.
Staff Comments The staff concludes that if ISAP V.b is implemented as stated in the Plan, the areas related to the original concern can be identified and resolved based on However, the sound engineering practice, FSAR commitments and NRC guidelines.
staff has raised a concern that the use of trends of inspection data to deter-mine the need for additional inspections must be reviewed on a case-by-case basis rather than collectively in order to determine if the trends require additional inspections.
V.d Plug Welds t
Description This ISAP addresses actions required by SSER No. 10, Mechanical and Piping category 4, allegation AW-14, concerning incorrectly located bolt holes in baseplatts, pipe supports, and cable tray supports that were " plug welded" without authorization, with undocumented weld filler metal and without quality control inspection.              .
B-11                        CP SSER 13 APP.8 03/31/86

Staff Comments                                    .
Based on its evaluation of ISAP V.d, the staff concluded that the ISAP was unacceptable. The staff found that the proposed combination of third-party overview of TUEC engineering evaluation of uncontrolled plug welds identified during the inspections would not provide reasonable assurance that the structural adequacy of CPSES pipe supports, baseplates and cable tray supports would not be compromised by uncontrolled plug welds. This is based upon the fact that the proposed inspection technique was not fully effective and consequently, the confidence level achievable by the may be considerably less than the desired 95/5 level.
The staff suggests that bounding analyses may be required to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, baseplates and cable tray supports to serve their intended function as stated in SSER No. 10.
V.e P.epositioning of the Main Steam Line Description This ISAP addresses actions required by SSER No. 10, Mechanical ana Piping Category 11, allegation AP-13, concerning the 32-inch main steam line that may have been forced into position by the polar crane and 3-ton come-alongs.
Tension induced in the line as a result of movement during the alleged incident may still be present in the line.
Staff Comments l   For the repositioning of the main steam line, the specific engineering evaluation and generic study described in this ISAP provides an acceptable basis for resolution of the issues and concerns re'sulting from the TRT B-12                         CP SSER 13 APP.B 03/31/86

investigations of allegations regarding forced movement of the main steam line and improper welding of temporary supports.
However, the staff has concerns that:
(1) The third party review of the RCLA work should not be limited to a verification only. Provisions for additional third party investigations should be provided, particularly since RCLA participation has ended.
(2) Although the CPRT has indicated that its investigation performed as part of ISAP V.e.,  Revisicn 3, have concluded that the sequence of events described in SSER No. 10 relating to main steam line incident is not correct, the generic implications of settlements of supports and stresses due to hydrostatic testing and flushing activities will still be required to be evaluated by TUEC, since the sequence of events described by the TRT could have occurred elsewhere.
8-13                                CP SSER 13 APP.B 03/31/86 l
l             '~ ~                 *     -   -     - -   -               . _ , . _ _ _ , _ _ _ _ _ , . _ ,

Civil / Structural Issues I.c Electrical Conduit Supports Description This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 14, allegation AE-17, on the installation of nonsafety-related conduit supports for conduit two inches in diameter or less in seismic Category I areas of the plant. No evidence could be found by the TRT that substantiated the adequacy of the installation, or in demonstrating that their failure would not adversely affect the function of safety-related components or cause injury to plant personnel.
Staff Comments The general scope and methoodology contained in this ISAP is responsive to concerns raised by the staff. However, in clarifying the disposition of rejects identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Sections 4.1.2.1 and Section 4.1.2.5 of ISAP I.c. The intent of this statement relative to sample expansion and compli:cce with Appendix D of the Plan is unclear.
Clarification and/or justification of the s+,atement in Section 4.1.2.1 and 4.1.2.5 is needed.
II.a Reinforcing Steel in the Reactor Cavity Description This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 6, allegation AC-38, on a documented occurrence in which reinforcing steel was omitted from a Unit 1 reactor cavity concrete placement between the 812-foot and 819-foot-1/2-inch elevations. Although the omission was documented, justification supporting the engineering conclusion to."use as is" was not available.
B-14                        CP SSER 13 APP.B 03/31/86

Staff Comments The general scope and methodology contained in this ISAP is responsive to the concerns raised by the staff. However, the plan should address the corrective actions to be taken if some structural members are deficient when reinforcing steel was omitted. Furthermore, the logic diagram in the attachment to the ISAP is incorrect. The second vertical branch at the left         and the s-shaped branch near the upper right hand corner should be deleted.
II.c Maintenance of Air Gap Between Concrete Structure Description This ISAP addresses actions required by SSER No. 8, Miscellaneous Category 2, where the TRT identified TUEC's lack of control of debris in critical spacings between components and/or structures. TUEC had not adequately demonstrated compliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which required separation of Seismic Category I buildings to prevent interaction during an earthquake.
Staff Comments The action plan is responsive to concerns raised by the staff. However, the flow diagram given in the ISAP should be clarified. There is no indication where item A, profile of as-built condition for selected rotofoam form work areas and for selected metal form work areas, and the staff does not understand designation C.
II.e Rebar in the Fuel-Handling Building Descriptio:3 This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 15, allegation AC-15, of an alleged instance of unauthorized 8-15                                CP SSER'13 APP.8 03/31/86

         - cutting or rebar in the Fuel-Handling Building due to the depth of core drilling.
Staff Comments The approach described in this ISAP is responsive to concerns raised by the staff.           However, the plan should address corrective actions to be taken if cut rebar produces an unacceptable structural mer.ber. Furthermore, the logic diagram given in the ISAP is incorrect, in that there are no arrows connected to the lower right-hand box.
8 A
8-16                       CP SSER 13 APP.B 03/31/86
* l Quality Assurance / Quality Control Issues I.d.3       Craft Personnel Training Description The objective of this ISAP is to respond to NRC concerns in SSER No. 7, Electrical and Instrumentation Category 2, by evaluating the Craft Training Program to determine if it was adequate in the past, and also to evaluate the current program.
The requirements of ANSI N45.2-1971 set forth, in part, that personnel performing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. To determine that these requirements are implemented, this ISAP has formulated a Special Evaluation Team (SET), comprised of individuals with no direct responsibility to CPSES, who will perform the evaluation of the Craft Training Program including the craft personnel selection, training, assignment and retraining.
Staff Comments The staff finds that the ISAP adequately addresses the NRC's concern pertaining to craft training, and implementation of the plan will determine compliance with FSAR commitments.        The CPRT approach will provide a broad-scope in-depth evaluation of the essential elements of the training program and will determine the effectiveness of both past and current trainir.g and its impact on the construction of the physical plant, and compliance with ANSI N45.2.6 and 10 CFR 50, Appendix B, Criterion II, as committed to in the FSAR.      Accordingly, the staff concludes that this ISAP is acceptable.
However, Section 4.4 of this ISAP must be revised to coraply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of the plan, the staff will confirm that the revision has been accomplished.
B-17                         CP SSER 13 APP.B 03/31/86

            'VII.a.3 Document Control Description Problems-as noted in SSER No. 11, Section 4.2 titled " Document Control" were identified over a period of time in the implementation of the Document Control Program'during the construction phase of CPSES. The scope of this ISAP is to provide confidence that the Document Control Program problems did not impact the installation and testing of hardware and that current design requirements are satisfied. The concerns identified in this Plan are addressed by review and evaluation of the results of the' implementation of ISAP III.d "Preoperational r
Testing" and ISAP VII.c " Construction Reinspection / Documentation' Review Plan" to determine if deficiencies identified under those plans are attributable to Document Control problems.                              Implementation of the action plans requires verification that the latest design information (e.g., drawings, design change authorizations and component modification cards) is used in the preparation of checklists used in the reinspections and documentation reviews. Program and procedures will be evaluated for adequacy against the applicable sections of the FSAR and 10 CFR 50 Appendix B Criterion VI.
Staff Comments The methodology of the Action Plan along with other actions plans adequately addresses the NRC's concerns regarding document control. However, Section 4.4 of this ISAP must be revised to comply with the P,rogram Plan, Attachment 3 in order to maintain consistency. During implementation of the Plan the staff will confirm that the revision has been accomplished.
VII.a.4 Audit Program and Auditor Qualification Description This ISAP addresses the NRC's concern in SSER No. 11, QA/QC Section P, Subsection 4.7, regard (ngtheadequacyoftheTUGC0AuditProgram.fromits inception to the present and will evaluate the program to determine the effect i
of any identified inadequacies on the Quality Assurance Program and/or the
 '                                                                                                             CP SSER 13 APP.B 03/31/86                                                        B'-18

physical plant, and to recommend appropriate corrections and/or improvements to the current program. This evaluation will be accomplished through a review which will address audit planning and scheduling, preparation, performance, reporting, followup and closeout, and audit personnel qualification.
Staff Comments Since FSAR commitments are identified in the plan, and that implementation of the plan will cover sufficient scope and depth to determine compliance with those commitments and any resultant impact on construction quality, the staff concludes that this ISAP is acceptable. However, Section 4.4 of this ISAP must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of the plan, the staff will confirm that the revision has been accomplished, and the staff will also confirm that the CPRT's evaluations have considered all revisions of the PSAR/FSAR and the TUGC0 QA Audit Program and Procedures.
VII.a.5 Management Assessment Description This plan addresses the NRC's concern in SSER No. 11, QA/QC Section P, Subsection 4.7, regarding the TUGC0 management assessment of the effectiveness of implementation of their QA Program during construction of CPSES. The issue arose because of TUGCO's failure to implement periodic management review of QA Programs in compliance with 10 CFR 50, Appendix B, Criterion II, QA Program, which states in part: The applicant shall regularly review the status and adequacy of the Quality Assurance Program.
Staff Comments The staff finds that this, plan is responsive to the action identified by the NRC, which requested that the applicant propose an action plan that will ensure that such problems a lack of a management assessment program, do not occur in 8-19                         CP SSER 13 APP.B 03/31/86

the future. The plan methodology adequately describes a viable approach to establishing a management review program. With regard to additional action identified by the NRC that the applicant evaluate the TRT's findings and address potential safety significance, root cause, generic implications and collective significance, this plan states that these factors are addressed in other hardware and programmatic ISAPs and the self-initiated ISAP VII.c. The staff finds that this is a satisfactory response to the action identified.
Based on this evaluation, and the plan's determination of compliance with 10 CFR 50, Appendix B, Criterion II, the staff concludes that this ISAP is acceptable. However, Section 4.4.1 of this ISAP must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of the plan, the staff will confirm that the revision has been accomplished.
VII.a.6 Exit Interviews Description The actions required by SSER No.11, QA/QC Category 7, allegation AQ-133, to determine if TUGC0 management has now established an effective program which encourages employees to voice concerns regarding safety and which seriously evaluates these concerns.
Staff Comments The staff notes that there is no regulatory position that requires the applicant to have a formal exit interview program; therefore, there is no standard to enable a comparison of the applicants program for compliance.
However, the staff has determined that proper implementation of this plan should establish adequate measures to address and resolve employees' concerns and to identify quality and safety implications. However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
B-20                               CP SSER 13 APP.B 03/31/86

VII.a.7 Housekeeping System Cleanliness Description The actions required by SSER 11, QA/QC Category SC, allegation AQ-54, pertaining to housekeeping and system cleanliness to determine the validity of the current housekeeping system and system cleanliness program for Units 1 and 2.
Results of other action plans, procedural requirements, surveys, etc., will be analyzed to determine any impact on hardware and programmatic implications.
Staff Comments The staff has determined that the housekeeping and cleanliness concern is adequately addressed and that proper implementation of the plan should resolve the issue and determine compliance with the FSAR. However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
VII.a.8 Fuel Pool Liner Documentation Description The actions required by SSER No. 11, QA/QC Category 6, Allegations AQ-55 and AQ-78,.regarding the applicants' inability to maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and inspection and pertains principally to operations travelers and related documentation.
Staff Comments The staff concludes that this plan is acceptable, since proper implementation of the plan should resolve the issue and that appropriate criteria are used to determine compliance with 10 CFR 50 Appendix B even though these criteria are not an FSAR commitment.
l I
i B-21                       CP SSER 13 APP.B 03/31/86

However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency.
VII.b.1 Onsite Fabrication Description This ISAP addresses the actions required by S'SER No. 11, QA/QC Category 58, allegations AQ-17,.AQ-19 and AQ-138, to resolve the NRC's concern regarding the procedural and management control of the fabrication shop work activities at CPSES.
Staff Comments The staff determined that proper implementation of the plan should adequately resolve the issue and determine FSAR compliance. However, Sections 4.3., 4.4 and 4.5 of the Action Plan must be revised to comply with the Program Plan, Appendix E, and Attachment 3, respectively, in order to maintain consistency.
VII.b.2 Valve Disassembly i
Description The actions required by SSER No. 11, QA/QC Category 5A, allegation AQ-52, to resolve the concern regarding valve assembly / disassembly and determine the adequacy of procedures that controlled the disassembly / reassembly process.
Staff Comments The staff has determined that proper implementation of the Plan's methodology should resolve the issues, however, the Plan must contain provisions to inspect for the interchange of critical valve external parts (e.g., bonnets) as well as internal parts. Additionally, Sections 4.2 and 4.6 of the Action Plan must be revised to comply with the Program Plan Attachment 3 in order to maintain consistency.
03/31/86                                B-22                          CP SSER 13 APP.B

VII.b.3 ' Pipe Support Inspections Description This ISAP addresses.the actions required by SSER No. 11, QA/QC Category 8, allegation AQ-50 regarding the adequacy of QC as-built inspections of pipe supports.
Staf f Comments 1
The staff has determined that the NRC's concern is correctly identified and that proper implementation of the Plan should adequately resolve the issue. -The staff finds, however, that although the Plan contains sufficient information to determine acceptability /non-acceptability of the items reinspected, the Plan lacks identification of the Codes / Standards and FSAR commitment which are used as comparisons to resolve the issue (e.g.,
inadequacy of QC inspections) and to' determine compliance. Accordingly,
;     Section 4.5 of the Action Plan must be revised to comply with the Program Plan Attachment 3 in the identification of Standards / Acceptance criteria in order
 ,-   to maintain consistency.
VII.b.4 Hilti Anchor Bolt Inspections i
Description l
This ISAP addresses the NRC's concern in SSER No. 11, QA/QC Category 8, allegation AQ-50, regarding Hilti anchor bolt installation on pipe supports and electrical raceway supports. The objective of this Action Plan is to i       assure the construction quality with respect to Hilti anchor bolt installation.
1 i       Implications resulting from the TRT findings will be resolved by reinspection for safety-significant attributes of Hilti bolts.
l l       Staff Comments i
The staff found that applicants correctly identified the issue and the Plan's methodology is adequately descriptive of the activity that is essential to B-23                         CP SSER 13 APP.B 03/31/86 i                                                                                               .

i l
l evaluation and resolution of the issue. The percentage of torque used in the torque verification program is an issue of concern that will be subject to staff review during implementation. Accordingly, the staff concludes that this ISAP is acceptable. However, of the Action Plan Section 4.6 does accurately identify the type of document from which the acceptance criteria will be derived.
Those specific documents, of necessity, were used to establish the inspection attributes. Therefore, discrete identification is known. Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 of this ISAP has been revised to comply with the Program Plan, Attachment 3 in order to main-tain consistency.
03/31/86                                    B-24                          CP SSER 13 APP.B

Document Name:
CP SSER 13 APP. C fy,, f 4 4 Requestor's ID:
ORDAZ M e.     % = 9 ~t'&
Author's Name:
Trammell Document Comments:
April 1, 1986 F
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Appendix C      PROGRAMMATIC CONCERNS Description of Concern The evaluation process defined in Appendix E does not provide sufficient detail on safety-significant evaluation. This concern is primarily related to the fact that safety-significant evaluations of discrepancies are currently underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern in the DAP are piping and cable trays and their supports.) Until this r'evised information becomes available as
                 ' "p lant record documentation" then the safety-significance evaluation process cannot be completed. Any evaluations made using existing documentation must be revisited when the new documentation becomes available. The major reason i
for this is that TUGC0 has elected to perform extensive reanalysis of piping, cable trays and their supports which could result in hardware modification related to optimization or deficiencies or, different design documents and values which form the basis for the safety-significant evaluation. Based on this, the staff feels that safety-significant evaluation and the potential for-scope expansion must be based on final plant documentation. This position does not preclude the fact that existing issues which led to the current reanalysis of piping and cable trays must be evaluated for root cause and generic implication to assure that programmatic deficiencies do not extend beyond the boundaries covered by the reanalysis efforts.
Action Required The CPRT must provide procedural direction or instruction to ensure that i                   safety-significant evaluation of discrepancies related to the self-
!                . initiated design or construction program and the potential for scope expansion must include evaluation using final plant documentation. This does not preclude the fact that existing issues must be evaluated for root cause and generic implication. During implementation the staff will confirmthatthisactionjasbeenaccomplished.
l 04/08/86                                C-1                  CP SSER .13 APP. C

Description of Concern This concern is related to the fact that safety-significant evaluations must be performed using Code or Regulatory approaches. That is, the techniques used and the extent of the evaluation must address each criterion which formed the basis for the original design. For example, the use of actual material properties versus Code defined material properties could be acceptable but does not preclude the fact that all evaluations committed to in l         the FSAR must be addressed in order to establish margins on all segments of 3
the acceptance criteria. Actual material properties (if higher than Code
:         minimums) may be of value in evaluating primary stresses and functionality but do little to change the fatigue margin. This concern is not limited to Design discrepancies but includes Construction discrepancies for which safety-significance is determined through the use of Design evaluations.
Action Required The CPRT must provide procedural direction or instruction to ensure that the techniques used and the extent of the evaluation addressees each criterion which formed the basis for the original design. During implementation the staff will confirm that this action has been accomplished.
Description of Concern There is a lack of discussion in the Plan on the approach to be used in root cause and generic implication detemination. In order to understand any CPRT proposed evaluation, the Plan needs to define the terms "rooti cause" and
           " generic implication." This is critical, since the depth and breadth of the root cause evaluation will be a function of the CPRT understanding of these terms. The staff anticipates that the CPRT will consider the following, as a l
minimum, in detemining the, root cause of deficiencies:
)
1          04/08/86                                      C-2                 CP SSER 13 APP. C

Personnel Process Procedures Design (as it effects construction)
Materials Management Action Required The Program Plan must be revised to provide those definitions or the CPRT shall issue procedural direction / instruction to ensure that persons performing these evaluations have commonality in their understanding of the factors that affect the determinations. During implementation the staff will confirm that this action has been accomplished.
Description of Concern Another area of staff concern is related to Adverse Trending. The discussion in Appendix E is general in nature and uses a set of examples to define the process by which a set of items could create a pattern for concern. The examples
  'given are related to a design process. The approach used by the CPRT is to evaluate HDAs rather than to review the design process. The concern is that evaluation of HDAs may not provide the appropriate information for trending as defined in Appendix E.
Action Ruquired The Program Plan must provide that the design process as well as Homogenous Design Activities will be reviewed to determine an adverse trend. During implementation the staff will confirm that this action has been accomplished.
i 04/08/86                                C-3                       CP SSER 13 APP. C

Description of Concern Revision 3 of the Program Plan provides a comprehe'nsive approach to the specification and approval of corrective action confirmation of implementation and responsibilities of the CPRT and the CPSES Project. The only major coment the staff has is related to the timing of SRT approval of CPRT RTL determination of the adequacy of correction actions defined by the CPSES Project. Appendix H provides two alternatives, approval on an ongoing basis as corrective actions are developed, or, approval as part of the Action Plan Results Report approval process.
The staff feels that the SRT should approve or disapprove corrective actions on an ongoing basis as they are developed. This action should follow that of the CPRT RTL. It is felt that this would keep the SRT more in line with CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES project involved in lengthy discussions when the RTL does not agree with the proposed corrective action.
Action Required Appendix H must be revised to state clearly that the SRT will review and approve / disapprove all corrective actions on an ongoing basis, subsequent to l
approval by the CPRT-RTLS. During implementation the staff will confirm that l this action has been accomplished.
Description of Concern The staff is concerned with a number of observations concerning interfaces as follows:
l The definition of interfaces provided in Appendix F establishes measures for l
the identification and control of design and construction interfaces and for coordination among the CPRT participant organizations. The availability of j
matrices will provide each affected organization the specific areas and items i
04/08/86                                  C-4                  CP SSER 13 APP. C

of information that must be executed and controlled. There are a number of areas where interface between various CPRT organizations and CPSES Project organizations is defined. In some cases, the interface appears to be dupli-                       -
cative and prime responsibility is not defined.           It is important that prime responsibility for interface control be defined to assure that involved organi-zations understand who is responsible for establishing, executing and controlling the interface. The following are staff observations on the individual matrices provided in Appendix F.
: 1. QA/QC-RTL and RTL to Unit I and Unit 2 Assistant Project General Managers (APGMs). Responsibility for 50.55(e) reportability is assigned to the TUGC0 Project per Appendix H of the Plan.
: 2. DAP-RTL to SWEC. Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports is provided to SWEC for "Information" when pertaining to the SWEC scope. Since this information could impact the SWEC analysis effort, it should be provided for " Action by SWEC."
Since DAP is auditing SWEC activity, this matrix should address those items associated with that effort, including Corrective Action.
: 3. DAP-RTL to Other Design Organizations.         Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports should be provided for " Action" to EBASCO and Impell, who are reanalyzing cable trays and supports. The CPRT may find it more appropriate to develop a separate matrix for the cable tray and support effort activities of EBASCO and Impell.
l
: 4. RTLs to CPSES Project. Action Plans are designated as both " Info" and
          " Action" by Project. It is the staff's understanding that Action Plans are provided to the CPSES Project for information only.
l   5. SWEC to Interfacing Organizations. Design- and construction-related concerns found during walkdown and document reviews should require action by DAP and Q0C RTLs. That action should include evaluation of the 04/08/86                                         C-5               CP SSER 13 APP. C

deviation in the same manner as if it were discovered as part of the CPRT self-initiated program. Loading from the piping system should be provided to QOC through the DAP since this information may be needed for safety-significance evaluation.
: 6. Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and DAP-RTL and EBASC0/
Impell and Interfacing Organizations.
Action Required The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT activities provided the concerns are satisfactorily resolved as follows:
(1) Define the organization with prime responsibility for duplicative interfaces.
      '(2)   Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports should be provided to SWEC, EBASCO and Impell since it could impact their reanalysis effort.
(3) Design- and construction-related concerns found during SWEC, EBASCO or Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action."
(4) Loading from the piping system to equipment, structures, penetrations, etc., should be provided to 00C through the DAP for use in safety-signficant evaluations.
(5)   Interface details (or matrices) should be provided for Other Design
,           Organizations and DAP-RTL and for EBASC0/Impell and Interfacing Organizations.
4 04/08/86                                C-6                  CP SSER 13 APP. C

(6) The CPRT auditing of SWEC activities involves interfaces which should be defined.
(7) Define more clearly CPSES project responsibility for action plans and 50.55(e) reportability.
The concerns related to 50.55(e) and to Action Plan responsibility in the RTL to CPSES Project Matrix are editorial in nature and can be confirmed during the implementation phase of the plan. Additionally, during implementation the staff will confirm that the other above noted actions have been accomplished.
9 I
4 04/08/86                                C-7                        CP SSER 13 APP. C

DSAP VIII, CPRT Overview
  -Description of Concern In order for TERA to perform an integrated review of major concrete and steel structures in a manner. consistent with their commitments referenced in the NRC Office of Inspection and Enforcement (IE) Inspection Report 50-445/85-17 and 50-446/85-14, Appendix 2, page A-4, unique loading determinations must be performed for the referenced buildings (i.e., auxiliary building, fuel storage building, containment building and other portions of selected buildings). DSAP VIII, Section 4.3.2.1, load Determination, indicates that only the auxiliary /
electrical buildings will be reviewed. This is inconsistent with TERA's commit-ment and in fact precludes the performance of a thorough review.
Action Required TERA should review other buildings than those listed in DSAP VIII, Section 4.3.2.1 Load Determination.
Description of Concern Thermal loadings or expansion considerations must be considered in the evaluation of the reactor building internal structure since this is a fundamental design consideration (e.g., to mitigate the effects of thermal l
expansion). DSAP VIII, Section 4.3.2.1, does not address thermal considerations and should be revised accordingly.
Action Required DSAP VIII, Section 4.3.2.1 should be revised to include thermal load considerations for reactor building internal structure.
l i
04/08/86                                        C-8           CP SSER 13 APP. C

Description of Concern The NRC inspection report (Appendix 7, item 4, page A-216) discusses embedment
  ' load tracking. The TERA response indicates that final design loads will be coordinated with the civil / structural discipline (e.g., to confirm that building designs are consistent with the final design loads). Section 4.3.2.1 of DSAP VIII doesn't discuss this and should be revised accordingly.
Action Required DSAP VIII, Section 4.3.2.1 should be revised to address how original building design loads are reconciled with the final design loads.
i I
l 04/08/86                               C-9                  CP SSER 13 APP. C

DSAP-VIII - Civil / Structural, Including Cable Tray / Conduit Supports Description of Concern The testing program may generate design and acceptance criteria which do not comply with FSAR commitments.
Action Required If the FSAR commitments are not met, the proposed acceptance criteria must be identified for approval by the staff prior to implementation.
Description of Concern Inconsistencies exist between the DAP, DSAP VIII and Impell-Ebasco project instructions. The inconsistencies involve the statements describing the methodologies that may be used to evaluate the cable tray support. In the DAP it is stated that the established Ebasco methodologies will be used while the DSAP allows the use of Impell and Ebasco design procedures. Further in the DSAP it is stated that only two methods of dynamic analysis will be used in analysis design verification of cable tray supports. The Impell project instructions, however, permit the use of time history methods, overlap methods and multi-level response spectrum methods in addition to the two methods
! referred to in the DSAP.
Action Required During implementation the staff will confirm that these inconsistencies be j resolved and the appropriateness of the above methodology demonstrated to the i staff.                             ,
Description of Concern
(
l The staff is concerned with the lack of prescriptiveness of review checklists
                                 ~
l used for the third part review. In general, the checklists define the review l 04/08/86                                  C-10                  CP SSER 13 APP. C t

scope by listing criteria and commitments for which the implementation will be verified in the review, but do not indicate the design considerations which must be accounted for in verifying that the commitments were met.
Action Required The checklists need to be more prescriptive with respect to all design criteria to be met.
Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection Report Nos. 50-445/85-17,50-446/85-14 indicates areas in which specific review checklists need to be expanded or clarified with respect to subject content.
Description of Concern The staff evaluation of the third-party activities for the review of project activities and corrective actions is based on audits performed at the offices of the CPRT third-party (TERA).
At the time of this audit Revision 3 of the Program Plan had not yet been issued. Revision 2 of the Program Plan was not definitive in stating the third-party activities for the cable tray / conduit program. This program was undergoing a major rewrite which now clearly defines the role of the third party.
Action Required i
The staff generally agrees with the Program Plan with respect to the third-party activities in the cable tray / conduit area; however, a complete evaluation will be made after the staff completes its audit of the details of
:       the third party review of the project actions.
l l
04/08/86                                    C-11                       CP SSER 13 APP. C

Description of Concern The staff review of the validity of identified HDAs and design activities not enveloped by the HDAs identified a concern with the HDA criteria for homogeneity.
HDAs are required to have common design or analysis approach / methodology or mechanics in design implementation such that meaningfully different complexities or considerations are not contained within that design activity.
However TERA had not obtained formal documentation pertinent to the Gibbs and Hill design / analysis methodology and approach. Such documentation (instructions and procedures) is normally utilized to establish design process-control and thereby establish uniformity of technical approach in the execution of engineering for a project.                   ,
The Civil / Structural Phase 3 Scope Validation document, including the HDAs identified within, is based on such items as the plant engineering documents available at Gibbs and Hill, TERA interviews with project personnel, and the engineering experience of TERA personnel in nuclear power plant design.
A review checklist, DAP-E-PM-001, dated October 27, 1985 states that, on a programmatic level (1) organizational and design control process changes within Gibbs and Hill have not affected the identified HDAs and (2) there have been no changes to design methodology over time at Gibbs and Hill such as to affect the the identified HDAs. These TERA conclusions are based on discussions with Gibbs and Hill rather than review of design control procedures, design methodology, etc.
TERA apparently recognizes that other homogeneous design activities (HDAs) may i           exist and that some currently so defined may in fact not be homogeneous since it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Phase 3 Scope Validation, Civil / Structural" that in the review effort there will remain an                         ,
open, "... search for substantive differences in criteria category,-design considerations, approach, or methodology in the design process."
04/08/86                                             C-12         CP SSER 13 APP. C

The team identified potential HDAs not identified by TERA, such as the design of the annualar structural steel normally inside the containment, the auxiliary building structural steel, foundation overturning design, the design              .
of walls for tornado missiles and the effect of Category II buildings on Category I buildings.
Due to the above uncertainty as to documented design methodology, there is a related question on sample sizes. In the area of concrete design, TERA has indicated that for the auxiliary building and the fuel building a total of five (5) slab and five (5) wall calculations will be selected at random for design review. Then another set of ten (10) calculations will be selected either randomly or based on any findings from the previous ten (10). Such a sample may not be valid if all thes'e calculations were by one individual, if there were fifteen (15) individuals doing independent designs for slabs and walls without any design process / methodology guidance b'eyond the FSAR criteria. If there were no controls within the Gibbs and Hill organization, for establishing homogeneity in design approach and methodology, one must compare individual engineers and designers completing similar tasks. For this situation, the actual homogeneity that exists can apparently only be established as the design review progresces.
To the degree that TERA relies on HDA populations as the basis for review sample selection, the staff plans to evaluate whether the review sample is representative of tne design process for that population and whether the population is homogeneous.
Action Required The staff generally agreed with the third-party conclusions that certain checklists adequately cover HDAs. Exceptions to this are addressed in detail in Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection
 ,       Report Nos. 50-445/85-17, 50-446/85-14 which was transmit.1ed to the Applicant in a letter from J. M. Taylor to W. G. Counsil dated January 21, 19.86. Staff approval of the CPRT Program Plan is contingent upon acceptable resolution of the staff concerns and staff comments on the review checklists provided in the IE Inspection Reports.
04/08/86                                           C-13             CP SSER 13 APP. C

DSAP IX - Staff Comment (Third-Party Review)
The staff requires the following items to be adequately completed in order to determine the acceptability of the piping and supports discipline spec.ific action plan related to the third-party (TERA) actions:
Description of Concern It was not evident that a process existed for identifying discrepancies (or deviation 4)inexternalsourceissuesbySWECinviewofthefactthathardware modifications may be made to piping and supports irrespective of the corrective actions required for safety-significant problems.
Action Required A root cause/ generic implication evaluation should be performed for all hard-ware modifications in order to document the reasons for such modifications.
Description of Concern In the staff review of the checklists to be used by the third-party (TERA) in their overview of the SWEC piping and supports program, only one of three checklists were completed.
Action Required Provide the checklists to be used for the overview of the SWEC piping analysis implementation and pipe support design implementation.
Description of Concern The staff review of the third-party overview of the SWEC construction /as-built program found that no third-party procedures were available at the. time of the staff audit.
04/08/86                                C-14                    CP SSER 13 APP. C

Action Required Provide the procedure to be used for the third-party overview of the SWEC construction /as-built activities.
Description of Concern The self-initiated review of the AFW system does not fully address the inter-face with the SWEC piping reanalysis program.
Action Required The third-party should include a portion of the AFW system in their review of the SWEC piping and pipe supports requalification effort.
l l.
04/08/86                               C-15                  CP SSER 13 APP. C

r DSAP IX - Staff Comments (Project /SWEC Actions)
               . The staff requires the following items to be adequately completed in order to determine the acceptability of the piping and supports discipline specific action plans related to Project (SWEC) actions:
Description of Concern The major technical details of the piping and supports requalification program are provided in Comanche Peak Project Procedures (CPPP-5, 7, 8, 9, 10 and 15).
The staff has not yet completed our review of these procedures. However, based on preliminary findings, the staff identified a concern that the design
             . criteria in CPPP-7 is not totally consistent with the CPSES FSAR licensing commitments.
Action Required The' acceptability of the CPRT Program Plan is contingent upon acceptable resolutions of technical concerns identified in our review of the Comanche Peak Project Procedures including consistency between FSAR licensing commitments and the design criteria in CPPP-7.
Description of Concern There is a lack of information in the CPRT Program Plan which explains the process used to assure the adequacy of the as-built data used in the SWEC piping reanalysis effort.
Action Required l
Provide a description of the process followed by the various activities in the Construction Adequacy Program and in the SWEC program for the evaluation of as-built discrepancies including the interfaces among ERC, SWEC, an'd TUGC0 i
projects and the applicable procedures used in the process.
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04/08/86                                   C-16                CP SSER 13 APP. C
    -,--mm--                   _  --

Description of Concern In our review of the as-built process and interfaces between the Construction AdequacyProgramandSWEC,thestafffoundthatjeviation, reports (DR's) issued               -
by ERC are not transmitted to SWEC. However, all DR's are transmitted to TUGC0 projects for initiating an NCR and only those NCR's dispositioned as "use-as-is" will be transmitted to SWEC.
Action Required Address the need for SWEC to review the DR's for the impact of construction deviations identified by the construction adequacy program on the piping reanalysis effort.
Description of Concern As a result of the as-built walkdown perfonned under CPPP-5, deviations were found in one of the four attributes (i.e. valve and strut orientation) result-ing in a 100 percent reinspection of that attribute. However, the staff noted that CPPP-5 did not expand its scope to address other as-built attributes (e.g.
pipe run geometry, clearances including those at floor and wall penetrations, embedments, and pipe attachments) which are also required to be examined under IE Bulletin 79-14.
Action Required Provide a justification for not reverifying the as-built attributes which were excluded under CPPP-5.
Description of Concern The staff is concerned that the design criteria and procedures used in the SWEC piping and support reanalysds might be impacted by as-built plant conditions which are act reflected in the design documents used by SWEC.
04/08/86                                          C-17             CP SSER 13 APP. C

F Action Required Provide the basis for assuring that all as-built conditions which can adversely affect the acceptability of the piping reanalysis program will be identified
                                                                                                        ,, A.
and corrected.
1   .
Description of Concern It appears to the staff that there is no evaluation of root cause or generic implication or adverse trend associfed with the as-built deviations identified in the SWEC as-built walkdowns. Furthermore, there does not appear to be a procedureorprocessfortheevaluationoftheresultingdesi[deficienciesor SWEC-identified construction deficiencies per 10 CFR 50.55(e).
Action Required Address the need for a program for ensuring that the results of the SWEC walk-downs will be adequately evaluated for root cause/ generic implications and adverse trends and that design and construction deviations identified as a result of SWEC walkdowns will be properly evaluated per 10 CFR 50.55(e).
Description of Concern l
The staff review of CPPP-10 finds that a final design document which estab-lishes the system design input must be prepared and satisfactorily reviewed by I         the staff.
Action Required Prepare a final document compiling all operating modes and system loading conditions.                   .
04/08/86                                C-18                 CP SSER 13 APP. C

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Description of Concern The scope of the Class 5 piping systems includes only those Class 5 piping systems within the boundaries of ASME Class 2 and 3 piping stress problems.
Action Required                                                                                                      I Justify excluding the remaining Class 5 piping systems from the SWEC scope.
Description of Concern The Comanche Peak Project Procedure for the requalification of small bore piping (CPPP-15) is not yet available for staff review.
Action Required The CPPP-15 should be completed and issued for staff review.
Description of Concern The staff has not yet completed its review of the resolutions to the special technical issues.
Action Required The acceptability of the CPRT Program Plan is contingent upon acceptable i
resolutions of the special technical issues.
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04/08/86                                C-19                                                      CP SSER 13 APP. C

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ABSTRACT 1                     Supplement 13 to the Safety Evaluation Report related to operation of the Comanche Peak Steam Electric Station, Units 1 and 2 (NUREG-0797), has been d'                   prepared by the Office of Nuclear Reactor Regulation of the U.S. Nuclear l                     Regulatory Commission. The facility is located in Somverve11 County, Texas,
   .l                    approximately 40 miles southwest of Fort Worth, Texas. This supplement presents the staff evaluation of the Comanche Peak Response Team Program Plan which was formulated by the applicant to resolve various construction and-design issues raised by the Atomic Safety and Licensing Board, allegers, NRC
!f                        inspections of various types, and Cygna Energy Services while conducting its
:l                       independent design assessment.
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* Subject to acceptable resolution of the items identified in the evaluation, the NRC staff concludes that the CPRT Program Plan will provide an acceptable
    ;                     assessment of design and construction adequacy when implemented.
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TABLE OF CONTENTS j                                                                                                                                                  P,ag 1
ABSTRACT............................................................                                                     1 d
CONTRIBUTORS........................................................                                                     iii J
:j:                         ACRONYMS AND ABBREVIATIONS..........................................                                                     iv
.;                          1.0 INTR 000CTION...................................................                                                     1-1
:t H                                       1.1    Background................................................
1.2 SSER Purpose, Scope, Organization.........................
1.3 CPRT Tenni no1 ogy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
I                                   1.4 Purpose of        CPRT...........................................
1'                                      1.5 Problem Identification and Classification.................
ri                                      1.6 CPRT Products; Corrective Action, and Reports.............
W                                       1.7 Overall        Conclusion........................................
ADEQUACY..........................................
2.0 CONSTRUCTION                                                                                                           2-1
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2.1 External Source          Issues....................................
2.2 Sel f-I ni ti a ted Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.3 Staff Evaluation..........................................
]                           3.0 DESIGN ADEQUACY................................................                                                        3-1 1                                      3.1 External Source          Issues....................................
3.2 Self-Initiated Program....................................
3                                       3.3 CPRT Oversight - Special Projects (SWEC, Ebasco, Impell)..
3.4 Staff Evaluation..........................................
't 4.0 CPRT QUALI'TY ASSURANCE PR0 GRAM.................................                                                      4-1

==5.0         CONCLUSION==
.....................................................                                                5-1 f
    ;                       APPENDIX A - Identification of the components of the CPRT i                                              Program Plan, including Appendices, ISAPs and DSAPs by Revision Number...............................                                             A-1 APPENDIX B - Items to be addressed by Applicant during the implementation phase of certain ISAPs..................                                             B-1 APPENDIX C - Items to be addressed by Applicant during the
                                                . implementation phase of certain DSAPS..................                                             C-1 LIST OF FIGURES Figure 4.1 - CPRT Organization i                        Figure 4.2                          .
1                          Figure 4.3 4
03/27/86                                                       11                                  Comanche Peak SSER 13
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                                                                                                                                             '-%-a 9           t-LIST OF PRINCIPAL CONTRIBUTORS i
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l NRC Staff                                     Consultants / Organization J
: 0. Jeng                                       R. Hookway          TES*
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LI                        E. Marinos                                    J. Malone           TES
  'l 1                       J. Calvo                                      J. Cragin           TES S. Hou                                        D. Landers          TES
  -j                        J. Knox                                       J. Rivard           TES I                        E. Tomlinson                                  R. Ciatto           TES r
1                         D. Terao                                      E. Solla            TES A. Vietti-Cook                                R. Masterson        EAS
                                                         ~
    ,                       D. Norkin                                     V. Ferrarini      s EAS J. Gilray                                     P. Chen             ETEC V. Noonan                                     E. Thompson         ETEC B. Grimes                                     B. Saffell          Battelle l                       C. Early                                      C. Hofmayer         BNL
    !                       C. Hale                                        N. Rivera           independent U
j                         S. Phillips                                   M. Yost             EG&G T. Westernan                                    L. Stanley         ZYTOR l;                           I. Barnes                                      R. Philleo         independent l!                          J. M11hoan                                      C. Huaghney        COMEX C. Tramell                                      P. Keshishian      independent
                               .                                            J. Nevshemal       WESTEC
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ACRONYMS AND ABBREVIATIONS i
A/E                 Architect / Engineer l                         ANSI                American National Standards Institute l                         ASLB                Atomic Safety and Licensing Board
     !                         ASME                American Society of Mechanical Engineeers l                          ASTM                American Society for Testing & Materials I-                          B&R                 Brown & Root i
j                           C/S                 Civil / Structural j                           CAP                 Construction Adequacy Program
     ,                         CASE                Citizens Association for Sound Energy CAT                 Construction Appraisal Team l
i                          CPRT                Comanche Peak Response Team f                         CPSES               Comanche Peak Steam Electric Station CTCS                Cable Tray,& Conduit Supports
:                          DAP                 Design Adequacy Program DSAP                Discipline-Specific Action Plan l                          ERC                 Evaluation Research Corporation
    ]                           ESI                 External Source Issues l                          FSAR                Final Safety Analysis Report G&H                 Gibbs & Hill HDA                 Homogenous Design Activities
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   -l                           HVAC                Heating, Ventilation & Air Conditioning I&C                  Instrumentation & Control
     !                          IAP                  Independent Assessment Program INPO                 Institute of Nuclear Power Operations l,                              ISAP                 Issue-Specific Action Plan LOCA                  Loss-of-Coolant Accident f
l NRC                  Nuclear Regulatory Commission 1:
'-                              NSSS          .      Nuclear Steam Supply System
'!                              PSAR                  Preliminary Safety Analysis Report fj                              QA                   Quality Assurance j'
* QAP                   Quality Assurance Program QC                    Quality Control 03/27/86                                           iv                         Comanche Peak SSER 13
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j                       QE QOC             Quality of Construction & QA/QC Adequacy Program RIV             Region IV                                                            .
RPVRI.          Reactor Pressure Vessel Reflective Insulation j                       RTL             Review Team Leader j                       SER             Safety Evaluation Report lj                            SET             Special Evaluation Team SIT             Special Inspection Team l-[
. .!                          SRT             Senior Review Team SSE             Safe Shutdown Earthquake if l[                            SSER            Supplemental Safety Evaluation Report SWEC            Stone & Webster Engineering Corporation
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ll                            TERA            Tera Corporation TNE             TUGC0 Nuclear Engineering TRT             Technical-Review Team
,',                           TUEC            Texas Utilities Electric Company .              .
!!                            TUGC0           Texas Utilities Generating Company i
UT              Ultrasonic Testing
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==1.0 INTRODUCTION==

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     !                     1.1 Background 1                     On March 12, 1984, the U.S. Nuclear Regulatory Commission's (NRC's) Executive 2
Director for Operations established a program to assure that technical j                        concerns and allegations related to Comanche Peak Steam Electric Station j                      (CPSES) design and construction activities would be addressed in a j                        coordinated and integrated manner by the NRC staff. As a means of executing
]                          its assigned responsibilities, the NRC formed. a Technical Review Team (TRT) representing the following disciplines:
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o   Electrical / Instrumentation
            ~
i                              o   Civil / Mechanical o   QA/QC o   Protective Cbatings
 ~ !l o   Testing Programs
 ~!                                 o   Miscellaneous The TRT initiated a series of onsite inspections and evaluations in July
 ,!                         1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report (NUREG-0797, Safety Evaluation Report related to the operation of the CPSES, Units 1 and 2. Supplements
!l-                         7-11). Prior to publication of these Supplemental Safety Evaluation Reports il                          (SSERs), the staff issued letters on September 18, 1984 November 29, 1984, jl                          and January 8,1985, summarizing the principal issues that required
!i                          resolution.
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l In response to the concerns and issues identified by the TRT, Texas Utilities i'                          Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the i                      purpose of addressing all TRT concerns. TUEC initially submitted its CPRT Program Plan on October 8,1984, and issued Revision 1 on November 21, 1984, to respond to comments on the initial version that were received from the NRC l;                           staff during meetings on October 19 and 23,1984.
1 The initial version and Revision 1 of the Program Plan were written prior to the publication of SSERs 7 through 11, which collectively provided over 1,000 04/08/86                                      1-1             CP SSER 13 SEC. I b - - ~ _ . _ .. _ _ _                                . m -    , , _ - . -                 - _ _ . _     ..... .   .

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1 pages of the staff's evaluation of the several hundred allegations of design
       !                       and construction inadequacies. Following publication of the detailed staff j                         evaluations contained in these SSERs and with the recognition of the need to j                           resolve outstanding issues raised by groups other than the TRT, TUEC submitted l                           Rev'ision 2 to the CPRT Program Plan on June 28, 1985. Revision 2 greatly expanded on the earlier revisions and provided an extensive corrective action program to be undertaken by TUEC to resolve outstanding issues from a variety
     ,                         of sources.
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In letters dated August 9, 1985 and September 30, 1985, the staff provided
;,                             comments on Revision 2 to the CPRT Program Plan. TUEC specifically addressed j
these staff comments in a {{letter dated|date=November 22, 1985|text=letter dated November 22, 1985}} and followed with 1                         Revision 3 to the CPRT Program Plan, dated January 27, 1986. Revision 3 has been supplemented by submissions in letters from TUEC on January 31,
~
February 7, and two letters on February 28, 1986. With these submissions and
                                                      ~
l[                             the anticipated receipt of one additional item involving hot functional
;l                             testing, TUEC has completed its description of its planned correction action program, the CPRT Program Plan. This Program Plan is intended to describe the
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program that will address all NRC concerns and demonstrate an adequate level of quality of the design and construction of the CPSES.
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1 1.2 SSER 13 Purpose Scope, and Organization 1.2.1 SSER 13 Purpose and Scope l
     }
The purpose of SSER 13 is to describe the NRC staff's evaluation of 4                         the CPRT Program Plan, Revision 3 dated January 27, 1986 and supplemented on
:                         January 31. February 7 and February 28, 1986, and to document the staff's approval of that plan, subject to the comments contained in this evaluation.
This SSER documents the staff's evaluation and conclusions regarding the CPRT
                                           ~
Program Plan and supporting appendices, except for the individual action l2                             plans contained in Appendix "C". These action plans are the subject of the staff's ongoing evaluation and inspection during the CPRT's implementation phase. As the CPRT issues reports describing the implementation of each action plan, the staff will conclude its evaluation of these plans.
04/08/86                             1-2                   CP SSER 13 SEC. 1

1.2.2 SSER 13 Organization 4
SSER 13 contains 5 sections.and 3 appendices. Section 1.0 is the
  .                              Introduction, which describes the background and purpose of the CPRT, intro-duces key terms associated with the CPRT, describes the CPRT process for identifying and evaluating problems and for ensuring proper corrective action.
Section 2.0 describes the staff's evaluation of the CPRT's Quality of Construc-tion and QA/QC Adequacy Program; Section 3.0 describes the staff's evaluation d                                of the Design Adequacy Program. Section 4.0 contains the staff's evaluation of the CPRT's quality assurance program; Section 5.0 describes the staff's conclusions regarding the CPRT program. Appendix A is a complete listing of the individual sections of the CPRT Program Plan that have been reviewed by
]                                the staff. This listing includes the appropriate revision for each section.
1 Appendices B and C contain those items the staff has requested TUEC to address J                                during the implementation phase of the CPRT.
Unlike the programs for resolving design and construction issues, the CPRT Program Plan does not contain a separate overall plan that applies to the individual testing action plans. For this reason, the staff has not included a separate section in this SSER describing its evaluation of the CPRT's
]                                testing program. The staff's evaluation of testing issues is ongoing and 1
will continue during the CPRT's implementation phase. The staff will conclude its final evaluation of these testing issues, when the CPRT has i                                 finished its assessment and has documented its results.
l 1.3 CPRT Terminology C
The CPRT effort has its own nomenclature, scme of which is introduced here to aid the reader.
.O i                                The CPRT e'ssentially consists of two parts--one part relates to CPSES design j                                 adequacy and the other part relates to construction adequacy. The first two l                             tems describe these parts.
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Design Adequacy Program (DAP). The DAP is that portion of the CPRT Program that resolves issues pertaining to design adequacy.
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Quality of Construction and Quality Assurance / Quality control (0A/0C) l'                     Adequacy Program (00C). This program is the portion of the CPRT that resolves issues related to the adequacy of the CPSES construction QA/QC program and the adequacy of installed hardware. The CPRT Program Plan uses the acronym QOC
  ]                      when referring to this program.
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Collectively, the DAP and the QOC constitute the CPRT Program. This combined program resolves issues from the two types of sources:
External Source issues. These issues arose from sources external to TUEC.
These sources include: 1)theTRT;2)theAtomicSafetyandLicensingBoard
   ;                      (ASLB) proceeding on the CPSES operating license; 3) the NRC staff's Supplemental Safety Ev~aluation Reports (SSERs); 4) the staff's Construction l
   !                     Appraisal Team (CAT) and Special Investigation Team (SIT) reports;
: 5) applicable Inspection Reports issued by the NRC's Region IV (RIV) office; f
l                       and 6) the Cygna Energy Services Independent Assessment Program (IAP).
Self-Initiated Evaluation. The CPRT is conducting a self-initiated
{                      evaluation of the CPSES quality of construction and adequacy of design. For
                         ' construction, this effort involves a sample reinspection of hardware that is representative of the activities and processes used in the construction of safety-related aspects of the plant. In the design area, the effort involves f
j                      reviews of designs that are representative of the aggregate A/E design scope relative to design criteria, disciplines, processes and organizations used in
,;                        the design of the safety-related aspects of the plant.
l:
   .                      The CPRT Program Plan contains two types of action plans to resolve
                                     ~
individual issues in the construction and desigr) areas. These action plans
!-                        are:
Issue Specific Action Plans (ISAPs). The ISAPs address specific CPSES
,{
construction QA/QC issues regarding either hardware or aspects of the QA/QC i
program that have been identified by external sources. An additional ISAP l
04/08/86                                  1-4                 CP SSER 13 SEC. 1
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implements the CPRT's self-initiated portion of the QOC. For a more complete description of the ISAPs, see pages 5 through 9 of Appendix B to the CPRT
    '                        Program Plan, Revision 3. For a list of the ISAPs, see Attachment 1 to Appendix B to the CPRT Program Plan, Revision 3.
Discipline Specific Action Plans (DSAPs). The DSAPs address specific CPSES 1
: 4.                       design issues regarding the adequacy of either the design or the design process which have been identified by external sources or by the CPP.T ss a result of other evaluations. Certain DSAP tasks also implement the CPRT's self-initiated design evaluations. Other DSAPs, encompassing piping and pipe supports and cable tray and conduit supports, entail a significant level of l                        engineering reanalysis, and are being performed for the CPSES Project by
    !                        engineering organizations that were not responsible for the original design.
CPRT third-party personnel will review'the analytical process and the design f
criteria for these major reanalysis efforts. For a more complete description i                        of the DSAPs, see pages 5 through 15 of Appendix A to the CPRT Program Plan,
:l                         Revision 1.
l 1.4 Purpose of the CPRT In this section.the staff relates the purpose of the CPRT, as described on pages 2 through 6 of Revision 3 to the Program Plan.
The CPRT is now charged with resolving issues so that it can advise TUEC f;                            management whether there is reasonable assurance that the CPSES has been jl                            designed, constructed, and tested such that it can be operated safely. To i
accomplish this goal, the CPRT has three objectives:
(1) The CPRT will evaluate each External Source issue relating to design
,l                                      adequacy, hardware quality, and testing. The CPRT will then determine
!l                                      the rfature of any safety-significant deficiencies and the necessary
,j                                      corrective action. Accomplishment of this objective by the CPRT is j                                  intended to provide TUEC with reasonable assurance that there are no
      !                                 undetected and ungorrected safety-significant deficiencies associated I                                  with any of the External Source issues.
I 04/08/86                                              1-5                      CP SSER 13 SEC. 1
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                                                                                         ~na                      a (2) The CPRT will investicate and attempt to determine the root cause of each safety-significant deficiency and any adverse trends from nonsafety-
   }                           significant deviations or design observations. The CPRT will analyze the
   '                           generic implications of each root cause that is found in order to deter-mine the extent of any additional construction, desigri, or testing
  ]
  ]I                           activities that might be deficient for the same reasons. The definitions of these term are discussed ir, Sc cticri 1.5 below. Accomplishment of this objective by the CPRT is intended to provide TUEC with a full resolution of each External Source issue and to fully bound the safety-
]                              significant implications of identified deviations.
d 1                    (3) Although the External Source issues are numerous, they are not inclusive j                              of all aspects of design and construction activities associated with the
 ;1                            CPSES. The CPRT recognized the need for additional evaluations in
 "                             certain areas in order to be able to make conclusive statements regarding            j CPSES design adequacy and construction quality. Accordingly, the CPRT l
developed a third objective to conduct a self-initiated evaluation of ll                             CPSES design adequacy and construction quality. In'the design area, the
                      -        self-initiated evaluation entails reviews of designs that are representa-
:l t,ive of the collective Architect-Engineer design scope. This design evaluation will examine design criteria, disciplines, processes, and l,                             organizations used in design of safety-related aspects of the plant. In the construction area, the self-initiated evaluation consists of a sample reinspection of installed hardware, which represents work processes used
    !                          during safety-related construction activities. Accomplishment of this
   !                            third objective will further enhance the CPRT's ability to advise TUEC management that there is reasonable assurance that the CPSES has been designed and constructed such that it can be operated without undue risk
    .                           to public health and safety.
As can be seen from a review of the earlier background section and from j ;l                       , statements in the CPRT Program Plan such as that on page 4 of Revision 3, the Program Plan has not been nor will it become a static document. By
!;                               its very nature, the implementation of the DAP, the QOC and the associ-l                            ated DSAPs and ISAPs, along with the root cause and adverse trend evalua-I                               tions, the determination of generic implications, the collective l
l l                       04/08/86                                 1-6                    CP SSER 13 SEC. 1
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significance evaluations, and the initiation of corrective action is
          -             -              intended to combine to produce a program that is iterative, flexible, and
  ,'                                   adequately controlled. The CPRT is a dynamic, responsive organization
  -l 1                                    that is undertaking a comprehensive evaluation and. corrective action
  ]                                    program that is described in the CPRT Program Plan, which is itself
: j.                                   subject to change as the program unfolds. The staff considers this                                 ,
flexible yet controlled approach to the CPRT to be acceptable.
h                                There are four reasons why the staff has concluded that the CPRT's methods N                                for modifying the Program Plan are satisfactory:
'J 1
:)                               (1) The CPRT has already successfully used this approach to appropriately I                                   expand the Program Plan to suit its developing evaluation. For if instance, new or expanded Appendices have been added on program QA, l}              .
interface control, and corrective action. In addition, a new ISAP has been added to evaluate and improve craft training.
!j                               (2) The CPRT Program's expandability ensures that new issues will be
!I                           .5        resolved using a consistent approach.
(3) During the evaluation process, as new perspectives become apparent to
..,l'                                  the CPRT, the Program's inherent approach can adapt to focus attention and resources on important issues. This approach greatly enhances the
!).                                    overall effectiveness of CPRT corrective action.
!i l                              (4) The flexibility in the CPRT Program ensures effective incorporation of i
lessons learned from the evaluation process.
The staff, therefore, approves the CPRT's methods for modifying the Program Plan, as described in the {{letter dated|date=January 27, 1986|text=January 27, 1986 letter}} from W. G. Counsil to V. S.
Noonan (CPRT-207), transmitting Revision 3 of the CPRT Program Plan.
1.5 Problem Identification and Classification
'i                                There are four key aspects of the CPRT Program:     (1) identification;(2) classification;(3) evaluation;and(4)correctionofproblems. In this 04/08/86                                1-7                            CP SSER 13 SEC. 1 "y*     -.,n-   ,        -           -      9- M9     - - , -
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section, the staff sumarizes the methods chosen by the CPRT to classify
    ;                 identified discrepancies. For a detailed discussion of discrepancy classifi-
    !                 cation, see pages 1 through 4 of 13 of Appendix E Revision 1 to the CPRT l                   Program Plan.
  *)I                                                                                                             I
   ]                  In Appendix E, the CPRT has described five different sets of definitions that I                 are used to classify problems, which are subject to evaluation by the                       ,
  ;;                  CPRT. These five different sets apply to the DAP, the QOC, the test programs                ;
j                   ISAPs, and the QA/QC portion of the CPRT. The staff's understanding of these i                  and other key terms, which have nearly universal applicability to all CPRT l                  activities, are described below:
j.
j                  (1) Discrepancy. The term discrepancy is used to convey any' problem eligible
[                        for consideration by the CPRT. This term encompasses the largest set of potential problems and carries no special meaning about the nature, importance, or potential safety impact of the potential problem.
j                  (2). Deviation. A deviation is a verified failure to meet a licensing commit-ment, to meet a regulatory requirement, or to properly install hardware.
Not all discrepancies may turn out to be deviations, since not all
   ;                         identified problems turn out to be actual failures to meet a requirement, comitment, or installation specification.
(3) Design Observations. The term observation has meaning only for the DAP portion of the CPRT Program. Each design discrepancy that is determined
,l                           n_ot to constitute a verified failure to meet a design comitment or i                            specification will be classified as a design observation.
(4) Deficiency. A deficiency is a deviation that has been evaluated as having safety-significance, a term that is defined below. Very few deviations are expected by the CPRT to be classified as deficiencies, since the CPRT expects that few will be determined to have safety-significance.
I (5) Programmatic Deficiency.       If a set of deviations is evaluated as having i                             an adverse trend, then a programatic deficiency is said to exist.
04/05/86                                1-8                     CP SSER 13 SEC. 1 l                                                                                    .
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y The CPRT expects that deviations in this special set will seldom be
[                                 sa'fety-significant by themselves.
     ?
(6) Safety-Sionificant Because of the importance of this term, the descrip-tion presented below is a virtual quote from the language of Appendix E.
      !'                              Revision 1 of the CPRT Program Plan. Safety-significant is defined to i                                mean that the identified discrepancy, if uncorrected, would result in the j                                 loss of capability of the affected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train or structure level. This definition, which is employed in the CPRT Program for purposes'of sample expansion, is more restrictive (conservative) than j                                  that usually applied to the term " safety-significant" for regulatory j                                purposes or in common parlance, in that it ignores redundancies that do exist in real life. Identification of a deficiency as " safety-l                                significant" for purposes of the CPRT Program, therefore, is not equiva-l                                lent to a statement that, in fact, the deficiency, if uncorrected,-would have resulted in unsafe operation.
f                                                                           .
(7) Adverse Trend. A trend is a set of related discrepancies having l
attributes that reflect commonality. Examples of possible commonalities i                                include:
i 1
u                                    o       The individual, group of individuals or organization perfoming the 1                                            activity.
1:
C o      The program requirements, procedures or controls governing the
:l   ,
i performance of the safety-related activity.
ll h                                     A tre.nd is considered to be adverse if it is determined that the identified pattern or comonality is likely to have resulted in the i!                                     occurrence of an undetected safety-significant deficiency in the i                                 affected area, population or stratum. Adverse trends are also ji                                     referred to as programatic deficiencies.
(8) Root Cause. A root cause is considered to be the fundamental event or decision that was the most likely cause of the identified problem.
04/08/86                                 1-9                      CP SSER 13 SEC. 1
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[                                      Where possible, the CPRT will determine root causes for safety-i significant deficiencies and for adverse trends of deviations and design observations.
1 (9) Generic Implications. Generic implications are the potential products y                                        of evaluations of safety-significant deficiencies or adverse trends of l                                      deviations that demonstrate whether these problems represent isolated 1
occurrences, generic weaknesses within a,particular area, or
  )
j                                       programatic weaknesses.
l                                 Appendix E to the Program Plan describes the CPRT's method for classifying problems. The staff finds the CPRT's problem classification system to be f
acceptable for the following three reasons:
]
3 (1) The definitions of the different classes of problems to be encountered are sufficiently 1: lear that the CPRT should be able to satisfactorily implement the classification of identified problems and the NRC. staff I                                       should be able to readily inspect the CPRT's implementation of this j                                       problem classification system.
(2) The CPRT's problem classification system includes an adequate framework
  ;                                       to address problem classification in that the system addresses all j                                         possible categories of problems that could be encountered.
(3) The staff finds that the classification process, which is intended to track identified problems through an evaluation sequence from discrepancy j                                         through deviation to safety-related deficiency, is a logical process that should be suitable for satisfactory implementation by the CPRT and for independent inspection by the NRC staff.
   .                               Initially,* the staff had expressed concern regarding the CPRT's ability to adequately identify items that were not in compliance with licensing comitments. The staff is now sathfied with the CPRT's intentions in this area, as described in Sevision 3 to the Program Plan, for the following reasons:
04/08/86                                      1-10                   CP SSER 13 SEC. 1
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: 1.           a o    All deviations, which include items that fail to meet current licensing commitments, are tracked, evaluated, and classified as to J                                          safety-significance, o    Deviations are evaluated to detemine if an adverse trend exists.
  ]
* o     If TUEC should determine that the issue need resolution by changing
   ."                                        a licensing commitment, they will s.ubmit an FSAR amendment requesting the staff's review and approval of the change.
1.6 CPRT Products: Evaluations. Corrective Action, and Reports.
l                             In accomplishing its activities, the CPRT will conduct or initiate four l                             types of actions to resolve identified' problems:
f o Determination of Root Causes
';                                      o Evaluation of Generic Implications o Initiation and Oversight of Corrective Action
    ,                                   o Documentation of Results in Reports t
* The first two of these actions constitute important evaluations that the CPRT intends to use to fully resolve identified problems and to bound the l]
fl  ;
safety-significance of the associated deviations. The staff's understanding and evaluation of these actions are described below (see pages 2 and 7 through l;
9 of Revision 3 to the CPRT Program Plan for TUEC's discussion of these                         3 i,                                actions).
l-                                 (1) Deterinination of Root Causes. The CPRT recognized that the specific I
l issues identified by External Sources may be representative of more i                                       fundamental, underlying concerns. Accordingly, the CPRT has committed to evaluate each issue, even if the issue is nonsafety-signficant.
Root causes will be investigated and determined where possible for all l
adverse trends of deviations, design observations, and all deficiencies 04/08/86                                         1-11            CP SSER 13 SEC. 1                         ,
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identified through the CPRT Program. Such determinations will assist the j                                  CPRT in identifying potential generic implications, establishing appropri-ate expanded scopes of review and defining appropriate corrective j                                 actions.                                                           ,
j                                    ISAPs and DSAPs include tasks that will determine where possible the j                                   root causes of identified deficiencies. These tasks are oriented both at
:!                              . specific testing of any initial root cause hypotheses and more general l                                   exploratory efforts that will lead to fonnulation and testing of new root
  )                                   cause hypotheses as the action plan is implemented.
l i'
Investigation of a deficiency into the probable cause initially may j                                    suggest many possibilities as contributing causes. In some cases, these
                          .           can be narrowed down to one most likely candidate. If the investigation l
i                                 shows no further possibilities, the CPRT plans to define the " root cause"
    '                                 as the event or decision which is the most likely cause of the identified i                                  deficiency. This process may, for example, lead to a finding that the
[                                 deficiency was due to errors in the instructions. However, if further j                                  investigation in the same area shows similar errors, it may be determined that the author of the instructions was the real " root cause." Discovery l
of the second, more extended root cause is intended to enable correction of the wider-ranging situation and to lead to greater assurance that
!!                                     there are no undetected and uncorrected safety-signficiant deficiencies associated with the causes of any deficiencies or adverse trends idaati-f
, ,i                                   fied by the External Source issues.
:1 The staff has examined the CPRT's description of their intended methods l
,:                                     for determining root causer and finds that the CPRT's description,
!'                                     although brief, is acceptable. At this stage in the CPRT process, few                                      '
     .                                  issues have been fully enough resolved to provide the CPRT with enough examples of safety-significant deficiencies or adverse trends to imple-
-i                                     ment a root cause evaluation process. Nonetheless, the CPRT has provided 4
an ample commitment to evaluate root causes as the Program progresses.
 ,!                                    The staff will continue its evaluation of the root cause determination tt i;                                      process during th' eCPRT implementation phase.
i 1-12                             CP SSER 13 SEC. 1                        i j                               04/08/86 i
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(2) Evaluation of Generic Implications.
j                                          At such time as the root causes of safety-significant deficiencies or adverse trends of non-safety-significant deviations have been determined, an evaluation will be performed to identify any associated potential
   !                                          generic implications. The CPRT maintains that such evaluations will enable them to detemine whether the deficiencies or deviations represent
  -]
i isolated occurrences, generic weaknesses within a particular area, or
  '                                           generic weaknesses that are programmatic in nature.
1 The CPRT has stated that the results of these evaluations, in conjunction i
with assessments of the safety-significance of the deviations, will enable them to define expanded scopes for review and to identify correc -
               ~
tive actions for both the specific deficiency and for prevention of repetition of the same types of deficiencies.
The staff has examined the CPRT's description of their intended. methods for detemining the generic implications of each root cause and finds
[
   !                           A              that the CPRT's description, although brief, is acceptable. At this I
stage in the implementation of the CPRT Program Plan, the root cause determinations have not progressed sufficiently to permit meaningful               ,
i detemination of generic implications. However, the CPRT has provided an adequate commitment to detemine the generic implications of each
        -                                      found root cause as the Program progresses. The staff will continue its evaluation of generic implications evaluations during the CPRT implementation phase.
Initiation and Oversicht of Corrective Action.
(3)
I The third action involves TUEC's methods for correcting identified probTems and the CPRT's methods for overseeing and, in some cases, f'
concurring in problem correction. Appendix H Revision 0, of the CPRT Program Plan contains TUEC's description of this corrective action
;j                                              process.             .
TUEC has structured its action to vest primary responsibility for imple-mentation of corrective action with the CPSES Project rather than the 04/08/86                                   1-13                     CP SSER 13 SEC. 1
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CPRT. Because of the special nature of this program. TUEC has internally required that corrective actions by the Project for all safety-significant deficiencies and certain categories of deviations must be acceptable to the CPRT.
ii                         The CPRT is responsible for transmitting all deviations and deficiencies to the CPSES Project for evaluation and disposition in accordance with
  !,                         Project procedures for processing non-conformances.
:l .
 ;]                          For each deviation or deficiency identified by the CPRT the CPSES Project is responsible for perfonning 10 CFR 50.55(e) reportability d
                .            evaluations and for defining appropriate corrective actions. The CPSES Project is also responsible for obtaining CPRT concurrence in the oefined
: j.                          corrective actions for:
:6
  'I h                           o   Each safety-si,,gnificant deficiency identified by the CPRT
  ,,                         o Each programatic deviation or programatic deficiency identified
:l                              by the CPRT
~
o Each design deviation identified by the CPRT that involves a
;,                               failure to meet FSAR criteria or commitments, other licensing j                                comunitments, or the regulations                 ,
4
* o Each deviation identified by the CPRT that ' as been determined by
{j                               the CPSES Project to meet the reportability criteria set forth in i'
10CFR50.55(e).
U In the event of disputes between the CPSES Project and the CPRT regarding the adequacy of corrective action, TUEC has described a process for reschation of such disputes on page 3 of 8 of Appendix H to the CPRT Program Plan, Revision O. The staff finds this described process for resolution lll' of disputes to be acceptable.                                                                                     ,
l.
I 04/08/86                                      1-14                              CP SSER 13 SEC. 1 i-l l
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I
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In order to verify that the CPSES Project's program for implementing corrective actions is being effectively implemented, the CPRT is respon-i-                              sible for performing confirmatory overviews of the implementation of certain corrective actions. These confirmatory overviews are intended to
  -                                 accomplish the following objectives:
f                                  o       To ensure that the corrective actions for each programatic deviation and programatic deficiency have been effectively implemented.
o       To ensure that the corrective actions for each specific safety-significant deficiency have been effectively implemented.
j                                 o       To ensure that the corrective actions for each specific design i                                        deviation that invclves a failure to meet FSAR and licensing l                                        commitments have been effectively implemented.
{                                o       To ensure that the corrective actions for each specific deviation l                                         that meets the reportability criteria of 10 CFR 50.55(e) have been effectively implemented.
l l
The CPRT will perform these overviews using design reviews, document reviews, and independent reinspection and inspection witnessing.
t The staff has determined that TUEC's method for implementing corrective action and the CPRT's commitment to independently concur and overview l                                key aspects of that corrective action to be acceptable for the following
   !                                three reasons:
(1) Deviations and deficiencies will be tracked, dispositioned, and
   ;                                        tlosed in an auditable system. TUEC's non-conformance report (NCR)
I                                         system.       In addition, the CPRT's tracking system for deviations
   !                                         ensures that TUEC will generate an NCR for each deviation.
1 l
04/08/86                                                1-15               CP SSER 13 SEC. 1
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(2) The prime responsibility for corrective action and records                .
associated therewith will reside with the organizational entity l                             that will acquire operational control of the facility upon issuance of an Operating License. The staff concludes that it is important that the eventual facility operator controls, ' implements, and is
(                              responsible for this corrective action.
(3) Even though the CPRT will not implement the corrective action resulting from its various evaluations, the CPRT will retain a sufficient level of concurrences and confirmatory overview of TUEC's corrective action for important deviations that the CPRT can ensure the adequacy of corrective action and can ensure the i                             credibility of this Program.                                           .
(4) Documentation of Results in Reports The fourth action entails documentation of the results of the CPRT's efforts l
u                         in a set of reports.
1 y                         The CPRT has described several types of reports that will document              -
  ;                        the prbducts of its activities. The principal types of reports that the CPRT will provide include:
j                       o     Results Reports, fI
'i                               Each ISAP and each DSAP will produce a Results Report. Each Results
;j i                            Report will at a minimum identify the safety-significant deficien-               l it                                                                                                                 l cies and programmatic deficiencies, their resolution, any root                   !
ll j                             causes and generic implications and their resolution and any recom-mendations for programmatic improvements to abate the potential for ll
!I                              teoccurrence. The CPRT overview of corrective action implementation t
(j                               required by Appendix H will either be. incl'Jded in the Results Report j                            or a supplement to the Results Report.
I 1
04/08/86                              1-16                    CP SSER 13 SEC. 1 l
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The DAP will also produce third-party CPRT Results Reports concur-ring in the criteria, the processes used and the implementation of l'
the piping and pipe support and cable tray and conduit support design verification efforts.
l                   o    Collective Evaluation Reports.
  .)                           ,
In the Quality of Construction and QA/QC Adequacy, Design Adequacy, and Testing Program Adequacy areas, the results of the various f                        activities will be collectively evaluated to ensure that potentially
     !                      safety-significant trends implicit in the collective data but not
    !                       apparent from the activity specific results are not overlooked.
These collective evaluations will be separately reported in Collective Evaluation ~ Reports.
i The Collective Ev~aluation Report relating to the adequacy of the QA/QC Program will include the identification of necessary improve-sients to futura CPSES construction activities and to future plant operations. The Collective Evaluation Report relating to the quality of installed hardware will include identification of the corrective actions necessary to resolve safety-significant hardware deficiencies.
l,*                         The Collective Evaluation Report relating to the DAP will be called r-
;-                          the Final Design Adequacy Program Report and will include identifica-
'I                          tion of improvements needed for future CPSES design activities and j
identification of corrective actions needed to resolve safety-i                       significant design deficiencies.
o    collective Sionificance Report.
{
A collective significance evaluation will focus on the integrated
(;                          impact of the identified deficiencies, both specific and program-i                       matic, on the design, construction and testing of CPSES. This l!                          evaluation will be conducted by the Senior Review Team (SRT), which 04/08/86                                    1-17                 CP SSER 13 SEC. 1 (l                                                                                  .
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consists of a tenfor TUEC line manager and senior industry consult-ants and which has been established with overall responsibility for the development and implementation of the CPRT Program. The CPRT Program Director is an ex-official member of the SRT.
I 1                      The staff finds that the CPRT's description of methods for documenting the l                     results of their efforts in Results Reports, Collective Evaluation Reports,                ,
t 2
and the Collective Significance Report to be acceptable for the following 1
1 reasons:
(1) These reports, if produced as described in the Program Plan, will give
                 ~
TUEC and the NRC staff sufficient basis for reaching a conclusion about the adequacy of the design and construction of the CPSES.
j                      (2) Although the Program Plan description of the Collective Evaluation
   !                           Reports and the Collective Significance Report is briefer than the description of the Results Reports, the description is considered l                             adequate. The collective evaluations that will support these reports
  !                             can only begin in earnest when the CPRT has completed the bulk of the examinations needed to resolve each ISAP and DSAP. At that time, the i                             respective issues will have become sufficiently understood so that the implications of each issue can be properly evaluated. The staff will              ,
inspect the CPRT's implementation of these collective evaluations during the implementation phase of the Program.
j               ,
1.7 Overall Conclusions i ,!
  '                      In SSER 13, the staff approves the CPRT Program Plan and finds reasonable
                                                                                                       ~
assurance that, if implemented subject to the comunents identified in this
  ;                     evaluation, the CPRT Program Plant will provide sufficient information to
!l                      ensure thtt the CPSES has been designed, constructed, and tested in a manner
!j                       that it can be operated without undue risk to public health and safety.
1 o
l ;'
04/08/86                                     1-18                 CP SSER 13 SEC. 1
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The staff. concludes, based on its evaluation in this SSER, that Revision 3 of the CPRT Program describes an acceptable process for resolving all currently l                        identified design, construction and QA/QC and testing external source issues and for conducting a self-initiated evaluation evaluation of the design and the quality of construction for all safety-related systems and components.
-                            That process is also an acceptable framework for the evaluation and
']'
resolution of any future issues which may arise.
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    '4 2.0 QUALITY OF CONSTRUCTION 3
The adequacy of the construction QA/QC program and'the quality of construction performed within the scope of that program have been questioned by a number of
~                             sources external to TUEC. The CPRT has been charged by TUEC with responding to and resolving these concerns. This section of the SSER documents the staff evaluation of the CPRT-formulated program (QOC Program) to evaluate questions 4
concerning construction QA/QC and the adequacy of installed hardware.
J The CPRT's objectives for the QOC Program are to identify and resolve all of the construction and QA/QC related external source issues, assess in an inte-
}                             grated fashion all identified safety-significant deficiencies and to make a statement about the adequacy of construction at CPSES. The CPRT's program has the following three components:
:e
  'l                          a.           Identification and resolution of external source issues,
 ,i
:                    b.           Root cause evaluation and generic implication assessment for each 1     1
;j                                         identified safety-significant deficiency or trend of nonsafety-significant deviations, and
  !!                          c.           Self-initiated reinspection and documentation review of a representative sample of QC accepted safety-related work activities, d
The objective of the staff's evaluation is to ascertain if the CPRT Program
;ti                           Plan describes a framework and process for accomplishing the three components
        ;                     listed above. Subsequent sections of this SSER address both the CPRT-proposed I
process and the staff's evaluation of this process. In performing this evalua-tion the staff conducted document reviews and audits for the purposes of
       )                      understanding the details of the QOC Program process, determining whether an auditable trail existed, and to provide assurance that the proposed process was
        ,                     adequate to meet the Program Plan objectives.
lI 04/02/86                                                  2-1                           CP SSER 13 SEC. 2
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l 2.1 External Source Issues
,2 Concerns regarding the adequacy of the CPSES construction QA/OC program and the adequacy of the constructed safety-related hardware have been raised by a number of sources external to TUEC and are referred to as External Source d                      Issues (ESIs). The QOC has established two components to resolve and bound the               !
'l
,J                      safety-significant implications of any ESI deficiency in either the hardware
.I                      or the CPSES QA/QC construction program. First, the CPRT will evaluate each external source issue by determining the scope of any safety-significant hardware deficiencies and the corrective actions necessary to resolve them.
h l                      This process included reinspection of hardware, documentation review, engineer-
'l                      ing analysis and evaluation, assessment of TUEC corrective action programs and 1
J i
an evaluation of data collected from other CPRT review team action plans.               -
i                     Second, the CPRT will determine the root cause of each discovered safety-i i                     significant deficiency or trend of nonsafety-significant hardware deviations.
l They will analyze the generic implications of each root cause in order to t                     determine the extent of any additional hardware that might be deficient for the same programmatic reasons and to determine if changes need to be in ongoing programs to prevent recurrence in the future (further details of this second component are explained and evaluated in Section 1.5 of this SSER).
Issue-specific actions plans (iSAPs) describe the CPRT plan for resolving each
  !                      of the external source issues. All construction QA/QC issues whether of a hardware nature or a QA/QC programmatic concern, will be the subject of an i                     ISAP. A single ISAP VII.c also describes the process and methodology for j
the CPRT's self-initiated hardware reinspection and documentation review which
   !                     is discussed in Section 2.2 below. The results report prepared for each ISAP I                     documents each individual issue evaluation. Should additional issues be identified by either other external sources or the CPRT, a new ISAP would be prepared for resolution of the new issue or an existing ISAP will be expanded
''                       as confirmed in revision 3 of the Program Plan. CPRT proposes to integrate i                     and collectively evaluate the findings from their external source issue evalua-l tions with the results of the self-initiated program in order to make a state-ment about construction quality at the Comanche Peak Steam Electric Station.
04/02/86                              2-2                  CP SSER 13 SEC. 2 m-             e-    . . _ .      .__._.w.,,--                _       ____      y            __            _ ,,

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Three reports will be prepared in addition to the individual action plans results reports to document the results of the integrated evaluation. Two i
collective evaluation reports will be prepared to address the adequacy of the construction QA/QC program and the quality of installed hardware. Finally, a summary report will integrate the results of the two collective evaluation
 'l                 reports and state the CPRT's conclusions regarding the quality of construction q
i                 and the QA/QC program at Comanche Peak plant. Any information that may be d
 ;-                 related to design adequacy which is identified during implementation of this
  }
l ISAP will be referred to CPRT personnel responsible for implementation of the DAP.
To assure that all issues / concerns from External Sources are addressed, the CPRT will develop a matrix that provides a cross-reference between each issue /
;,                  concern and the action plan (s) that addres'ses it. This matrix will also serve
   !                as an aid in the collective evaluation process. The matrix format will present
>                   information such that valid concern can be tracked to the appropriate criteria
:j                  of 10 CFR 50, Appendix B, and/or hardware area, and tracked to the ISAP govern-
;)                  ing the concern.
2.2 Self-Initiated Pronram a
'}                  The self-initiated evaluation of construction adequacy is described in ISAP ll
  )                 VII.c. This action plan describes the proposed CPRT reinspection and documen-tation review of a representative sample of completed and QC-accepted safety-related construction work activities performed at Comanche Peak. The objective of this effort is to provide additional confidence that there are no unidentified l
safety-significant concerns related to the quality of construction of the
   ;                 hardware at Comanche Peak. The CPRT's Plan consists of a reinspection of a f                 representative sample of safety-related construction work which has been inspected and accepted by CPSES QC for Units 1, 2 and their common areas,
;i                   supplemented by a review of related documentation for uninspectable hardware attributes. Construction activities are organized into three disciplines as
;i t'                    follows:
o     Civil / Structural o     Electrical, and o     Mechanical / Piping 04/02/86                             2-3                   CP SSER 13 SEC. 2
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The methodology for the self-initiated construction adequacy review consists of ll           ,
establishing reasonably homogeneous populations of construction work activitic:
 -t
  .!                           by reviewing applicable drawings and specifications, codes and standards, work and inspection procedures and by identifying organizations and crafts who performed the work. The populations are then sampled and evaluated by means of 9
physical reinspections of safety related attributes and documentation reviews of uninspectable attributes. The results of these evaluations with conclusions f
4                          drawn will be documented in an action plan results report. The self-initiated review begins with the categorization of all safety-related hardware into
  ]~
populations made up of homogenous work activities for which samples can be drawn for evaluation. Population and work process descriptions are prepared
:j                           for each construction category. The population description describes the boundaries of the population while the work activity describes the process
'. 1
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required to install or construct a certain category of hardware. Attributes associated with each work activity are established based upon the provisions of
    '                           installation and inspection procedures and/or specifications used for installa-
  .i       -                   tion of the subject hardware. For each population, two randes samples will be
:i                            selected'in accordance with the procedure in Appendix D of the Program Plan.
 !j                            The first sample is derived from the total population while the second sample (which is essentially an expansion of the first) is drawn from that portion of the total population which is defined by the CPRT as having greater importance l
to safety. In parallel with the sample selection, checklists and inspection ll                              procedures are developed from the attributes used to characterize each work process. Both inspection and documentation review checklists are developed
    ;                            from the Quality Instructions. Verification packages are then assembled for i!                               each sample ites to facilitate an inspection or documentation review. Any
]   i deviations identified as a result of a reinspection or a ilocumentation review are documented in a Deviation Report which will then be evaluated to determine j~
the safety-significance of the deviation. In addition, all deviations are collectively evaluated for adverse trends. An action plan results report I                            documenting the overall results of the inspections for all populations is the i                            vehicle for documenting the results and evaluations of this ISAP.
I i
5 i
04/02/86                               2-4                     CP SSER 13 SEC. 2
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                                                                                                                                                 ;3 The sample size for each population which is part of the construction adequacy review program is targeted by the CPRT in Appendix D to meet a 95/5 confidence level. This confidence level is used by tik CPRT as a means for l
detecting programmatic or systematic deficiencies. For each work
;                               activity of interest, a minimum sample size of 60 will be taken. If no safety-significant deficiencies are found in the sample, the work activity is                                           l
,i j
d                               accepted. If a deficiency is found, the sample is expa'nded. For a single
     !                          sample expansion, the sample would be increased to 95 and the' work activity is I
    *!                          accepted only if the total number of deficiencies does not exceed one. As noted in Attachment 4 to Appendix D of the Program Plan and confirmed by the Applicant in a meeting with the staff on March 18, 1986, only one sample I
                       ~
expansion will be made prior to performing a 100% reinspection or reevaluation i
of an attribute, stratum, or population as conditions dictate. Provisions are d-L!                              provided in Appendix D for 100% reinspection or review of a population. If the
[                               items from the samples contain no safety-significant deficiencies, and there
  ,l                            are no apparent adverse trends of nonsafety-significant deviations, no further i                            reinspections or documentation reviews would be required. If a sample is found
:!                            to contain one or more safety-significant deficiencies, or if there is evidence of an adverse trend, the sample would be expanded and additional reinspections/
ll                               documentation reviews conducted. -All safety-significant deficiencies will a
'j                              be analyzed for root cause and generic implications in conjunction with these I                          expanded reinspection / documentation reviews and will be consistent with the l
process used to establish the HWAs.                                                                               ,
Ii 1'
A results report will be prepared documenting the results of the self-initiated evaluation program. Any information that may be related to design adequacy which is identified during implementation of this ISAP will be referred to CPRT f
:l                               personnel responsible for implementation of the DAP.
I'
'i 2.3 Staff Evaluations 7l l!                                            .
i;.
l The staff reviewed the applicable sections of the Program Plan and each l                            individual ISAP including the ISAP describing the self-initiated evaluation l
program for the purpose of ascertaining if the CPRT's construction adequacy
'I                               program can accomplish'its stated objectives (See CPRT Program Plan, Appendix B, Page 2). In addition to the review of each individual ISAP, on-site audits l
04/02/86                                              2-5               CP SSER 13 SEC. 2 l.
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of the documentation being prepared in support of external source issue reso-lution and of the self-initiated evaluation program were performed for the purpose of developing an understanding of the CPRT process. These audits also served to establish that the Applicant was documenting construction adequacy evaluation activities in sufficient detail to permit audit now or in the
 .4 d                        future.
1
 -i
 -I                      Review of the construction adequacy program plan has been accomplished by teams of NRC staff and consultants. External source issue review have been organized in a manner similar to the NRC's Technical Review Teams (TRTs) and include the following disciplines.
1                               a. Electrical and instrumentation issues l                           b. Testing program issues
: c. Mechanical and piping issues and miscellaneous issues
: d. Civil and structural issues
: e. QA/QC issues i
Many of the individuals responsible for reviewing the scope methodology and implementation of the external source ISAP's were members of NRC's Technical Review Team. Review of the self-initiated evaluation program is accomplished
 ,l                      by a multidisciplinary team encompassing most of the disciplines addressing
    '                     external source issues. This team has reviewed the methodology for the self-initiated program and has audited the safety related hardware populations.
4:
,;                        The scope of each ISAP contained in Revision 3 of the Program Plan has been reviewed by the staff for the purpose of comparing its content with that 4
required by the Issue Specific Action Plan Format (Attachment 3 to CPRT Program Plan) and its scope with the issue requiring resolution. The format i                      required by the CPRT describes the elements of the ISAP process and includes:
 'l;                                   .
 !!.                               a. Description of the issue
: b. Actions identified by the NRC
: c. Background f'
: d. CPRT Action Plan 04/02/86                                 2-6                 CP SSER 13 SEC. 2 P p*m** ep -   ew .,
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The ISAP Format also provides guidance for the development of the CPRT Action j                            Plan. F'or example, the approach to resolution, the required tasks, and assess-l                            ment for potential generic implications must all be included in the CPRT Action Plan. Also, applicable procedures, responsible organizations, personnel qualification, and acceptance and decision criteria must be addressed in each ISAP to comply with the CPRT's specified ISAP Format. Further, implementation j                                of an ISAP is to be in accordance with the CPRT's Quality Assurance Program and the status of each ISAP will be monitored through the CPRT Program Records with documentation provided in a Results Report. Based upon the assessment of the
(                               ISAP format, which essentially describes the CPRT's process for resolving issues, the staff finds that this process contains the elements necessary for systematically addressing issues raised by external scurces, as well as any
 ,1 i                             specific issues which may be identified by the CPRT or other external s,ources     .
t 1                             in the future. The CPRT acknowledges in Revision 3 to its Program Plan that 1
     ;                            the scope of its activities will be revised as appropriate. This commitment j                                provides the staff with, additional assurance that the CPRT will appropriately
     !                            address and resolve any other construction and QA issues which may be raised in the future. The staff finds the individual ISAPs are gen'erally responsive to the issues based on the staff's technical review of each ISAP, since they           ,
adhere to the ISAP format and address the specific concerns by means of a systematic approach to resolution. Specific comments are provided in Appendix B to this SSER.
The staff reviewed the CPRT's process for their self-initiated program includ-l                                  ing their sampling program to determine if it would accomplish its stated if l!                                 objectives. This review which included on-site audits examined the homogeneous i
I work activities to develop an understanding of the CPRT's self-initiated program, to ensure that an auditable trail existed and to determine if the same f
procedure was being applied to all disciplines. The audits did not address the implementation of the reinspections and the document reviews. The staff found i                              the documentation of the populations to be compatible with the'CPRT's Plan i                             described in ISAP VII.c and found the development of the inspection checklists and the documentation associated with this process to be consistent for all populations. The staff further found that the documentation was adequate to ensure that this proces's could be audited in the future. The basis, descrip-tions, items list, and work activity definition for most populations was 04/02/86                                2-7                   CP SSER 13 SEC. 2
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reviewed and found to be acceptable since they properly addressed the concept
   ,                              of homogeneity and were documented to enable evaluation of the work activities                      .
U                               and their accompanying attributes.
The sampling procedure is based on assumptions that characterize a binomial population (i.e. acceptable or not acceptable). These assumptions include, among others: (1) homogeneity of items within a work activity; (2) random e
selection of sample items from a work activity; (3) ability to classify an item a                                 as either acceptable or deficient with certainty; (4) the number of items in the work activity is essentially infinite. The homogeneity.of the various work activities, required by Assumptiou 1, is determined and justified by engineer-ing considerations. Homogeneity is a necessary attribute for a population if j                              conclusions based on a sample of a population are to be valid for the entire
                                                                                   ~
j                               population. If the population of interest is found to be non-homogenous, the work activity boundaries are redrawn and samples are selected at random from the respective work activities.
;{                                The selection of the items from the HWAs is made through a random
!!                                sampling procedure described in Attachment 2 of Appendix D.           Since all popula-ll                                tions developed for the self-initiated program are finite, all sample sizes 1l will be larger than required because of Assumption 4.        The 95/5_ assurance level
,l was selected by the Applicant as a criterion to allow a quantification of the quality of the work activity performance without having to reinspect each and every individual item. From a strict probabilistic view, the sampling plan stated in Appendix D offers less than 95 percent assurance, primarily because of the Plan's associated expansion. A plan which allows no expansion (i.e.,
ff accept the work activity only if zero deficiencies are found in a sample size
   !                               of 60) actually offers 95.4 percent assurance that no more than 5 percent of
   !                               the items in the work process are unacceptable. If one expansion is allowed,
    '                              the assurance level is 93 percent. On the other hand, the 95/5 level of assurance is only an arbitrary target value and somewhat smaller assurance (at
             -                     least 90/5) is in the staff's judgement considered acceptable for this application. Moreover, there are many factors that would further enhance this i
assurance.      Some of the.se factors are:
t 2-8              CP SSER 13 SEC. 2 04/02/86
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: 1. As previously noted in this subsection, the initial sample is supplemented by a second sample drawn from that portion of the population having greater'importance to safety.
1 J                             2. The sampling scheme assumes (assumption 4) that the size of the work activity is infinite. For small groupings of work activitier, the j                                 sample size is considerably larger than need be and hence the
   '.:                                associated assurance is understated.
l'
  .i
: 3. The sampling assurance is increased when a deficiency is. identified 1
i                                 and repaired. For categories involving a small number of work j                                   activities this increase may be very significant.
i l
   ]                             4. When a deficiency is identified, the CPRT Plan calls for further
!j                                    sampling. This activity increases the sample size, generally giving a still greater assurance.
    .                                                 ~
     '                     The CPRT's self-initiated program for evaluation of construction adequacy commits to performing root cause evaluations and generic implication assess-l
  .I                       ments of safety significant deficiencies and adverse trends of non-safety
 ]:.                       significant deviations. In addition, adverse trends will be investigated to                ,
:l identify trend boundaries and to determine the affect of the trend on other areas if applicable. Closed external source issues will be considered in
  'l the root cause and generic implication evaluations.
The staff considers that the CPRT's self-initiated program for evaluation of lj construction adequacy to be acceptable because it:
l, il
.;                                a)   is a structured process which complies with the CPRT's ISAP Format b)   employs an appropriate procedure for assuring homogenous populations for sampling by the use of HWAs.
1 C)   employs a conventional sampling process accepted in the industry.
04/02/86                                 2-9                   CP SSER 13 SEC. 2 A
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     ;                                d)      establishes a targeted level of assurance by the 95/5 criterion which should be sufficient to identify progr'ammatic deficiencies.
 . f.
e)      provides for a 100 percent reinspection of a population if two or more deficiencies of the same type are detected in the minimum
 .I
  .1                                           initial sample.
:I
''                                             requires root cause evaluation and generic implication assessments f) of both safety significant deficiencies as well as adverse trends of non-safety significant deviations and A
j                                g)       is documented in a manner suitable for audit now and in the future.
J
            -                 2.4 Conclusions i        .
The staff concludes, based on its evaluation described above, that Revision 3 l
of the CPRT Program documents an acceptable process for resolving all i
currently identified construction and QA/QC external source' issues and for i
 .l                        ,
conducting a self-initiated evaluation of the quality of construction for all safety related systems and components. That process is ,also an acceptable framework for the evaluation and resolution of any future issues which may j                        arise.
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Document Name:
CP SSER 13 APP. A
      ,                                Requestor's ID:
ORDAZ Author's Name:
Trammell Document Comments:
Identification of all Components of CPRT Program Plan
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* l[             Appendix A - Identification of all Components of the CPRT Procram Plan,
    !                             including Appendices, ISAP's and DSAP's by Revision Number 1
Although reference is made in this evaluation to " Revision 3" of the CPRT Program Plan, this document actually consists of numerous-documents, each with
  !1               its own revision number. In addition, " Revision 3" is considered to include 1
  ,i               four additional letters received after Revision 3 was issued on January 27,
   )               1986. Therefore, for purposes of this assessment, Revision 3 is considered to F                consist of the basic Revision 3 submittal of January 27, 1985, plus the follow-ing: 1) Appendix D, CPRT Sampling Approach, submitted on January 31, 1986; 2)
Appendix E, CPRT Procedure for Classification, Evaluation, and Tracking of Specified Design or Construction Discrepancies Identified by the CPRT, sub-f              mitted on February 7, 1986; 3) the Testing Issue - Specific Action Plans (ISAPs), submitted on February 28, 1986*, and 4) Appendix G, Overview Quality Team, submitted on February 28, 1986.
s Identified below is the revision number for each appendix, ISAP, DSAP, and j
attachment contained in Revision 3 of the CPRT Program Plan as of the date of this evaluation.
I i
  -'
* ISAP III.a.1 was not included.
4 i
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1 l-
: 1.                             .
03/26/86                                            A-1                CPSSER 13 App. A.
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Revision                                    l l
l                    QA/QC ISAPs 1
I.d.1               'QC Inspector Qualifications                                                  2 I.d.2               Guidelines for Administration of QC
     !                                         Inspector Test                                                               2 I.d.3               Craft Personnel Training                                                      0 VII.a.1             Material Traceability                                                         1
   ,                      VII.a.2             Non-Conformance and Corrective Action System                               -
1
     ;                    VII.a.3             Document Control                                                              1 VII.a.4             Audit Program and Auditor Qualification                                       1
   .i                     VII.a.5              Periodic Review of QA Program                                               '1          ,
l,                   VII.a.6              Exit Interviews                                                              1 VII.a.7             Housekeep,ing and System Cleanliness                                          1
      !                   VII.a.8              Fuel Pool Liner Documentation                                                1 l
j                    VII.b.1             On-Site Fabrication                                                           1 VII.b.2             Valve Disassembly                                                             1
        .                 VII b.3              Pipe Support Inspections                                                     1 VII.b.4              Hilti Anchor Bolt Installation                                               1 VII.b.5              DELETED 3
l                    VII.c                Construction Reinspection / Documentation Review Plan 1 i
t DSAPs f
I                                         VIII           Civil / Structural Discipline Specific
"                                                                                                                           1 Action Plan l                                         IX             Piping and Support Discipline Specific Action Plan                                                   1
 ;i                                            X              Mechanical Systems and Components ff                                                            Discipline Specific Action Plan                               1 XI        ,
Electrical /I&C Systems and Components Discipline Specific Action Plan                               1
!l
:?
      +
03/26/86                                                   A-4               CPSSER 13 App. A.
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Comoonent Title                                    Revision ll
.g.
Program Plan                                             3 Appendix A                           Design Adequacy Program Plan                              1 Appendix B                           Quality of Construction and QA/AC Adequacy Program Plan                               3 j                      Appendix C                           Action Plans
: j.                                       Electrical ISAPs I.a.1               Heat-Shrinkable Cable Insulation Sleeves                  4 I.a.2               Inspection Reports on Butt-Splices                        4 I.a.3               Butt-Splice Qualification                                 4 I.a.4               Agreement Between Drawings and Field i                                                           Terminations                                              4 I.a.5               NCRs on Vendor Installed Amp Terminal Lugs                4
  .                                      I.b.1                Flexible Conduit to Flexible Conduit i                                                            Separation                                               4 I.b.2                Flexible Conduit to Cable Separation                     4 1.b.3                Conduit to Cable Tray Separation                         4 I.b.4                Barrier Removal                                          4
.i                                       Civil / Structural ISAPs I
t j                                        I.c                  Electrical Conduit Supports                               3 l^                                      II.a                 Reinforcing Steel in the Reactor Cavity                   3 Concrete Compression Strength                             3
.i                                       II.b II.c                 Maintenance of Air Gap Between Concrete 1
Structures                                                3 f                                                            Seismic Design of Control Room Ceiling j                                        II.d Elements                                                  3 II.e                 Rebar in the Fuel Handling Building                      3 1
i l
.I
(
A-2                        CPSSER 13 App. A.
03/26/86 s
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Revision Testina ISAPs III.a.1            Hot Functional Testing (HFT) Data Packages III.a.2            JTG Approval of Test Data                                             3
 ]
III.a.3            Technical Specification for Deferred Tests                            3 III.a.4            Traceability of Test Equipment                                        4 III.b              Conduct of the CILRT                                                  4 III.c              Prerequisite Testing                                                  4 III.d              Preoperational Testing                                                4
   .                                  IV.                Reserved for Protective Coatings, however, SSER-9 declassified protective coatings and negated the need for a protective coatings.
f t
ISAP. Paint quality concerns are being addressed under the Quality of Construction l
Program.
Mechanical ISAPs
.I                                    V.a                  Inspection for Certain Types of Skewed Welds in NF Supports                                                       2 i
V.b                  Improper Shortening of Anchor Bolts in Steam
'l                                                        Generator Upper Lateral Supports                                      2 i
   $                                  V.c                 Design Consideration for Piping Systems
   \                                                       between Seismic Category I and Non-Seismic i
   !                                                       Category I Buildings                                                 2 V. d.               Plug Welds                                                           2 V.e                 Installation of Main Steam Pipes                                     2 i
VI.a                Gap between Reactor Pressure Vessel l
l                                                        Reflective Insulation and the Biological Shield Wall                                                          2 VI.b                 Polar Crane Shimming                                                 2 l                                               ,
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* ISAP III.a.1 was not included 03/26/86                                            A-3                         CPSSER 13 App. A.
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     .      e Revision OA/QC ISAPs I                                      QC Inspector Qualifications                                            2 I.d.1
.                               I.d.2         Guidelines for Administration of QC Inspector Test                                                        -2 j                           I.d.3         Craft Personnel Training                                               0 1
VII.a.1       Material Traceability VII.a.2       Non-Confomance and Corrective Action System                                                          1 1
]-
VII.a.3 VII.a.4 Document Control Audit Program and Auditor Qualification                                1 VII.a.5       Periodic Review of QA Program                                          1 VII.a.6       Exit Interviews                                                        1
   ' }.           .
VII.a.7       Housekeeping and 5ystem Cleanliness                                    1 l                                                          ,
VII.a.8       Fuel Pool Liner Documentation                                          1
       ,I VII.b.1       On-Site Fabrication                                                    1 l
Valve Disassembly                                                      1
                              .sVII.b.2                                                 .
Pipe Support Inspections                                               1 VII.b.3 Hilti Anchor Bolt Installation                                          1 I                      VII.b.4 VII.b.5       DELETED VII.c          Construction Reinspection / Documentation l                                       Review Plan 1
'I.
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'I                                             DSAPs VIII           Civil / Structural Discipline Specific lf                                                            Action Plan                                             1 j j' IX             Piping and Support Discipline Specific Action Plan                                             1 f                                       X              Mechanical Systems and Components i                                                                                                               1 i                                                      Discipline Specific Action Plan
'i l                                              XI             Electrical /I&C Systems and Components t                                                      Discipline Specific Action Plan                          1 t
A-4                  CPSSER 13 App. A.
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I Appendix D                    CPRT Sampling Approach                               1 Appendix E                    CPRT Procedure for Classification, Evaluation, and Tracking of Specified Design or Construction Discrepancies Identified by
  ]-l                                                   the CPRT                                             1 1'
                         , Appendix F                   CPRT Interfaces                                      1 Appendix G                    Overview Quality Team                                 0 1                                      Attachment 1: CPRT Third-Party Quality Assurance Program            0 Attachment 2: Management Program Plan for the QA/QC Review Team                                      4 I                                    Attachment 3: Design Adequacy Review Team Quality
  't
     ;f'                                                     Assurance Program                                0 i
Attachment 4: Verification of Issue-Specific Action Plan Working Files                                    0 Appendix H                    CPRT Procedure for the Development, Approval,
    'l I                                                   and Confirmation of Implementation of Corrective Actions                                   0 E
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CP SSER 13 APP.B Requestor's ID:
ORDAZ Author's Name:
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Appendix B -       Items to be addressed by Applicants during the implementation ph'ase of certain ISAPS 4
1 l                This Appendix discusses only those ISAPs concerning which the NRC staff has comments. These should be addressed by the Applicants during the
    ~
implementation phase of each ISAP. The NRC staff has no comments on the
     ,.                remaining ISAPs which are acceptable for implementation as submitted.
The NRC staff will examine the Applicants' response to these comments as part of its inspection program for the CPRT Program Plan implementation of all
    ,                  ISAPs.
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4 Electrical / Instrumentation Issues and Control Systems and Components I.a.1 Class 1E Heat Shrinkable Cable Insulation Sleeves Description 1
   '                 Heat-shrinkable insulation sleeves are required for uninsulated butt splices, 480-volt and 6.9 kv motor terminations, at cable reduction splices,and at electrical penetration assembly cable connections. The NRC concern as noted in SSER No. 7, Electrical and Instrumentation Categories 1 and 6, centered on the lack of awareness by craft and inspection personnel as to where the j
sleeves should be installed and the high percentage of missed or improperly documented inspections requiring witnessing.
Staff Comment This ISAP is adequate to establish the accuracy and completeness of documentation records for the heat shrinkable sleeve issue with respect to completed construction items since it commits to retraining after revision of the applicable procedures. However, since the cause of the concern has been identified as inadequate personnel training, additional training along with revised procedures must be provided and the ISAP l                    should be expanded to include provisions for inspecting future electrical construction to ensure the effectiveness of the additional training and procedure revision.
l 1
l I.a.2 Inspection Reports on Butt Splice Inspection Reports
.I l
j                  Description lI QC inspection reports for 12 butt splices were found to be deficient in one or more respects as noted in SSER No. 7, Electrical and Instrumentation. Category ll                    1. Nine reports used a post-installation inspection form instead of a t.
witnessing-type inspection form. Six of these nine reports did indicate that
             ~
j installation of the heat shrinkable sleeves had been witnessed, but did not j
indicate that such witnessing was required. The other three of these nine l
B-2                      CP SSER 13 APP.B 03/31/86 l
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forms did not indicate that installation of the splices had been witnessed.                           !
The remaining three reports using the correct form indicated t' hat witnessing 3
of the installations'of heat shrinkable sleeves was not applicable (or required). the NRC recommendation was that all QC inspections requiring j                witnessing for splices be performed and properly documented, and that all but j               splices be identified on design drawings and physically identified within the f               appropriate panels.
Staff Comments This ISAP is unsatisfactory both in its approach and in the lack of quantita-tive commitments for inspection and pullout testing of existing butt splices because it presumes that they are satisfactory rather than demonstrating their
   ,               adequacy. The ISAP should be revised to state explicitly the number of butt splices to be inspected and pullout tested, to identify the approach to resolution of documentation deficiencies and to identify each butt splice.
l
  .t I.a.3 Butt Splice Qualification Description On a limited basis as described in FSAR Amendment 44, the practice of butt
}l i                splicing cable conductors in panels has been permitted subject to:
j                (1) adequate provisions in installation procedures to verify the operability of circuits using butt splices; (2) qualification of the wire splices for anticipated service conditions, and (3) staggering of the splices so that they are not adjacent to or pressing against one another in the same wire bundle.
l In addition, reinspection of all existing butt splices was to be accomplished
  ]
i                using adequate installation and inspection procedures.        As noted in SSER No.
   !                7, Electrical and Instrumentation Category 1, circuits containing butt
   ;                 splices were to be tested, and retested if reworked, during plant
!i                  preoperational and startup tests to assure their operability.
1 B-3                                    CP SSER 13 APP.B 03/31/86 lu ._ - _ , _ _ .             _ _ . _ . _      __ % _ _ ___               _ _ ,        . , _ _ _ _ ,            ,_ _

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4 Staff Comments Since all butt splices in various panels will be inspected to assure that no butt splice touches another one within a wire bundle and rework splices in nonconforming wire bundles will be reworked, this ISAP for butt spifce qualiff-j                     cation is adequate to address this issue. However, functional operability of those circuits containing butt splices must be demonstrated by the proposed use
 ]
of circuit continuity checks.
1                     I.b.1 Flexible Conduit Separation Description Industry criteria, such as IEEE Std. 384-1974, have established minimum
          ~
i separation distances to be maintained between redundant safety-related cables and between safety-relsted and nonsafety-related cables within control room
 't                     panels and cable spreading room termination cabinets. Lesser separation
   !                     distances may be justified if supported with engineering analysis of the
                       ^ involved circuits and components. The TRT, as noted in SSER No. 7, Electrical and Instrumentation Category 3, observed that flexible conduits containing
'I                       safety and nonsafety cables within these panels were in direct physical i
contact, and could not find' evidence that analyses had been performed to
;                        justify this deviation from requirements in the industry standards.                          <
I                     Within main control room panels, for example, flexible conduit identified with t
.!                       one separation division (orange color) has been bundled together with flexible i                     conduit identified with the redundant separation division (green color). In f                     this instance, a' technical justification for the lack of one inch separation distance between conduits containing safety-related circuits has not been f
i provided.
ll i;                        A reinspection of all panels containing redundant safety-related conduits or i                      both safety-related and nonsafety-related conduits was required to either correct each violation.of the separation criteria or to demonstrate by
,j analysis the acceptability of the conduit as a barrier.
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Staff Comments                  ,
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   ;                         Since conformance of internal panel cables and conduits to applicable industry separation criteria is required by this ISAP, it is responsive to the issue of           -
adequate separation of flexible conduits in main control room panels and
  'd                         vertical panels in an acceptable manner. However, it does not specifically address the issue of SERVICAIR flex in areas outside the main control room. In
  'l                         Sections 3.0 and 4.1.5 of this ISAP the Applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installa-4                         tions. For any installations outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be determined on a case-by-case basis. The staff will find this acceptable and 1 -
j                           responsive to the action items stated in SSER 7 on confirmation that "two or
[                         more trains" is interpreted to mean any panel, termination cabinet, etc.,
i                        containing two or more Class 1E and non-class 1E circuits.
I.b.2 Flexible Conduit to Cable Separation l
* Description ll                           This particular NRC concern as noted in SSER No. 7, Electrical and Instrur.mn-l t'                         tation, Category 3, is similar in many respects to ISAP 1.b.1 regarding the lf                           accomplishment of minimum separation distances between flexible conduits within I
main control room panels and vertical panels. In ISAP 1.b.2, the TRT identi-
  .t j
fied twenty-one cables within four panels where the minimum separation distance of 6 inches specified in industry standards had not been maintained relative to l                         SERVICAIR flexible metal conduits containing safety-related cables.
I NRC required that a reinspection be performed of main control room panels, other panels located in the control room, and panels located in other areas of the plant khere cables and flexible conduit had been used. TUGC0 was requested to either correct any separation criteria violations in these panels or demonstrate that the flexible metal conduit was an adequate barrier in 4
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                                                                                                  -m.-    .  ..  .-       - :   a accordance with IEEE Std. 384-1974.           If the flexible conduit could not be j             .          shown to be a suitable barrier, a minimum separation distance of 6 inches was
    ;                       to be maintained between cables and flexible conduit within the panels.             In j                        addition, drawings and related documents were to be revised to indicate the
  ]                         revised minimum separation distances.
  ]
Staff Comments Since conformance of internal panel cables and conduits to applicable industry h                         separation criteria is required, this ISAP is adequate for assuring compliance j                         with minimum separation requirements for main control room panels and
               -            vertical panels.
j                         The ISAP, however, does not explicitly address the issue of SERVICAIR j                        flex in areas outside the main control room. In Sections 3.0 and 4.1.5 of the l
Action Plan the applicant states that all panels with two or more trains will
   ;                        be inspected for any additional SERVICAIR flex installations. For any.
i                        installations outside the control room the applicability of the separation f
:l                          criteria developed for the control boards and vertical panels will be
:l                          determined on a case-by-case basis. The staff will find this acceptable and responsive to the action items stated in SSER 7 on conformation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc.
containing two or more Class 1E circuits, or Class 1E and non-Class IE
  )                         circuits. Also, in Section 4.5.1 of the ISAP, the acceptance criteria j                           is stated as " testing and/or analysis". This is inconsistent with the other lj                          sections of the plan which describe testing and analysis, combined, as the means of demonstrating the adequacy of SERVICAIR flex as a barrier, and is
,j                          therefore not acceptable.
I.b.3 Conduit to Cable Tray Separation r; ,
,;                          Description t
Ii l'
A minimum separation di, stance of one inch between an enclosed rigid conduit i
5                        and open ladder type cable trays was established by Gibbs & Hill in specification 2323-ES-100; however, the Gibbs & Hill analysis supporting 03/31/86                                           B-6                          CP SSER 13 APP.B
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3 this separation criterion was neither referenced in the FSAR nor reviewed by j              the NRC for acceptability. IEEE Std. 384-1974 requires the installation of a f              barrier between a conduit and an open cable tray unless greater minimum separation distances are maintained or are otherwise justified by an engineering analysis. The TRT, as noted in SSER No. 7, Electrical and Instrumentation Issues, Category 3, requested that the Gibbs & Hill analysis
  ]
i               supporting the one inch separation distance be submitted for NRC review in sufficient detail to permit an independent evaluation of the establishment of f
i               this criterion.
Staff Comments
   ]
4
  .I                Since this ISAP commits to compilation, review, and approval of the applicable I                documentation to support the one inch minimum separation distance between 4               rigid conduits and open cable trays, and submittal of this material for NRC independent review, th.is ISAP is responsive to concerns raised by the staff.
j               The plan is therefore, acceptable. Final resolution of this issue, however, is i               contingent on the staff review and acceptance of the engineering justification j               analysis. In the event the justification is found not acceptable, the ISAP l               will have to be expanded to cover conduit and cable tray modifications committed to in Section 4.6 of this plan.
  ] i I
I.b.4 Barrier Removal
  ] !
]
Description ll As noted in SSER No. 7, Electrical and Instrumentation, Category 3, the
'}                   TRT inspection of auxiliary feedwater panel CP1- Q +ACB-09, found two barriers
    ;                used to separate redundant devices and cab 1-4 :Isri g. Within panel CP1-EC-PRCB-03, field wiring was not separntd op ce minimum separation distance of 6 inches.
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9 03/31/86                                         B-7                         CP SSER 13 APP.B
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Staff Comments Since this ISAP commits to correction of two identified separation violations, it is responsive to concerns raised by the staff for main control room panels.
To assure that existing separatio.: violations have been detected in a timely
  '                        manner, the physickl inspection portion of the ISAP should be expanded to include the cable spreading room termination cabinets and safety-related instrument racks located throughout the plant.      In addition, Section 4.5 of the plan is not acceptable. The applicant should explain what is meant by meeting "the intent" of IEEE-384 and Regulatory Guide 1.75 requirements, and why this is acceptable. In the absence of an adequate explanation, the applicant should commit to " meet" the requirements of the above documents.
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Testina Issues III.a.1 Hot Functional Testing
,                 Revision'3 of this ISAP has not been provided by the applicant.
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Mechanical and Pipina Issues j                 V.a   Inspection of Certain Types of Skewed Welds in NF Supports 1                                                                    .
Description s
This ISAP addresses actions required by SSER No. 10, Mechanical and Piping *
    .J                Category 3, allegation AQW-73, concerning the failure of TUEC to provide documentation that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., interfaces of curved 4                sections).
j                Staff Comments
'j' The staff conducted an evaluation of the CPRT Program Plan for ISAP V.a and f
j               found the action plan to be generally responsive to the issues raised since the plan addressed inspection methods, procedure revisions, and reinspections.
The staff, however, requires assurance that the root cause of the issue and its generic implications are properly addressed, independent of whether any safety significiant deficiencies are found. The staff perceives the root cause and generic implication aspect of this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC, thus suggesting potential generic implications.
i{                    In addition, the response by the CPRT to Item 1 of the staff letter of
'l                    September 30, 1985 concerning ISAP V.a requires further explanation concerning
!l                    the intent of procedure QI-QAP-11.1-28 with respect to the inspection of l               skewed welds.
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                                                                                                     , _ .         n, V. b Improper Shortening of Anchor Bolts in Steam Generator (SG) Upper Lateral Supports Description i
u 4                      This ISAP addresses actions required by SSER No. 10, Mechanical and Piping a                                                                                                              -
Category 18, allegations A8-12 and AQB-3, concerning anchor bolts in the steam generator upper lateral support that may have been shortened during instal-
:4 $                     lation without proper authorization to less than the length shown on the design drawings. TUEC performed reinspection of the anchor bolts and determined that j  1 insufficient thread engagement existed in specific locations.
Staff Comments The staff concludes that if ISAP V.b is implemented as stated in the Plan, the areas related to the original. concern can be identified and resolved based on sound engineering practice, FSAR commitments and NRC guidelines. However, the l
staff has raised a concern that the use of trends of inspection data to deter-j eine the need for additional inspections must be reviewed on a case-by-case basis rather than collectively in order to determine if the trends require additional inspections.
V. d Plug Welds i                     Description
' e.
ThisISAPaddressesactionsrequiredbySSERNo.10,ykchanicalandPiping t
,{                         category 4, allegation AW-14, concerning incorrectly located bolt holes in baseplates, pipe supports, and cable tray supports that were " plug welded" without authorization, with undocumented weld filler metal and without quality l
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l:                          control inspection.
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Staff Comments
     <'                        Based on its evaluation of ISAP V.d, the staff concluded that the ISAP
   >                           was unacceptable. The staff found that the proposed combination of third-3 party overview of TUEC engineering evaluation of uncontrolled plug welds j                          identified during the inspections would not provide reasonable assurance that i                            the structural adequacy of CPSES pipe supports, baseplates and cable tray l                            supports would not be compromised by uncontrolled plug welds. This is based l                           upon the fact that the proposed inspection technique was not fully effective and consequently, the confidence level achievable by the may be considerably less than the desired 95/5 level.
1 i
l  1 The staff suggests that bounding analyses may be required to assess the                            -
               ~
generic effects of uncontrolled plug welds on the ability of pipe supports, l                                                                                                                                ,
j            .             baseplates and cable tray supports to serve their intended function as l                         stated in SSER No. 10.-
i j                         V.e Repositioning of the Main Steam Line
  'i                       ..
Description This ISAP addresses actions required by SSER No. 10, Mechanical and Piping Category 11, allegation AP-13, concerning the 32-inch main steam line that may
     ?.                        have been forced into position by the polar crane and 3-ton come-alongs.
 ,;                            Tension induced in the line as a result of movement during the alleged incident tj                           may still be present in the line.
il
,i                              Staff Comments i'                              For the repositioning of the main steam line, the specific engineering evaluation
* and generic study described in this ISAP provides an acceptable basis for resolution of the issues and concerns resulting from the TRT
!     i l
03/31/86                                                  B-12                      CP SSER 13 APP.B l
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investigations of allegations regarding forced movement of the main steam line and improper welding of temporary supports.
  '1 However, the staff has concerns that:
(1) The. third perty review of the RCLA work should not be limited to a
'[                                           verification only.          Provisions for additional third party investigations should be provided, particularly since RCLA participation has ended.
-j (2). Although the CPRT has indicated that its investigation performed as part of ISAP V.e. , Revision 3, have concluded that the sequence of events described in SSER No. 10 relating to main steam line incident is not y                                            correct, the generic implications of settlements of supports and stresses l                                      due to hydrostatic testing and flushing activities will still be required.
i
;]                                           to be evaluated by TUEC, since the sequence of events described by the i                                       TRT could have occurred elsewhere.
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03/31/86                                               B-13                       CP SSER 13 APP.B
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s Civil / Structural Issues I.c ' Electrical Conduit Supp. orts Description s
  .                     This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 14, allegation AE-17, on the installation of nonsafety-related conduit
  ')                     supports for conduit two inches in diameter or less in seismic Category I areas of the plant. No evidence could be found by the TRT that substantiated the adequacy of the installation, or in demonstrating that their failure would not adversely affect the function of safety-related components or cause injury to plant personnel.
j                    Staff Comments
  '!                     The general scope and methoodology contained in this ISAP is responsive to I                   concerns raised by the staff. However, in clarifying the disposition of rejects identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is nade in Sections 4.1.2.1 and
                        -Section 4.1.2.5 of ISAP I.c. The intent of this statement relative to sample expansion and compliance with Appendix D of the Plan is unclear.
Clarification and/or justification of the statement in Section 4.1.2.1 and 4.1.2.5 is needed.
t i                    II.a Reinforcing Steel in the Reactor Cavity l
p j                     Description
     ?
This ISAP addresses actions required by SSER No. 8, Civil and Structural f,                   Category 6", allegation AC-38, on a documented occurrence in which reinforcing
     !                    steel was omitted from a Unit 1 reactor cavity concrete placement between the
-                         812-foot and 819-foot-1/2-inch elevations. Although the omission was j                         documented, justification supporting the engineering conclusion to "use as is"
'I                        was not available.
03/31/86                                 B-14                                       CP SSER 13 APP.B LL_                      -         -. _ .. _. _ _ _ _ _.        -

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Staff Comments                                                              ,
i                    The general scope and methodology contained in this ISAP is responsive to the
    ' t ._
concerns raised by the staff. However, the plan should address the corrective actions to be taken if some structural members are deficient when reinforcing j                       steel was omitted. Furthermore, the logic diagram in the attachment to the 1                         ISAP is incorrect. The second vertical branch at the left and the s-shaped branch near the upper right hand corner should be deleted.
II.c Maintenance of Air Gap Between Concrete Structure
    .l j                     Description                                     -
l This ISAP addresses actions required by SSER No. 8, Miscellaneous Category 2, where the TRT identified TUEC's lack of control of debris in critical spacings i                    between components and/or structures. TUEC had not adequately demonstrated f                    compliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which required separation of Seismic Category I buildings to prevent interaction during an earthquake.                             -
   .i                         Staff Comments The action plan is responsive to concerns raised by the staff. However, the
  ]} j                        flow diagram given in the ISAP should be clarified. There is no indication jl-                           where ites'A, profile of as-built condition for selected rotofoam form work l !-                          areas and for selected metal form work areas, and the staff does not 11 j                             understand designation C.
1 II.e Rebar in the Fuel-Handling Building
{
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i Description l                    This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 15, allegation AC-15, of an alleged instance of unauthorized 03/31/86                                     8-15                     CP SSER 13 APP.B m Tmmuse mnerw .. .                        m  m;vny:w.anecxes;-       :e 3  ----
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:i' cutting or rebar in the Fuel-Handling Building due to the depth of core j                      drilling.
z Staff Comments
  'l j-                      The approach described in this ISAP is responsive to concerns raised by the
   ')                     staff. However, the plan should address corrective actions to be taken if cut n
   .'                     rebar produces an unacceptable structural member. Furthermore, the logic diagram given in the ISAP is incorrect, in that there are no arrows connected to the lower right-hand box.
i
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i 03/31/86                                  B-16                                 CP SSER 13 APP.B
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Quality Assurance / Quality Control Issues I.d.3   Craft Personnel Training Description i,
j                        The objective of this ISAP is to responc to NRC concerns in SSER No. 7, j
 .i Electrical and Instrumentation Category 2, by evaluating the Craft Training Program to determine if it was adequate in the past, and also to evaluate the current program.
The requirements of ANSI N45.2-1971 set forth, in part, that personnel performing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. To determine l
that these requirements are implemented, this ISAP has formulated a Special
    '                      Evaluation Team (SET)," comprised of individuals with no direct responsibility
 .i to CPSES, who will perform the evaluation of the Craft Training Program
      -                    including the craft personnel selection, training, assignment and retraining.
l
!                          Staff Comments The staff finds that the ISAP adequately addresses the NRC's
!                          concern pertaining to craft training, and implementation of the plan will i
determine compliance with FSAR commitments. The CPRT approach will provide a
    ,!                     broad-scope in-depth evaluation of the essential elements of the training
   *                 . program and will determine the effectiveness of both past and current training 4
and its impact on the construction of the physical plant, and compliance with ANSI N45.2.6 and 10 CFR 50, Appendix B, Criterion II, as committed to in the FSAR. Accordingly, the staff concludes that this ISAP is acceptable.
    !                       However, Section 4.4 of this ISAP must be revised to comply with the Program
                                       ~
Plan, Attachment 3 in order to maintain consistency. During implementation of i
the plan, the staff will confirm that the revision has been accomplished.
I                                                .
4 03/31/86                                  B-17                         CP SSER 13 APP.B i_._.~,.-_..__                                . _ _ _ _ _ _           ___                   _            , . _ . . , _ . , , _ , _

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i VII.a.3 " Document Control i
8                   Description Problems as noted in SSER No. 11, Section 4.2 titled " Document Control" were identified over a period of time in the implementation of the Document Control f                     Program during the construction phase of CPSES. The scope of this ISAP is to provide confidence that the Document Control Program problems did not impact the installation and testing of hardware and that current design requirements are I                     satisfied. The concerns identified in this Plan are addressed by review and evaluation of the results of the implementation of ISAP III.d "Preoperational
}                    Testing" and ISAP VII.c " Construction Reinspection / Documentation Review Plan" to determine if deficiencies identified under those plans are attributable to
]          ,
]                     Document Control problems. Implementation of the action plans requires i           .
: i.                   verification that the latest design information (e.g., drawings, design change
: j.                  authorizations and component modification cards) is used in the preparation of
 !                    checklists used in the reinspections and documentation reviews. Program and procedures will be evaluated for adequacy against the applicable sections of
                    " the FSAR and 10 CFR 50 Appendix B Criterion VI.
  .                    Staff Comments The methodology of the Action Plan along with other actions plans adequately j
addresses the NRC's concerns regarding document control. However, Section 4.4 l
of this ISAP must be revised to comply with the Program Plan, Attachment 3 in l                    order to maintain consistency. During implementation of the Plan the staff will confirm that the revision has been accomplished.
I VII.a.4 Audit Program and Auditor Qualification j                    Description i
This ISAP addresses the NRC's concern in SSER No. 11, QA/QC Section P,
  !                    Subsection 4.7, regarding the adequacy of the TUGC0 Audit Program from its inception to the present and will evaluate the program to determine the effect f                   of any identified inadequacies on the Quality Assurance Program and/or the 03/31/86                                   8-18                        CP SSER 13 APP.B
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physical plant, and to recommend appropriate corrections and/or improvements                     !
1
     !                    to the current program. This evaluation will be' accomplished through a review which will address audit planning and scheduling, preparation, performance,
   ,                      reporting, followup and closecut, and audit personnel qualification.
4-l                    Staff Comments l
l                      Since FSAR commitments are identified in the plan, and that implementation of 1
the plan will cover sufficient scope and depth to determine compliance with
  ]
j                       those commitments and any resultant impact on construction quality, the staff
  ;l,               -     concludes that this ISAP is acceptable. However, Section 4.4 of this ISAP must j                    be revised to comply with the Program Plan, Attachment 3 in order to maintain 1                       consistency. During implementation of the plan, the staff will confirm that I
the revision has been accomplished, and the staff will also confirm that the l
     ;                    CPRT's evaluations have considered all revisions of the PSAR/FSAR and the
     !                    TUGC0 QA Audit Program and Procedures.
I I
  .l                      VII.a.5 Management Assessment Description f                    This plan addresses the NRC's concern in SSER No. II, QA/QC Section P, l                        Subsection 4.7, regarding the TUGC0 management assessment of the effectiveness
   ;                       of implementation of their QA Program during construction of CPSES. The issue                ,
arose because of TUGCO's failure to implement periodic management review of QA 1
Programs in compliance with 10 CFR 50, Appendix B, Criterion II, QA Program, l
     '                     which states in part: The applicant shall regularly review the status and adequacy of the Quality Assurance Program.
!!                         Staff Comments
;l l                     The staff finds that this plan is responsive to the action identified by the NRC, which requested that the applicant propose an action plan that will ensure i
j                     that such problems a lack of a management assessment program, do not occur in f
i i
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the future. The plan methodology adequately describes a viable approach to establishing a management review program. With regard to additional action
       !                 identified by the N'RC that the applicant evaluate the TRT's findings and address potential safety significance, root cause, generic implications and a
   .j -                  collective significance, this plan states that these factors are addressed in 1                    other hardware and programmatic ISAPs and the self-initiated ISAP VII.c. The staff finds that this is a satisfactory response to the action identified.
f
  'l                     Based on this evaluation, and the plan's determination of compliance with 1
  -'                     10 CFR 50, Appendix B, Criterion II, the staff concludes that this ISAP is acceptable. However, Section 4.4.1 of this ISAP must be revised to comply
   .i j                     with the Program Plan, Attachment 3 in order to maintain consistency. During l                  implementation of the plan, the staff will confirm that the revision has been accomplished.
   ]
ti
      !                  VII.a.6 Exit Interviews Description The actions required by SSER No. 11, QA/QC Category 7, allegation AQ-133, to determine if TUGC0 management has now established an effective program which i
encourages employees to voice concerns regarding safety and which seriously evaluates these concerns.
i f
i                   Staff Comments t
      '                   The staff notes that there is no regulatory position that requires the 1
'f                        applicant to have a formal exit interview program; therefore, there is no
't 1
standard to enable a comparison of the applicants program for compliance.
l>                        However, the staff has determined that proper implementation of this plan should establish adequate measures to address and resolve employees' concerns
:1                        and to identify quality and safety implications. However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
1
      ?
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VII.a.7 Housekeeping System Cleanliness Description The actions required by SSER 11, QA/QC Category SC, allegation AQ-54, pertaining
 ]                            to housekeeping and system cleanliness to determine the validity of the
 }-                           current housekeeping system and system cleanliness program for Units 1 and 2.
1 Results of other action plans, procedural requirements, surveys, etc., will be
~
analyzed to determine any impact on hardware and programmatic implications.
Staff Comments The staff has determined that the housekeeping and cleanliness concern is adequately addressed and that proper implementation of the plan should resolve the issue and determine compliance with the FSAR. However, Section 4.4 of the
   !                           Action Plan must be re~ vised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
LI VII.a.8 Fuel Pool Liner Documentation Description l
The actions required by SSER No. 11, QA/QC Category 6, Allegations AQ-55 and f                             AQ-78, regarding the applicants' inability to maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and
.,                              inspection and pertains principally to operations travelers and related
]                               documentation.
I                             Staff Comments
  }
The staff concludes that this plan is acceptable, since proper implementation j                             of the plan should resolve the issue and that appropriate criteria are used to j                             determine compliance with 10 CFR 50 Appendix B even though these criteria are not an FSAR commitment, 03/31/86                                 B-21                        CP SSER 13 APP.B A*                   w
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However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency.
i VII.b.1 Onsite Fabrication
   )                     Description 1
j                     This ISAP addresses the actions required by SSER No. II, QA/QC Category 58, I
j                    allegations AQ-17, AQ-19 and AQ-138, to resolve the NRC's concern regarding
   ,i                    the procedural and management control of the fabrication shop work activities at CPSES.
3 Staff Comments The staff determined that proper implementation of the plan should adequately resolve the issue and iletermine FSAR compliance. However, Sections 4.3. , 4.4
;l                       and 4.5 of the Action Plan must be revised to comply'with the Program Plan, ll                       Appendix E, and Attachment 3, respectively, in order to maintain consistency.
: l,                                              ,
VII.b.2 Valve Disassembly
't
:l                       Description lf!;
The actions required by SS$R No. 11, QA/QC Category SA, allegation AQ-52, to i
resolve the concern regarding valve assembly / disassembly and determine the adequacy of procedures that controlled the disassembly / reassembly process.
Staff Comments i
f                    The staff has determined that proper implementation of the Plan's methodology should resolve the issues, however, the Plan must contain provisions to inspect I                     for the interchange of critical valve external parts (e.g., bonnets) as well as i
internal parts. Additionally, Sections 4.2 and 4.6 of the Action Plan must be revised to comply with.the Program Plan Attachment 3 in order to maintain f                     consistency.
03/31/86                                 B-22                          CP SSER 13 APP.B
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VII.b.3 Pipe Support Inspections Description r
This ISAP addresses'the actions required by SSER No. 11, QA/QC Category 8, allegation AQ-50 regarding the adequacy of QC as-buil,t inspections of pipe supports.
r                          Staff Comments The staff has determined that the NRC's concern is correctly identified and that proper implementation of the Plan should adequately resolve the issue. The staff finds, however, that although the Plan contains sufficient information to determine acceptability /non-acceptability of the items 1                          reinspected, the Plan lacks identification of the Codes / Standards and FSAR commitment which are used as comparisons to resolve the issue (e.g.,
  }
  !!                         inadequacy of QC inspections) and to determine compliance. Accordingly, 3
1 Section 4.5 of the Action Plan must be revised to comply with the Program Plan
'd                           Attachment 3 in the identification of Standards / Acceptance criteria in order to maintain consistency.
L j                            VII.b.4 Hilti Anchor Bolt Inspections Description u
                       -     This ISAP addresses the NRC's concern in SSER No.11, QA/QC Category
  ];                         8, allegation AQ-50, regarding Hilti anchor bolt installation on pipe supports y
and electrical raceway supports. The objective of this Action Plan is to assure the construction quality with respect to Hilti anchor bolt installation.
}
Implications resulting from the TRT findings will be resolved by reinspection for safety-significant attributes of Hilti bolts.
Staff Comments t
l The staff found that applicants correctly identified the issue and the Plan's
     }                        methodology is adequately descriptive of the activity that is essential to i
03/31/86                                  B-23                            CP SSER 13 APP.B t!
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evaluation and resolution of the issue. The percentage of torque used in the 1
torque verification program is an issue of concern that will be subject to
             ~
staff review during implementation. Accordingly, the staff concludes that this ISAP is acceptable. However, of the Action Plan Section 4.6 does accurately 4                             identify the, type of document from which the acceptance criteria will te derived.
1                            Those specific documents, of necessity, were used to establish the inspection i
i attributes. Therefore, discrete identification is known. .Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 of this ISAP has been revised to comply with the Program Plan, Attachment 3 in order to main-tain consistency.
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Document Naine: -
l CP SSER 13 APP. C Requestor's ID:
ORDAZ                                              -
Author's Name:
Trammell 1
Document Comments:
April 1, 1986
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 .;                   Appendix C      PROGRApWATIC CONCERNS                                   .
N Description of Concern i                     The evaluation process defined in Appendix E does not provid'e sufficient i                     detail on safety-significant evaluation. This concern is primarily related to d                      the fact that safety-significant evaluations of discrepancies are currently underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern in the DAP are piping and cable trays
      '                andtheirsupports.) Until this revised information becomes available as
                       " plant record documentation" then the safety-significance evaluation process        -
]                      cannot be completed. Any evaluations made _using existing documentation must be revisited when the new documentation becomes available. The major reason
][
;j                     for this is that TUGC0 h,,as elected to perform extensive reanalysis of piping,
;i                     cable trays and their supports which could result in hardware modification j                related to optimization or deficiencies or, different design documents and values which form the basis for the safety-significant evaluation. Based on
!}
this, the staff feels that safety-significant evaluation and the potential for scope expansion must be based on final plant documentation. This position does
;i                     not preclude the fact that existing issues which led to the current reanalysis l                      of piping and cable trays must be evaluated for root cause and generic implication to assure that programatic deficiencies do not extend beyond the I                boundaries covered by the reanalysis efforts.
l'                     Action Required l
The CPRT must provide procedural direction or instruction to ensure that
      .                 safety-significant evaluation of discrepancies related to the self-initiated design or construction program and the potential for scope expansion must include evaluation using final plant documentation. This does not preclude the fact that existing issues must be evaluated for f
j                 root cause and generic implication. During implementation the staff will confirm that this action has been accomplished.
04/08/86                              C-1                  CP SSER 13 APP. C ts h'Wt%1saact* yew %eo.mmuan tk@wwrraa. u.mm on nw                              -m=     -
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      .-                  Description of Concern                                                      ,
This concern is related to the fact that safety-significant evaluations must be perfomed using Code or Regulatory approaches. That is, the techniques used and the extent of the evaluation must address each criterion p                       which formed the basis for the original design. For. example, the use of j                       actual material properties versus Code defined material properties could be acceptable but does not preclude the fact that all evaluations connitted to in 1                       the FSAR must be addressed in order to establish margins on all segments of the acceptance criteria. Actual material properties (if higher than Code j        '
minimums) may be of value in evaluating primary stresses and functionality but.       ,
     !                    do little to change the fatigue margin. This concern is not limited to Design.
q'
  ,                       discrepancies but includes Construction discrepancies for which safety-j                       significance is detemined through the use of Design evaluations.
Action Required i
u                       The CPRT must provide procedural direction or instruction to ensure that the techniques used and the extent of the evaluation addressees each criterion which formed the basis for the original design. During implementation the staff will confirm that this action has been accomplished.
Description of Concern
  .)                      There is a lack of discussion in the Plan on the approach to be used in root
]                         cause and generic implication detemination. In order to understand any CPRT proposed evaluation, the Plan needs to define the terms " root cause" and
,                         " generic implication." This is critical, since the depth and breadth of the
!                         root cause evaluation will be a function of the CPRT understanding of these l                         terms. The staff anticipates that the CPRT will consider the following, as a
]                         minimum, in determining the root cause of deficiencies:
9 04/08/86                                           C-2              CP SSER 13 APP. C
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Design (as it effects construction)
  <                        Materials Management Action Required The Program Plan must be revised to provide those definitions or the CPRT
>                   shall issue procedural direction / instruction to ensure that persons performing these evaluations have comonality in their understanding of the factors that "
affect the determinations. During implementation the staff will confirm that '
this action has been accomplished.
l Description of Concern f
Another area of staff" concern is related to Adverse Trending. The discussion in Appendix E is general in nature and uses;a set of examples to' define the process by which a set of items could create a pattern for concern. The examples given are related to a design process. The approach used by the CPRT is to evaluate HDAs rather than to review the design process. The concern is that j                evaluation of HDAs may not provide the appropriate information for trending as defined in Appendix E.
J.
1 Action Required j                The Program Plan must provide that the design process as well as Homogenous Design Activities will be reviewed to determine an adverse trend. During
{
implementation the staff will confirm that this action has been accomplished.
i 04/08/86                                  C-3                   CP SSER 13 APP. C m .m .m&             .~         _   _ _ _ . ,_.                ,,_,_m,..      . ,.m , . . _ ,_.m _,,,.,,

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Description of Concern 3                                                                                       -
Revision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirmation of implementation and responsibilities of the CPRT and the CPSES Project. The only major' j  .!
comunent the staff has is related to the timing of SRT approval of CPRT RTL determination of the adequacy of correction actions defined by the CPSES 1                  Project. Appendix H provides two alternatives, 4
4 approval on an ongoing basis as corrective actions are developed, or.
9 approval as part of the Action Plan Results Report approval process.
q                   The staff feels that the SRT should approve or disapprove corrective actions d                   on an ongoing basis as they are developed. This action should follow that of
;i the CPRT RTL. It is feTt that this would keep the SRT more in line with CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES project involved in lengthy discussions when the RTL does not agree with the proposed corrective action.
Action Required Appendix H must be revised to state clearly that the SRT will review and approve / disapprove all corrective actions on an ongoing basis, subsequent to
         .          approval by the CPRT-RTLS. During implementation' the staff will confirm that N                   this action has been accomplished.
d
:1
;j                  Descripticr. of Concern ii i.
The staff is concerned with a number of observations concerning interfaces as t
follows:
.t The definition of interfaces provided in Appendix F establishes measures fo/
I                the identification and control of design and construction interfaces and for
!!                   coordination among the CPRT participant organizations. The availability of matrices will provide each affected organization the specific areas and items
     ,               04/08/86                                 C-4                CP SSER 13 APP. C i.
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.l                     of information that must be executed and controlled. There are a number.of
 '                     areas where, interface between various CPRT organizations and CPSES Project organizations is defined. In some cases, the interface appears to be dupli-J                      cative and prime responsibility is not defined. It is important that prime responsibility for interface control be defined to assure that involved organi-9                      zations understand who is responsible for establishing, executing and controlling 1                     the interface. The following are staff observations on the individual matrices provided in Appendix F.
j                      1. QA/QC-RTL and RTL to Unit 1 and Unit 2 Assistant Project General Managers 4      .                      (APGMs). Responsibility for 50.55(e) reportability is assigned to the                           -
l      .                   TUGC0 Project per Appendix H of the Plan.                                                         -
l           .
.;                     2. DAP-RTL to SWEC. Infonnation on root-cause analyses, generic implications,
  ; -                         Evaluation Reports and Results Reports is provided to SWEC for "Information" when pertaining to the SWEC scope. Since this infonnation could impact j-                    ,
the SWEC analysis effort, it should be provided for " Action by SWEC."
Since DAP is auditing SWEC activity, this matrix should address those l
l items associated with that effort, including Corrective Action.
: 3. DAP-RTL to Other Design Organizations. Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports j                           should be provided for " Action" to EBASCO and Impe11, who are reanalyzing j                             cable trays and supports. The CPRT may find it more appropriate to i                           develop a separate matrix for the cable tray and support effort activities of EBASCO and Impell.
l;
: 4. RTLs to CPSES Project. Action Plans are designated as both " Info" and
                              " Action" by Project. It is the staff's understanding that Action Plans are provided to the CPSES Project for information only.
l i
   !                   5. SWEC to Interfacing Organizations. Design- and construction-related concerns found during walkdown and document reviews should require action by DAP and QOC RTLs. That action should include evaluation of the i
(                   04/08/86                                                C-5                     CP SSER 13 APP. C i
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  !                         deviation in the same manner as if it were discovered as part .of the CPRT i                          self-initiated program. - Loading from the piping system should be provided 'to Q0C through the DAP since this infomation may be needed for safety-significance evaluation.
{                    6. Interface details (or matrices) could not be found for the interface 1,
activities between Other Design Organizations and DAP-RTL and EBASC0/-
f                          Impe11 and Interfacing Organizations, j                     Action Required 1
I       .
j'                  The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT.
l                   activities provided the concerns are satisfactorily resolved as follows:
j                   (1) Define the organization with prime responsibility for duplicative interfaces.
    -                 (2) Information on root-cause analyses, generic implications. Evaluation Reports and Results Reports should be provided to SWEC, EBASCO and Impe11 since it could impact their reanalysis effort.
3 (3) Design- and construction-related concerns found during SWEC, E8ASCO or i                           Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action."
t 1
j                     (4) Loading from the piping system to equipment, structures, penetrations, j                           etc., should be provided to QOC through the DAP for use in safety-signficant evaluations.
W
[                     (5) Interface details (or matrices) should be provided for Other Design
]                           Organizations and DAP-RTL and for EBASC0/Impell and Interfacing i                          Organizations.
l 04/08/86                                  C-6                  CP SSER 13 APP. C i
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(6) The CPRT auditing of SWEC activities involves interfaces whicit should be defined.
(7) Define more clearly CPSES project responsibility for action plans and 50.55(e) reportability.
k The concerns related to 50.55(e) and to Action Plan responsibility in the RTL to CPSES Project Matrix are editorial in nature and can be confirmed during the implementation phase of the plan. Additionally, during implementation the staff will confirm that the other above noted actions have been accomplished.
                                                                                                               ~
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1 j                      DSAP VIII CPRT Overview il Description of Concern                                                    ,
In order for TERA to perfo m an integrated review of major concrete and' steel structures in a manner consistent with their comitments referenced in the NRCOfficeofInspectionandEnforcement(IE)InspectionReport 50-445/85-17 and 50-446/85-14, Appendix 2, page A-4, unique loading deteminations must be
   <                   performed for the' referenced buildings (i.e., auxiliary building, fuel storage building,containmentbuildingandotherportionsofselectedbuildings). DSAP VIII, Section 4.3.2.1, Load Determination, indicates that only the auxiliary /
electrical buildings will be reviewed. This is inconsistent with TERA's comi -
q ment and in fact precludes the perfomance of a thorough review.
i l                  Action Required
    +
TERA should review other buildings than those listed in DSAP VIII, Section 4.3.2.1 Load Detemination.
Description of Concern Themal Loadings or expansion considerations must be considered in the
    !                   evaluation of the reactor building internal structure since this is a I       .           fundamental design consideration (e.g., to mitigate the effects of themal expansion). DSAP VIII Section 4.3.2.1, does not address thermal considerations and should be revised accordingly.
t Action Required f
DSAP VIII, Section 4.3.2.1 should be revised to include thermal load j                    considerations for reactor building internal structure.
3 l
04/08/86                              C-8                   CP SSER 13 APP. C cr 7mwangren                             ,.w e y: m . < y ,v          .gy-7:cr;t,pw;,;p3 ,;rz:; 7.n

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s
* i Description of Concern                                                           ,
The NRC inspection report (Appendix 7, item 4, page A-216) discusses embedment load tracking. The TERA response indicates that final design loads will be j                   coordinated with the civil / structural discipline (e.g., to confirm that building designs are consistent with the final design loads). Section 4.3.2.1 of DSAP VIII doesn't discuss this and should be revised accordingly.
Action Required DSAP VIII, Section 4.3.2.1 should be revised to address how original building .
          ~
design loads are reconciled with the final design loads.                                        ,
i 6.
4 e
i i
l l
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04/08/86                                 C-9                             CP SSER 13 APP. C
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j   q DSAP VIII - Civil / Structural. Including Cable Tray / Conduit Supports e
1 Description of Concern i
The testing program may generate design and acceptance criteria which do not comply with FSAR commitments.
Action Required If the FSAR couaitments are not met, the proposed acceptance criteria must be t                 identified for approval by the staff prior to implementation.                            -
1      .
Description of Concern
                                                  ~
Inconsistencies exist between the DAP, DSAP VIII and Impell-Ebasco project l                 instructions. The inconsistencies involve the statements describing the
    !                  methodologies that may be used to evaluate the cable tray support. In the DAP l                  it is stated that the established Ebasco methodologies will be used while the
  -l                   DSAP allows the use of'Impell and Ebasco design procedures. Further ir, the j                  DSAP it is stated that only two methods of. dynamic analysis will be used in j                 analysis design verification of cable tray supports. The Impell project j                 instructions, however, permit the use of time history methods, overlap methods
     ;                 and multi-level response spectrum methods in addition to the two methods ll
           .           referred to in the DSAP.
.4 Action Required lI II                     During implementation the staff will confirm that these inconsistencies be
    },
resolved and the appropriateness o'f the above methodology demonstrated to the staff.
!!                                                                                                            s j                  Description of Concern
,!                     The staff is concerned with the lack of prescriptiveness of review checklists
     !                 used for the third part review. In general, the checklists define the review l
1
;                      D4/08/86                                    C-10                      CP SSER 13 APP. C l
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                                 .  *[* ^
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I scope by listing criteria and commitments for which the implementation will be verified in the review, but do not indicate the design considerations which p                     must be accounted for in verifying that the 'connitments were net.
Action Required                     ,
The checklists need to be more prescriptive with respect to all design criteria to be met.
I                    Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection Report Nos. 50-445/85-17,50-446/85-14 indicates areas in which specific review
           ',          checklists need to be expanded or clarified with respect to subject content.             ,
1            .
Description of Concern      ,,
5 i -
   !                   The staff evaluation of the third-party activities for the review of project               i 1
activities and corrective actions is based on audits performed at the offices l
f the CPRT third-party (TERA).                   .
1
='                      At the time of this audit Revision 3 of the Program Plan had not yet been
't
:!                       issued. Revision 2 of the Program Plan was not definitive in stating the i
a                       third-party activities for the cable tray / conduit program. This' program was f'
* undergoing a major rewrite which now clearly defines the role of the third party.                                                                                   ,
1 9
* Action Required i!
:                        The staff generally agrees with the Program Plan with respect to the
                                                                 ~
ll                       third-party activities in the cable tray / conduit area; however, a complete evaluation will be made after the staff completes its audit of the details of the third party review of the project actions.
'I J
J 04/08/86                                  C-11                     CP SSER 13 APP. C
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ll il                  Description of Concern                                                  ,
f The staff review of the validity of identified HDAs and design activities not enveloped by the HDAs identified a concern with the HDA criteria for homogeneity.
4 HDAs are required to have common design or analysis approach / methodology or mechanics in design implementation such that meaningfully different complexities or considerations are not contained within that design activity.
                                      ~
However. TERA had not obtained fomal documentation pertinent to the Gibbs and lj                                                                                                      -
ll        .
Hill design / analysis methodology and approach. Such documentation
    /               (instructions and procedures) is norina11y utilized to establish design process.
control and thereby establish uniformity of technical approach in the
 '!                 execution of engineering. for a project.
 .r                                                                                                       ;
i The Civil / Structural Phase 3 Scope Validation document, including the HDAs
;[
j                   identified within, is based on such items as the plant engineering documents available at Gibbs and, Hill, TERA interviews.with project personnel, and the j                    engineering experience of TERA personnel in nuclear power plant design.
l
;j                   A review checklist DAP-E-PM-001, dated October 27, 1985 states that, on a jl                    progransnatic level (1) organizational and design control process changes i
ll                   within Gibbs and Hill have not affected the identified HDAs and (2) there have been no changes to design methodology over time at Gibbs and Hill such as to l
:i                    affect the the identified HDAs. These TERA conclusions are based on l                discussions with Gibbs and Hill rather than review of design control
:l                   procedures, design methodology, etc.                                                ,
TERA apparently recognizes that other homogeneous design activities (HDAs) may exist and that some currently so defined may in fact not be homogeneous since
:l
!!                    it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Phase 3 Scope i                Validation, Civil / Structural",that in the review effort there will remain an open, "... search for substantive differences in criteria category, design
     }
considerations, approach, or methodology in the design process."
C-12                   CP SSER 13 APP. C 04/08/86 w mem- m                   m       om m.mm                    m     --
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q                The team identified potential HDAs not identified by TERA, such as ,the design of the annualar structural steel normally inside the containment, the l{
j '
auxiliary buf1 ding structural steel, foundation overturning design, the design of walls for tornado missiles and the effect of Category II buildings on.
y                Category I buildings.
Due to the above uncertainty as to documented design methodology, there is a
(                related question on sample sizes. In the area of concrete design. TERA has indicated that for the auxiliary building and the fuel building a total of 0                five (5) slab and five (5) wall calculations will be selected at random for l
design review. Then another set of ten (10) calculations will be selected              .
either randomly or based on any findings from the previous ten (10). Such a             .
j              sample may not be valid if all these calculations were by one individual, if therewerefifteen(15)individualsdoingindependentdesignsforslabsand 4
walls without any design process / methodology guidance beyond the FSAR criteria. If there were no controls within the Gibbs and Hill organization, for establishing homogeneity in design approach and methodology, one must compare individual engineers and designers completing similar tas"ks. For t'his                   <
situation, the actual homogeneity that exists can apparently only be jl               established as the design review progresses.
To the degree that TERA relies on HDA populations as the basis for review l
sample selection, the staff plans to evaluate whether the review sample is l
representative of the design process for that population and whether the l                population is homogeneous.
i l              Action Required i
The staff generally agreed with the third-party conclusions that certain checklists adequately cover HDAs. Exceptions to this are addressed in detail                     :
l                 in Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection                   l 1
i              Report Nos. 50-445/85-17,50-446/85-14 which was transmitted to the Applicant in a letter from J. M. Taylor to.W. G. Counsil dated January 21, 1986. Staff j              approval of the CPRT Program Plan is contingent upon acceptable resolution of the staff concerns and staff consents on the review checklists provided in the IE Inspection Reports.
04/08/86                                 C-13                CP SSER 13 APP. C i
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DSAP IX - Staff Coment (Third-Party Review)                               .
The staff requires the following items to be adequately coinpleted in order to determine the acceptability of the piping and supports discipline specific t                  action plan related to the third-party (TERA) actions:
Description of Concern 4
It was not evident that a process existed for identifying discrepancies (or deviatio%in external source issues by SWEC in view of the fact that hardware
          .        modifications may be made to piping and supports irrespective of the corrective actions required for safety-significant problems.
li                  Action Required
 !!                 A root cause/ generic implication evaluation should be performed for all hard-ware modifications in order to document the reasons for such modifications.
Description of Concern
  ] 1 In the staff review of the checklists to be used by the third-party (TERA) in their overview of the SWEC piping and supports program, only one of three checklists were ccupleted.
Action Required I
:)
{
Provide the checklists to be used for the overview of the SWEC piping analysis      l i
implementation and pipe support design implementation.
J                                                                                                     i
{
i
!                    Description of Concern                           -
l l
The staff review of the third-party overview of the SWEC construction /as-built program found that no third-party procedures were available at the time of the j                staff audit.
i C-14                 CP SSER 13 APP. C 04/08/86
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Provide the procedure to be used for the third-party overview of the SWEC (j              construction /as-built activities.                                             -
   .i Description of Concern The self-initiated review of the AFW system does not fully address the inter-face with the SWEC piping reanalysis program.         -
          .       Action Required The third-party should include a portion of the AFW system in their review of j             the SWEC piping and pipe supports requalification effort.
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j          .
The staff requires the following items to be adequately completed in order to
  <                  detemine the acceptability of the piping and supports discipline specific action plans related to Project (SWEC) actions:
3 Description of Concern
 ]                   The majer technical details of the piping and supports requalification program are provided in Comanche Peak Project Procedures (CPPP-5, 7, 8, 9, 10 and 15).
The staff has not yet completed our review of these procedures. However, based on preliminary findings, the staff identified a concern that the design il                                                                                                       .
j                   criteria in CPPP-7 is not totally consistent with the CPSES FSAR licensing
   !                 commitments.
                                                ~
:l j                   Action Required
 ,j
                   ~
j                    The acceptability of the C:?RT Program Plan is contingent upon acceptable resolutions of technical concerni identified'in our review of the Comanche Peak
;'                   Project Procedures including consistency between FSAR licensing commitments and fI                   the design criteria in CPPP-7.
l ff
]          -
Description of Concern 1,
1                  There is a lack of information in the CPRT Program Plan which explains the process used to assure the adequacy of the as-built data used in the SWEC piping reanalysis effort.
i Action Required f
(
    ,i                Provide a def.cription of the process followed by the varicus activities in the
    !                 Construction Adequacy Program and in the SWEC program for the evaluation of '
i as-built discrepancies including the interfaces among ERC, SWEC, and TUGC0
    !                 projects and the applicable procedures used in the process.
04/08/86                                   C-16                 CP SSER 13 APP. C h a m ern m us= m e m + ~ w n. m .a :x u su                                       . ,    . , g w. . ~~      -

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                   ~
Description of Concern                                               ,                            j l
In our review of the as-built process and interfaces between the Construction                     l AdequacyProgramandSWEC,thestafffoundthatjeviation, reports (DR's) issued by ERC are not transmitted to SWEC. However, all DR's are transmitted to TUGC0 projects for initiating an NCR and only those NCR's dispositioned as "use-as-is" will be transmitted to SWEC.
Action Required Address the need for SWEC to review the DR's for the impact of construction             .
deviations identified by the construction adequacy program on the piping                 .
reanalysis effort.
  .)
i
 '!'! .                     Description of Concern i
As a result of the as-built walkdown performed under CPPP-5, deviations were
[ound in one of the four attributes (i.e. valve and strut orientation) result-ing in a 100 percent reinspection of that attribute. However, the staff noted that CPPP-5 did not expand its scope to address other as-built attributes (e.g.
pipe run geometry, clearances including those at floor and wall penetrations, (I                          embedments, and pipe attachments) which are also required to be examined under                   t i
       '.                    IE Bulletin 79-14.
Action Required Provide a justification for not reverifying the as-built attributes which were 2                      excluded under CPPP-5.
3 Description of Concern 1
r1 The staff is concerned that the design criteria and procedures used in the SWEC piping and support reanalysis might be impacted by as-built plant conditions which are not reflected in the design documents used by SWEC.
t!
'i 04/08/86                                        C-17         CP SSER 13 APP. C t4%ierdtiaWMuWihElhuSA:=edh 5 4 u 1-hG #r'~ Mi w@i W r 1. t               ,-      -- / 3 -W,iT ~7

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Action Required                                                      ,
Provide the basis for assuring that all as-built conditions which can adversely
                                        ~
affect the acceptability of the piping reanalysis program will be identified and corrected.
Description of Concern It appears to the staff that there iss.no evaluation of root cause or generic
                . implication or adverse trend assoc (ted with the as-built deviations identified in the SWEC as-built walkdowns. Furthermore, there does not appear to be a       .
: j.              procedureorprocessfortheevaluationoftheresultingdesigdeficienciesoc .-
  )               SWEC-identified construction deficiencies per 10 CFR 50.55(e).
Action Required I               Address the need for a program for ensuring that the results of the SWEC walk-downs will be adequately evaluated for root cause/ generic implications and' adverse trends and that design and construction deviations identified as a result of SWEC walkdowns will be properly evaluated per 10 CFR 50.55(e).
g ll                                                                                                          .
Description of Concern The staff review of CPPP-10 finds that a final design document which cstab-l lishes the system design input must be prepared and satisfactorily reviewed by lI                 the staff.
l Action Required                       -
Prepare a final document compiling all operating modes and system loading l
conditions.
U l
C-18                 CP SSER 13 APP. C 04/08/86 Mwmmsmm. n.n:s                                             .y.,    ,
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        . g Description of Concern                                                ,
The scope of the Class 5 piping systems includes only those Class 5 piping
- f,      systems within the boundaries of ASME Class 2 and 3 piping stress problems.
1
:t f      Action Required 1
Justify excluding the remaining Class 5 piping systems from the SWEC scope.
Description of Concern j  .
The Comanche Peak Project Procedure for the requalification of small bore          .
piping (CPPP-15) is not yet available for staff review.
1
                                   ~
.;        Action Required                                                               .
S
   !      The CPPP-15 should be completed and issued for staff review.
Description of Concern I
-I The staff has not yet completed its review of the resolutions to the special technical issues.
f*      Action Required
;1 D
The acceptability of the CPRT Program Plan is contingent upon acceptable
.l
'I        resolutions of the special technical issues.
l 04/08/86                                C-19                  CP SSER 13 APP. C l;
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Dociment Namet CF SSER 13 PAGES I-V                .
Requestor's ID:
ORDAZ Author's Name:
Tramel Document' Comments:
L                   Abstract, Table of Contents, Contributors, Acronyms & Abbrev f
I 1,                                                             4,I9(f b 3
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* l ABSTRACT l
 ,             Supplement 13 to the Safety Evaluation Report related to operation of the                 !
l              Comanche Peak Steam Electric Station, Units.1 and 2 (NUREG-0797), has been prepared by the Office of Nuclear Reactor Regulation of the U.S.' Nuclear f
Regulatory Commission. The facility is located in Somervell County, Texas, approximately 40 miles southwest of Fort Worth, Texas. This supplement presents the staff evaluation of the Comanche Peak Response Team Program Plan which was formulated by the applicant to resolve various construction and design issues raised by the Atomic Safety and licensing Board, allegers, NRC d              inspections of various types, and Cygna Energy Services while conducting its j              independent design assessment.
1 i           Subject to acceptable resolution of the items identified in the evaluation.
the NRC staff concludes that the CPRT Program Plan will provide an acceptable l
1            assessment of design and construction adequacy when implemented.
l 1
.1 I
l i
04/09/86                                    i               Comanche Peak SSER 13 n w mom m vun w nes.t.c; w .m &1w,ue w &.w a. sky..+.,0..ww.;;7                            ,

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E' TABLE OF. CONTENTS o                                                                                                                                                 Page A B ST RA CT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 CONTRIBUTOR $,.......................................................
[                                                                                                                                                    iii r
ACRONYMS AND ABBREVIATIONS..........................................                                                                   iv i            

==1.0   INTRODUCTION==
...................................................                                                                  1-1 1.1      Background................................................
1.2 SSER Purpose. Scope, Organization.........................
1.3 CPRT Terminology..........................................
1.4 Purpose of CPRT...........................................
.r                  1.5 Problem Identi fi cation and Classi fication. . . . . . . . . . . . . . . . .
1.6 -CPRT Products: Evaluations, Corrective. Action, and Reports.
 ,                  1.7 Overall          Conclusion........................................
    .l 1
2.0 CONSTRUCTION           ADEQUACY..........................................                                                            2-1
 ]'                 2.1 External Source                   Issues....................................
: 2. 2. Sel f-Ini ti ated P rogram. . . . . . . . . . . .-. . . . . . . . . . . . . . . . . . . . . . . .
2.3 Staff Evaluation..........................................
l            3.0 DESIGN
                                                                                 ~
ADEQUACY................................................                                                                3-1 4.0 CPRT QUALITY ASSURANCE PR0 GRAM.................................                                                                     4-1

==5.0   CONCLUSION==
.....................................................                                                                    5-1 3
APPENDIX A - Identification of the components of the CPRT 1'                              Program Plan, including Appendices, ISAPs and
   .                             DSAPs by Revision Number...............................                                                               A-1 APPENDIX B - Items to be addressed by Applicant during the
 !j;                             implementation phase of certain ISAPs..................                                                               B-1 APPENDIX C - Items to be addressed by Applicant during the
 'f                              implementation phase of certain DSAPS..................                                                               C-1
 .j-LIST OF FIGURES
 -l Figure 4.1 - CPRT Organization                                            ,
o            Figure 4.2 Figure 4.3 i
t
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04/12/86                                                                  11                                    Comanche Peak SSER 13 1
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                            ~
LIST OF PRINCIPAL CONTRIBUTORS j
e
 '!               NRC Staff                                       Consultants / Organization o
(                 D. Jeng                                         R. Hookway                 TES*
L. Shao                                         J. Flaherty                TES.
E. Marinos                                      J. Malonson                TES J. Calvo                                        J. Cragin                  TES i
S. Hou                                          D. Landers                  TES J. Knox                                         J. Rivard                  TES E. Tomlinson                            ~
R. Ciatto                   TES D. Terao                                        E. Solla                    TES i            A. Vietti-Cook                                  R. Masterson                EAS 4
l            D. Norkin                                       V. Ferrarini                EAS P. Chen
 ]                J. Gilray E. Thompson ETEC ETEC V. Noonan B. Grimes                                       B. Saffell                  Battelle C. Early                                        C. Hofmayer                 BNL C. Hale                                         N. Rivera                   independent S..Phillips                                     M. Yost                     EG&G T. Westerman                                    L. Stanley                  ZYTOR
;j                I. Barnes                                        R. Philleo                 independent' 1            J. Milhoan                                       C. Haughney                COMEX i
C. Trammell                                      P. Keshishian              independent                                        ,
J. Nevshemal               WESTEC
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04/12/86                                              111                           Comanche Peak SSER 13
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ACRONYMS AND ABBREVIATIONS A/E          Architect / Engineer 4                  ANSI         American National Standards Institute
;                   ASLB         Atomic Safety and Licensing Board 1                  ASME         American Society of Mechanical Engheeers ASTM         American Society for Testing & Materials B&R          Brown & Root C/S          Civil / Structural CAP          Conttruction Adequacy Program CASE         Citizens Association for Sound Energy CAT          Construction Appraisal Team j                CPRT         Comanche Peak Response Team j                  CPSES        Comanche Peak Steam Electric Station CTCS         Cable Tray & Conduit Supports f.
1                   DAP          Design Adequacy Program j
* DSAP         Discipline-Specific Action Plan ERC          Evaluation Research Corporation ESI          External Source Issues FSAR         Final Safety Analysis Report G&H          Gibbs & Hill HDA          Homogenous Design Activities HWA          Homogenous Work Activity q                   HVAC         Heating, Ventilation & Air Conditioning
   !                I&C          Instrumentation & Control l!                  IAP          Independent Assessment Program INP0         Institute of Nuclear Power Operations ll
: l.                  ISAP         Issue-Specific Action Plan t
LOCA         Loss-of-Coolant Accident NRC          Nuclear Regulatory Commission l~
NSSS         Nuclear Steam Supply System l,                  PSAR         Preliminary Safety Analysis Report QA           Quality Assurance j                QAP          Quality Assurance Program QC           Quality Control 04/09/86                               iv                              Comanche Peak SSER 13
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1 QE           Quality Engineering i           QOC          Quality of Const.ruction & QA/QC Adequacy Program RIV          Region IV RPVRI        Reactor Pressure Vessel Reflective Insulation U           RTL          Review Team Leader
.1 3         SER          Safety Evaluation Report
           . SET         Special Evaluation Team SIT          Special Inspection Team SRT          Senior Review Team                              '
SSE          Safe Shutdown Earthquake SSER         Supplemental Safety Evaluation Report SWEC         Stone & Webster Engineering Corporation
.i          TERA         Tera Corporation j        TNE          TUGC0 Nuclear Engineering l        TRT          Technical Review Team TUEC         Texas Utilities Electric Company TUGC0        Texas Utilities Generating Company UT           Ultrasonic Testing
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Document Name:
CP SSER 13 SEC. 1                         .
Requestor's ID:
ORDAZ
          <                                Author's Name:
C                                      Trammel Document Comments:
Comanche Peak SSER 13 Introduction l
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==1.0 INTRODUCTION==
i 1.1 Background                                                                                               .
    ?
On March 12, 1984, the U.S. Nuclear Regulatory Commission's (NRC's) Executive
    ~
Director for Operations established a program to assure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a coordinated and integrated manner by the NRC staff. As a means of executing
  .    .             Its assigned responsibilities, the NRC formed a Technical Review Team (TRT) representing the following disciplines:
o-   Electrical / Instrumentation i                    o    Civil / Mechanical l                     o    QA/QC 0    Protective Coatings l
l                      o    Testing Programs I                     o    Miscellaneous The TRT initiated a series of onsite inspections and evaluations in July 1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report (NUREG-0797, Safety Evaluation Report related to the operation of the CPSES, Units 1 and 2, Supplements 7-11). Prior to publication of these Supplemental Safety Evaluation Reports l,                   (SSERs), the staff issued letters on September 18, 1984, November 29, 1984, j                   and January 8,1985, sumarizing the principal issues that required
    .!               resolution.
     )               In response to the concerns and issues identified by the TRT, Texas Utilities
(!                  Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the
,!                   purpose of addressing all TRT concerns. TUEC initially submitted its CPRT
;{                   Program Plan on October 8, 1984, and issued Revision 1 on November 21, 1984, j                   to respond to comments on the initial version that were received from the NRC staff during meetings on October 19 and 23, 1984.
l:
l
      ,             04/12/86                                  1-1                       CP SSER 13 SEC. 1
         "*._,4-,,
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gr,-3g/,----

yc w n - s- n.m n a n .mm m,n m m                                                                     5 The. initial version and Revision 1 of the Program Plan were written prior to f          the publication of SSERs 7 through 11, which collectively provided over 1,000 pages of the staff's evaluation of the several hundred allegations of design and construction inadequacies. Following publication of the detailed staff evaluations contained in these SSERs and with the recognition of the need to 5
resolve outstanding issues raised by groups other than the TRT, TUEC submitted s
Revision 2 to the CPRT Program Plan on June 28, 1985. Revision 2 greatly expanded on the earlier revisions and provided an extensive corrective action i          program to be undertaken by TUEC to resolve outstanding issues from a variety of sources.
In letters dated August 9, 1985 and September 30, 1985, the staff provided comments on Revision 2 to the CPRT Program Plan. TUEC specifically addressed I       these staff comments in a {{letter dated|date=November 22, 1985|text=letter dated November 22, 1985}} and followed with l       Revision 3 to the CPRT Program Plan, dated January 27, 1986. Revision 3 has been supplemented by submissions in letters from TUEC on January 31, February 7, and two letters on February 28,-1986. With these submissions and the anticipated receipt of.one additional item involving hot functional terting, TUEC has completed its description of its planned corrective action           -
program, the CPRT Program Plan. This Program Plan is intended to describe the program that will address all NRC concerns and demonstrate an adequate level of quality of the design and construction of the CPSES.
i l       1.2 SSER 13 Purpose, Scope, and Organization t
i i      1.

==2.1 Purpose and Scope==

   }       The purpose of SSER 13 is to describe the NRC staff's evaluation of the CPRT j          Program Plan, Revision 3 dated January 27, 1986, as supplemented on i      January 31, February 7 and February 28, 1986, and to document the staff's i      approval of that plan, subject to the comments contained in this evaluation.
    !      This SSER documents the staff's evaluation and conclusions regarding the CPRT Program Plan and supporting appendices, except for the individual' action plans contained in Appendix "C". These action plans are the subject of the q
staff's ongoing evaluation and inspection during the CPRT's implementation 04/12/86                              1-2                    CP SSER 13 SEC. I 1
L      . -      __             _-       ___
_     . _ _ _   _-_ o

1
       <              phase. As the CPRT issues reports describing the implementation of each action plan, the staff will conclude its evaluation of these plans.
1.2.2 Organization
     ?
     '                SSER 13 contains 5 sections and 3 appendices. Section 1.0 is the Introduction, which describes the background and purpose of the CPRT, intro-duces key terms associated with the CPRT, describes the CPRT process for identifying and evaluating problems and for ensuring proper corrective action.
Section 2.0 describes the staff's evaluation of the CPRT's Quality of Construc-I                 tion and QA/QC Adequacy Program; Section 3.0 describes the staff's evaluation of the Design Adequacy Program. Section 4.0 contains the staff's evaluation of the CPRT's quality assurance program; Section 5.0 describes the staff's 4                 conclusions regarding the CPRT program. Appendix A is a complete listing of
         ;            the individual sections of the CPRT Program Plan that have been reviewed by the staff. This listing includes the appropriate revision for each section.
l 1                Appendices B and C contain those items the staff has requested TUEC to address i              during the implementation phase of the CPRT.
This SSER does not contain an explicit evaluation of the 50 individual action plans that resolve issues from the design, construction, and testing areas.
u                  The CPRT has written eight individual action plant., that resolve issues in the testing area. As with the other individual action plans, the staff does not i              explicitly describe its evaluation of these eight testing action plans in this SSER. The staff's evaluation of all the individual action plans is
:l                    ongoing and will continue during the CPRT's implementation phase. The staff will conclude its final evaluation of these testing issues, when the CPRT has
"!                    finished its assessment and has documented its results.
i~t
        )
:{
1.3 CPRT Terminology i
The CPRT effort has its own nomenclature, some of which is introduced here
        ;              to aid the reader.
 ;1
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e n .x . >       wmm -mnw m ,. m :n                                                       1 The CPRT essentially consists of two parts--one part relates to CPSES design adequacy and the other part relates to construction adequacy. The first two q        ~ terms describe these parts.
l
   ;        Design Adequacy Program (DAP). The DAP is that portion of the CPRT Program that resolves issues pertaining to design adequacy.
Quality of Construction and Quality Assurance / Quality Control (QA/QC)        _
Adequacy Program (QOC). This program is the portion of the CPRT that resolves issues related to the adequacy of the CPSES construction QA/QC program and the adequacy of installed hardware. The CPRT Program Plan uses the acronym QOC
  -         when referring to this program.
J Collectively, the DAP and the QOC constitute the CPRT Program. This combined 5     program resolves issues from the two types of sources:
External Source issues. These issues arose from sources external to TUEC.
These sources include: 1) the TRT; 2) the Atomic Safety and Licensing Board (ASLB) proceeding on the'CPSES operating license; 3) the NRC staff's Supplemental Safety Evaluation Reports (SSERs); 4) the staff's Construction Appraisal Team (CAT) and Special Investigation Team (SIT) reports;
: 5) applicable Inspection Reports issued by the NRC's Region IV (RIV) office; and 6) the Cygna Energy Services Independent Assessment Program (IAP).
i Self-Initiated Evaluation. The CPRT is conducting a self-initiated i     evaluation of the CPSES quality of construction and adequacy of design. For construction, this effort involves a sample reinspection of hardware that is
~[          representative of the activities and processes used in the construction of
:l          safety-related aspects of the plant. In the design area, the effort involves
     )      reviews of designs that are representative of the aggregate A/E design scope relative to design criteria, disciplines, processes and organizations used in the design of the safety-related aspects of the plant.
1                          -
      !     The CPRT Program Plan contains two types of action plans to resolve individual issues in the construction and design areas. These action plans are:
04/12/86                              1-4                    CP SSER 13 SEC. I

                                                                                                 ~
4 .                                                          ,
Issue Specific Action Plans (ISAPs). The ISAPs address specific CPSES I              construction QA/QC issues regarding either hardware or aspects of the QA/QC program that have been identified by external sources. An additional ISAP implements the CPRT's self-initiated portion of the QOC.. For a more complete 1,                description of the ISAPs, see pages 5 through 9 of Appendix B to the CPRT
)                 Program Plan, Revision 3. For a li,st of the ISAPs, see Attachment 1 to Appendix B to the CPRT Program Plan, Revision 3.
O Discipline Specific Action Plans (DSAPs). The DSAPs address specific CPSES l                 design issues regarding the adequacy of either the design or the design process which have been identified by external sources or by the CPRT as a result of other evaluations. Certain DSAP tasks also implement the CPRT's self-initiated design evaluations. Other DSAPs, encompassing piping and pipe supports and cable tray and conduit supports, entail a significant level of engineering reanalysis, and are being performed for the CPSES Project by
;;                engineering organizations that were not responsible for the original design.
CPRT third-party personnel will review the analytical process and the design criteria for these major reanalysis efforts. For a more complete description of the DSAPs, see pages 5 through 15 of Ap'pendix A to the CPRT Program Plan,
'j                Revision 1.
1.4 Purpose of the CPRT h
As described on pages 2 through 6 of Revision 3 to the Program Plan, the f-CPRT is charged with resolving issues so that it can advise TUEC management whether there is reasonable assurance that the CPSES has been designed,
;j                 constructed, and tested such that it can be operated safely. To accomplish j               this goal, the CFRT has three objectives:
(1) The CPRT~will evaluate each External Source issue relating to design
:  !                    adequacy, hardware quality, and testing. The CPRT will then determine
  -i N                       the nature of any safety-significant deficiencies and the necessary
 ;;                      corrective action. Accomplishment of this objective by the CPRT is
:I                      intended to provide TUEC with reasonable assurance that there are no undetected and uncorrected safety-significant deficiencies associated f
with any of the External Source issues.
04/12/86                                             1-5                           CP SSER 13 SEC. 1 WM = ' - -                  Y.Y ~ L, s j'F j- r y , x} ( Q ._eg & % K % fy &6 } e,yy,'{ - Q ~3    & y ,' y f~ ); f } T~ ~ ~%

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(2) The CPRT will investigate and attempt to detennine the' root cause of each l         safety-significant deficiency and any adverse trends from nonsafety-significant deviations or design observations. The CPRT will analyze the generic implications of each root cause that is found in order to deter-
:        mine the extent of any additional construction, design, or testing
   .          activities that might be deficient for the same reasons. The definitions of these terms are discussed in Section 1.5 below. Accomplishment 1            of this objective by the CPRT is intended to provide TUEC with a full
    -         resolution of each External Source issue and to fully bound the safety-3            significant implications of' identified deviations.
(3) ' Although the External Source issues are numerous, they are not inclusive of all aspects of design and construction activities associated with the CPSES. The CPRT recognized the need for additional evaluations in f       certain areas in order to be able to make conclusive statements regarding CPSES design adequacy and construction quality. Accordingly, the CPRT
{
i        developed a third objective to conduct a self-initiated evaluation of CPSES design adequacy and construction quality. In the design area, the               -
o            self-initiated evaluation entails reviews of designs that are representa-tive of the collective Architect-Engineer design scope. This design evaluation will examine design criteria, disciplines, processes, and organizations used in design of safety-related aspects of the plant. In L             the construction area, the self-initiated evaluation ccnsists of a sample
-             reinspection of installed hardware, which represents work processes used during safety-related construction activities. Accomplishment of this
     +        third objective will further enhance the CPRT's ability to advise TUEC 1
,!            management that there is reasonable assurance that the CPSES has been designed and constructed such that it can be operated without undue risk
[        to public health and safety.
l l'
     !  As can be seen from a review of the earlier background section and from f  statements in the CPRT Program Plan such as that on page 4 of Revision 3, the Program Plan has not been nor will it become a static document. By its very nature, the implementation of the DAP, the QOC and the associated DSAPs and ISAPs, along with the root cause and adverse trend evaluations, the determination of generic implications, the collective significance evalua-f 1     04/12/86                                  1-6                         CP SSER 13 SEC. 1 I-                        )b              m.___.>     [-f'h%j ' Mq , h,$ db   ,d  -k g "[ ( [mE i

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s
    ,   tions, and the initiation of corrective action is intended to combine to           -
j     produce a program that is iterative, flexible, and adequately controlled. The CPRT is a dynamic, responsive organization that is undertaking a comprehensive evaluation and corrective action program that is described in the CPRT Program Plan, which is itself subject to change as the program unfolds. The staff considers this flexible yet controlled approach to the CPRT to be acceptable for four reasons:
  ;     (1) The CPRT has already successfully used this approach to appropriately expand the Program Plan to suit its developing evaluation. For instance, new or expanded Appendices have been added on program QA,
  -          interface control, and corrective action. In addition, a new ISAP has been added to evaluate and improve craft training.
I l   (2) The CPRT Program's expandability ensures that new issues will be
{-       resolved using a consistent approach.
i (3) During the evaluation process, as new perspectives become apparent to the CPRT, the Program's inherent approach can adapt to focus attention
]_           and resources on important issues. This approach greatly enhances the overall effectiveness of CPRT corrective action.
(4) The flexibility in the CPRT Program ensures effective incorporation of j            lessons learned from the evaluation process.
L j      -The staff, therefore, approves the CPRT's methods for modifying the Program Ii      Plan, as described in the {{letter dated|date=January 27, 1986|text=January 27, 1986 letter}} from W. G. Counsil to V. S.
Noonan (CPRT-207), transmitting Revision 3 of the CPRT Program Plan.
l i.
:   1.5 Problem Identification and Classification I,
There are four key aspects of the CPRT Program:     (1) identification; (2)
[j      classification;(3) evaluation;and(4) correction'ofproblems.             In this i;
;!      section, the staff summarizes the methods chosen by the CPRT to classify f  identified discrepancies. For a detailed discussion of discrepancy classifi-l' ll 04/12/86                             1-7                         CP SSER 13 SEC. 1 L                     ...                   . . . w nn .   . wwc.,.a -       - ~ ~ - - -   v-n --

cation, see pages 1 through 4 of 13 of. Appendix E Revision 1, to the CPRT
:l        Program Plan.
   .      In Appendix E, the CPRT has described five different sets of definitions that
   ,      areusedtoclassifyproblems,whicharesubjecttoevaluationbythe l         CPRT. These five different sets apply to the DAP, the QOC, the test programs
  ;      - ISAPs, and the QA/QC portion of the CPRT. The staff's understanding of these
]         and other key terms, which have nearly universal applicability to all CPRT
  .    . activities, are described below:
(1) Discrepancy. The term discrepancy is used to convey any problem eligible for consideration by the CPRT.. This term encompasses the largest set of
               . potential problems and carries no special muning about the nature, importance, or potential safety impact of the potential problem.
il
;j        (2) Design Observations. The tenn observation has meaning only for the DAP portion of the CPRT Program. Each design discrepancy that is determined
]
not to constitute a verified failure to meet a design commitment or specification will be classified as a design observation.
(3) Deviation. A deviation is a verified, failure to meet a licensing commit-ment, _to meet a regulatory requirement, or to properly install hardware.
    ;           Not all discrepancies may turn out to be deviations, since not all identified problems turn out to be actual failures to meet a requirement, commitment, or installation specification.
j      (4) Deficiency. A deficiency is a deviation that has been evaluated as having safety-significance, a term that is defined below. Very few deviations j          are expected by the CPRT to be classified as deficiencies, since the        ,
j           CPRT expects that few will be determined to have safety-significance.
l (5) Programmatic Deficiency. If a set of deviations is evaluated as having an adverse trend, then a programmatic deficiency is said to exist.
i j             The CPRT expects that deviations in this special set will seldom be J             safety-significant by themselves.
  ,i i
6 04/12/86                        _
1-8                    CP SSER 13 SEC. 1 Eww.a- ~.a       m aae m a n a w - w m m w m m en w a u m +o ,                           xmm

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(6) Safety-Significant Because of the importance of this term, the descrip-
  '          tion presented below is a virtual quote from the language of Appendix E, Revision 1, of the CPRT Program Plan. Safety-significant is defined by I
the CPRT to mean that the identified discrepancy, if uncorrected, would N-           result in the loss of capability of the affected system, structure or component to perform its intended safety function. For purposes of the
~
CPRT Program, credit is not allowed for redundancy at the component, 1
system, train or structure level. This definition, which is employed in the CPRT Program for purposes of sample expansion, is more restrictive (conservative) than that usually applied to the term " safety-significant" for regulatory purposes or in, common parlance, in that it ignores redun-dancies that do exist in.real life. Identification of a deficiency as
             " safety-significant" for purposes of the CPRT Program, therefore, is not equivalent to a statement that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.
(7) Adverse Trend. A trend is a set of related discrepancies having attribut~es that reflect commonality. Examples of possible comonalities I          include:
o     The individual, group of individuals or organization performing the activity.
o     The program requirements, procedures or controls governing the performance of the safety-related activity.
/
A trend is considered to be adverse if it is determined that the j-           identified pattern or commonality is likely to have resulted in the
],           occurrence of an undetected safety-significant deficiency in the 1            affected area, population or stratum. Adverse trends are also referred to as programmatic deficiencies, i    Appendix E to the Program Plan describes the CPRT's method for classifying i    problems. The staff finds the CPRT's problem classification system to be acceptable, for the following three reasons:
04/12/86                                 1-9                    CP SSER 13 SEC. 1 N-_  __
                                                      .               ,               ~   - ,

(1) The CPRT's problem classification system includes an adequate framework to address problem classification in that the system addresses all
 -7 r
possible categories of problems that could be encountered.
V (2) The staff finds that the classification process, which is intended to track identified problems through an evaluation sequence from discrepancy r                  through deviation to safety-related deficiency, is a logical process that should be suitable for satisfactory implementation by the CPRT and for
}
q                  independent inspection by the NRC staff.
(3) The definitions of the different classes of problems to be encountered are sufficiently clear that the CPRT should be able to satisfactorily implement the classification of identified problems and the NRC staff 9                should be able to readily inspect the CPRT's implementation of this problem classification system.
 .-l 1
]             Initially, the staff had expressed concern regarding the CPRT's ability to il            adequately identify items that were not in compliance with licensing commitments. The staff is now satisfied with the CPRT's intentions in this area, as described in Revision 3 to the Program Plan, for the following reasons:
j o      All deviations, which include items that fail to meet current i                          licensing comitments, are tracked, evaluated, and classified as to
]                          safety-significance.
I 1
ij                  o      Deviations are evaluated to determine if an adverse trend exists.
{!
!                   o      If TUEC should determine that an issue needs resolution by changing a licensing commitment, they will submit an FSAR amendment request-ing the staff's review and approval of the change.
1.6 CPRT Products: Evaluations, Corrective Action, and Reports.
In accomplishing its activities, the CPRT will conduct or initiate four 5f types of actions to resolve identified problems:
04/12/86                               1-10                      CP SSER 13 SEC. 1
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L       _ . _                    - _ _ _ _             n.               ,_-n_-       _ ~-

o Determination of' Root Causes 1
o Evaluation of Generic Implications i                                 o ' Initiation 'and Oversight of Corrective Action o Documentation of Results in Reports s                            The first two of these actions constitute important evaluations that the CPRT intends to use to fully resolve identified problems and to bound the safety-significance of the associated deviations. The staff's understanding
  ,                          and cvaluation of these actions are described below (see pa~ges 2 and 7 through 9 of Revision 3 to the CPRT Program Plan for TUEC's discussion of these actions).
j                            (1) Determination of Root Causes. The CPRT recognized that the specific issues identified by External Sources may be representative of more
  <                                fundamental, underlying concerns. Accordingly, the CPRT has comitted to evaluate each issue, even if the issue is nonsafety-signficant.
The term " root cause" has not been explicitly defined by the CPRT. The staff understands a root cause to be the fundamental event or-decision that was the most likely cause of the identified problem. Root causes j                                  will be investigated and determined where possible for all adverse trends of deviations, design observations, and all deficiencies identified
]
through the CPRT Program. Such determinations will assist the CPRT in identifying potential generic implications, establishing appropriate expanded scopes of review and defin'ing appropriate corrective actions.
'l 1
.i                                 ISAPs and DSAPs include tasks that will determine where possible the root causes of identified deficiencies. These tasks are oriented both at specific testing of any initial root cause hypotheses and more general exploratory efforts that will lead to formulation and testing of new root cause hypotheses as the action plan is implemented.
     ;                       04/12/86                                                                    1-11               CP SSER 13 SEC. I j

s Investigation of a deficiency into the probable cause initially may suggest.many possibilities as contributing causes. In some cases, these can be narrowed down to one most likely candidate. If the investigation N                     shows no further possibilities, the CPRT plans to define the " root cause"~
as the event or decision which is the most likely cause of the identified
/                     deficiency. This process may, for example, lead to a finding that the I                     deficiency was due to errors in the instructions. However, if further investigation in the same area shows similar errors, it may be detemined that the author of the instructions was the real " root cause." Discovery
* of the second, more extended root cause is intended to enable correction of the wider-ranging situation and to lead to greater assurance that there are no undetected and uncorrected safety-signficiant deficiencies associated with the causes of any deficiencies or adverse trends identi-fied by the External Source issues, t
i                                                                                                '
f The staff has examined the CPRT's description of their intended methods for determining root causes and finds that the CPRT's description, c                     although brief, is acceptable. At this stage in the CPRT process, few issues have been fully enough resolved to provide the CPRT with enough examples of safety-significant deficiencies or adverse trends to imple-ment a root cause evaluation process. Nonetheless, the CPRT has provided an ample commitment to evaluate root causes as the Program progresses.
The staff will continue its evaluation of the root cause determination process during the CPRT implementation phase.
(2) Evaluation of Generic Implications.
The term "ganeric implications" has not been defined by the CPRT. The
.).                   staff considers generic implications to be the potential products of evaluations of safety-significant deficiencies or adverse trends of 3                     deviations that demonstrate whether these problems. represent isolated occurrences, generic weaknesses within a particular area, or programatic
)
weaknesses.
     )
l               At such time as the root causes of safety-significant deficiencies or
      !               adverse trends of nonsafety-significant deviations have been determined,
       ,       04/12/86                                 1-12                 CP SSER 13 SEC. 1
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an evaluation will be performed to identify any associated potential                                      1 generic implications. The CPRT maintains that such evaluations will enable them to determine whether the deficiencies or deviations represent
                                                                     - isolated occurrences, generic weaknesses within a particular area, or J
generic weaknesses that are programmatic in nature.                                                       i The CPRT has stated that the results'of these evaluations, in conjunction
[                                                                   with assessments of the safety-significance of the deviations, will enable them to define expanded scopes for review and to identify correc-t                                                                   tive actions for both the specific deficiency and for prevention of repetition of the same types of deficiencies.
The staff has examined the CPRT's description of their intended methods for determining the generic implications of each root cause and finds
   ]
i                                                                that the CPRT's do.cription, although brief, is acceptable. At this stage in the implementation of the CPRT Program Plan, the root cause
   ]
1                                                                 determinations have not progressed sufficiently to permit meaningful determination of generic implications. However, the CPRT has provided an adequate commitment to determine the generic implications of each found root cause as the program progresses. The staff will continue its
                                                                  ' evaluation of generic implications evaluations during the CPRT 2                                                                      impleuentation phase, j'
                                               ' (3)                    Initiation and Oversight of Corrective Action.
j                                                                      The third action involves TUEC's methods for correcting identified problems and the CPRT's methods for overseeing and, in some cases,
]
j                                                                       concurring in problem correction. Appendix H. Revision 0, of the CPRT ll                                                                      Program Plan contains TUEC's description of this corrective action process.
]
i.
'J t
TUEC has structured its action to vest primary responsibility for imple-mentation of corrective action with the CPSES Project rather than the CPRT. Because of the special nature of this program, TUEC has internally l                                                                 required that corrective actions by the Project for all safety-
'l    .
r                                              04/12/86                                          1-13                  CP SSER 13 SEC. 1
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l significant deficiencies and certain categories of deviations must be d                acceptable to.the CPRT.
The CPRT is responsible for transmitting all deviations and d'eficiencies
                     ~
                'to the CPSES Project for evaluation and disposition in accordance with Project procedures for processing non-conformances.
l             For each deviation or deficiency identified by the CPRT, the CPSES
.                Project is responsible for performing 10 CFR 50.55(e) reportability evaluations and for defining appropriate corrective actions. The CPSES Project is also responsible for obtaining CPRT concurrence in the defined corrective actions for:
;                o Each safety-significant deficiency identified by the CPRT o Each programmatic deviation or programmatic deficiency identified by the CFRT o Each design deviation identified by the CPRT that involves a failure to meet FSAR criteria or commitments, other licensing commitments, or the regulations
  .              o Each deviation identified by the CPRT that has been determined by the CPSES Project to meet the reportability criteria set forth in 10 CFR 50.55(e).
In the event of disputes between the CPSES Project and the CPRT regarding l{               the adequacy of corrective action, TUEC has described a process for
]                resolution of such disputes on page 3 of 8 of Appendix H to the CPRT Program Plan, Revision 0. The staff finds this described process for resolution
    )
of disputes to be acceptable for the following reasons:
l' L}
i,               o     The Program Plan describes a method for elevating disputes involving corrective action between a Review Team Leader and the ll                     CPSES Project through successively higher levels of CPRT and CPSES
(!                     Project management.
l l
04/12/86                                 1-14                   CP SSER 13 SEC. I m%mwmmwemwCmWmewMmom@mwww%+ - .

         .y      n             .
we +           n.                  . - ww w,.cwn,,wmm,. m 7 o      The ultimate responsibility for resolution of these disputes rests i                       with TUEC's senior nuclear officer, the Executive Vice President.
f                       By virtue of'this person's background, experience and assigned                          I
                        . responsibility, this official has overall nuclear safety
                       . responsibility for the facility's design, construction, testing, 9                       and operation. Appropriately, the Executive Vice President is 3
TUEC's final authority for resolving disputes involving the adequacy of corrective action, and this official bears the responsibility for the outcome of decisions that resolve these i
disputes.
In order to verify that the CPSES Project's program for implementing corrective actions is being effectively implemented, the CPRT is respon-sible for performing confirmatory overviews of the implementation of l             certain correctiv,e actions. These confirmatory overviews are intended to accomplish the following objectives:
 ].
o      To ensure that the corrective actions for each progransnatic deviation and programmatic deficiency have been effectively implemented.
o      To ensure that the corrective actions for each specific safety-significant deficiency have been effectively implemented.
1 1                o      To ensure that the corrective actions for each specific design deviation that involves a failure to meet FSAR and licensing commitments have been effectively implemented.
'i ll               o      To ensure that the corrective actions for each specific deviation j                       that meets the reportability criteria of 10 CFR 50.55(e) have been effectively implemented.
1l The CPRT will perform these overviews using design reviews, document reviews, and independent reinspection and inspection witnessing.
l 04/12/86                                     1-15                            CP SSER 13 SEC. 1
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                                              - . ~ .     . mm. . . - - -      ' - ~ ' -     - ^ ~ = ~ -~ =  ^^^

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The staff has determined that TUEC's method for implementing corrective action and the CPRT's cc=itment to independently concur and overview key aspects of that corrective action to be acceptable for the following three reasons:
l u,
1                     -(1) Deviations and deficiencies will be tracked, dispositioned, and closed in an auditable system, TUEC's non-conformance report (NCR) system. In addition, the CPRT's tracking system for deviations ensures that TUEC will generate an NCR for, each deviation.
1                    (2) The prime responsibility for corrective action and records associated therewith will reside with.the organizational entity that will acquire operational control of the' facility upon issuance j                             of an Operating license. The staff concludes that it is important
     !                        that the eventual facility operator controls, implements, and is responsible for this corrective action.
l
.l I                   (3) Even'though the CPRT will not implement the corrective action i
resulting from its various evaluations, the CPRT will retain a sufficient level of concurrences and confirmatory overview of
     ;                        TUEC's corrective action for important deviations that the CPRT can ensure the adequacy of corrective action and can ensure the
     ,                        credibility of this Program.
(4) Documentation of Results in Reports The fourth action entails documentation of the results of the CPRT's efforts j                    in a set of reports.
i
.j                      The CPRT has described several types of reports that will document l                   the products of its activities. The principal types of reports that the CPRT will provide include:
-I i
i
 't 04/12/86                               1-16                    CP SSER 13 SEC. 1
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7_-______________
c      .
C o       Results Reports.
f             ,
Each ISAP and each DSAP will produce a Results Report. Each Results Report will at a' minimum identify the safety-significant def' icien-
[
k                              cies and programmatic deficiencies, their resolution, any root
$                              causes and generic implications and their resolution and any recom-
{                              mendations for programatic improvements to abate the potential for j                              reoccurrence. The CPRT overview of corrective action implementat. ion i                              required by Appendix H will either be included in the Results Report I                              or a supplement to the Results Report.
The DAP will also produce third-party CPRT Results Reports concur-ring in the criteria, the processes used and the implementation of the piping and pipe support and cable tray and conduit support design verification efforts.
o       Collective Evaluation Reports.
]
1 L                              In the Quality of Construction and QA/QC Adequacy, Design Adequacy, and Testing Program Adequacy areas, the results of the various activities will be collectively evaluated to ensure that potentially safety-significant trends implicit in the collective data but not apparent from the activity specific results. are not overlooked.
These collective evaluations will be separately reported in Collective Evaluation Reports.
The Collective Evaluation Report relating to the adequacy of the j                              QA/QC Program will include the identification of necessary improve-1                             ments to future CPSES construction activities and to future plant
                                                                       ~
)                              operations. The Collective Evaluation Report relating to the
]                              quality of installed hardware will include identification of the l'                             corrective actions necessary to resolve safety-significant hardware deficiencies.
The Collective Evaluation Report relating to the DAP will be called 7
   '                           the Final Design Adequacy Program Report and will include 1-17                 CP SSER 13 SEC. 1 03/27/86 A
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a identification of improvements needed for future CPSES design activities and identification of corrective actions needed to
                              - resolve safety-significant design deficiencies.
f                  .
o       Collective Significance Report.
F A collective significance evaluation will focus on the integrated impact of the identified deficiencies, both specific and program-matic, on the design, construction and testing of CPSES. This evaluation will be conducted by the Senior Review Team (SRT), which consists of a senior TUEC line manager and senior industry consult-
>                              ants and which has been established with overall responsibility for the development and implementation of the CPRT Program. The CPRT Program Director is an ex-officio member of the SRT.
3 The staff finds that the CPRT's description of methods for documenting the results of their efforts in Results Reports, Collective Evaluation Reports, and the Collective Significance Report to be acceptable for the following reasons-                -
(1) These reports, if produced as described in the Program Plan, will give TUEC.and the NRC staff sufficient basis for reaching a conclusion about the adequacy of the design and construction of the CPSES.
~
(2) Although the Program Plan description of the Collective Evaluation O                      Reports and the Collective Significance Report is briefer than the description of the Results Reports, the description is considered
    ]
adaquate. The collective evaluations that will support these reports j                  can only begin in earnest when the CPRT has completed the bulk of the examinations needed to resolve each ISAP and DSAP. At that time, the respective issues will have become sufficiently understood so that the implications of each issue can be properly evaluated. The staff will inspect the CPRT's implementation of these collective evaluations during the implementation phase of the Program.
1 i            03/27/86                                   1-18                CP SSER 13 SEC. 1 i
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        ~1.7  Overall Conclusions 1
L4 h   In-SSER 13, the staff approves the CPRT Program Plan and finds reasonable
    ;   assurance that, if implemented subject to the comments identified in this .
2   evaluation, the CPRT Program Plan will-provide sufficient information to j   ensure that the CPSES has been designed, constructed, and tested in a manner that it can be operated without undue risk to public health and safety.
The staff concludes, based on its evaluation in this SSER, that Revision 3 of the CPRT Program describes an acceptable process for resolving all currently identified design, construction and QA/QC and testing external source issues
[   and for conducting a self-initiated O't:'":ti d aluation of the design and        X the quality of construction for all safety-related systems and components.
-].
That process is also an acceptable framework for the evaluation and
.i      resolution of any future issues which may arise.
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   'l 2.0 QUALITY OF CONSTRUCTION
:j The adequacy of the construction QA/QC program and the quality of construction I       performed within the scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC with responding to s
and resolving these concerns. This section of the SSER documents the staff evaluation of the 'PRT-formulated C             program (QOC Program) to evaluate questions
(      concerning construction QA/QC and the adequacy of installed hardware.
The CPRT's objectives for the QOC Program are to identify and resolve all of the construction and QA/QC related external source issues, assess in an inte-
   >      grated fashion all identified safety-significant deficiencies and to make a statement about the adequacy of construction at CPSES. The CPRT's program has
     )
the following three components:
1
: a. Identification and resolution of external source issues, I       b. Root cause evaluation and generic implication assessment for each i             identified safety-significant deficiency or trend of nonsafety-significant deviations, and p       c. Self-initiated reinspection and documentation review of a representative sample of QC accepted safety-related work activities.
The objective of the staff's evaluation is to ascertain if the CPRT Program Plan describes a framework and process for accomplishing the three components listed above. Subsequent sections of this SSER address both the CPRT proposed f    process and the staff's evaluation of this process. In performing this evalua-j    tion the staff conducted document reviews and audits for the purposes of
!!        understanding the details of the QOC Program process, det'ermining whether an auditable trail existed, and to provide assurance that the proposed process was adequate to meet the Program Plan objectives.
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04/02/86                              2-1                CP SSER 13 SEC. 2 U                                                      ~        . -. .nn-      --n.~.       ...

5 2.1   External Source I' ssues e
Concerns regarding the adequacy of the CPSES construction QA/0C program and I         the adequacy of the constructed safety-related ha'rdware have been raised by a i
9         number of sources external to TUEC and are referred to as External Source Issues (ESIs). The QOC has established two corsponents to resolve and bound the safety-significant implications of any ESI deficiency in either the hardware
(
E         or the CPSES QA/QC construction program. First, the CPRT will evaluate each external source issue by determining the scope of any safety-significant 7
[         hardware deficiencies and the corrective actions necessary to resolve them.
l         This process included reinspection of hardware, documentation review, engineer-ing. analysis and evaluation, assessment of TUEC corrective action programs and an evaluation of data collected from other CPRT review team action plans.
Second, the CPRT will determine the root cause of each discovered safety-significant deficiency or trend of nonsafety-significant hardware deviations.
      ,   They will analyze the generic implications of each root cause in order to 1
determine the extent of any additional hardware that might be deficient for the
        . same programmatic reasons and to determine if changes need to be in ongoing programs to prevent recurrence in the future (further details of this second component are explained 2nd evaluated in Section 1.5 of this SSER).
Issue-specific actions plans (ISAPs) describe the CPRT plan for resolving each of the external source issues. All construction QA/QC issues whether of a
',        hardware nature or a QA/QC programmatic concern, will be the subject of an ISAP. A single ISAP VII.c also describes the process and methodology for the CPRT's self-initiated hardware reinspection and documentation review which is discussed in Section 2.2 below. The results report prepared for each ISAP documents each individual issue evaluation. Should additional issues be identified by either other external sources or the CPRT, a new ISAP would be l     prepared for resolution of the new issue or an existing ISAP will be expanded as confirmed in revision 3 of the Program Plan. CPRT proposes to integrate and collectively evaluate the findings from their external source issue evalua-tions with the results of the self-initiated program in order to make a state-4
     <    ment about construction quality at the Comanche Peak Steam Electric Station.
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Three reports will be prepared in addition to the individual action plans results reports to document the results of the integrated evaluation. Two collective evaluation reports will be prepared to address the adequacy of g             the construction QA/QC program and the quality of installed hardware. Finally,
   \          a summary report will integrate the results of the two collective evaluation reports and state the CPRT's conclusions regarding the quality of construction and the QA/QC program at Comanche Peak plant. Any information that may be i             related to design adequacy which is identified during implementation of this 9
g             ISAP will be referred to CPRT personnel responsible for. implementation of the DAP.
To ' assure that all issues / concerns from External Sources are addressed, the CPRT will develop a matrix that provides a cross-reference between each issue /
j          concern and the action plan (s) that addresses it. This matrix will also serve l3         as an aid in the collective evaluation process. The matrix format will present t
information such that valid concern can be tracked to the appropriate criteria of 10 CFR 50, Appendix B, and/or hardware area, and tracked to the ISAP govern-ing the concern.
{
2.2 Self-Initiated Program The self-initiated evaluation of construction adequacy is described in ISAP VII.c.      This action plan describes the proposed CPRT reinspection and documen-tation review of a. representative sample of. completed and QC-accepted safety-related construction work activities performed at Comanche Peak. The objective of this effort is to provide additional confidence that there are no unidentified safety-significant concerns related to the quality of construction of the
  ?          hardware at Comanche Peak. The CPRT's Plan consists of a reinspection of a representative sample of safety-related construction work which has been inspected and accepted by CPSES QC for Units 1, 2 and their common areas, M
q supplemented by a review of related documentation for uninspectable hardware 4
attributes. Construction activities are organized into three disciplines as follows:
o     Civil / Structural o     Electrical, and
'lt                  o     Mechanical / Piping 04/02/86                                 2-3                CP SSER 13 SEC. 2 l

The methodology for the self-initiated construction adequacy review consists of establishing reasonably homogeneous populations of construction work activities o
by reviewing applicable drawings and specifications, codes and standards, work and inspection procedures and by identifying organizations and crafts who performed the work. The populations are then sampled and evaluated by means of 4                  physical reinspections of safety related attributes and documentation reviews of uninspectable attributes. The results of these evaluations with conclusions l                  drawn will be documented in an action plan results report. The self-initiated
 ,                 review begins with the categorization of all safety-related hardware into j                  populations made up of homogenous work activities (HWAs) for which samples can
 ,                 be drawn for evaluation. Population and work process descriptions are prepared for each construction category. The population description describes the boundaries of the population while the work activity describes the process required to install or construct a certain category of hardware. Attributes associated with each work activity are established based upon the provisions of installation and inspection procedures and/or specifications used for installa-tion of the subject hardware. For each population, two random samples will be i
selected in accordance with the procedure in Appendix D of the Program Plan.
The first sample is derived from the total population while the second sample (which is essentially an expansion of the first) is drawn from that portion of the total population which is defined by the CPRT as having greater importance to safety. In parallel with the sample ~ selection, checklists and inspection procedures are developed from the attributes used to characterize each work process. Both inspection and documentation review checklists are developed from the Quality Instructicas. Verification packages are then assembled for each sample item to facilitate an inspection or documentation review. Any deviations identified as a result of a reinspection or a documentation review are documented in a Deviation Report which will then be evaluated to determine t
i               the safety-significance of the deviation.                  In addition, all deviations are collectively evaluated for adverse trends. An action plan results report
   !               documenting the overall results of the inspections for all populations is the vehicle for documenting the results and evaluations of this ISAP.
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l The sample size for each population which is part of the construction adequacy             1 review program is targeted by the CPRT in Appendix D to meet a 95/5 confidence             !
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level. This confidence level is used by the CPRT as a means for                            l detecting programmatic or systematic deficiencies. , For each work activity of interest, a minimum sample size of 60 will be taken. If no safety-significant deficiencies are found in the sample, the work activity is 0'
accepted. If a deficiency is found, the sample is expanded. For a single sample expansion, the sample-would be increased to 95 and the work activity is accepted only if the total number of deficiencies does not exceed one. As noted in Attache uc 4 to Appendix D of the Program Plan and confirmed by the Applicant in a meeting with the staff on March 18, 1986, only one sample expansion will be made prior to performing a 100% reinspection or reevaluation
  .                                       of an attribute, stratum, or population as conditions, dictate. Provisions are i
provided in Appendix D for 100% reinspection or review of a population. If the items from the samples contain no safety-significant deficiencies, and there i                                     are no apparent adverse trends of nonsafety-significant deviations, no further I                                      reinspections or documentation reviews would be required.      If a sample is found l
to contain one or more safety-significant deficiencies, or if there is evidence J
i                                      of an adverse trend, the sample wou'Id be expanded and additional reinspections/
documentation reviews conducted. All safety-significant deficiencies will be analyzed for root cause and generic implications in conjunction with these expanded reinspection / documentation reviews and will be consistent with the process used to establish the HWAs.
j                                         A results report will be prepared documenting the results of the self-initiated evaluation program. Any information that may be related to design adequacy
)1 which is identified during implementation of this ISAP will be referred to CPRT l
]                                         personnel responsible for implementation of the DAP.
1 1
    !                                     2.3 Staff Evaluations
 )                                        The staff reviewed the applicable sections of the Program Plan and each individual ISAP including the ISAP describing the self-initiated evaluation program for the purpose of ascertaining if the CPRT's construction adequacy program can accomplish its stated objectives (See CPRT Program Plan, Appendix B, Page 2). In addition to the review of each individual ISAP, on-site audits 03/27/86                             2-5                  CP SSER 13 SEC. 2 i        .__                                            _                         _    _            ~ .- _ . -               _- , _

y       n.    ,,              - -     n w ~~   ~m        mmm. mw+ u m n         ,,,m m e n m m of the documentation being prepared in support of external source issue reso-g          lution and of the self-initiated evaluation program were performed for the purpose of developing an understanding of the CPRT process. These audits also y          served to establish that the Applicant was documenting construction adequacy j           evaluation activities in sufficient detail to permit audit now or in the future.
l1 Review of the construction adequacy program plan has been accomplished by teams of NRC staff and consultants. External source issue review have been organized in a manner similar to the NRC's Technical Review Team (TRT) and include the following disciplines.
b                a. Electrical and instrumentation issues
: b. Testing program issues
 .1 i            c. Mechanical and piping issues and miscellaneous issues i
    ;             d. Civil and structural issues
     !            e. QA/QC issues Many of the individuals responsible for reviewing the scope methodology and implementation of the external source ISAP's were members of NRC's Technical Review Team. Review of the self initiated evaluation program is accomplished by a multidisciplinary team encompassing most of the disciplines addressing l'          external source issues. This team has reviewed the methodology for the L           self-initiated program and has audited the safety related hardware populations.
I Il        The scope of each ISAP contained in Revision 3 of the Program Plan has been Lj          reviewed by the staff for the purpose of comparing its content with that l       required by the Issue Specific Action Plan Format (Attachment 3 to CPRT l      Program Plan) and its scope with the issue requiring resolution. The format required by the CPRT describes the elements of the ISAP process and includes:
]
q                a. Description of the issue
{            b. Actions identified by the NRC f             c. Background
: d. CPRT Action Plan 2-6 03/27/86                                                   CP SSER 13 SEC. 2 i
L'                                 __2

The ISAP Format also provides guidance for the development of the CPRT Action-Plan. For example, the approach to resolution, the required tasks, and assess-f            ment for potential generic implications must all be included in the CPRT Action d            Plan. Also, applicable procedures, responsible organizations, personnel g
qualification, and acceptance and decision criteria'must be addressed in each I          ISAP'to comply with the CPRT's specified ISAP Format. Further, implementation of an ISAP is to be in accordance with the CPRT's Quality Assurance Program and
{
the status of each-ISAP will be monitored through the CPRT Program Records with
            ' documentation provided in a Results Report. Based upon the assessment of the ISAP format, which essentially describes the CPRT's process for resolving L
issues, the staff finds that this process contains the elements necessary a            for systematically addressing issues raised by external sources, as well as any specific issues which may be identified by the CPRT or other external sources
:f           in the future. The CPRT acknowledges in Revision 3 to its Program Plan that i
i        -the scope of its activities will be revised as appropriate. This commitment 1-provides the staff with additional assurance that the CPRT will appropriately 9
I         address and resolve any other construction and QA issues which may be raised in the future. The staff finds the individual ISAPs are generally responsive to the issues based on the staff's technical review of each ISAP,'since they adhere to the ISAP format and address the specific concerns by means of a systematic approach to resolution. Specific comments are provided in Appendix B to this SSER.                               _
The staff reviewed the CPRT's process for their self-initiated program includ-ing their sampling program to determine if it would accomplish its stated
  ;          objectives. This review which included on-site audits examined the homogeneous work activities to develop an understanding of the CPRT's self-initiated
_1           program, to ensure that an auditable trail existed and to determine if the same l
procedure was being applied to all disciplines. The audits did not address the l        implementation of the reinspections and the document reviews. The staff found 1
.;           the documentation of the populations to be compatible with the CPRT's Plan described in ISAP VII.c and found the development of the inspection checklists and the documentation associated with this process to be consistent for all populations. The staff further found that the documentation was adequate to ensure that this process could be audited in the future. The basis, descrip-I         tions, items list, and work activity definition for most populations was I
04/02/86                              2-7                 CP SSER 13 SEC. 2 d                                   _

reviewed and found to be acceptable since they properly addressed the concept of homogeneity and were documented to enable evaluation of the work activities and their accompanying attributes.
The sampling procedure is based on assumptions that characterize a binomial population (i.e. acceptable or not acceptable). These assumptions include,
: j.                            - among others: (1) homogeneity of items within a work activity; (2) random selection of sample items from a work activity; (3) ability to classify an item as either acceptable or deficient with certainty; (4) the number of items in lf                                   the work activity is essentially infinite. The homogeneity of the various work jL                                   activities, required by Assumption 1, is determined and justified by engineer-ing considerations. Homogeneity is a necessary attribute for a population if
          ,                            conclusions based on a sample of a population are to be valid for the entire population. If the population of interest is found to be non-homogenous, the
   ;                                   work activity boundaries are redrawn and samples are selected at random from i                                ^
j                                   the respective work activities.
l                                    The selection of the items from the HWAs is made through a random sampling procedure described in Attachment 2 of Appendix D. Since                    all popula-tions developed for the self-initiated program are finite, all sample sizes 1
will be larger than required because of Assu=ption 4. The 95/5 assurance level was selected by the Applicant as a criterion to allow a quantification of the quality of the work activity performance without having to reinspect each and every individual item. From a strict probabilistic view, the sampling plan stated in Appendix D offers less than 95 percent assurance, primarily because of the Plan's associated expansion. A plan which allows no expansion (i.e.,
i.
accept the work activity only if zero deficiencies are found in a sample size j '1 of 60) actually offers 95.4 percent assurance that no more than 5 percent of h                                     the items in the work process are unacceptable.           If one expansion is allowed,
   ?
ll                                     the assurance level is 93 percent. On the other hand, the 95/5 level of
{ ;-                                  assurance is only an arbitrary target value and somewhat smaller assurance (at I
;j                                    least 90/5) is in the staff's judgement considered acceptable for this application. Moreover, there are many factors that would further enhance this a                                     assurance. Some of these factors are:
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j                       1. As previously noted in this subsectioa, the initial sample is j                             supplemented by a second sample drawn from that portion of the population having greater importance to safety.
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: 2. . The sampling scheme assumes (assumption 4) that the size of the work I                             activity is infinite. For small groupings of work activities, the sample size is considerably larger than need be and hence the l                            associated assurance is understated.
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 )                        3. The sampling assurance is increased when a deficiency is identified and repaired. For categories involving a small number of work activities this increase may be very significant.
: 4. When a deficiency is. identified, the CPRT Plan calls for further sampling. This activity increases the sample size, generally giving a still greater assurance.
l                                                        -
i i       The CPRT's self-initiated program for evaluation of construction adequacy commits to performing root cause evaluations and generic implication assess-ments of safety significant deficiencies and adverse trends of non-safety significant deviations.              In addition, adverse trends will be investigated to identify trend boundaries and to determine the affect of the trend on other areas if applicable. Closed external source issues will be considered in the root cause and generic implication evaluations.
The staff considers that the CPRT's self-initiated program for evaluation of construction adequacy to be acceptable because it:
i                              is a structured process which complies with the CPRT's a) t!
it                             ISAP Format l                       b)   employs an appropriate procedure for assuring homogenous populations for sampling by the use of HWAs.
1 c)   employs a conventional sampling process accepted in the industry.
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d)    establishes a targeted level of assurance by the 95/5 criterion y                   which should be sufficient to identify programmatic deficiencies.
X e)    provides for a 100 percent reinspection of a population if two or more deficiencies of the same type are detected in the minimum initial sample.
f)   requires root cause eval,uation and generic implication assessments of both safety significant deficiencies as well as adverse trends of    ,
non-safety significant deviations and g)    is ' documented in a manner suitable for audit now and in the future.
2.4 conclusions i      The staff concludes, based on its evaluation described above, that Revision 3 I
of the CPRT Program documents an acceptable process for resolving all currently identified construction and QA/QC external source issues and for conducting a self-initiated evaluation of the quality of construction for all safety related systems and components. That process is also an acceptable framework for the evaluation and resolution of any future issues which may arise.                             ,
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CPRT QUALITY ASSURANCE PROGRAM 4 l4 g,       '
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4.0            CPRT QUALITY ASSURANCE PROGRAM 4.1            Introduction L
i                      Section 1.4 of this SSER discusses the objectives of the CPRT. The CPRT Senior Review Team (SRT) directed that a written description of the QA program control-j           .      ling the CPRT activities be developed based on the appropriate criteria in 10             .
CFR Part 50, Appendix B.            The staff's evaluation of. the CPRT QA program is based on a review of the program description to determine that (1) it provides a means
                  -      to control the quality-related activities of the CPRT program and (2)'it meets the appropriate provisions of 10 CFR Part 50, Appendix B. These provisions include organization; QA program; design control; procurement document control; instru-l                    ctions, procedu6is, and drawings; document control; control of purchased material, equipment, and services; inspection; nonconformance control; corrective action;
;j                       QA records; and audits. They do not specifically address identification and iI    '
control of material, parts, and components; control of special processes; test control; control of measuring and test equipment; handling, storage, and shipping;
;                         and inspection, test, and operating status since these activities (except for the control of measuring and test equipment) are not directly related to the i     !                   CPRT program functions.
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The staff has evaluated the CPRT QA program described in the CPRT Program            ;
Plan to determine its acceptability based on the appropriate provisions of           '
I               10 CFR Part 50, Appendix B and how these provisions will be carried out.
  ;                The result of our evaluation is discussed below.
Organization. We find TUGCO's responsibility for the establishment and . execution of the QA program with the authority to delegate these functions to contractors or consultants, providing TUGC0 retains the .
responsibility therefor, acceptable and meeting the organizational
         ~
requirements of 10 CFR Part 50 Appendix B. We further find it acceptI able to the 10 CFR Part 50 Appendix B requirements for TUGC0 to delegate to the CPRT organization the responsibility for a third party investi-gation and evaluation and third party review and oversight of CPSES I
project activities. The authority and duties of the CPRT organization responsible for implementing the CPRT program are acceptably described withiti the CPRT program (Ref. Sec. VIII of CPRT Program Plan). The CPRT responsibility for the quality of CPRT activities rests with the SRT which consists of the Vice President of TUGCO, the Vice President of International Technology Corporation (consultant), the Vice President of Management Analysis Company (consultant), the Manager of Nuclear Safety and Licensing, TERA Corporation (consultant), the President of 4                            Nyer Corporation (consultat), and Dr. John H. Beck (consultant).
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The QA organizations responsible for assuring that the CPRT QA program controls are effectively executed have the authority and organizational freedom to identify quality problems and assure that corrective actions   ,
are identified and properly carried out. The independence of the QA 1)1                           organizations from the pressure of cost and schedules is acceptable i
since they do not report to the line management directly responsible for the work being verified by the QA . organization.
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QA Program. We find the QA program acceptable based on the following measures described in the CPRT Program Plan. Activities are required            ,
to be carried out using documented, controlled procedures. Technical l
and QA personnel involved in implementing and verifying, respectively; 2
l i                         the CPRT program are to be qualified in the areas of the assigned responsibil.ities and are to be trained as necessary on the provisions of the CPRT Program Plan. The SRT regularly reviews the status and adequacy of the CPRT program through the review and approval of action plan results, the review of audit results identified by internal audits and b[outside agencies, and the review of corrective actions resulting I                         from audit findings.
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* Design Control. We find the CPRT design controls acceptable based on l!
i H                                 the following measures described in the CPRT Program Plan. Design 1.-
verifications will be performed in accordance with written procedures l{
by qualified, trained personnel other than those who performed the f
       !                         ' original design. The verification activities include the preparation i
6 of checklists and criteria lists, calculation review, input review, alternate calculations, and review of quality and QA requirements.
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* 9 Further, the design activities will be performed in accordance with ANSI M5.2.11, "QA Requirements for the Design of Nuclear Power Plants."
* Procurement Document Control. We find the CPRT procurement document controls acceptable based on the following measures described in the CPRT Program Plan. Procurement documents for services relating to 4
CPRT activities will include appropriate QA requirements. These docu-ments will be reviewed by a CPRT QA Manager. Their technical content                       .
will be reviewed by a' CPRT RTL or his designated representative. These reviews will be documented.                                                         -
i
* Instructions, Procedures, and Drawings. We find the CPRT use of t                        ,
instructions, procedures , and drawings acceptable based on the following nieasures described in the CPRT Program Plan. Procedures or checklists will be used in the performances of inspections, tests, and record reviews. The CPRT Program Plan includes the fonnat and procedu,res for specific action plans and results reports. Implementing p
proce'dures and. instructions have been established and are described or referenced in the CPRT Program Plan. Activities will be accomplished in accordance with the procedures. Acceptance criteria are included j                         in the specific action plans.
* Document Control. We find the CPRT program for document control acceptable based on the following measures described in the CPRT Pro-gram Plan. Procedures have been established to control the issue of I
       ;                      documents. These procedures require that the SRT review and approve i
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                          . action plans and revision to action plans, corrective action recommended by RTLs, action plan result reports, and corrective evaluation reports.
                          . The latest revision of documents are utilized by personnel perfonning the CPRT activities. Changes to CPRT documents are required to recieve the same level of review as the originals.
  '                     '   Control of Purchased Material, Equipment, and Services. We find the CPRT program for the control of purchases acceptable based on the
{                                                                                                       .
j                          following measures described in the CPRT Program Plan. Procurement of services by DAP participants will require that services be performed .
under the total requirements of the CPRT QA program or the procurement l~
will include measures to ensure that such services are provided in l                                                                         Procurement of services by accordance with procurement requirements.
QOC will be made only from organizations en ERC's Approved Source List.
I t
Pre-award surveys will be conducted and personnel qualifications will be reviewed in accordance with an ERC personnel procedure.
Inspection. We find the CPRT controls of the CPRT inspections accept-able based on the following measures described in the CPRT Program Plan.
:.                           Procedures and instructions define the inspection system. Inspectors ll                           are provided the necessary drawings, inspection instructions, accept /
li
!i                           reject criteria, checklists, and forms for documenting the inspection.
i                       Procedures also address requirements for utilizing calibrated inspec-l                        tion equipment. Further, CPRT inspectors are qualified in accordance with ANSI N45.2.6, " Qualification of Inspection, Examination and Test-ing Personnel for the Construction Phase of Nuclear Power Plants."
                                                                  .                    . . . ann        ..._e

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Nonconfomance Control. We find the controls for nonconformances acceptable based on the followir.g measures described in the CPRT Pro-
                                       ~
I                   gram Plan. Nonconformances such as deviations deficiencies will be identified during the conduct of CPRT activities. These nonconfomances will be documented, evaluated, classified, and trended by the CPRT 3
before belg transmitted to the CPSES Project for evaluation and
  )                   disposition.
* Corrective Action. We find the controls for corrective action accept-1 i                able based on the following measures described in the CPRT Program I
Plan. CPSES is responsible for evaluating and determining the correce.
 ]        .
tive action of nonconformances identified by the CPRT and for perform-ing 10 CFR 50.55 (e) reportability. The CPRT RTL's are responsible for determining the adequacy of the corrective actions defined by the CPSES Project. The CPRT may recommend proposed corrective actions to the CPSES Project with approval by the SRT. The CPRT must satify itself
       ,              that tKe'CPSES Project's corrective actions will correct the specific non-c nforming conditions identified by the CPRT and, if applicable, l                    will preclude the recurrance of similiar non-conforming conditions in the future. The CPRT RTLs will perform documented confimatory over-
;l                    views of the implementation of selected corrective actions.
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* QA Records. We find the CPRT controls for QA records acceptable based on the following measures described in the CPRT Program Plan.
Records generated as a result of the CPRT Program Plan will be main-tained at the CPRT central file by the CPRT Program Director. Records will contain the action plan working files, results of analyses, SRT l
!                      meeting minutes, result reports, and personnel qualifications.
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* Audits. We find the CPRT Controls for audits conditionally acceptable based on the following measures described in the CPRT Program Plan.
i                               /.udits will be performed to verify compliance with the implementation l                              of the CPRT's Quality of Construction and QA/QC Adequacy Program and the Design Adequacy Program. Personnel performing the audits will
    !                              be qualified and will not-have direct responsibilities in the areas l                                being audited. Checklists will be used in conducting the audits and results will be documented and reported to the management having                                ,
responsibility for the audited areas. Followup review will be                                     j initiated to assure the proper close out of identified open items.
1
 ..j In addition, the Overview Quality Team will support the Senior Review                    ..
Team by reviewing the results and corrective actions associated with                              -
audits performed under the Design Adequacy and Quality of Construction Quality Assurance Program including those performed by NRC and TUGCO.
In lieu of a formal documented audit program the TRT-ISAP program provides layers of overview of activities and documents thorugh (1) j                              checEs' of activities by the Review Team Leaders to ensure that action plans within their areas of responsibility are being properly imple-H R                                  mented; (2) review verification and approval of the results of imple-(I menting the ISAPs by the CPRT Results Report and File Review Comittee; ll                                 and (3) review and approval of Result Report by the SRT. We find, lll                                 however, a general lack of detail in regard to a systematic audit I
^
                                   , approach of the TRT-ISAP program.                   In this regard a more formal audit program should be established and implemented by the SRT or justification ll                                  should be provided for not doing so.
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i il                   As noted in section 4.1 above, the CPRT Program Plan does not address a number i
u                 - of specific provisions of 10 CFR Part 50, Appendix B. This is acceptable to
  ;                  the staff because these provisions are not applicable to CPRT activities. How-ever if activities whicn normally come under the control of these provisions are initiated by the CPRT, there is a commitment in the CPRT Program Plan that these provisions will be provided as they are appropriate to a given issue. The staff will verify by its inspection of the CPRT Program Plan that these elements are j-                incorporated, if and when needed, into the appropriate ISAPs, DSAPs, instructions, and procedures.
..                   4.3 Conclusion of OA Program                                                            ,.
'h The CPRT management and QA program controls provide for a systematic desciplined approach for carrying out the CPRT Program Plan and documenting the results.
l                 The QA programs associated with implementing the CPRT Program Plan describe adequate QA controls and QA organizational responsibilities. The organizations andpersonsperlormingQAfunctionshavesufficientdefinedresponsibilitiesand 4                    authority to carry out the elements of the QA program. The QA program describes q                    requirements, procedures, and controls that, when properly implemented, meet ti the appropriate provisions of Appendix B to 10 CFR Part 50 except as noted in the area of auditng the TRT-ISAP.
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      <'                              MARIGGIO
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       .                              Trammel
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J                                Comanche Peak SSER 13 5.0 conclusion 4
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: j.             5.0 Conclusion i               The NRC staff evaluated the CPRT's Program Plan and finds it to be comprehen-4 l-              sive in scope and structured to address all existing issues and any future issues which may be identified by external sources. The Program Plan also
{               contains the Applicant's commitment to a set of self-initiated programs I                 intended to assess the adequacy of design and construction of the Comanche Peak
:               Steam Electric Station. Finally, the CPRT Program Plan provides a commitment on the part of the Applicant to resolve staff concerns and demonstrate overall j                plant safety.
4 4
I                The staff's evaluation of the Program Plan included reviews and audits of the 9
l               self-initiated programs intended to evaluate design and the design adequacy and construction of the CPSES. The staff finds these self-initiateu programs to be appropriate mechanisms for evaluating design and construction quality.
Further, the implementation and results of these programs are being documented in sufficient detail to permit current and future in-depth review should this
        ,           be necessary. Implementation of these programs will be audited until completion of these actjvities with results to be documented in a future SSER.
[                Staff acceptance of the self-initiated programs is intended to indicate that an acceptable process has been proposed; an acceptable framework provided for its j                implementation; and a commitment made to document this process, its results and conclusions in a manner amenable to future audits. Further, the staff's evaluation finds the issue-specific and discipline-specific action plans generally responsive to external source issues identified at this time.
The Applicant has' indicated that sampling as used in the CPRT program is
[                   intended to ensure that a systematic approach is used in tne resolution of i,                  specific issues and in the execution of the self-initiated evaluation.          The p                   staff finds that the Applicant's general sampling approacn is acceptable.
Specific application of sampling will continue to be reviewed and audited by j
the staff during the implementation of the program. The staff notes that some l
areas have already been identified for 100 percent reevaluation such as piping and cable trays and conduit supports.       The staff concurs with the Applicant's intent to completely reevaluate these areas.
04/01/86                                5-1                         CP SSER 13 SEC. 5 w , ,, y_,__                    -          - -
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Finally, although concerns are noted in this report, the staff finds the Plan appropriate and acceptable for its in' tended application. Because the CPRT Program Plan is the Applicant's framework for completely addressing all j                        currently identified issues and is the mechanism for the identification, 1
evaluation, and resolution of any future issues, the Applicant should resolve
   ]                        the staff concerns in a future plan revision.
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04/01/86                               5-2                        CP SSER 13 SEC. 5
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CP SSER 13 APP. A 4
Requestor's ID:
ORDAZ Author's Name:
l 3                   . Trammell Document Comments:
g Identification of all Components of CPRT Program Plan
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1 Appendix A - Identification of all Components of the CPRT Program Plan,
   ;                                including Appendices, ISAP's and DSAP's by Revision Number I
Although reference is made in this evaluation to " Revision 3" of the CPRT Program Plan, this document actually consists of numerous documents, each with its own revision number. In addition, " Revision 3" is considered to include l
g                four additional letters received after Revision 3 was issued on January 27, 1986. Therefore, for purposes of this assessment, Revision 3 is considered to consist of the basic Revision 3 submittal of January 27, 1986, plus the follow-ing:     1) Appendix D, CPRT Sampling Approach, submitted on January 31, 1986; 2)
]                Appendix E, CPRT Procedure for Classification, Evaluation, and Tracking of I             Specified Design or Construction Discrepancies Identified by the CPRT, sub-l             mitted on February 7, 1986; 3) the Testing Issue - Specific Action Plans l             (ISAPs), submitted on February 28, 1986*, and 4) Appendix G, Overview Quality 1
   ^
Team, submitted on February 28, 1986.
Identified below is the revision number for each appendix, ISAP, DSAP, and i             attachment contained in Revision 3 of the CPRT Program Plan as of the date of l             this evaluation.
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* ISAP III.a.1 was not included.
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03/26/86                                         A-1               CPSSER 13 App. A.
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Revision g           QA/QC ISAPs I.d.1        QC Inspector Qualifications                                          2 3           I.d.2       Guidelines for Administration of QC Inspector Test                                                       2 s            I.d.3        Craft Personnel Training                                             0 i          VII.a.1      Material Traceability                                                 1 VII.a.2       Non-Conformance and Corrective Action System                                                         1 l           VII.a.3       Document Control                                                     1 l          VII.a.4      Audit Program and Auditor Qualification                               1 j           VII.a.5       Periodic Review of QA Program                                        1 VII.a.6       Exit Interviews                                                      1 VII.a.7       Housekeeping and System Cleanliness                                  1 VII.a.8       Fuel Pool Liner Documentation                                        1 f          .VII.b.1     On-Site Fabrication                                                   1 VII.b.2      Valve Disassembly                                                     1 t          VII.b.3       Pipe Support Inspections                                             1
   $          VII.b.4       Hilti Anchor Bolt Installation                                       1
    ,         VII.b.5       DELETED l          VII.c         Construction Reinspection / Documentation Review Plan 1
[                                                 .
DSAPs
.i VIII         Civil / Structural Discipline Specific
.                                        Action Plan                                             1 IX           Piping and Support Discipline Specific Action Plan                                             1 i                         X            Mechanical Systems and Components Discipline Specific Action Plan                         1 XI           Electrical /I&C Systems and Components
    .                                    Discipline Specific Action Plan                         1 03/26/86                                      A-4                  CPSSER 13 App. A.
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Program Plan                                       3 Appendix A                 Design Adequa'cy Program Plan                       1
  ;J          Appendix B                 Quality of Construction and
 ']                                      QA/AC Adequacy Program Plan              -
3
  ]           Appendix C                 Action Plans Electrical ISAPs I.a.1        Heat-Shrinkable Cable Insulation Sleeves            4
 -l                         I.a.2         Inspection Reports on Butt-Splices                 4
.j                          I.a.3        Butt-Splice Qualification                           4
[                           I.a.4        Agreenent Between Drawings and Field
   -l                                    Terminations                                        4 I.a.5        NCRs on Vendor Installed Amp Terminal Lugs          4
    ?                       I.b.1        Flexible Conduit to Flexible Conduit Separation                                          4 I.b.2        Flexible Conduit to Cable Separation                4 j'
I.b.3        Conduit to Cable Tray Separation                    4 I.b.4        Barrier Removal                                     4 Civil / Structural ISAPs I.c          Electrical Conduit Supports                         3
    -                       II.a         Reinforcing Steel in the Reactor Cavity 3
II.b         Concrete Compression Strength                       3 II.c         Maintenance of Air Gap Between Concrete Structures                                          3
    ^
II.d         Seismic Design of Control Room Ceiling Elements                                            3
    ;                       II.e         Rebar in the Fuel Handling Building                 3 e
a 03/26/86                                  A-2                    CPSSER 13 App. A.
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4,f                                III.a.1      Hot Functional Testing (HFT) Data Packages                        *
    ;                              III.a.2      JTG Approval of Test Data                                         3
  ]                                III.a.3      Technical Specification for Deferred Tests                        3 l
III.a.4      Traceability of Test Equipment                                   4
  ~j                               III.b        Conduct of the CILRT                                             4 u
   'I                              III.c        Prerequisite Testing                                             4 j                              III.d        Preoperational Testing                                           4 ij                                IV.          Reserved for Protective Coatings, however,
 ' ,j                                           SSER-9 declassified protective coatings and negated the need for a protective coatings ISAP. Paint quality concerns are being
    ;                                           addressed under the Quality of Construction i                                           Program.
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 's                                Mechanical ISAPs V.a          Inspection for Certain Types of Skewed Welds
   .;                                           in NF Supports                                                    2
    }                              V.b          Improper Shortening of Anchor Bolts in Steam
.i                                              Generator Upper Lateral Supports                                  2 V.c          Design Consideration for Piping Systems i                                           between Seismic Category I and Non-Seismic l   2' Category I Buildings                                              2 V.d          Plug Welds                                                        2 i
:                              V.e          Installation of Main Steam Pipes                                  2 VI.a         Gap between Reactor Pressure Vessel h                                               Reflective Insulation and the Biological Shield Wall                                                       2 VI.b         Polar Crane Shimming                                              2 l
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* ISAP III.a.1 was not included 03/26/86                                         A-3                       CPSSER 13 App. A.
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'j          I.d.2       Guidelines for Administration of QC Inspector Test                                                     2 I.d,3       Craft Personnel Training                                           0 i         VII.a.1-    Material Traceability                                              1 VII.a.2     Non-Conformance and Corrective j                    Action-System                                                      1 VII.a.3     Document Control                                                   1 lj          VII.a.4     Audit Program and Auditor Qualification                            1
   !'       VII.a.5     Periodic Review of QA Program                                      1
   ;        VII.a.6     Exit Interviews                                                    1
   ;        VII.a.7     Housekeeping and System Cleanliness                                1 VII.a.8     Fuel Pool Liner Documentation                                      1 4
VII.b.1     On-Site Fabrication ~                                              1
-l VII.b.2     Valve Disassembly                                                  1 l
VII.b.3     Pipe Support Inspections                                            1
,i          VII.b.4     Hilti Anchor Bolt Installation                                      1 VII.b.5     DELETED
'{
I        VII.c       Construction Reinspection / Documentation t-l_                    Review Plan 1 DSAPs
   .b l                     VIII        Civil / Structural Discipline Specific Action Plan                                            1 IX          Piping and Support Discipline Specific Action Plan                                            1 i                     X           Mechanical Systems and Components Discipline Specific Action Plan                        1
    >                    XI           Electrical /I&C Systems and Components Discipline Specific Action Plan                       1 A-4                 CPSSER 13 App. A.
03/26/86
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1 Appendix D                CPRT Samplir.g Approach                              1 Appendix E                CPRT Procedure for Classification, Evaluation,
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  ]
Construction Discrepancies Identified by l                                the CPRT                                             1 Appendix F                CPRT Interfaces                                      1
  ;4j      Appendix G                Overview Quality Team                                0 j                     Attachment 1: CPRT Third-Party Quality Assurance Program         0
  ';                     Attachment 2: Management Program Plan for the QA/QC Review Team                                      4 j                    Attachment 3: Design Adequacy Review Team Quality
:                                    Assurance Program                                0 l
Attachment 4: Verification of Issue-Specific Action Plan l
j                                    Working Files                                    0
  .;       Appendix H                CPRT Procedure for the Development, Approval, l                                and Confirmation of Implementation of I                                Corrective Actions                                   0 I
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      ;                             Document Name:
I CP SSER 13 APP.B s
j                              Requestor's ID:
ORDAZ l
     ;                              Author's Name:
l                              CTrammell "i                                  Document Comments:
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1 Appendix B -~      Items to be addressed by Applicants during the " implementation phase of certain ISAPS
:1 This Appendix discusses only those ISAPs concerning which the NRC staff has
  'd                comments. These should be addressed by the Applicants during the
    ')              implementation phase of each ISAP. The NRC staff has no comments on the remaining ISAPs which are acceptable for implementation as submitted.
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j             The NRC staff will examine the Applicants' response to these comments as part
  'l                of its inspection program for the CPRT Program Plan implementation of all j               ISAPs.
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* Electrical / Instrumentation Issues and Control Systems and Components I.a.1 Class 1E Heat Shrinkable Cable Insulation Sleeves Description 1
Heat-shrinkable-insulation sleeves are required for uninsulated butt splices,
 ,               480-volt and 6.9 kv motor terminations, at cable reduction splices,and at electrical penetration assembly cable connections. The NRC concern as noted in SSER No. 7, Electrical and Instrumentation Categories 1 and 6, centered on the lack of awareness by craft and inspection personnel as to where the
:i sleeves should be installed and the high percentage of missed or improperly documented inspections requiring witnessing.
: i.           Staff Comment l
l             This ISAP is adequate to establish the accuracy and completeness of i
documentation records for the heat shrinkable sleeve issue with respect to completed construction items since it commits to retraining after revision of the applicable procedures.       However, since the cause of the concern has been identified as inadequate personnel training, additional
   )             training along with revised procedures must be provided and the ISAP should be expanded to include provisions for inspecting future electrical construction to ensure the effectiveness of the additional training and procedure revision.
{             I.a.2   Inspection Reports on Butt Splice Inspection Reports i
Description i
j            QC inspection reports for 12 butt splices were found to be deficient in one or more respects as noted in SSER No. 7, Electrical and Instrumentation Category l
l             1. Nine reports used a post-installation inspection form instead of a witnessing-type inspection form. Six of these nine reports did indicate        that I             installation of the heat shrinkable sleeves had been witnessed, but did not
'I               indicate that such witnessing was required.       The other three of these nine 03/31/86                                    B-2                          CP SSER 13 APP.B i                                                                                       n.       _ ._ . s.,n w ---        -m-               m~xpv     .

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iI forms did not indicate that installation of the splices had been witnessed.
{         The remaining three reports using the correct form indicated that witnessing of the installations of heat shrinkable sleeves was not applicable (or required). the NRC recommendation was that all QC inspections requiring j          witnessing for splices be performed and properly documented, and that all but j          splices be identified on design drawings and physically identified within the l           appropriate panels.
Staff Comments This ISAP is' unsatisfactory both in its approach and in the lack of quantita-tive commitments for inspection and pullout testing of existing butt splices because it presumes that they are satisfactory rather than demonstrating their j          adequacy. The ISAP should be revised to state explicitly the number of butt splices to be inspected and pullout tested, to identify the approach to resolution of documentation deficiencies and to identify each butt splice.
i j           I.a.3    Butt Splice Qualification
 -l q
Description On a limited basis as described in FSAR Amendment 44, the practice of butt splicing cable conductors in panels has been permitted subject to:
l         (1) adequate provisions in installation procedures to verify the operability l'         of circuits using butt splices; (2) qualification of the wire splices for anticipated service conditions, and (3) staggering of the splices so that they
,f           are not adjacent to or pressing against one another in the same wire bundle.
j            In addition, reinspection of all existing butt splices was to be accomplished li           using adequate installation and inspection procedures. As noted in SSER No.
'~
7, Electrical and Instrumentation Category 1, circuits containing butt splices were to be tested, and retested if reworked, during plant preoperational and startup tests to assure their operability.
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   !             Since all butt splices in various panels will be inspected to assure that no butt splice touches another one within a wire bundle and rework splices in nonconforming wire bundles will be reworked, this ISAP for butt splice qualifi-cation is adequate to address this issue.        However, functional operability of
 ]
i l             those circuits containing butt splices must be demonstrated by the proposed use l               of' circuit continuity checks.
p           .
 .I I . b.1 Flexible Conduit Separation I
Description l
1 l
Industry criteria, such as IEEE Std. 384-1974, have established minimum
}
..               separation distances to be maintained between redundant safetv-related cables j             and between safety-related and nonsafety-related cables within control room
~!               panels and cable spreading room termination cabinets. Lesser separation 1
q                distances may be justified if supported with engineering analysis of the involved circuits and components. The TRT, as noted in SSER No. 7, Electrical and Instrumentation Category 3, observed that flexible conduits containing safety and nonsafety cables within these panels were in direct physical contact, and could not find evidence that analyses had been performed to justify this deviation from requirements in the industry standards.
f j                Within main control room panels, for example, flexible conduit identified with one separation division (orange color) has been bundled together with flexible conduit identified with the redundant separation division (green color).        In
;'               this instance, a technical justification for the lack of one inch separation distance between conduits containing safety-related circuits has not been
:             provided.
.i               A reinspection of all panels containing redundant safety-related conduits or
   ;             both safety-related and nonsafety-related conduits was required to either t             correct each violation of the separation criteria or to demonstrate by analysis the acceptability of the conduit as a barrier.
03/31/86                                     B-4                          CP SSER 13 APP.B i
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                        - Since conformance of internal panel cables and conduits to applicable industry separation criteria is required by this ISAP, it is responsive to the issue of 3                        adequate separation of flexible conduits in main control room panels and
  'E vertical panels in an acceptable manner. However, it does not specifically address the issue of SERVICAIR flex in areas outside the main control room.                                     In d                        Sections 3.0 and 4.1.5 of this ISAP the Applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installa-
]                        tions.       For any installations outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will
;-l j                        be determined on a case-by-case basis.             The staff will find this acceptable and i8                       responsive to the action items stated in SSER 7 on confirmation that "two or j   '
:;                       more trains" is interpreted to mean any panel, termination cabinet, etc.,
ij                       containing two or more Class 1E and non-class 1E circuits.
I.b.2       Flexible Conduit to Cable Separation 1
Description This particular NRC concern as noted in SSER No. 7, Electrical and Instrumen-tation, Category 3, is similar in many respects to ISAP 1.b.1 regarding the
]                        accomplishment of minimum separation distances between flexible conduits within d
main control room panels and vertical panels.             In ISAP 1.b.2, the TRT identi -
^
fied twenty-one cables within four panels where the minimum separation distance J;                       of 6 inches specified in industry standards had not been maintained relative to SERVICAIR flexible metal conduits containing safety-related cables.
b                        NRC required that a reinspection be performed of main control room panels,
:                  other panels located in the control room, and panels located in other areas of the plant where cables and flexible conduit had been used. TUGC0 was i                        requested to either correct any separation criteria violations in these panels
      .                   or demonstrate that the flexible metal conduit was an adequate barrier in p
03/31/86                                         B-5                                      CP SSER 13 APP.B D
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accordance with IEEE Std. 384-1974.       If the flexible conduit could not be shown to be a suitable barrier, a minimum separation distance of 6 inches was to be' maintained between cables and flexible conduit within the panels.         In addition, drawings and related documents were to be revised to indicate the
  ]                revised minimum separation distances.
1 j                Staff Comments Since conformance of internal panel cables and conduits to applicable industry separation criteria is required, this ISAP is adequate for assuring compliance with minimum separation requirements for main control room panels and vertical panels.
The ISAP, however, does not explicitly address the issue of SERVICAIR i              flex in areas outside the main control room. In Sections 3.0 and 4.1.5 of the Action Plan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installations outside the control room the applicability of the separation
 ]
j!                criteria developed for the control boards and vertical panels will be
    !               determined on a case-by-case basis. The staff will find this acceptable and 1
    '               responsive to the action items stated in SSER 7 on conformation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc.
containing two or more Class 1E circuits, or Class 1E and non-Class 1E circuits. Also, in Section 4.5.1 of the ISAP, the acceptance criteria is stated as " testing and/or analysis". This is inconsistent with the other sections of the plan which describe testing and analysis, combined, as the means of demonstrating the adequacy of SERVICAIR flex as a barrier, and is i               therefore not. acceptable.
j                I.b.3  Conduit to Cable Tray Separation Description i
!j                  A minimum s2paration distance of one inch between an enclosed rigid conduit and open ladder type cable trays was established by Gibbs & Hill in specification 2323-ES-100; however, the Gibbs & Hill analysis supporting 03/31/86                                    B-6                           CP SSER 13 APP.B II e a . 0,-~ __.s >                        #u_                 m     .~.    -

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:        the NRC for acceptability.         IEEE Std. 384-1974 requires the installation of a barrier between a conduit and an open cable tray unless greater minimum
 >            separation distances are maintaine'd or are otherwise justified by an
 -{
engineering analysis. The TRT, as noted in SSER No. 7, Electrical and 4          Instrumentation Issues, Category 3, requested that the Gibbs & Hill analysis supporting the one inch separation distance be submitted for NRC review in 1            sufficient detail to permit an independent evaluation of the establishment of this criterion.
 ]
9 l          Staff Comments j           Since this ISAP commits to compilation, review, and approval of the applicable
{          documentation to support the one inch minimum separation distance between
 .j           rigid conduits and open cable trays, and submittal of this material for NRC
    '         independent review, this ISAP is responsive to concerns raised by the staff.
The plan is therefore, acceptable.        Final resolution of this issue, however, is f
j            contingent on the staff review and acceptance of the engineering justification analysis. In the event the justification is found not acceptable, the ISAP will have to be expanded to cover conduit and cable tray modifications committed to in Section 4.6 of this plan.
i iI I.b.4       Barrier Removal l
i
'i
:{            Description As noted in SSER No. 7, Electrical and Instrumentation, Category 3, the
'i            TRT inspection of auxiliary feedwater panel CP1-EC-PRCB-09, found two barriers used to separate redundant devices and cables missing. Within panel
{
CP1-EC-PRCB-03, field wiring was not separated by the minimum separation distance of 6 inches.
:l 03/31/86                                         B-7                          CP SSER 13 APP.B
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Staff Comments 1
i
,                    Since this ISAP commits to correction of two identified separation violations, it is responsive to concerns raised by the staff for main control room panels.
To assure that existing separation violations have been detected in a timely manner, the physical inspection portion of the ISAP should be expanded to include the cable spreading room termination cabinets and safety-related 1
instrument' racks located throughout the plant. In addition, Section 4.5 of the plan is not acceptable. The applicant should explain what is meant by meeting "the intent" of IEEE-384 and Regulatory Guide 1.75 requirements, and why this is acceptable. In the absence of an adequate explanation, the Ilq                  applicant should commit to " meet" the requirements of the above documents.
1 1
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Testina Issues t
4 III.a.1 Hot Fun,ctional Testing l
'1 1               Revision 3 of this ISAP has not been provided by the applicant.
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V.a Inspection of Certain Types of Skewed Welds in NF Supports
    -       Description c
1 This ISAP addresses actions required by SSER No. 10, Mechanical and Piping Category 3, allegation AQW-73, concerning the failure of TUEC to provide documentation that certain types of skewed fillet welds were reinspected
  ~
correctly (welds that exhibited a skewed condition; i.e., interfaces of curved sections).
i l        Staff Comments j
  .j       The staff conducted an evaluation of the CPRT Program Plan for ISAP V.a and found the action plan to be generally responsive to the issues raised since the plan addressed inspection methods, procedure revisions, and reinspections.
The staff, however, requires assurance that the root cause of the issue and its l
j        generic implications are properly addressed, independent of whether any safety l    significiant deficiencies are found. The staff perceives the root cause and generic implication aspect of this issue as important, since the inspection o
techniques for skewed welds had been addressed previously by TUEC, thus suggesting potential generic implications.
1 f    In addition, the response by the CPRT to Item 1 of the staff letter of
 -}        September 30, 1985 concerning ISAP V.a requires further explanation concerning
      !    the intent of' procedure QI-QAP-11.1-28 with respect to the inspection of t
';         skewed welds.
1 4
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V. b Improper Shortening of Anchor Bolts in Steam Generator (SG) Upper Lateral Supports Description
          ,             This ISAP addresses actions required by SSER No. 10, Mechanical and Piping Category 18, allegations AB-12 and AQB-3, concerning anchor belts in the steam generator upper lateral support that may have been shortened during instal-lation without proper authorization to less than the length shown on the design drawings. TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations.
    . ,i Staff Comments The staff concludes that if ISAP V.b is implemented as stated in the Plan, the j             areas related to the original concern can be identified and resolved based on sound engineering practice, FSAR commitments and NRC guidelines.             However, the
:l staff has raised a concern that the use of trends of inspection data to deter-mine the need for additional inspections must be reviewed on a case-by-case basis rather than collectively in order to determine if the trends require additional inspections.
V. d Plug Welds
;                       Description
'l This ISAP addresses actions required by SSER No. 10, Mechanical and Piping                     .
ll.
category 4, allegation AW-14, concerning incorrectly located bolt holes in l
baseplates, pipe supports, and cable tray supports that were " plug welded"
!i
!!                      without authorization, with undocumented weld filler metal and without quality
:s Jj                      control inspection.                                                                       .
l i
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i
   ,              Based on its evaluation of ISAP V.d the staff concluded that the ISAP was unacceptable. The staff found that the proposed combination of third-party overview of TUEC engineering evaluation of uncontrolled plug welds identified during the inspections would not provide reasonable assurance that the structural adequacy of CPSES pipe supports, baseplates and cable tray 4
supports would not be compromised by uncontrolled plug welds. This is based upon the fact that the proposed inspection technique was not fully
(               effective and consequently, the confidence level achievable by the may be 3               considerably less than the desired 95/5 level.
i l
l             The staff suggests that bounding analyses may be required to assess the i             generic effects of uncontrolled plug welds on the ability of pipe supports, baseplates and cable tray supports to serve their intended function as a
j             stated in SSER No. 10.
i
:             V.e Repositioning of the Main Steam Line l
Description This ISAP addresses actions required by SSER No. 10, Mechanical and Piping               ,
Category 11, allegation AP-13, concerning the 32-inch main steam line that may have been forced into position by the polar crane and 3-ton come-alongs.
Tension induced in the line as a result of movement during the alleged incident may still be present in the line.
'i t
Staff Comments i             For the repositioning of the main steam line, the specific engineering
    ,             evaluation and generic study described in this ISAP provides an acceptable j                 basis for resolution of the issues and concerns resulting from the TRT i,
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investigations of allegations regarding forced movement of the main steam line-and improper welding of. temporary supports.
   }
]             However, 'the staff has concerns that:
(1) The third party review of the RCLA work should not be limited to a' verification only. Provisions for additional third party investigations should be provided, particularly since RCLA participation has ended.
  ,1 I
  .i          (2) Although the CPRT has indicated that its investigation performed as part of ISAP V.e.,     Revision 3, have concluded that the sequence of events described in SSER No. 10 relating to main steam line incident is not j                correct, the generic implications of settlements of supports and stresses j                due to hydrostatic testing and flushing activities will still be required to be evaluated by TUEC, since the sequence of events described by the
   !               TRT could have occurred elsewhere.
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Civil / Structural Issues
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1              I.c Electrical Conduit Supports t                                                                                               .
Description
     }
   -1
    .1 This ISAP addresses actions required by SSER No. 8, Civil and Structural
[               Category 14, allegation AE-17, on the installation of nonsafety-related conduit 1             supports for conduit two inches in diarneter or less in seismic Category I areas of the plant. No evidence could be found by the TRT that substantiated the adequacy of the installation, or in demonstrating that their failure would not adversely affect the function of safety-related components or cause injury to l           plant personnel.
i Staff Comments l
  ;{              The general scope and methoodology contained in this ISAP is responsive to concerns raised by the staff. However, in clarifying the disposition of rejects f
identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Sections 4.1.2.1 and Section 4.1.2.5 of ISAP I.c. The intent of this statement relative to sample expansion and compliance with Appendix D of the Plan is unclear.
Clarification and/or justification of the statement in Section 4.1.2.1 and
,j                4.1.2.5 is needed.
  .I
:t lI                II.a Reinforcing Steel in the Reactor Cavity
 -s l!
E                 Description l'                This ISAP addresses actions required by SSER No. 8, Civil and Structural l
l l
Category 6, allegation AC-38, on a documented occurrence in which reinforcing steel was omitted from a Unit 1 reactor cavity concrete placement between the
!                 812-foot and 819-foot-1/2-inch elevations. Although the omission was 1
['                documented, justification supporting the engineering conclusion to "use as is" l;                was not available.
i 03/31/86                                  B-14                                      CP SSER 13 APP.B
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1 Staff Comments 1
j        The general scope and methodology contained in this ISAP is responsive to the concerns raised by the staff. However, the plan should address the corrective a
actions to be taken if some structural members are deficient when reinforcing j        steel was omitted. Furthermore, the logic diagram in the attachment to the ISAP is incorrect. The second vertical branch at the left and the s-shaped j        branch near the upper right hand corner should be deleted.
1 II.c Maintenance of Air Gap Between Concrete Structure Description This ISAP addresses actions required by SSER No. 8, Miscellaneous Category 2, where the TRT identified TUEC's lack of control of debris in critical spacings between components and/or structures. TUEC had not adequately demonstrated compliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which required separation of Seismic Category I buildings to prevent interaction during an earthquake.
i l        Staff Comments i
  'j         The action plan is responsive to concerns raised by the staff. However, the flow diagram given in the ISAP should.be clarified. There is .no indication
 !!          where item A, prcfile of as-built condition for selected rotofoam form work
}l           areas and for selected metal form work areas, and the staff does not
'{           understand designation C.
I
,,           II.e Rebar in the Fuel-Handling Building I
d Description
  'I l'           This ISAP addresses actions required by SSER No. 8, Civil and Structural Category 15, allegation AC-15, of an alleged instance of unauthorized
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cutting or rebar in the' Fuel , Handling Building due to the depth of core j                drilling.
31 Staff Comments j
'.i                The approach described in this ISAP is responsive to concerns raised by the staff. However, the plan should address corrective actions to be taken if cut
                  - rebar produces an unacceptable structural member.              Furthermore, the logic diagram given in the ISAP is incorrect, in that there are no arrows connected
:                  to the lower right-hand box.
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Quality Assurance / Quality Control Issues i
I.d.3   Craft Personnel Training Description The objective of this ISAP is to respond to NRC concerns in SSER No. 7, Electrical and Instrumentation Category 2, by evaluating the Craft Training Program to determine if it was adequate in the past, and also to
   ,             evaluate the current program.
The requirements of ANSI N45.2-1971 set forth, in part, that personnel q               performir.g activities affecting quality are trained and indoctrinated to, assure that suitable proficiency is achieved and maintained. To determine l
that these requirements are implemented, this ISAP has formulated a Special f
Evaluation Team (SET), comprised of individuals with no direct responsibility
                'to CPSES, who will perform the evaluation of the Craft Training Program including the craft personnel selection, training, assignment and retraining.
Staff Comments The staff finds that the ISAP adequately addresses the NRC's concern pertaining to craft training. and implementation of the plan will j             determine compliance with FSAR commitments. The CPRT approach will provide a l            broad-scope in-depth evaluation of the essential elements of the training 1
     .           program and will determine the effectiveness of both past and current training I
    ,            and its impact on the construction of the physical plant, and compliance with li ANSI N45.2.6 and 10 CFR 50, Appendix B, Criterion II, as committed to in the FSAR. Accordingly, the staff concludes that this ISAP is acceptable.
However, Section 4.4 of this ISAP must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of 9                 the plan, the staff will confirm that the revision has been accomplished.
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  ,              VII.e.3 Document Control Description Problems as noted in SSER No. 11, Section 4.2 titled " Document Control" were identified over a period of time in the implementation of the Document Control Program during the construction phase of CPSES. The scope of this ISAP is to provide confidence that the Document Control Program problems did not impact the installation and testing of hardware and that current design requirements are satisfied. The concerns identified in this Plan are addressed by review and evaluation of the results of the implementation of ISAP III.d "Preoperational i
j                Testing" and ISAP VII.c " Construction Reinspection / Documentation Review Plan" l              to determine if deficiencies identified under those plans are attributable to Document Control problems. Implementation of the action plans requires e
verification that the latest design information (e.g., drawings, design change authorizations and component modification cards) is used in the preparation of checklists used in the reinspections and documentation reviews. Program and
]'               procedures will be evaluated for adequacy against the applicable sections of the FEAR and 10 CFR 50 Appendix B Criterion VI.
Staff Comments l
     }
The methodology of the Action Plan along with other actions. plans adequately addresses the NRC's concerns regarding document control. However, Section 4.4 i           of this ISAP must be revised to comply with the Program Plan, Attachment 3 in j             order to maintain consistency. During implementation of the Plan tne staff will confirm that the revision has been accomplished.
VII.a.4 Audit Program and Auditor Qualification Description o
This ISAP addresses the NRC's concern in SSER No. 11, QA/QC Section P,
'I               Subsection 4.7, regarding the adequacy of the TUGCO Audit Program from its
   ,             inception to the present and will evaluate the program to determine the effect of any identified inadequacies on the Quality Assurance Program and/or the 4
03/31/86                                      8-18                        CP SSER 13 APP.B 35--            gn ',   w
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l l:          physical plant, and to recommend appropriate corrections and/or improvements
   ;         to the current program. This evaluation will be accomplished through a review i           which will address audit planning and scheduling, preparation, performance, reporting, followup and closeout, and audit personnel qualification.
 .)          Staff Comments                                                                                   -
4 9
l J           Since FSAR commitments are identified in the plan, and that implementation of the plan will cover sufficient scope and depth to determine compliance with j           those commitments and any resultant impact on construction quality, the staff 4
concludes that this ISAP is acceptable.       However, Section 4.4 of this ISAP must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of the plan, the staff will confirm that the revision has been accomplished, and the staff will also confirm that the CPRT's evaluations have considered all' revisions of the PSAR/FSAR and the TUGC0 QA Audit Program and Procedures.
 'l VII.a.S Management Assessment Description This plan addresses the NRC's concern in SSER No. 11, QA/QC Section P,
 ,5          Subsection 4.7, regarding the TUGC0 management assessment of the effectiveness i
   !         of implementation of their QA Program during construction of CPSES. The issue f         arose because of TUGCO's failure to implement periodic management review of QA
   $         Programs in compliance with 10 CFR 50, Appendix 8, Criterion II, QA Program,
   !         which states in part:       The applicant shall regularly review the status and adequacy _of the Quality Assurance Program.
'l           Staff Comments i
The staff finds that this plan is responsive to the action identified by the
!l NRC, which requested that the applicant propose an action plan that will ensure that such problems a lack of a management assessment program, do not occur in lf 8
03/31/86                                    B-19                            CP SSER 13 APP.B 9    9
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  )j                  the future. The plan methodology adequately describes a viable approach to j                 establishing a management review program. With regard to additional action identified by the NRC that the applicant evaluate the TRT's findings and j                   address potential safety significance, root cause, generic implications and collective significance, this plan s.tates that these factors are addressed in 1                   other ' hardware and programmatic ISAPs and the self-initiated ISAP VII.c. The i
staff finds that this is a satisfactory response to the action identified.
Based on this evaluation,.and the plan's determination of compliance with 10 CFR 50, Appendix B, Criterion II, the staff concludes that this ISAP is q                   acceptable. 'However, Section 4.4.1 of this ISAP must be revised to comply with the Program Plan, Attachment 3 in order to maintain consistency. During implementation of the plan, the staff will confirm that the revision has been accomplished.
VII.a.6 Exit Interviews
  'l                  Description 4
I The actions required by SSER No.11, QA/QC Category 7, allegation AQ-133, to determine if TUGC0 management has now established an effective program which 4
i                  encourages employees to voice concerns regarding safety and which seriously I
j                  evaluates these concerns.
i i
   !                  Staff Comments t
,1 The staff notes that there is no regulatory position that requires the
.l                    applicant to have a formal exit interview program; therefore, there is no
!!                    standard to enable a comparison of the applicants program for compliance.
However, the staff has determined that proper implementation of this plan
'i                    should establish adequate measures to address and resolve employees' concerns
,l                    and to identify quality and safety implications. However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
if 03/31/86                                    B-20                         CP SSER 13 APP.B i -.                                                                                 -
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[      VII.a.7 Housekeeping System Cleanliness Description q         The actions required by SSER 11, QA/QC Category SC, allegation AQ-54, pertaining i         to housekeeping and system cleanliness to determine the validity of the 1
j         current housekeeping system and system cleanliness program for Units 1 and 2.
}          Results of other action plans, procedural requirements, surveys, etc., will be analyzed to determine any impact on hardware and programmatic implications.
Staff Comments 4
The staff has determined that the housekeeping and cleanliness concern is adequately addressed and that proper implementation of the plan should resolve i       the issue and determine compliance with the FSAR. However, Section 4.4 of the Action Plan must be revised to comply with the Program Plan, Attachment 3, in order to maintain consistency.
VII.a.8 Fuel Pool Liner Documentation Description The actions required by SSER No. 11, QA/QC Category 6, Allegations AQ-55 and
   ;.      AQ-78, regarding the applicants' inability to maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and l-  '
inspection and pertains principally to operations travelers and related j       documentation.
   }
i       Staff Comments i
The staff concludes that this plan is acceptable, since proper implementation o
t       of the plan should resolve the issue and that appropriate criteria are used to
.i
,;         determine compliance with 10 CFR 50 Appendix B even though these criteria are not an FSAR commitment.
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However, Section 4.4 of the Action Plan must be revised to comply with the
            ^
Program Plan, Attachment 3 in order to maintain consisten::y.
  .'i         .
4
  ")                 VII.b.1 Onsite Fabrication                                                -
d)
  -                  Description d               This ISAP addresses the actions required by SSER No. 11, QA/QC Category 58, allegations AQ-17, AQ-19 and AQ-138, to resolve the NRC's concern regarding l              the procedural and management control of the fabrication shop work activities
      !              at CPSES.
I A
Staff Comments The staff determined that proper implementation of the plan should adequately i
resolve the issue and determine FSAR compliance. However, Sections 4.3., 4.4 f               and 4.5 of the Action Plan must be revised to comply with the Program Plan,
  .}                 Appendix E, and Attachment 3, respectively, in order to maintain consistency.
 ~!
VII.b.2 Valve Disassembly l                    Description
.l                                                                           .
I
{
The actions required by SSER No. 11, QA/QC Category SA, allegation AQ-52, to ll                    resolve the concern regarding valve assembly / disassembly and determine the i)                    adequacy of procedures that controlled the disassembly / reassembly process.
'i i
l               Staff Comments i
The staff has determined that proper implemeritation of the Plan's methodology f
1               should resolve the issues, however, the Plan must contain provisions to inspect i               for the interchange of critical valve external parts (e.g., bonnets) as well as internal parts. Additionally, Sections 4.2 and 4.6 of the Action Plan must be revised to comply with the Program Plan Attachment 3 in order to maintain
;                     consistency.
03/31/86                                  B-22                          CP SSER 13 APP.B
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   ,       VII.b.3 Pipe Support Inspections I
 /         Description j         This ISAP addresses the actions required by SSER No. 11, QA/QC Category 8, a
allegation AQ-50 regarding the adequacy of QC as-built inspections of pipe supports.
 ]                                                          _-
d          Staff Comments h         The staff has determined that the NRC's concern is correctly identified I         and that proper implementation of the Plan should adequately resolve the issue. The staff finds, however, that although the Plan contains sufficient j        information to determine acceptability /non-acceptability of the items i        reinspected, the Plan lacks identification of the Codes / Standards and FSAR commitment which are used as comparisons to resolve the issue (e.g.,
inadequacy of QC inspections) and to determine compliance. Accordingly,
{_
j          Section 4.5 of the Action Plan must be revised to comply with the Program Plan Attachment 3 in tM identification of Standards / Acceptance criteria in order f          to maintain censistency.
t VII.b.4 Hilti Anchor Bolt Inspections
.!         Description 1
:       This ISAP addresses the NRC's concern in SSER No. 11, QA/QC Category j        8, allegation AQ-50, regarding Hilti anchor bolt installation on pipe supports 1
  ;        and electrical raceway supports.      The objective of this Action Plan is to j          assure the construction quality with respect to Hilti anchor bolt installation.
   .       Implications resulting from the TRT findings will be resolved by reinspection
   ,       for safety-significant attributes of Hilti bolts.
ll t Staff Comments
   ;       The staff found that applicants correctly identified the issue and the Plan's I!         methodology is adequately descriptive of the activity that is essential to 03/31/86                                   B-23                          CP SSER 13 APP.B
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t j                          evaluation and resolution of the issue. The percentage of torque used in the
* l{                         torque verification program is an issue of concern that will be subject to
      ,                      staff review during implementation. Accordingly, the staff concludes that this ISAP is acceptable. However, of the Action Plan Section 4.6 does accurately identify the type of document from which the acceptance criteria will be derived.
j                       Those specific documents, of necessity, were used to establish the inspection attributes. Therefore, discrete identification is known. Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 of this ISAP has been revised to comply with the Program Plan, Attachment 3 in order to main-tain consistency.
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CP SSER 13 APP. C Requestor's ID:
ORDAZ
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Tramell
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Document Coments:
3                           April 1,1986 l
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'l Appendix C     PROGRAMMATIC CONCERNS 26 Description of Concern 3                                                                                 .
[                  The evaluation process defined in Appendix E does not provide sufficient detail on safety-significant evaluation. This concern is primarily related to o                the fact.that safety-significant evaluations of discrepancies are currently underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern in the DAP are piping and cable trays 9                  and their supports.) Until this revised information becomes available as
                   " plant record documentation" then the safety-significance evaluation process d                  cannot be completed. Any evaluations made using existing documentation must
: j.                 be revisited when the new documentation becomes available. The major reason 1                  for this is that TUSCO has elected to perform extensive reanalysis of piping, N                  cable trays and their supports which could result in hardware modification
:!                 related to optimization or deficiencies or, different design documents and values which form the basis for the safety-significant evaluation. Based on this, the staff feels that safety-significant evaluation and the potential for scope expansion must be based on final plant documentation. This position does D                  not preclude the fact that existing issues which led to the current reanalysis of piping 'And cable trays umst be evaluated for root cause and generic implication to assure that programmatic deficiencies do not extend beyond the
  ,                boundaries covered by the reanalysis efforts.
1
''                 Action Required d
j
]                  The CPRT must provide procedural direction or instruction to ensure that
:                safety-significant evaluation of discrepancies related to the self-
'!                 initiated design or construction program and the potential for scope j                  expansion must include evaluation using final plant documentation. This j                  does not preclude the fact that existing issues must be evaluated for root cause and generic implication. During implementation the staff will confirm that this action has been accomplished.
 ]
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      ;         Description of Concern This concern is related to the fact that safety-significant evaluations must be performed using Code or Regulatory approaches. That is, the techniques used and the extent of the' evaluation m'Jst address each criterion j             which formed the basis for the original design. For example, the use of actual' material-properties versus Code defined material properties could be acceptable but does not preclude the fact that all evaluations committed to in the FSAR must be addressed in order to establish margins on all segments of 3          the acceptance criteria. Actual material properties (if higher than Code minimums) may be of value in evaluating primary stresses and functionality but do little to change the fatigue margin. This concern is not. limited to Design discrepancies but includes Construction discreparcies for which safety-significance is determined through the use of Design evaluations.
1, i
?
l'              Action Required M
The CPRT must provide . procedural direction or instruction to ensure that the techniques used and the extent of the evaluation addressees each criterion jj              which formed the basis for the original design. During implementation the staff will confirm that this action has been accomplished.
L l               Description of Concern There is a lack of discussion in the Plan on the approach to be used in root cause and generic implication detemination. In order to understand any CPRT l               proposed evaluation, the Plan needs to define the terms " root cause" and 1
l          " generic implication." This is critical, since the depth and breadth of the-
{          root cause evaluation will be a function of the CPRT understanding of these terms. The staff anticipates that the CPRT will consider the following, as a j               minimum, in determining the root cause of deficiencies:
I 04/08/86                                  C-2                  CP SSER 13 APP. C Lu.               .~.             ~ ~ . -      - - -     -. . . -  sm        ,
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Management I   Action Required The Program Plan must be revised to provide those definitions or the CPRT shall issue procedural direction / instruction to ensure that persons performing g     these evaluations have commonality in their understanding of the factors that affect the determinations. During implementation the staff will confirm that
   ;. this action has been accomplished.
I Description of Concern
.l l
Another area of staff concern is related to Adverse Trending. The discussion in Appendix E is general in nature and uses a set of examples to define the process by which a set of items could create a pattern for concern. The examples given are related to a design process. The approach used by the CPRT is to evaluate HDAs rather than to review the design process. The concern is that I   evaluation of HDAs may not provide the appropriate information for trending as 1     defined in Appendix E.
I j   Action Required
  ,   The Program Plan must provide that the design process as well as Homogenous
   !  Design. Activities will be reviewed to determine an adverse trend. During implementation the staff will confirm that this action has been accomplished.
I
.l L 04/08/86                                 C-3                   CP SSER 13 APP. C t
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l Description of Concern                                                                     i Revision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirmation of implementation and responsibilities of the CPRT and the CPSES Project. The only major lf   conenent the staff has is related to the timing of SRT approval of CPRT RTL l    determination of the adequacy of correction actions defined by the CPSE5 Project. Appendix H provides two alternatives,
   ;              approval on an ongoing basis 'as corrective actions are developed, or, approval as part of the Action Plan Results Report approval process.
  ]
i j   The staff feels that the SRT should approve or disapprove corrective actions f   on an ongoing basis as they are developed. This action should follow that of
{   the CPRT RTL. It is felt that this would keep the SRT more in line with
   !  CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES project involved in lengthy discussions when the RTL does not agree with the proposed corrective action.
  ,I l  Act' ion Required Appendix H must be revised to state clearly that the SRT will review and p  approve / disapprove all corrective actions on an ongoing basis, subsequent to j  approval by the CPRT-RTLS. During implementation the staff will confirm that this action has been accomplished,
   }
a Description of Concern i   The staff is concerned with a number of observations concerning interfaces as
   ;  follows:
b The definition of interfaces provided in Appendix F establishes measures for the identification and control of design and construction interfaces and for
    ; coordination among the CPRT participant organizations. The availability of j  matrices will provide each affected organization the specific areas and items 04/08/86                                     C-4                    CP SSER 13 APP. C M_      W ad P_    e-'          3 ' *- E 9-

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j                 of information that must be executed and controlled. There are a number of 3                areas where interface between various CPRT organizations and CPSES Project organizations is defined. In some cases, the interface appears to be dupli-g                 cative and prime responsibility is not defined. It is important that prime responsibility for interface control be defined to assure that involved organi-zations understand who is responsible for establishing, executing and controlling i                 the interface. The following are staff observations on the individual matrices provided in Appendix F.
: 1. QA/QC-RTL and RTL to Unit 1 and Unit 2 Assistant Project General Managers
 >                       (APGMs). Responsibility for 50.55(e) reportability is assigned to the TUGC0 Project per Appendix H of the Plan.          ,
: 2. DAP-RTL to SWEC. Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports is provided to SWEC for "Information"
 'I                      when pertaining to the SWEC scope. Since this information could impact the SWEC analysis effort, it should be provided for " Action by SWEC."
Since DAP is auditing SWEC activity, this matrix should address those
 .,                      items associated with that effort, including Corrective Action.
I I
j                3. DAP-RTL to Ciner Design Organizations.       Infonnation on root-cause j                     analyses, generic implications, Evaluation Reports and Results Reports
 'j                      should be provided for " Action" to EBASCO and Impell, who are reanalyzing
'j                       cable trays and supports. The CPRT may find it more appropriate to j                     develop a separate matrix for the cable tray and support effort activities of EBASCO and Impell.
ff U
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: 4. RTLs to CPSES Project. Action Plans are designated as both " Info" and
,j                       " Action" by Project. It is the staff's understanding that Action Plans (l                       are provided to the CPSES Project for information only.
    ;              5. SWEC to Interfacing Organizations. Design- and construction-related l                    concerns found during walkdown and document reviaws should require action by DAP and QOC RTLs. That action should include evaluatien of the 04/08/86                                     C-5                  CP SSER lo APP. C i
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l deviation in the same manner as if it were discovered as part of the CPRT self-initiated program. Loading from the piping system should be provided to QOC through the DAP since this information may be needed for g
safety-significance evaluation.
l L
: 6. Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and CAP-RTL and EBASC0/
Impe11 and Interfacing Organizations.
  ~
Action Required The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT j             activities provided the concerns are satisfactorily resolved as follows:
1 i
    ;           (1) Define the organization with prime responsibility for duplicative
  }                   interfaces.
(2) Information on root-cause analyses, generic implications, Evaluation Reports and Results Reports should be provided to SWEC, EBASCO and Impell since it could impact their reanalysis effort.
(3) Design- and con'struction-related . concerns found during SWEC, EBASCO or Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action."
(4) Loading from the piping system to equipment, structures, penetrations,
#f                    etc., should be provided to 00C through the DAP for use in safety-
-i                    signficant evaluations.
l           (5) Interface details (or matrices) should be provided for Other Design i                Organizations and DAP-RTL and for EBASC0/Impell and Interfacing
 '!                   Organizations.
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04/08/86                                    C-6                  CP SSER 13 APP. C
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.I l         (6) The CPRT auditing of SWEC activities involves interfaces which should be j                defined.
(7) Define more clearly CPSES project responsibility for action plans and
   ;               50.55(e) reportability.                                     .
d 1
j         The concerns related to 50.55(e) and to Action Plan responsibility in the RTL to CPSES Project Matrix are editorial in nature and can be confirmed during the implementation phase of the plan. Additionally, during implementation the
}
j         staff will confirm that the other above noted actions have been accomplished.
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i 1-j 1          Items to be Addressed by Applicants During the Implementation Phase of DSAPs.
The.following presents comments of the NRC staff on the DSAPs which should be addressed by the Applicants during the implementation phase.
d i           The NRC staff will examine the Applicants' response to these comments as part j
of its inspection program for the CPRT Program Plan implementatio of all DSAPs.
DSAP VIII, CPRT Overview j           Description of Concern In order for TERA to perform an integrated review of major concrete and steel
   !          structures in a manner consistent with their commitments referenced in the NRC Office of Inspection and Enforcement (IE) Inspection Report 50-445/85-17 l
i and 50-446/85-14, Appendix 2, page A-4, unique loading determinations must be performed for the referenced buildings (i.e., auxiliary building, fuel storage building, containment building and other portions of selected buildings). DSAP VIII, Section 4.3.2.1, load Determination, indicates that only the auxiliary /
q electrical buildings will be reviewed. This is inconsistent with TERA's commit-ment and in fact precludes the performance of a thorough review.
Action Required
  ]-
1 i          TERA should review other buildings than those listed in DSAP VIII, Section ji            4.3.2.1 Load Determination.
!I Description of Concern j             Thermal Loadings or expansion considerations must be considered in the u             evaluation of the reactor building internal structure since this is a j             fundamental design consideration (e.g., to mitigate the effects of thermal y             expansion). DSAP VIII, Section 4.3.2.1, does not address thermal considerations and should be revised accordingly.                          .
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DSAP VIII, Section 4.3.2.1 should be revised to include thermal load considerations for reactor building internal structure.
Description of Concern The NRC inspection report (Appendix 7, item 4, page A-216) discusses embedment load tracking. The TERA response indicates that final design loads will be coordinated with the civil / structural discipline (e.g., to confinn that building designs are consistent with the final. design loads). Section 4.3.2.1
   '1 t             of DSAP VIII doesn't discuss this and should be revised eccordingly.
I q
1               Action Required i
DSAP VIII, Section 4.3.2.1 should be revised to address how original building design loads are reconciled with the final design loads, i
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04/01/86                                      C-9                CP SSER 13 APP. C b     .,
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   ,;                       DSAP VIII - Civil / Structural, Including Cable Tray / Conduit Supports Description of Concern The testing program may generate design and acceptance criteria which do not comply with FSAR comitments.
i i                        Action Required If the FSAR commitments are not met, the proposed acceptance criteria must be identified for approval by the staff prior to implementation.
3 Description of Concern i
   'i                       Inconsistencies exist between the DAP, DSAP VIII and Impell-Ebasco project j                      instructions. The inconsistencies involve the statements describing the methodologies that may be used to evaluate the cable tray support. In the DAP
   >                        it is stated that the established Ebasco methodologies will be used while the DSAP allows the use of Impell and Ebasco design procedures. Further in the DSAP it is stated that only two methods of dynamic analysis will be used in analysis design verification of cable tray supports. The Impell project instructions, however, permit the use of time history methods, overlap methods ij                         and multi-level response spectrum methods in addition to the two methods referred to in the DSAP.
Action Required During implementation the staff will confirm that these inconsistencies be
;j                          resolved and the appropriateness of the above methodology demonstrated to the staff.
:}
l r!                         Description of Concern i}
j                     The staff is concerned with the lack of prescriptiveness of review checklists
     !                     used 'or the third part review.           In general, the checklists define the review 04/01/86                                       C-10                  CP SSER 13 APP. C
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j            . scope by listing criteria and commitments for which the implementation will be verified in the review, but do not indicate the design considerations which i             must be accounted for in verifying that the connitments were met.
Action Required The checklists need to be more prescriptive with respect to all design criteria to be met.
Appendix 12 of the NRC Office, of Inspection and Enforcement (IE) Inspection L             Report Nos. 50-445/85-17,50-446/85-14 indicates areas in which specific review b            checklists need to be expanded or clarified with respect to subject content.
j           Description of Concern The staff evaluation of the third-party activities for the review of project j             activities and corrective actions is based on audits performed at the offices of the CPRT third-party (TERA).
At the time of this audit Revision 3 of the Program Plan had not yet been issued. Revision 2 of the Program Plan was not definitive in stating the third-oarty activities for the cable tray / conduit program. This program was a               undergoing a major rewrite which new clearly defines the role of the third 7    .
        .       party.
if              Action Required The staff generally agrees with the Program Plan with respect to the
,j              third-party activities in the cable tray / con +11t area; however, a complete evaluation will be made after the staff compl* :es its audit of the details of ll              the third party review of the project actions.
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04/01/86                                   C-11                 CP SSER 13 APP. C
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Description of Concern The staff review of the validity of identified HDAs and design activities not G            enveloped by the HDAs identified a concern with the HDA criteria for t
q           homogeneity.
HDAs are req'uired to have common design or analysis approach / methodology or mechanics in design implementation'such that meaningfully different complexities or considerations are not contained within that design activity.
      .       However TERA had not obtained formal documentation pertinent to the Gibbs and Hill. design / analysis methodology and approach. Such documentation (instructions and procedures) is normally utilized to establish design process control and thereby establish uniformity of technical approach in the execution of engineering for a project.
The Civil / Structural Phase 3 Scope Validation document, including the HDAs identified within, is based on such items as the plant engineering documents available at Gibbs and Hill, TERA interviews with project personnpl, and the engineering experience of TERA personnel in nuclear power plant design.
A review checklist, DAP-E-PM-001, dated October 27, 1985 states that, on.a programmatic level, (1) organizational and design control process changes
:)         . within Gibbs and Hill have not affected the identified HDAs and (2) there have been no changes to design methodology over time at Gibbs and Hill such as to affect the the identified HCAs. These TERA conclusions are based on ll            discussions with Gibbs and Hill rather than review of design control procedures, design methodology, etc.
H TERA apparently recognizes that other homogeneous design activities (HDAs) may
[
exist and that some currently so defined may in fact not be homogeneous since j             it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Phase 3 Scope
!i            Validation, Civil / Structural" that in the review effort there will remain an
: j.            open, "... search for substantive differences in criteria category, design considerations, approach, or methodology in the design process."
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04/01/86                                  C-12                   CP SSER 13 APP. C I;l o
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The team identified potential HDAs not identified by TERA, such as the design
: j.         of the annualar structural steel normally inside the containment, the auxiliary building structural steel, foundation overturning design, the design
  ;       . of walls for tornado missiles and the effect of Category II buildings on Category I buildings,
}
t          Due to the above uncertainty as to documented design methodology, there is a a          related question on sample sizes. In the area of concrete design, TERA has f         indicated that for the auxiliary building and the fuel building a. total of five (5) slab and five (5) wall calculations will be selected at random for design. review. Then another set of ten (10) calculations will be selected either randomly or based on any findings from the previous ten (10). Such a
'i         sample may not be valid if all these calculations were by one individual, if l        there were fifteen (15) individuals doing independent designs for slabs and
   !       walls without any design process / methodology guidance beyond the FSAR l
:        criteria. If there were no controls within the Gibbs and Hill organization, j          for establishing homogeneity in design approach and methodology, one must compare individual engineers and designers completing similar tasks. For this situation, the actual homogeneity that exists can apparently only be l
.j         established as the design review progresses.
To the degree that TERA relies on HDA populations as the basis for review j          sample-selection, the staff plans to evaluate whether the review sample is
[       representative of the design process for that population and whether the
{        population is homogeneous.
J Action Required i
The staff generally agreed with the third-party conclusions that certain checklists adequately cover HDAs. Exceptions to this are addressed in detail f
,i         in Appendix 12 of the NRC Office of Inspection and Enforcement (IE) Inspection Report Nos. 50-445/85-17, 50-446/85-14 which was transmitted to the Applicant
{
in a letter from J. M. Taylor to W. G. Counsil dated January 21, 1986. Staff l
approval of the CPRT Program Plan is contingent upon acceptable resolution of
   !       the staff concerns and staff comments on the review checklists provided in the IE Inspection Reports.
04/01/86                                 C-13                 CP SSER 13 APP. C D a w wn erm m m u.msr.2,m m:w:>w m ,a.g;w m.u m ;w                               .g.,m ,ng.g;c ;

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                      -DSAP IX - Staff Comment (Third-Party Review) h                    The staff requires the following. items to be adequately completed in order to
   ]                   detemine the acceptability of the piping and supports discipline specific
:               action plan related to the third-party (TERA) actions:
:.1 1
L                   Description of Concern 4
1' It was not evident that a process existed for identifying discrepancies (or
    $_                 deviations) in external source issues by SWEC in view of the fact that hardware modifications may be made to piping and supports irrespective of the corrective
   'l                  actions required for safety-significant problems.
       ;               Action Required A root cause/ generic implication evaluation should be performed for all hard-ware modifications in order to document the reasons for such modifications.
Description of Concern In the staff review of the checklists to be used by the third-party (TERA) in their overview of the SWEC piping and supports program, only one of three j               checklists were completed.
f Action Required I
;;                     Provide the checklists to be used for the overview of the SWEC piping analysis
!i'i                   implementation and pipe support design implementation.
~!
 .t                    Description of Concern I
t The staff review of the third-party overview of the SWEC construction /as-built i               program found that no third-party procedures were available at the time of the
        !              staff audit.
04/01/86                                    C-14               CP SSER 13 APP. C i            -                            -
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Action Required 2
e            Provide the procedure to be used for the third-party overview of the SWEC i..          construction /as-built activities.
(           Description of Concern j            The self-initiated review of the AFW system does not fully address the inter-face with the SWEC piping reanalysis program.
P
,.           Action Required
.- j The third-party should include a portion of the AFW system in their review of the SWEC piping and pipe supports requalification. effort.
i I
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i 04/01/86                                  C-15               CP SSER 13 APP. C i
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,l j            DSAP IX - Staff Comments (Project /SWEC Actions)
The staff requires the following items to be adequately completed in order to detennine the acceptability of the piping and supports discipline specific action plans related to Project (SWEC) actions:
Description of Concern
            .The major technical details of the piping and supports requalification program are provided in Comanche Peak Project Procedures (CPPP-5, 7, 8, 9, 10 and 15).
L            The staff has not yet completed our review of these procedures. However, based i           on preliminary findings, the staff identified a concern that the design criteria in CPPP-7 is not totally consistent with the CPSES FSAR licensing comitments.
I           Action Required The acceptability of the CPRT Program Plan is contingent upon acceptable resolutions of technical concerns identified in our review of the Comanche Peak Project Procedures including consistency between FSAR licensing commitments and i          the design criteria in CPPP-7.
l l     .
Description of Concern i
 !           There is a lack of information in the CPRT Program Plan which explains the
  !          process used to assure the adequacy of the as-built data used in the SWEC piping reanalysis effort.
  ;          Action Required Provide a description of the process followed by the various activities in the Construction Adequacy Program and in the SWEC program for the evaluation of l
j            as-built discrepancies including the interfaces among ERC, SWEC, and TUGC0
   !         projects and the applicable procedures used in the process.
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l Description of Concern
  }
L
   .         In our review of the as-built process and interfaces between the Construction
* Adequacy Program and SWEC, the staff found that Deviation Reports (DR's) issued
)            by ERC are not transmitted to SWEC. However, all DR's are transmitted to TUGC0
 $           projects for initiating an NCR and only those NCR's dispositioned as "use-as-is" will be transmitted to SWEC.
      ~
Action Required
  -s j-           Address the need for SWEC to review the DR's for the impact of construction i
deviations identified by the construction adequacy program on the piping reanalysis effort.
1i
 ..          Description of Concern i
As a result of the as-built walkdown performed under CPPP-5, deviations were found in one of the four attributes (i.e. valve and strut orientation) result-ing in a 100 percent reinspection of that attribute. However, the staff noted that CPPP-5 did not expand its scope to address other as-built attributes (e.g.
pipe run geonietry, clearances including those at floor and wall penetrations, embedments, and pipe attachments) which are also required to be examined under
..           IE Bulletin 79-14.
!)
>4
:l
;;           Action Required i
iI.:
 '$          Provide a justification for not reverifying the as-built attributes which were
,i           excluded under CPPP-5.
it Description of Concern i
The staff is concerned that the design criteria and procedures used in the SWEC
:l      ,
piping and support reanalysis might be impacted by as-built plant conditions
,;           which are not reflected in the design documents used by SWEC.
04/01/86                                  C-17                 CP SSER 13 APP. C
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: [.         Action Required 7            Provide the basis for assuring that all as-built conditions which can adversely j            affect the acceptability of.the piping reanalysis program will be identified j            and corrected.
1 Description of Concern It appears to the staff that there is no evaluation of root cause or generic implication or adverse trend associated with the as-built deviations identified
  ?)l          in the SWEC as-built walkdowns. Furthermore, there does not appear to be a l         procedure or process for the. evaluation of the resulting design deficiencies or
  .l           SWEC-identified construction deficiencies per 10 CFR 50.55(e).
l j        Action Required                           '
i Address the need for a program for ensuring that the results of the SWEC walk-downs will' be adequately evaluated for root cause/ generic implications and adverse trends and that design and construction deviations identified as a
 ,i            result of SWEC walkdowns will be properly evaluated per 10 CFR 50.55(e).
1 l}
Description of Concern
:l
,!             The staff review of CPPP-10 finds that a final design document which estab-
'i lishes the system design input must be prepared and satisfactorily reviewed by the staff.
!!             Action Required l
Prepare a final document compiling all operating modes and system loading conditions.
1 i
,i 1
j              04/01/86                                C-18                  CP SSER 13 APP. C 4
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    .i             Description of Concern
    ,              The scope of the Class 5 piping systems includes only those Class 5 piping j               systems within the boundaries of ASME Class 2 and 3 piping stress problems.
3 f              Action Required Justify excluding the remaining Class 5 piping systems from the SWEC scope.
Description of Concern The Comanche Peak Project Procedure for the requalification of small bore piping (CPPP-15) is not yet available for staff review.
j              Action Required i
i j             The CPPP-15 should be completed and issued for staff review.
Description of Concern The staff has not yet completed its review of the resolutions to the special technical issues.
il                            .
!                  Action Required fl
;j                 The acceptability of the CPRT Program Plan is contingent upon acceptable
   ~'
resolutions of the special technical issues.
,i i
i 04/01/86                                 C-19                  CP SSER 13 APP. C
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     -                                                       DSAP X - Mechanical Systems and Components Discipline Specific Action Plan
   ;                                                         Description of Concern E                                                          This action plan describes the approach and methodology established to address the design of mechanical systems and components.. In the area of mechanical i                                                          components, TUEC initiated a review of active valves after discovering that n                                                          some vendor-supplied specifications were deficient since they deviated from FSAR comitments.
Staff Coments In response to the NRC's {{letter dated|date=August 9, 1985|text=August 9,1985 letter}} providing comments to TUEC on
  .l                                                         the CPRT Program Plan, the CPRT issued Revision 3 of the Plan to address the
  .j                                                         issue of active valves. The CPRT has addressed this concern in the Design l                                                        Adequacy Program Phase 3 scope development process. However, additional
  'l                                                         information is required. The CPRT should specify where specifically in the DAP Phase 3 process this issue is being addressed. Since the Plan intends to i
provide complete coverage of all areas with safety significance, the CPRT I
should consider the issue of active valves in the Plan's root cause/ generic implication evaluation. The CPRT's response to the staff concern did not specifically address the issue of active valves nor did it provide any
* commitment to evaluate the significance of the errors. The CPRT should
.                                                            specifically review whether there exists any procedure to document l                                                         deficiencies in specifications detected by vendors, whether there exists any
;j                                                           documentation of or prompt follow-up of deficiencies such as those identified h                                                            with active valves, and why the system to control the quality of design documents did not detect that the specifications had deviated from FSAR I!
I;                                                           commitments.
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l,                                                           04/01/86                                C-20                 CP SSER 13 APP. C l
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MEMORANDUM FOR: Jose A. Calvo, Manager Systems / Operational Group Comanche Peak Project FROM:              E. B. Tomlinson, Leader Review Support Group Systems / Operational Group, Comanche Peak Project

==SUBJECT:==
REPORT OF SITE AUDIT OF CPRT SELF-INITIATED CONSTRUCTION ADEQUACY PROGRAM - OCTOBER 1985 During October, 1985, the staff conducted an audit of the CPRT Self-Initiated Construction Adequacy Program. This program is detailed in ISAP.VII.c of the CPRT Program Plan.
The audit was conducted in three phases spanning the month of October, 1985, as follows: October 14-18, October 21-25, and October 28-31. The audit was conducted by a group comprised of NRP staff personnel and selected consultants. The audit participants are listed in the attached Appendix A of this repert. The staff and consultants are hereinafter referred to as "the audit team."
The audit was conducted with two primary objectives in mind. The first was to fully understand the methodology that ERC will utilize in developing and imple-menting the program. The second objective was to determine if ERC was providing a clear, auditable trail of program activities commencing with program develop-ment and continuing through implementation and final reports. With this in mind, the audit team concentrated on the major areas of population definition, the basis for population homogeneity, development of work processes and attributes, development of population lists, random sampling, and documentation for these areas.
Details of specific audits covering all disciplines and a portion of the total populations are included in Appendix A of this report. It was not intended to address the technical adequacy of the program during this audit as this is a
5-67     -.

2 considered part of the program implementation. A detailed audit for technical adequacy will be conducted at a later date.
E. B. Tomlinson, Leader Review Support Group Systems / Operational Group Comanche Peak Project cc:   V. Noonan C. Tramell A. Vietti-cook L. Shao T. Westerman E. Marinos E. Tomlinson P. Chan, LLNL, P. O. Box 45, Mercury, NV 89023 l

a     .                                                       l
      .                                                         1 APPENDIX A Report of Site Audit of CPRT Self-Initiated Construction Adequacy Program October 1985 t
l l
i
(         .
i 1
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   +   .
I 2     j
: 1. Audit Participants NRC .
J. Calvo E. Marinos J. Knox E. Tomlinson Consultants P. Chan          LLNL M. Yost          EG8G J. Flaherty      TES J. Rivard        TES J. Nevshemal     Westec B. Saffell       Battelle-Columbus R. Masterson     EAS R. Philleo Applicant Personnel Contacted B. Shair, ERC E. Farino, ERC A. Patterson, ERC J. Christensen, ERC R. Merham, ERC T. Kulaga, ERC J. Hansel, ERC D. Boulton, ERC J. Branc, ERC J. DiMare, ERC M. Iannuci, ERC J. M. Schauf, ERC G. Hefter, ERC A. Eurke, ERC H. Bossung, ERC J. Brown, ERC R. Tate, ERC F. Korensky, ERC T. Bori, ERC E. Baum, ERC N. Bancrjce, ERC R. Brown, ERC J. Tablerion, ERC J. Greer, ERC J. Warrington, ERC D. Alexander, ERC V. Hoffman, ERC (SWEC)
W. Bailey, ERC J. Beck, TUEC l
i
: 2. CPRT Construction Reinspection / Documentation Review Program The object of the program is to verify the adequacy of the construction, and to gain additional insight of the quality of the plant. The program consists of establishing a comprehensive method of reinspection and verification independent of the applicant's authority.
Audits of the Comanche Peak Response Team (CPRT) Construction Reinspection /
Documentation Review Program (ISAP VII.c), subsequently referred to as the Construction Adequacy Program, were conducted on October 14-18, 21-25, and 28-31, 1985, at the Comanche Peak Steam Electric Station site. All disciplines--mechanical, civil / structural, electrical and instrumentation and control--were audited by teams composed of NRC staff and consultants. Through these audits, the NRC reviewed the basis for establishment of the populations within each discipline and the work processes associated with each pnpulation and utilized by the CPRT for assessment of construction adequacy. The audits were conducted to determine that (1) the bases for establishing populations within a discipline were sound, (2) homogeneity within each population was established, and (3) to determine if there was an auditable trail covering all of ERC's efforts in the program.
The construction adequacy review program is being performed within the purview of the Comanche Peak Response Team with ERC, Inc., responsible for performing the review. The presentation made by Mr. John Hansel of ERC, Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury, Texas, provided the basis for the staff's initial audit of the CPRT Construction Adequacy Program.
l l
Work processes are being identified which reflect construction of safety l               related systems, components, and supports. Each work process will be evaluated by a random sample drawn from the associated population of systems, components, or supports related to that work process. Further, sample items reviewed are drawn from Unit 1, Unit 2, and common areas, and must be
?

1                        ,
                   .                                                                                                             \
4 construction complete and accepted. Each work process sample is expanded to 4
include an engineered sample. The engineered sample assures that a number of safe shutdown system items equivalent to the number of items addressed by the randcn sample are also reviewed for adequacy of construction. The selection of random samples in discussed in Section 6 of this Appendix.
Subsequent sections describe the NRC audits of the above process.
: 3.          Electrical and Instrumentation Discipline The electrical and instrumentation discipline is subdivided into five populations as follows:
(a)             Instrumentation Equipment (b) Cable Tray (c) Electrical Equipment (d) Conduit (e) Cable Work processes with associated reinspection attributes were established for each population. This provided the basis for a uniform approach to verifica-tion without omitting any major characteristics common to the group.
i The Construction Adequacy Program Review for the electrical populations is only addressing construction complete items and only includes construction activities. Vendor fabrication is not within the scope of the Construction Adequacy Program.                           For each of the electrical areas, ERC provided a
                                   " Population Description" which addressed the contents of each population and
: i.                                how the population boundaries were established. In addition to the
                                   " Population Descriptions," ERC also provided a flow chart describing the work processes associated with construction activities within each population. This yy -, . , , -       , , , . . . - - - . . .,n. _ . . . - . , , . - - -   -

7   .
flow chart contained attributes associated with each work process. ERC indicated,these attributes will provide the basis for the checklists which are being developed for re-inspection of electrical systems and components.
ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program.
(a)               Instrumentation Eauirment. The selection of the work processes was reviewed for homogeneity and comprehensiveness. The attreibutes for each work process were also reviewed.
The instrumentation equipment population is divided into two work processes, and the attributes for each process are as follows:
: 1. Tubing / Piping and Component Installation: attributes -
Material Identification, Tubing Size & Marking, Routing, Slope, Air Gap, Separation, System Bends, and Flex Hose Installation.
: 11. Instrument Installation: attributes - Idetnfication, Location, Installation, Separation, and Damage.
The NRC staff and consultants discussed each work process and attribute with the ERC personnel. The auditors discussed how each work process and attribute was derived, and reviewed the rationale behind ERC's consideration with respect to the adequacy of the work process and attributes.
An instrumentation equipment population item list was made listing all 1024 population items in Unit 1, Unit 2, and common areas. These items were all safety related, and they were listed with their respective instrument tag numbers and flow diagram numbers. This constituted the total population from which instrumentation equipment samples will be selected. A random number will be generated for each population item in the list, and a random sample of 60 items will be selected for reinspection and analysis. This sample will
        -     g  . <- - _ . -                  ~

contain items only from Unit I and the common areas. None of the items from Unit 2 wil1 be included as Unit 2 is under construction and the Unit 2 items were not completed or accepted. If the initial sample of 60 items does not include 60 items related to safe shutdown, additional items will be selected until a total of 60 items related to safe shutdown have been selected. It     is anticipated that this procedure will result in an average of about 95-100 items being selected for reinspection for each population.
(b) Cable Tray This population has one work process: cable tray installation. The work process is supported by the following attributes: Identification and color code, No damage, Configuration (Tray size, Routing, Attachments, Welding, Rung spacing, and Bolting), Clearance, Fire stops, and Separation criteria. One of these attributes, welding, has 12 contributing sub-attributes.
There are 5311 sections of cable tray in the population. Brown and Root's Electrical Group is responsible for the supervision of cable tray installations, with its craftspersons performing the actual installation. The installation was performed employing: Gibbs and Hill specifications and procedures, Brown and Root procedures, and TUGC0 Quality Instructions.
During the audit the work process and attributes were discussed and evaluated to determine how each was derived and approved by ERC. The auditors also reviewed the method to be used in the sample selection process where a sample of 60 safety related items will be selected.
                                                                    .r-

      .                                                                                             \
(c) Electrical Equipment                                                            .
The e'lectrical equipment population is made up of two work processes with several supporting attributes. The two work processes are: (1) electrical equipment installation, and (2) field assembly and field modifications. The population includes electrical equipment of various sizes and unique configurations such as electrical penetrations.
Documentation used in the installation of this equipment are Gibbs and Hill procedures and specifications, Brown and Root installation procedures, and TUGC0 quality instruction procedures. Brown and Root's Electrical Group is responsible for the supervision of electrical equipment installation and Brown and Root's electricians perform the actual equipment installation.
The above work processes, attributes, and documentation were discussed with ERC during the audit. It appears that the electrical equipment installation was performed to the above specification and procedures in the same manner as the other electrical populations. The sampling process is the same as for the previously described electrical populations.
(d) Conduit This population has three work processes with the following supporting attributes:
: 1. Selection attributes: Size / Material
: 11. Preparation attributes: Conduit / Fabrication, Cutting, De-burring,-
and Repair iii. Installation attributes:    Identification, Origin / Destination, Fittings, Bends, Pull points, Flexible conduit, Interface (tray),
Clearance, Fire stops and seals, and Separation.

h The work processes apply to both rigid and flex conduit. The conduit was installed to Brown and Root specification and procedures. The above work processes, attributes, and documentation were discussed with ERC during the audit. It appears that the conduit population installation was performed to the Brown and Root specification and procedures in the same manner as the-other electrical populations. Also, the sampling process is the same as for the other electrical population.
(e) Cable This population has three work processes with the following supporting attributes:
: 1. Prepull attributes:               Size, Type, Color, Defects, and Raceway.
ii. Pull attributes: Lubricant, Routing, Bend radius, Spacing, Slack, Pull tension, Separation, Damage, and Repair.
iii. Terminate attributes: Identification, Testing, Insulation, Conductors, Terminals, Hardware, Landings, Heat Shrink, and Secure.
These three work processes encompass cables of all sizes. During the audit several documents were reviewed and evaluated, which include Gibbs and Hill procedures and specifications, Brown and Root procedures, and TUGC0 quality instructions. The Brown and Root construction management organization has been responsible for all cable installation work processes since the beginning of construction work.
Each work process and attribute was discussed and evaluated, with respect to the above documentation, to determine how each was derived and considered adequate by ERC. Also discussed was the sampling process and how the 60 safe shutdown samples were selected to achieve a reasonably homogeneous population. The staff was concerned that the third work
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9 process, " Terminations," and its associated attributes represented too broad a scope. It was the staff's position that there was a significant difference in the terminations for various types of cables and that these differences would undermine population homogeneity within this work process. Consequently, total reinspections resulting from combined random and engineered samples would not provide an adequate basis for inferring that all cable terminations in the plant were (or were not) acceptable. To address this concern, it was agreed to clarify the attributes under this work process to specifically address all types of terminations. This clarification will result in an increased number of attributes which will effectively represent sub-groups of the single work process. The sample size will be increased, as required, to ensure an adequate number of reinspections within each of these sub-groups. With these modifications to the work process, the homogeneity within the cable population will be maintained.
: 4.           Mechanical Discipline The mechanical discipline is divided into nine populations which are:
(a) HVAC ducts and pleriums (b) HVAC equipment installation (c) Field fabricated tanks (d) Mechanical equipment installation (e) Large bore piping configuration (f) Small bore piping configuration (g) P.ipe-welds / material (h) Piping system bolted joints / material.
l Each of these populations was discussed with ERC personnel by NRC staff and l
l           consultants participating in the audit. Only field construction work processes are addressed by the scope of this activity; vendor fabrication is     '
not within the scope of the Construction Adequacy Program. For each of the mechanical areas, ERC had prepared a " Population Description' addressing the

contents of each category, its boundary, and any specific interfaces germane to the population. In addition to the Population Descriptions, a flow chart describing the work processes and associated attributes for each sample population was provided and discussed with ERC's Population Engineers. ERC indicated that these attributes provide the basis for the checklists which are being developed for reinspection of mechanical systems and components.
ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program.
Specific commetns on each population within the mechanical discipline are provided in the subsequent paragraphs.
(a) HVAC Ducts and Plenums. This population contains all passive equipment in the safety-related HVAC system whereas the HVAC equipment population contains only active items. The HVAC Duct and Plenum population encompasses 6800 items. Fabrication, installation and welding are the three work processes associated with construction of HVAC ducts and plenums. Reasonable homogeneity is established because the population is limited to work done by a single sub-contractor, the work processes are covered by the same specifications, and the work processes are reasonably common to all equipment within the population, except as noted below. The attributes associated with each work process were reviewed and appeared to be complete.
The HVAC Ducts and Plenums population has been modified based on a concern raised during the audit. The work process for Equipment Setting by Brown & Root has been deleted and will be combined with the mechanical equipment installation (MEIN) population since the same Brown & Root procedures and installation specifications were used.

(b) HVAC Equipment Installation. This population contains 604 items of
_ active equipment in the safety-related HVAC system whereas the HVAC Ducts & Plenums population contains only passive items. The work processes associated with HVAC equipment installation are the setting of the equipment and then connectino it to the plenum and ductwork. Reasonable homogeneity is established because the population is limited to work done by a single sub-contractor, the work processes are covered by the same specifications, and the work processes are reasonably common to all equipment within the population, except as noted below. The attributes associated with the work processes were reviewed and appeared appropriate for the process.
This population has been modified based on a concern raised during the audit. The work process for Equipment Setting by Brown & Root has been deleted and will be combined with the MEIN population since the saine Brown & Root installation procedures and specifications were used.
(c) Field Fabricated Tanks. This particular activity was discussed in a qualitative manner. ERC informed the audit team that eight field fabricated tanks exist and that all would be reinspected. This was not pursued further as population homogeneity was not an issue because of the 100 percent reinspection.
(d) Mechanical Equipment Installation. The mechanical equipment installation population encompasses 336 items. The governing construction document is the Gibbs & Hill Mechanical Erection Specification 2323-MS-101. The implementation of this is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", MCP-1. The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment.
The attributes of each work process were discussed in depth.

9 There are currently two work processes being reviewed. The welding
             , work process will be deleted from the MEIN population and put in the appropriate pipe weld work process. ERC is also reviewing the deletion of grout from the attribute list and considering establishing a new population that specifically addresses grout.
This change is due primarily to the way documentation was established.
Construction specifications and installation procedures for six items of equipment within this population were reviewed for compatibility with the attributes associated with the work processes.
Compatibility did appear to exist between the work process attributes and equipment installation procedures in all cases.
(e/f) Large Bore Piping Configuration /Small Bore Piping Configuiation.
The large and small bore piping configuration populations are based on 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. Large bore piping includes that piping which is 2-1/2 inches and larger in diameter; small bore pipirg is that piping less than 2-1/2' inches in diameter. The installation work process and its attributes are the same for both large and small bore piping. The piping considered in this review includes all ASME code piping. ERC reported that all piping of large and small bore is installed by one contractor using the same installation procedure and specifications. The attributes corresponding to the installation of large and small bore piping appear to be accurate and complete.

(g) Pipe-Welds and Material. As with large and small bore pipe
                 , configuration, the welding of large and small bore pipe are considered as one grouping. Separate samples, however, will be utilized to address each. More than 66,000 welds are required to connect safety-related large and small bore piping. The work processes associated with welding of either large or : mall bore are pre-welding, welding, post-welding. As with the other categories within the mechanical discipline, the population description was reviewed and appeared complete. Welds addressed by this study include only field welds. All field welds were performed by Brown &
Poot.
The piping welding area was audited and verified for the following:
(1) the basis for establishment of each population; (2) population boundaries; (3) population exclusions; (4) population list ~ source and basis; (5) work process and basis; and (6) attributes associated with work process. The weld work processes and attributes appeared complete.
Based upon the fact that both large bore and small bore pipe welds were fabricated to the same procedure, ERC decided to lump the populations together. The staff reviewed the Large Bore Welding Materials (LBWM) and the Small Bore Welding Materials (SBWMI population basis, description memorandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Welding. The audit team expressed concern regarding the lumping of stainless steel welds with carbon steel welds. .ERC pointed out that welder qualification is in compliance with Brown & Root Specification WES-031 which qualifies a welder to both carbon and stainless steel welding. The staff reviewed WES-031 and Brown & Root procedure CP-CPM-6.90, " Welding and Related Processes", and found very few areas where the procedures or specifications differed with regard to stainless versus carbon steel welding.             -

The audit team also raised a concern about the two welding methods which were used for pipe welds; i.e., Gas Tungsten Arc Welding (GTAW) and Shielded Metal Arc Welding (SMAW). ERC will address this concern by ensuring that adequate samples of each weld method are selected for reinspection from the Pipe Weld and Material (PIWM) population. In reviewing the welding work process for the above concern, it was emphasized that large and small bore piping welds are covered by the same welding procedures and specifications.
Based on this, ERC has revised the population to combine large and small bore piping. This revision of the PIWM pupulation will result in a more homogeneous approach to the PIWM reinspection.
(h) Pipino System Bolted Joints. Two work processes comprise the piping system bolted joint category. They are installation preparation and final bolt fitup. There are 7000 bolted joints at the Comanche Peak Steam Electric Station. The work processes and their attributes appear to adequately represent the bolting of piping joints. The procedure which governs this is CP-CPM-6.9E, Revision 8. A flow chart and population description had been prepared to provide the basis for the sampling of bolted joints.
The following ERC procedures were reviewed during the audit:
: 1. Vork Process Definitions
: 2. Population Description
: 3. Population Items List l
The NRC auditors raised the concern on torque being an attribute and not a work process. the concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC,                                                                                            it

was noted that there are approximately 7000 items in the piping system bolted joint population. Of the approximately 7000 items, 6700 are in line-piping connections which were installed in accordance with Brown & Root Procedure CP-CPM-6.9E. Section 3.12 of the Brown & Root procedure did not require a specific torque value to be used.
The governing requirement was that the joint "shall be tightened sufficiently to prevent leakage during pressure testing." Since ISAP VII.C is addressing accepted items, only reinspection per the original specification is required.
The only flanges which may have required specific torque values would therefore be in the Mechanical Equipment Population. ERC has reviewed the PEIN population and has only found approximately six flanges which required specific values. Therefore, the issue raised during the audit is not an issue for the Piping System Bolted Joints population.
It was also noted that the Population Description and Population Item Lists will be revised to delete instrument flanges. These will now be included in the electrical area.
: 5. Civil / Structural Discipline The civil / structural discipline is divided into 15 populations which are:
(a) Concrete Placement (b) Structural Steel (c) Liners (d) Fuel Pool Liner (e)   Fill and 12ackfill Placement (f) Grout-Cement (g) Grout-Epoxy (h) Large Bore Pipe Supports - Rigid (1) Large Bore Pipe Supports - Non-rigid (j) Small Bore Pipe Supports

i   .
(k) Large Bore Pipe Whip Restraints (1) _Instrument Pipe / Tube Supports (m) Category 1 Conduit Supports (n) HVAC Duct Supports (o) Equipment Supports Fost of these areas were discussed with ERC personnel by the NRC staff and consultants participating in the audit. Some areas have been reviewed in depth while others have been treated in a cursory manner.
Populations (k) and (1) have not been reviewed as of this time because they had recently been fonnulated and the work processes and work process attributes were still being developed.
(a) Concrete Placement The concrete placement population is presently subdivided into three work processes, each work process having various numbers of attributes.
Some of the attributes are to be reviewed by means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and i
documentation review. A few concerns evolved from this audit; however, the work processes and attributes covering rehspection of concrete placement do establish an appropriate level of homogeneity. The concerrs were discussed with ERC and were left as open items. The following is a list of open items:
: 1. ERC is to consider establishing cadwelds as a work process rather l
than as an attribute. ERC is to review the cadweld inspection l
procedure and the concrete pour card sign-off requirements to l                 determine whether cadwelds should be a separate work process.
;          2. ERC is to consider estabiishing Richmond Inserts as a separate attribute instead of including it with the embedment attribute.
: 3. ERC is to determine if the condition exists where embedded pipe sleeves are used to anchor the piping system. If this situation
                    ,does exist, the embedded sleeves should be a separate attribute.
(b) Structural Steel After performing this general overview of the structural steel reinspection activity, it is felt that the work processes and attributes identified generally will achieve acceptable homogeneity.
(c) Liners The containment liner population includes horizontal, vertical, and penetration welds. The work processes were reviewed and ERC was informed that consideration should be given to including a plumbness requirement as a work process. Also, it was suggested that ERC consider revising the tolerance when a 6-inch template is substituted for a 10-inch template.
(d) Fuel Pool Liners The first audit addressed only the formation of the populations. All welds covered by travelers will form this population.
(e) Fill and Backfill Placement The initial audit addressed the population formation and the work processes within the population. Testing is a work process within this population and not within concrete. Consideration should be given to the need for consistency. If testing is retained as a work process, the population description should be modified to reflect this as a separate work process.

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(f/g) Grout-Cement / Grout-Epoxy These are new populations which have not yet been reviewed.
(h/i/j) Large Bore Pipe Supports - Rigid (LESR)/ Nonrigid (LBSN)/Small Bore Pipe Supports (SBPS)
All of the noted pipe support populations were addressed in the audit.
These populations were formulated in order to assure a proper sampling of rigid and non-rigid pipe supports. This is important, since the maiority of " standard catalog supports" are in the non-rigid category. The small bore sampling was not divided, because the number of non-rigid small bore supports is very small and also because the type of support is not 4
readily obvious from the support number (as in the case for LB supports). The SBPS population was made up of four work processes:
fabrication, installation, welding, and inspection. The ERC management seemed to be at variance with the staff as to whether inspection should be a work process or an attribute. The two LB populations did not show inspection as a work process. After much discussion, the individual in charge of the SBPS group indicated that rework to a support very often occurred during the inspection phase as a result of an UNSAT Inspection Report (IR). Since this work was performed under the umbrella of inspection in order to close out the IR, this was a separate work process. the individuals in charge of the LB group appeared hesitant to accept this but eventually they did. However, at the exist interview, ERC upper management indicated that they would like to investigate this area further. They indicated that if they made any changes, they would contact the staff (the staff agrees with inspection being a separate work process).
The staff reviewed the population items list, work process justification, '
and attribute description and basis. An auditable trail existed such that all work processes and accompanying attributes could be verified.
The staff noted that under pipe supports welding two attributes were
                                          ,.           . _ _ _ _ -     . _          -   -=. -

i were omitted (cleanliness and base metal defects). ERC pointed out that cleanliness was unattainable both from a reinspection standpoint (preweld-ing attribute), and from the point of view of document review                                       l (cleanliness was not a hold point on the Multiple Weld Data Card
,          (MWDC)). ERC also said that they did net include base metal defects for supports es an attribute, since it was difficult to see defects through the paint. The staff pointed out that requirements for identifying base metal defects existing in ASME Subsection NR-4000 and Brown & Root Procedures QI-QAP-11.1-28.       ERC stated that during the reinspection of the sample supports, base metal defects were looked for in each case and noted as an "out of scope" observation fnr inclusion in the normal deviation system. The staff would not accept this, and asekd ERC to reconsider this approach. After some discussion, ERC committed to put base metal defects into the attribute list and to treat all instances as part of the construction adequacy.
(k) Large Bore Pipe Whip Restraints.
An overview of 'he pipe whip restraint population was provided by ERC.
This population consists of moment restraints, pipe whip restraints and restraint support structures listed in section 3.6 of FSAR. _Due to the original construction, two populations may be established, one for the restraint and one for the support structure. Nine sy' stems have postulated line breaks. Some restraints are listed by Gibbs & Hill and other restriants are listdd by Site Damage Group. At this time ERC is still reviewing the work process and is establishing which groups were responsible for insta11ation.
(1/m/n/o)    Instrument Pipe / Tube Supports // Category / Conduit Supports //HVAC Duct Supports // Equipment Supports.
These populations were formed after the initial audit and have not yet been reviewed.

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: 6. SELECTION OF RAND 0M SAMPLES The purpose of the self-initiated Construction Adequacy Program is to provide additional confidence about the ' adequacy of installed hardware. This program is concentrating on construction completed items, only. However, the results of the program will be applicable by inference to ongoing construction activities.
To accomplish this goal, the applicant (through its contractor, ERC) will employ a statistical approach to reinspection of selected systems and/or components from the disciplines and populations previously described.
The critical element in this statistical approach is the selection of random samples for reinspection from a reasonably homogeneous population. In general, ERC will select enough random samples to test each attribute under each work process a minimum of 60 times. In addition to the random sample, an engineered sample representing only safe shutdown systems and components will be developed. As with the random sample, the goal will be to test each attribute within the engineered sample a minimum of 60 times. Because of the random sampling, it is highly probable there will be an overlap between the engineered sample and the random sample for any population. It is anticipated that approximately 95-I00 samples will be required to meetithe goal of testing each attribute from both samples a minimum of 60 times.
In some instances, it may be impractical or undesirable to test each attribute under each work process a minimum of 60 times. In such cases, the attribute (s) will be identified and a rationale provided for why they will not be tested a minimum of 60 times.
Documentation covering the sampling process will be provided. This documentatien will include details of how population's, work processes, and attributes are established, how random numbers are assigned to populations and random samples taken, how random samples are expanded when required, and

justification for the number of tests for each attribute. This documentation constitutes an auditable trail. The audit team has determined that this auditable trail is in place.                                                    .
The purpose of these audits was to determine that ERC's methodology, when implemented, would result in a truly random approach to sampling. The audit team did not address the statistical aspects of the program. The adequacy of the sample size, criteria for sample expansion based on the number of unacceptable reinspections, and the ultimate numeric confidence level goal are the subject of a separate evaluation.
: 7. DOCUMENTATION The staff's goal in conducting the audits discussed in this report was better comprehension of the overall Construction Adeauacy Program. Emphasis was placed on overall program methodology, population definition, work process definition and population homogeneity, selection of attributes, and whether or not the entire process was adequately documented.
In general, the audits were confined to technical discussions and review of the following types of documentation when available:
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: 1. Gibbs Specifications
: 2. Brown & Root Procedures
: 3. TUGC0 Inspection Procedures 4   ERC Population Descriptions
: 5. ERC Population Item Lists
: 6. ERC Definition of Work Processes
: 7.   "A Million Random Digits" by the Rand Corporation
: 8. Drawings and/or equipment items lists covering plant construction and developed by TUGCO, Gibbs & Hill, Brown & Root, or sub-contractors.
: 9. Applicable vendor instructions / drawings

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The amount of available documentation varie,1 among the various populations.
However, accomplishing the overall goal was not contingent upon having the same level of documentation available for all populations. Sufficient information was available to support staff conclusions regarding program methodology and capability to audit program development and implementation.
At the time of these audits, the population documentation packages were in various stages of development. In some instances. Quality Instructions had beerrcompleted. These documents provide the basis for implementing the m'.nspection effort. When available, these instructions were looked at.
We6ver, none were reviewed in detail, no conclusions were drawn regarding thtm, nd they did not influence staff conclusions with the possible exception of additional confidence regarding an auditable documentation trail. Detailed review of Quality Instructions and other program implementation related docu-mentation will be reviewed during the implementation phase of this program, t}}