ML20099E749

Rev 1 to Program Plan & Issue-Specific Action Plans

ML20099E749
Person / Time
Site:	Comanche Peak
Issue date:	11/19/1984
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20099E742	List: ML20099E749 TXX-4367, Forwards Rev 1 to Program Plan & Issue-Specific Action Plans, Per 841019 & 23 Meetings W/Nrc.Rev Adds Two non-util Members to Senior Review Team & Replaces All Issue Team Leaders w/non-util Experts
References
PROC-841119, NUDOCS 8411260057
Download: ML20099E749 (30)

Text

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COMANCHE FEAK STEAM ELECTRIC STATION O

UNITS I AND 2

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g PROGRAM PLAN AND Ii ISSUE-S?ECIFIC ACTION PLANS REVISION I i

g NOVEMBER 19,1984 is Il

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l TEXAS UTILITIES GENERATING COMPANY

'l A DIVISION OF TEX AS UTILITIES ELECTRIC COMPANY

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,,0c,AM,LAN ISSUE-SPECIFIC ACTION PLANS REVISION I NOVEMBER 19, 1984 I

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TEXAS UTILITIES GENERATING COMPANY I

A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY

Revision:

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1I TABLE OF CONTENTS I.

INTRODUCTION II.

PROGRAM PLAN OBJECTIVES III.

PROGRAM PLAN PRIhCIPLES IV.

PROGRAM ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES V.

PROGRAM PRO.'ESS VI.

PROGRAM OUTPUTS VII.

PROGP.AM QUALITY ASSURANCE VIII.

PROGRAM RECORDS IX.

SCHEDULE I

ATTACHMENT 1: CPRT ORGANIZATION CHART ATTACHMFNT 2: ACTION PLAN FORMAT ATTACHMENT 3: ACTION PLAN RESULTS REPORT t0RMAT ATTACHMENT 4: SUMMARS. OF PROGRAM PROCESS APPENDIX A:

ISSUE - SPECIFIC ACTION PLANS l

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I lI II COMANCHE FEAK RESPONSE TEAM PROGRAM PLAN I

Rev. Description Prepared by Date Approved by Date l

Program 'Ae. nager Senior Review Team

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Page 1 of 17

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ComancSe Peak Steam mectric Station y

/I Comanche Peak Response Team c

Ptogram Plan T I, 6,

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INTE V JCTION

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The Nuclear Regulatory Commission (NRC) establie}ed a Technical haview Team (TRT) to review certain aspects of the E,(

'4 Comanche Petk Steam Electrde Station (CPSES). The purpose of

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the TRT is to eva.aate certain technical issues and

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33 allegations of improper construction practices a..

CP3ES. 'n N.:

E July, 1984, the TRT began onsite activities as part of its review plan using a team divided into five groups:

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electrical / instrumentation, c.ivil/me hanical, QA/QC,

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protective coatings, and test programs.

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On Seprember 18, 1984, a public meeting was held in the NRC's

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offices in Bethes,da, Maryland, a. which NRC management and the TRT presentes Texas 1,Lilities Electric Company (TUEC) with a

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request for additional 1 formation. This request was based on z, r.

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the results of the TRT efforts to date in the e'vetrical/

U instrumentation, civil, and testing program areno.

The TRT stated that <aey required additional information in order to 3' -

make a determination of the safety significance of certain c onc e rns.

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The TRT requer-for information was documented in an 4

attache at to n NRC letter dated %ptember 18, 1984. The

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request was divided into three pratary m ens and several b-sub-areas, each representing a nubject of concern to the TRT.

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,t TUEC developed a Program Plan and individual Action Plans for each of the issues identified in the September 18, 1984, 0

'l letter.

The Program Plan and the Issue-Specific Action Plans

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were submitted to the NRC by let er dated October 8, 1984

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Sul,seque.tly, public meetings were held at the NRC's Bethe-ta,

'g Maryland, office-on 6,3ber 19 and 23 at which TUEC made

'pg verbal presenta, anc of the Program Plan ano the Action Plans, i

obtained verbal NRC comments, and provided clarifications by answericg questions.

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As a result of the meetings with the NRC, TUEC han revised the Program Plan at.J is in the process of revising the 1

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Issue-Specific Action Plans. Thene revisions refles.

cons'oeratton of the NRC's commentn and observations, i

clartfications needed to respond t.

questions that were

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rained, and experience gained during the initial stages of f.

' I imptomentation of the original version of the Program Plan and the Action Plans.

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eM The overall 2rogram Plan, as revised, is presented below., The revised Issue-Specific Actica Plans will be provided in a

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4 future revision to Appendix A.

Similar Issue-Specific Action

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Plans will be developed to respond to any additional T C

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issues identified to TUEC in the future.

1 II.

PROGRAM PLAN OBJECTIVES TUEC continues to be committed to the safe, reliable, and

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efficient design, construction, and operation of CPSES ard will cooperate fully with the NRC and its TRT to resolve the

-9 identified issues. The Program Plan described in this documect is intended to establish a framework for responding m

to the TRT's requests for additional information and to assist

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in dispositioning the associated issues. Where necessary.

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corrective action will be taken. Appropriate action will also be taken to preclude similar da n ciencies from occurrint in the future. Therefore, the objectives of the Program Plan are to:

Evaluate and respond to the issues raised by the TRT g

Identify the root cause and evaluate the generic implications of identified deficiencien l

R Evaluate the collective significance of identified I

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deficiencies

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Defire necu,sary corrective actions for identified deficiencies I

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Define steps necessary to preclude similar occurrences in J

the future

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III.

PROGRAM PLAN PRINCIPLES

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To ensure that the Program Plan objectives arr. set, the

-a program was developed using the following principles:

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Thorough Reviews the NRC's September 19, 1984, letter and its attachment

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identified specific requests for additional information and provided specific examples at potential deficiencies, a

It is recognized that the specific examples identified by the NRC-TRT may be representative of an underlying

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concern. Accordingly, each of these issues will be thoroughly evaluated, even if a preliminary assessment of J;

l the specific exar91es indicates that they have no safety

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significance.

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Page 3 of 17 The NRC-TRT used sampling techniques in the performance I

of its reviews.

In some cases it will be appropriate to expand the size of the sample to explore the issues identified by the NRC-TRT more thoroughly. This will I

enable TUEC to obtain a more complete understanding of root causes, potential generic implications, and safety significance of any identified deficiencies and to achieve a higher degree of confidence in the Program Plan I

results.

Some of the issues identified by the NRC-TRT are directly I.

related to similar questions currently before the Comanche Peak Atomic Safety and Licensing Hearing Board (ASLB). For those instances where TUEC is aware of cdditional information that has been presented to the I

Board (or matters raised directly by the Board) and that is directly relevant to an issue identified by the NRC-TRT, the Issue-Specific Action Plans will appropriately include consideration of such information.

B.

Root Cause Determinations I

Root causes will be determined for each issue identified by the NRC-TRT and for all valid deficiencies identified I

by the NRC-TRT or by TUEC. Such determinations will

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enable TUEC to identify potential generic implications.

to establish appropriate expanded scopes of review, and to define appropriate corrective actions.

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In some cases, preliminary determinations of root causes can be made during the development of the Issue-Specific I

Action Plans and, where appropriate, reflected in an expanded scope of review in an Issue-Specific Action Plan. However, in most cases, the root causes of potential or actual deficiencies cannot be immediately I

determined. The Issue-Specific Action Plans are being developed to include tasks that are intended to idt.ntify root causes of identified deficiencies. These tasks are

~l oriented both at specific testing of initial root cause W

hypothesis as well as m,ro general exploratory efforts that will lead to new root cause hypothesis. The Action Plans will provida a description of the iterative actions and alternatives used to identify root causes.

It is recognized that the determinations of root causes

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Action Plans. The Action Plans will be structured to eliminate the need for unnecessary revisions. TUEC will I

strive to identify the rcot causes conclusively as soon as possible for each Issue-Specific Action Plan.

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1 Page 4 of 17 C.

Generic Implications Evaluations I

At such time as the root causes of identified n

deficiencies have been determined, an evaluation will be

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performed to identify any associated potential generic implications. Such evaluations will enable TUEC to 2

a determine whether the deficiencies represent f.solated occurrences, non-isolated or generic weaknesses within a i

particular area, or generic weaknesses that are programmatic in nature.

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T1.e results of such evaluations, in conjunction with an 7

assessment of the safety-significance of the deficiencies and weaknesses, will enable TUEC to define appropriate expanded scopes of review and to identify appropriate 7

corrective actions.

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Safety Significance Evaluations 2

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The safety-significance of identified deficiencies, both specific and generic / programmatic, will be evaluated to facilitate the definition of the scope of appropriate expanded reviews and the definition of appropriate corrective action.

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Collective Signit'icance Evaluation

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The Collective Significance Evaluation will focus on the j

integrated impact of the identified deficiencies, both specific and generic / programmatic, on the CPSES project.

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1 This evaluation will be based primarily on the h

information developed through the root cause

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determinations, generic implications evaluations, and safety significance evaluations. It will include a 1

determination as to whethec the existence of multiple, apparently isolated and relatively minor deficiencies indicates a common shortcoming in the programs and procedures applicable to the CPSES project. It will also identify " lessons learned" as they apply to future y

activities at CPSES Unita 1 and 2.

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4 F.

Corrective Actions 4

Appropriate corrective actions will be defined and i

implemented to resolve all specific deficiencies identified by the NRC-TRT and by TUEC during the course of this review and evaluation program.

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In addition to corrective actions designed to resolve

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B specific deficiencies, actions will be identified to dE prevent the future occurrence of similar deficiencies at T

CPSES Units 1 and 2.

Such actions will be developed 3[

using the results of the evaluations of root causes, 21 I

genetic implications, and collective significance.

Accordingly, the focus of these ccrrective actions will g

be to resolve actual or potentia: weaknesses that are g

generic or programmatic in nature.

G.

Objectivity I

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,E; The Program Plan submitted tc, the NRC staff by TUEC on October 8, 1984, included a number of features that were

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intended to provide assurance regarding the objectivity Y

of the Program. Nonetheless, during subsequent pullic meetings vfth the NRC staff, it became appe*ent that it would be necessary to incorporate additioral features to M

- I further ensure the objectivity and credibility of the u

Program. Accordingly, additional programmatic features N

have been ituplemented to ensure that the Prograr is I

conducted in such a manner that its obj ectivity and 3

credibility will be beyond question.

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As described in Section IV, the CPRT Program Organization

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includes a substantial number of partic% ants in key i

decision-making positions who are affiliated with

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organizations external to TUEC.

Three of the six members

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of the Senior Review Team and all five Review Team 5

Leaders are experienced nuclear-industry consultants who 5

have not been previously involved with the CPSES I

activities that they will now be reviewing. The Review 7-Team Leaders, subject to Senior Review Team review and

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approval, have the authority and responsibility to a_

este,lish the scope and content of the Issue-Specific Action Plans and to determine how and by whom the p

Issue-Specific Action Plane will be implemented. The members of the SRT and the Review Team Leaders have I

access to all plant areas, documentation, calculations, files, and personnel as they deem neceuary to meet the g

Program Obj ectives.

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_7 The Senior Review Team has established the followirg 4

guidelines with respect to the objectivity in 7'-

implementation of the Action Plans:

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,l Analyses and calculations either will be performed x

n organization not previously responsible for F

echnical subj ect area for the CPSES project or

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engineering design verification of the 3

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analysis / calculation will be performed uy a T"

third-party organization.

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1 Page 6 of 17 Inspections either will be performed by qualified inspectors not previously affiliated sith the CPSES project and not currently affiliated with TUEC or its principal contractors for the CPSES project ot; ZE the f nspections will be performed by qualified inspectors who were not personally involved in the inspection activities in question and an inspection validation progrom will be conducted on a sampilng a

basis by third-party inspection personn?l.

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Selection of personnel for inspection activities will be mutually agreed upon by the respensible

=a Review Team Leader and the Review Term Leader for

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the QA/QC area.

Records reviews and evaluations either will be

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performed by third-party persor. el cy; by CPSES project personnel with a third party validation on e sampling basis.

G Testing and NDE activities (other than preoperational testing) will be conducted and test results will be certified by third-party personnel.

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Personnel Qualifications / Training

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Issue-Specific Action Plan implementation act?vities (such as analyses, inspections, records reviews, and testing) will be performed by personnel selected by the Review Team Leaders on the basis of technical competence and subject to the obj ectivity guidelines noted above.

(For Action Plan activities performed Prior to the J

aaoption of Revision of the Program Plan, (>ch Review Team Leaoer will determine the acceptability of that work relative to the additional objectivity and other 2

requirements contained in Revision 1.)

11ere applicable, such personnel will also receive training on the procedures to be utilized and will be qualified / certified in accordance with the existing CPSES 0A Program a

provisions.

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Sampling

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Issue-Specific Action Plan implementation activities may 2-include the use of sampling techniques. The bases for 1l using sampling and the sampling method will be documented in each Issue-Specific Action Plan when sampling is used.

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1 Page 7 of 17 In general the following guidelines will apply:

Samples will be randomly selected from pop lations or subpopulations of concern (e.g. of concern to safety) for the purpose of identifying the existence

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j and/or the extent of potential deficiene.ies.

MIL-STD 105D, or other appropriate procedures, will g

be used to deternine sample size.

Sampling programs will be designed to include a limiting quality of 5 percent with an acceptance probability of 0.05 (i.e.

.,i at least 95% of the popu]stion is in conformance with the acceptance criteda at the 95% confidence leve ).

Acceptance / rejection criteria will be explicitly i

defined.

Mc. John Reed of Jack Benjamin & Associates will be used

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as a third-party engineering statistics consultant to iidi provide an objective evaluation of the adequacy c' the design of ear.h sampling program and to ensure consistency in the interpretation of results.

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Records and Quality Assurance

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The ProFram Plan requires that the activities performed

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appropriately along with the reaults of the Action Plan.

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The resulting records will be maintained in auditable ygg form.

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j Action Jlan activities that otherwise would be subject to the CPSES QA program shall be performed in accordance

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Urilizing the general principles presentel above, revised p, p$ viI

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Issue-Specific Action Plans are being developed for each issue p~

identified in the September 18, 1984, letter with Qlh.g.

consideration given to comments received at the October 18 and f y. f.(, l-23 meetings. These revised Action Plans will be provided as a O,;.).:'

revision to Appendix A of this document.

Similar l,j.Q{!;

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Issue-Specific actior Plans will be developed to respond to i g.

TRT questions in the mechanical, QA/QC, and protective

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coatings areas when they are identified to TUEC.

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IV.

PROGRAM ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES A.

Introduction The organization established by TUEC to develop and impismant this Program Plan has been designated as the Comanche Peak Response Team (CPRT). A chart depicting the organizational structure and principal members of the CPRT is presented as Attachment 1.

The personnel assignments to this project reflect the importance that TUEC hee attributed to its successful conduct and

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completion.

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B.

Team Members -- Roles and Responsibilities

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Senior Review Team 714 ? ?

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A Senior Review Team, conoisting of senior TUGC0

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line managers and senior nuclear-industry

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consultants, has been established with overall

(-7kyj responsibility for the development, implementation, SA.;Q)E t3 and management of the CPRT Program.

l The Senior Review Team (SRT) for the CPRT Program

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is Mr. Lou F. Fikar, Executive Vice-Presilent, T le. "

';.y.$ffI Engineering. TUGC0

$.,.(A Mr. Billy R. Clements, Vice-President, Nuclear I i /El Operations, TUGC0 y".?..h h

('..d:S_k Mr. John W. Beck, Manager, Nuclear Licensing,

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(2':..U Mr. John C. Gu!.bert, Consultant; Manager, Nuclear Safety & Licensing, TERA Corporation f*;.f d '

Mr. Anthony R. Buhl, Consultant; President, P fk ':

Energx Corporation

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-. e Mr. John L. French, Consultant; Vice-President,

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Delian Corporation

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Team include the following:

'j4T E Development of the CPRT Program Plan, and any j.j%-;;k subsequent revisions thereof j;y 'e,

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(b Establishment of CPRT Program standards for personnel qualifications and objectivity

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Assignment of CPRT Program Review Team Leaders q

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3 Review and approval of Issue-Specific Action 6q.

Plans, and any subsequent revisions thereof f *.(*;d e

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Ensuring that necessary resources are provided i.i. f. : "

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to support the successful implementation of the M J j:

CPRT Program W

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Ensiiring that " root cause" and " generic M j*:5 c #r implications" evaluations are conducted as soon A]pf f;

as possible for each issue identified by the j

TRT

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Review and approval of " root cause"

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determinations aad " generic implications" assessments, including evaluations of the p!

C adequacy of the Action Plans to adfress these ly.; j 5

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Monitoring the status of the implementation of the Issue-Specific Action Plans

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1.,,g'.,r S-5 Review and approval of the Issue-Specific Action Plan Recults Reports N$.'-?

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j Review and approval of the Collective 1.# '.

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Significance Evaluation Report

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Advising the President of TUCCO regarding the f,'$

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the CPRT Program z y '@%.;

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Mr. Fikar is chairman of the SRT. The SRT chairman

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has assigned additional responsibilities to certain

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SRT members.

Mr. Beck will serve as the principal

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interface with tha NRC staff's TRT Program Director

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for CPRT/TRT matters.

Mr. Guibert will be (7[ic' responsible for tha development of the Collective t.1 E..

Significance Evaluation Report.

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Senior Review Team Support Group

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q In order to assist the SRT in the execution of its

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-s established. The functions of the SttT Support Group 4

fall within the two general categories of project

$!jJ.f coordinatien and project administration and include

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Assisting the Review Team Leaders in obtai-ing access to CPSES ptcject personnel, project C y f '.,

documentation, and project physical spaces If, ',:. '

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1 Page 10 of 17 Providing necessary on-site clerical and administrative support to the SRT and to the g

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Review Team Leaders 1

Maintaining the CPRT Project Central File g

Developing programmatic procedures and guidelines at the request and for the approval

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of the SRT 3

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Assisting the SRT in monitoring the 2;3.1. '.

implementation schedules for the Issue-Specific p.j,K Action Plans

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7 Other support functions as assigned by the SRT

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Revie" Team Leaders

.i-4,4 A-Review Team Leaders have been assigned to develop D:T.y b}y e and manage the implementation of the Issue-Specific Action Plans within each of the six general areas evaluated by the NRC's TRT. Each of the Review Team E l.Q.j 3

Leaders is a member of an organization external to

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Review Team Leaders were selected by the Senior h

Review Team using the following criteria:

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Knowledge and experience in quality assurance, N;

'3 nuclear safety, and the review area subject

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matter, as appropriate.

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Kanagerial competence based on experience in

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managing technical projects and reviews

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.9 Integrity of both the individuals and the

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'.i es organizations with which they are affiliated

'> ;V,p based upon their reputation and standing within i."'

y the nuclear industry

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Objectivity of both the individuals and the M ys;.

organizations with which they are affiliated

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reputation for providing objective, dispassionate technical judgements on the basis p.y

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of technica' merit.

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Objectivity of both the individuals and the

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based upon the lack of previous involvement in 92$.

the CPSES preject activities in question

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B-Revision:

1 Page 11 of 17 ll The specific Review Team Leader assignments are as i

follows:

B Mr. Howard A. Levin; Manager, Engineering, TERA Corporation; Review Team Leader for the Civil, Structural, and Mechanical Areas Mr. John L. Hansel; Director, Energy & Environmental Science Division, Evaluation Research Corporation;

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Review Team Leader for the Quality Assurance / Quality Control Area

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Mr. Martin B. Jones, Jr.; Private Consultant; Review Team Leader for the Electrical / Instrumentation Area

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Mr. E. P. Stroupe; Director, Technical Services Division, Technology for Energy Corporation; Review Team Leader for the Protective Coatings Area I

Mr. Monte J. Wise; President, Wise & Associates; Review Team Leader for the Testing Programs Area The specific responsibilities of the Review Team Leaders I

include the following:

Serving as the principal interface with the NRC-TRT Leaders in their respective areas for the purpose of ensuring that additional clarifying information is ootained (where necessary), for obtaining feedback on the adequacy of Action Plans within their area, and for ensuring that responses to NRC questions regarding implementation of Actic'n Plans within 3

their area are provided Developmenc of the Issue-Specific Action Plans within their area, and any subsequent revisions thereof, using the format and content guidelines set forth in Attachment 2 Ensuring that personnel implementing the Action Plans (including personnel performing validations or design verift ations described in Section III.G, above) within their ares meet CPRT Program standards for personnel qualifications and objectivity Assignment of Issue Coordinators

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Identifying and obtaining necessary resources to N

impicment the Action Pians within their area Ensuring that the Action Plans within their area are being implemented appropriately Providing periodic status reports to the Senior i

Review Team on the implementation of the Issue-Specific Action Plans within their area n

ZZ Revision:

1 Page 12 of 17 Detet'nining " root causes" and " generic implications" of identified deficiencies within their area; ensuring that these determinations are adequately y

addressed in the associated Action Plans or ensuring that the Action Plans are appropriately revised Identifying and defining corrective actions for any identified deficiencies within their area Identifying and defining necessary actions to

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preclude occurrence of similar deficiencies in the future

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Developing Issue-Specific Action Plan Results c 'c :.

Reports, using the format and content guidelines set

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forth in Attachment 3 l; 3 V

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Maintaining a Project Working File for each Action pg*

Plan within their area jy}

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,,D...f-w Transferring Project Working Files to the Project

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Central File at such time that each Action Plan is

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and approved by the Senior Review Team)

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Issue Coordinators

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h.kJ In order to assist the Review Team Leaders in implementing the Issue-Specific Action Plans within

d their artc, they have been authorized to assign

.S Issue Coordinators for each of their specific Action

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Plana. Review Team Le Mars also have the option of f

g assigning themselves as Issue Coordinator for some k{.

or all of the Action Plans within their area.

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The criteria for selection of Issue Coordinators is 6.f

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essentially the same as that for selection of Review jM Team Leaders.

In cases where an Issue Coordinator W.fi has had some degree of previous involvement in the M7~.

2 CPSES project activities in question, specific g%

provisions will be established in the Action Plan to pfg ensure that the objectivity guidelines of Section H ?:.

3 III.G are met.

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,y.,n Issue Coordinators are responsible for assisting the

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Review Team Leaders in Issue-Specific activities as Yc7 L

3 directed by the Review Team Leaders.

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V.

PROGRAM PROCESS The overall ptocess for the development and implementation of l

this Progrma Plan and its associated individual Action Plans l

was presented, to a large extent, in the preceeding sections.

I A summary of the key elements of the overall program process is presented in Attachment 4.

Additional information related to the process for developing Issue-Specific Action Plans is presented in Attachment 2.

While each Action Plan is unique, the programmatic guidelines I

set forth in Attachment 2 and the Action Plan review and approval process ensure that each Action Plan is developed and implemented in a manner that meets the Program Plan Objectives and the Program Plan Principles. Each Action Plan includes a I

description, where applicable, of the following:

scope and methodology identification of procedures and checklists participating personnel qualifications el participating personnel training of participating personnel l

sampling plan l

relevant standards applicable acceptance criteria, and applicable decision et iteria.

1 B

Additional information related to the process for developing Issue-Specific Action Plan Results Reports is presented in l.

The prograwatic guidelines set forth in and the Results Report review and approval process ensure that the following subjects are adequately addressed where appropriate during the implementation of the j

Action Plan:

identification of root causes of identified deficiencies.

an evaluation of the safety significance of any identified deficiencies, c determination regarding potential generic implications and a description of how they were addressed, identification of necessary corrective actions to resolve identified deficiencies, identification of necessary action to preclude recurrence in the future.

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Page 14 of 17

1. h.fY To the maximum extent possible, the scope of the gy.y Issue-Specific Action Plans vill be based on a preliminary

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assessment of the root cause and potential generic y

4 implienons of the identified deficiencies. Action Plans

'sy Sf will be safficiently broad to identify and assess root causes,

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generic implications, and safety significance. Accordingly,

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most of the Issue-Specific Action Plans will utilize iterative 71'y M

.. g./W or phased implementation approaches that include an initial e

phase which is exploratory in nature. Conclusive Q[g determinations of root causes and potential generic y;b."1 M

implications will be made as soon as possible. Determinations

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};. 43 with respect to the safety significance of identified or potential deficiencies will also be reached. The adequacy of the scope of the associated Issue-Specific Action Plans will l ;g,

be reassessed in light of these determinations.

If an Action

(,f j 3

Plan is determined not to be sufficiently broad to meet j f.[,y g.s program requirements, it will be appropriately revised and new

'f.4 f J Action Plans may be developed (if appropriate) to ensure that the potential generic implications of identified deficiencies Qr l~ j are properly investigated and addressed.

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VI.

PROGRAM OUTPUTS RNI

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The principal outputs of the CPRT Program will be the Action Plan Results Reports. The format and content to be utilized

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in the development of these Reports is presented in Attachment

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,p 3.

Specific conclusions will be reached regarding root cause, safety significance, and generic implications. Necessary Yj corrective actions will be identified to resolve deficiencies, f.

including any corrective actions necessary to preclude f.[D;?

35 recurrence of similar deficiencies in the futvre, f"/

a f.g An additional report documenting the results of the Collective

9. e. -

9 iq;. -

Significance Evaluation will be developed. This report will,

~.Q, M in large measure, be based upon an integrated assessment of FY..c the Action Plan Results Reports. The principal focus of this

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evaluation will be to identify additional programmatic

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" lessens learned" which should be reflected in future project-related activities for both Comanche Peak Unit 1 and b4..

Comanche Peak Unit 2.

%$.bh At the conclusion of the CPRT Program, a Final Report summarizing the results and conclusions of the Program will be submitted to the NRC. Interim status reports or briefings vill be provided to the NRC staff as requested.

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Page 15 of 17 VII.

PROCRAM QUALITY ASSURANCE Activities associated with the implementation of individual Action Plans will be conducted within the framework of the existing CPSES QA Program. Existing procedures, revised or supplemented as necessary to address special requirements, will be used to perform reassessment activities, reinspection activities, and rework activities performed by engineering, construction, and QA/QC personnel.

VIII.

PROGRAM RECORDS In order to ensure that an auditable recora of the CPRT

~

Program is available, the documentation described below will be developed and maintained.

A.

Project Central File The Project Central File will be maintained by the SRT Support Group. At the completion of the CPRT Program, it will contain all project documentation, including the Projece Working Files maintained by the Review Team Leadets during the conduct of the Program. During the conduct of the Program, the Project Central File will contain the following material:

A co y of the Program Plan avbmitted to the NRC and any subsequent revisions thereof A copy of the individual Action Plans submitted to the NRC and any subsequent revisions thereof A copy of the individual Action Plan Results Reports l

A ccpy of the individual Action Plan Working File for vil Action Plans which have been completed (i.e., Action Plan Results Reports reviewed and approved by the Senior Review Team).

B.

Project Working Files

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Project Working Files will be maintained by the Review Team Leaders for each Action Plan under their cognizance

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until such time as the Action Plan has been completed.

At that time, the Project Working File for the completed Action Plan will be transferred to the Project Central File. The specific material contained in each Project

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Working File will vary, depending upon the nature of the associated Action Plan; where applicable, it will contain, at a minimum, the following material:

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1 Page 16 of 17 Copies of letters, memoranda or reports documenting the results of analysis performed as part of the Action Plan, including any associated documentation related to the evaluation of such results.

Copies of letters, memoranda, or reports documenting the results of testing performed as part of the Action Plan, including any associated documentation related to the evaluation of such results.

Copies of procedures or checklists used in the performance of testing.

Copies of letters, memoranda, reports, drawings or other means of documenting the results of inspections performed as part cf the Action Plan, N.;.-.

including any associated documentation related to 4'M][+

'44 the evaluation of such results.

.$h? ?k Copies of procedures or checklists utilized in the y,CV performance of inspections.

Copies of letters, memoranda, or reports documenting J~

the results of record reviews performed as part of N/

the Action Plan, including any associated

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documentation related to the evaluation of such y Tf ]7 results.

gy, p Copies of procedures or checklists utilized in the g:@G.

.f performance of record reviews.

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A record of personnel qualifications and a record of g/

training for personnel participating in the W

=.? r implementation of the Action Plan.

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)f.M IX.

SCHEDULE y *s5 At the present time, it is impractical to accurately estimate

%d the schedule for completion of the entire CPRT Program. This

,, ; j is primar'ly due to two elements of uncertainty:

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Several of the Action Plans utilize a phased approach for resolution, consequently the full scope of the necessary review effort camtot be determined until preliminary results e c;q' become available; and

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v..n The TRT questions in the areas of mechanical, QA/QC, and MJ protective coatings have not yet been provided to TUEC, consequently the nature of the Action Plan ac tivities necessary to respond to these questions (and their associated schedule) cannot be determined until a later date.

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The Action Plans presented in Appendix A address, to the L

extent practicable at the present time, the current status and projected schedules for completion of selected elements of the individual Action Plans and, in a few cases, the schedule for

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completion of the entire Action Plan. As addit!.onal information becomes available regarding projected completion schedules for individual Action Plans and for the entire CPRT Progran., it will be provided to the NRC staff.

TUEC is committed to a thorough and complete review of the saf. sty-rclated issues identified by the TET. A satisfactory resolution of these issues which potentially affect the safe operation of the Comanche Peak Units takes precedence over schedule concerns.

As the implementation of the CPRT Program proceeds and after s

the additional TRT questions have been received and additional Action Plans have been developed to address them TUEC intends to perform an evaluation to determine, at that time, whether a safety basis exists to support authorization for fuel loading and precritical testing at Comanche Peak Unit 1 prior to the

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completion of the entire CPRT Progrcm. TUEC will inform the NRC staff of the results of this evaluation.

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COMANCHE PEAK RESPONSE TEAM l

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TUGCO PRESIDENT M SPENCE SENIOR R EVIEW TEAM L. F. FlK *.R B.R.CLEMENTS J.W. B ECK J.L. FRENCH J.C GulBERT g

A. R. B U HL SRT SUPPORT GROUP k

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ELECTRICAL /

CIVIL / 'JECH PROTECTIVE COATING GA/QC TESTING PROGftAMS l

lNSTR. LE ADER LEAOCR LEADER LEADER LE ADER M.8. JONES H. A. LEVl*1 E. P. STROUPE J. L. H A N S EL 3.J. WISE I

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ATTACHMENT I REVISION I

Rr,vicions 1

Page 1 of 3 I

ATTACHMENT 2 ACTION PLAN FORMAT ITEM NUMBER (Short Title) 1.

Description of Issue Identified by NRC l

-Verbatim statement of the TRT issue as stated in the enclosure to the NRC issue transmitted letter

-Develop a separate Action Plan for cach numbered TRT item 2.

Action Identified by NRC

-Verbatim statement of NRC - directed action as stated in the enclosure to the NRC issue transmitted letter

===3.

Background===

-Relevant information which clarifies the issue definition

-Relevant information to provide additional perspective and I

understanding of the issue (including consideration of relevant information before the ASLB)

-Aa explanation (where applicable) of why TUEC has dacided to I

pursue the approach described under Section 4.0 below, where alternative approaches were available

, lE

-If possible, a statement regarding the preliminary determination of root cause and potential generic implications of identified deficiencies 4.

TUEC Action Plan

-Scope and Metbodology l

-Describe approach (phased, if applicable)

-tasks to be performed without conditions I

-tasks to be performed under certain conditions (e.g.,

"If we find "x",

then we will take the following additional action...")

-tasks to be performed as part of an expanded review l'g (where applicab'.a and where this has already been

!g determined) i

-describe how potential generic implications are being

!l considered (where applicable and where this has already l

a been determined) l

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-Procedure (s) to be used

-refarence existing procedures

-describe any now or revised procedures

-Participant's Roles and Responsibilities

-which organizations are involved

-scope for each organization

-identify lead individual

-Qualifications of Personnel I

-state qualifications of personnel implementing the Action Plan I

-referenec these qualifications to existing requirements

-discuss training of personnel which will be I

conducted

-Sampling Plan

-if performing a 100% review, state that a 100%

review is being done

-if sampling is used, provide informatioa. relevant to the. sampling plan, and provide justification for the sample size

-Describe any other features c,2 the sampling plan (e.g. random sampl.1g of the universe, random sampling of ear.S discipline, etc.)

-Provide the definition of a " reject"

-Stands.rds/ Acceptance Criteria

-describe the standards (e.g., FSAR, IEEE, Re;.

l Guides, etc.) against which you are performing the I

review b

-Decision Criteria

-describe the criteria to be used for going to the next phase of a phased-approach review or for expanding the sample size for a review using sampling techniques I

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-Describe the criteria for closing out this item (this is related to the standards / acceptance criteria and the criteria for subsequent phases) 5.

Schedule / Status Describe schedule and current status, to the extent possible. Reference the schedule to the phases where appropriate. If a schedule for a phase cannot be provided until additional information is obtained, state that a schedule will be developed at the completion of the previous phase.

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l ATTACHMDIT 3 j

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ACTION PLAN RESULTS REPORT FORMAT ITEM NUMBER l

(Short Title) 1.

Description of Issue Identified by NRC (same a: Action Plan) 2.

Action Identified by NRC (same as Action Plan)

===3.

Background===

(same as Action Plan) 4.

TUEC Action Plan

-Scope and Methodology

-Same as Action Plan except:

-where conditional phases were implemented, reword trae conditional statement so that it is clear that the phase had been implemented

-where a conditional phase was determined not to be necessary, state that it was not needed and provide a

-l reference to a subsequent part of the report which 5

justifies the decision not to implement the conditional phase

-describe any other substantive changes to the Action Plan and why the changes were necessary 5.

Discussion of Results

-Comparison of results against standards / acceptance criteria

-Comparison of results against decision criteria I

-Dfscussion of corrective actions for any identified deliciencies (e.g., any reinspectic.ts, rework, reanalysis, etc.)

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Conclusions

-Identification of root cause of any deficiencies

-Evaluation of safety significance of identified deficiencies

-Evaluation of generic implications

-where applicable, describe expanded scope of review to address them

-demonstrate linkage to the root cause

-where applicab?e, describe basis for conclusion that no generic implications exist 7.

Ongoing Activities

-Describe any activities still in progress

-State whether these on-going activities have safety significance

-State schedule for completing activities, State whether the work must be completed by fuel load, initial criticality, or I

power above 5%.

8.

Action to Preclude Occurrence in the Future

-Training, Procedural changes, etc.

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ATTACHMENT 4 I

SUMMARY

OF PROGRAM PROCESS 1.

Receipt of NRC-TRT request for addit.ional information.

2.

Preliminary review of issue by Senior Review Team and

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appropriate Review Team Leader.

3.

Review Team Leader obtain additional, clarifying information from liRC-TRT to ensure full understanding of l

the concern (if necessarf).

4.

Review Team Leadcr make a preliminary determination of root cause and potential generic implications of I

ident!fied def'ciencies (if poscible) 5.

Review Team Leader develop Action Plan to resolve concern using guidance providcu in Attachment 2.

6.

Action Plan approved by Senior Review Tess.

7.

Feview Team Leader implement Action Plan.*

8.

Review Team Leader mcke a conclusive determination of I

root cauea and potential generic implications of identified deficiencies.

9.

Review Team Leader obtain concurrence of Senior Review Team in root cause definition and potential generic implications assessment.

I 10.

Review Team Leader develop revised Action Plan to reflect the conclusive determination of root cause and potential generic implications (if applicable).

11.

Revised Action Plan approved by Senior Review Team (if applicable).

I 12.

Review Team Leader implement Revised Action Plan (if applicable).*

13.

Review Team Leader define necessary corrective action for I

identified deficiencies (if applicable).

14.

Review Team Leader define necessary corrective action to I

prevent recurrence of similar deficiencies in the future (if applicable).

15.

Review Team Leader develop Action Plan Results Report using guidance provided in Attachment 3.

16.

Action Plan Results Report approved by Senior Review Team.

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SRT assess Action Plan Results Repert as part of Collective Significance Evaluation.

18.

SRT define necessary corrective actions stemming from the Collective Significance Evaluation 19.

Submit Final Report to NRC, including implementation schedule for necessary corrective a:: ions.

20.

TUEC implement necessary corrective action.

I

• Action Plans and revised Action Plans will be submitted to the NRC staff for review and comment at the time they-have been approved by the SRT; however, implementation of Action Plans will not be delayed pending receipt of NRC staff cournents. Any necessary changes to Action Plans resulting from NRC review and comments will be incorporated expeditiously.

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I APPENDIX A ISSUE-SPECIFIC ACTION PLANS 4

(Revision 1 to be submitted under separate cover)

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