ML20205J334

Rev 3 to Comanche Peak Response Team Program Plan & Issue-Specific Action Plans

ML20205J334
Person / Time
Site:	Comanche Peak
Issue date:	01/27/1986
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20205J321	List: ML20205J318 ML20205J334
References
PROC-860127, NUDOCS 8601300159
Download: ML20205J334 (759)

Text

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COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN AND ISSUE-SPECIFIC ACTION PLANS REVISION 3

[eR* 28ss 8I8hs TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY l .'

ADVANCED COPIES SENT TO:

NRC CONSULTANTS Charles Trammell D. Landers (TES)

Jose Calvo B. Masterson (Eng. Analysis Services)

John Knox C. liofmayer (Brookhaven)

Ed Tomlinson C. liaughney (COMEX)

Dave Jeng P. Keshishian Larry Shao (4) cys H. Saffell (Battelle)

Shou llou J. Nevshema David Terao L. Stanley (Zytor Inc.)

Geary Mizumo Tom Westerman (6) cys D. Norkin (2) cys C Early A. Marinos LTR ENCL Docket File i 1 NRC PDR 1 1 NSIC 1 1 LPDR 1 1 CHARLES THAMMELL - EXTRA COPIES DISTRIBUTION PERT C. TRAMMELL (PM)

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1 l b O COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 4

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COMANCHE PEAK RESPONSE TEAM 1

PROGRAM PLAN 1

AND I 1

ISSUE-SPECIFIC ACTION PLANS

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! REVISION 3 i

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TEXAS UTILITIES GENERATING COMPANY

,O A DIVISION OF

! TEXAS UTILITIES ELECTRIC COMPANY

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O COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN Rev. Description 0 Oriainal Issue 10/08/84 Revised to Reflect 1 NRC Comunents 11/19/84 General Revision to Reflect NRC 2 Cosunents 06/28/85 Revised to Reflect O 3 NRC Comments 01/25/86 0

TABLE OF CONTENTS O I. INTRODUCTION - OBJECTIVES II. CPRT CHARTER III. CPRT PROGRAM PLAN PRINCIPLES IV. CPRT PROGRAM STRUCTURE AND METHODOLOGY V. CPRT PROGRAM PROCESS VI. CPRT PROGRAM OUTPUTS VII. CPRT OBJECTIVITY CUIDANCE VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES ATTACHMENT 1: CHRONOLOGY Or EVENTS ATTACHMENT 2: CPRT ORGANIZATION CHARTS ATTACHMENT 3: ISSUE-SPECIFIC ACTION PLAN (ISAP) FORMAT ATTACHMENT 4: DISCIPLINE SPECIFIC ACTION PLAN (DSAP) PORMAT ATTACHMENT 5: ISAP RESULTS REPORT FORMAT ATTACC ENT 6: DSAP RESULTS REPORT FORMAT ATTACHMENT 7: CPRT OBJECTIVITY FORM APPENDIX At DESIGN ADEQUACY PROGRAM PLAN APPENDIX B: QUALITY OF CONSTRUCTION AND QA/QC ADEQUACY PROGRAM PLAN ,

APPENDIX C: ACTION PLANS t."PENDIX D CPRT SAMPLING APPROACH, APPLICATIONS AND GUIDELINES APPED IX Et CPRT PROCEDURE FOR THE CLASSIFICATION, EVALUATION AND TRACRING OF SPECIFIC DESIGN OR CONSTRUCTION DISCREPANCIES IDENTIFIED BY CPRT APPENDIX F: CFRT INTERFACE IDENTIFICATION APPENDIX G CPRT THIRD-PARTY QUALITY ASSl"!ANCE PROGRAM O APPENDIX H: CPRT PROCEDURE FOR THE DEVELOPMENT, APPROVAL, AND CONFIRMATION OP IMPLEMENTATION OF CORRECTIVE ACTION

p ABBREVIATIONS AND ACRONYMS

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CAR Corrective Action Request

! CASE (1) Co-ordinated Agency for Suppliers Evaluation CASE (2) Citizens Association for Sound Energy CAT Construction Assessment Team (NRC)

CMC Component Modification Cards CPRT Comanche Peak Response Team CPPE Comanche Peak Project Engineering CPSES Comanche Peak Steam Electric Station CPSRT Comanche Peak Special Review Team (NRC) i CRAV Control Room Area Ventilation CTCS Cable Tray and Conduit Supports DAPTS Design Adequacy Program Tracking Systems DAP Design Adequacy Program DCA Design Change Authorization DCC Document Control Center DIR Deviation Information Report D/IRR Discrepancy / Issue Resolution Report DR Deviation Report DSAP Design Specific Action Plan DSG Damage Study Group DSP Damage Study Program ERC Evaluation Research Corporation ESFAS Engineered Safety Features Actuation System GAP Government Accountability Project

\-- CIC Generic Implications Coordinator RDA Homogeneous Design Activity HELB High Energy Line Break HFT Hot Functional Testing IAP Independent Assessment Program (Cygna)

IDI Integrated Design Inspection IDVP Independent Design Verification Program IR ,

Inspection Report (NRC)

ISAP Issue Specific Action Plan LCTS Licensing Commitment Tracking System NPSH Net Positive Suction Head NPSI Nuclear Power Services, Inc.

PAC Project Assistance Corporation PDRF Piping Deviation Request Forms l

PPRV Permanent Plant Records Vault PPSP Project Piping and Supports Program QOC Quality of Construction and QA/QC Adequacy l Program t

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I ABBREVIATIONS AND ACRONYMS Cont'd RA Records Administrator RIL Review Issues List (Cygna/IAP)

RIV Region IV (NRC)

RLCA Robert L. Cloud Associates RTL Review Team Leader SAFETEAM (Registered Trademark)

SDAR Significant Deficiency Analysis Report SET Special Evaluation Team SIT Special Inspection Team (NRC)

SRP Standard Review Plan

! SSEG Safety Significance Evaluation Group (S&W)

SSER Supplemental Safety Evaluation Report (NRC) l SRT Senior Review Team SRT Special Review Team (NRC)

STE System Test Engineer i SWEC Stone and Webster Engineering Corporation TAG TUCCO Audit Group TDCR Test Deviation Change Request TDR Test Deficiency Report TDDR THE Design Deviation Report TNE TUGC0 Nuclear Engineering TPD Test Procedure Deviation O TRT TUEC Technical Review Team (NRC)

Texas Utilities Electric Company j

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R;vicicn 3 Pcg2 1 cf 45 Comanche Peak Steam Electric Station

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Comanche Peak Response Team O Program Plan I. INTRODUCTION - OBJECTIVES The U.S. Nuclear Regulatory Commission's (NRC's) Executive Director for Operations (EDO) issued a directive on March 12, 1984, establishing a program for assuring the overall coordination, integration and resolution of technical concerns and allegations prior to the NRC Staff's licensing decision on Comanche Peak. In response to this directive, the various offices within the NRC l

formed a Technical Review Team ("TRT"). In July 1984, the TRT began onsite activities as a part of its review plan using a team divided into five groups: electrical / instrumentation, civil /

mechanical, QA/QC, protective coatings and testing programs.

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

-offices in Bethesda, Maryland. NRC management and its TRT presented Texas Utilities Electric Company (TUEC) with a request for additional information in the electrical / instrumentation, civil and testing program areas.

In response to this request TUEC formed the Comanche Peak Response Team (CPRT) and formulated a program and Issue-Specific Action Plans to address the TRT concerns. On October 8, 1984, the CPRT Program Plan and Issue-Specific Action Plans (ISAPs) were l

] originally submitted to the NRC. Since that time, TUEC has made a j number of changes to the CPRT Program as a result of a.) additional meetings with NRC, CASE, Cygna and allegers, b.) additional NRC i requests for informati6n and c.) TUEC% determination that the CPRT should engage in the self-initiated evaluations of design adequacy and quality of construction that are described herein. A chronology of these events is included as Attachment 1.

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First, the CPRT scope has been expanded. In addition to the TRT concerns, the CPRT charter was expanded to include quality of

construction and construction QA/QC issues raised by the following additional sources

the NRC ASLB proceedings on the CPSES

operating license , the NRC Staff's Supplemental Safety Evaluation l Reports ("SSERs") and its Construction Assessment Team (" CAT") and Special Investigation Team (" SIT") reports, Inspection Reports issued by NRC's Region IV ("RIV") and the Cygna Independent Assessment Program ("IAP"). (Collectively these are referred to in this Program Plan as the " External Sources" and the specific issues they raise as the " External Source issues.") Thereafter, the charter was expanded again to include quality of design issues raised by the same External Sources (or to which the CPRT might be led in the course of investigating External Source-generated quality of construction issues). Finally, the charter was expanded to include a mandate of assuring TUEC management of the safety of g the plant regardless of the extent to which issues might have been raised by External Sources. This has resulted in the development of two comprehensive CPRT self-initiated evaluation programs.

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1. INTRODUCTION - OBJECTIVES (Cont'd)

At the same time the composition of CPRT has evolved. Initially a l

CPSES project effort with some input from third-party experts, CPRT -

' today is.primarily a third-party effort in the sense that i

evaluations are either performed by or overviewed by third-party experts.

! CPRT is now charged with responding to and resolving the open TRT l

ASLB, SSER, CAT, SIT, RIV and IAF issues and with advising TUEC j management whether there~is reasonable assurance that CPSES has i'

been designed, constructed and tested such that it is capable of being operated without undue risk to the public. To discharge.this

mission, the CPRT has three overall objectives

i l First, the CPRT will evaluate each of the specific External j Source issues relating to design adequacy, quality of installed hardware, and testing. It will determine the nature l of any safety-significant deficiencies and the corrective i actions necessary to resolve them. This component of the l Program will lead to reasonable assurance that there are no i undetected and uncorrected safety-significant deficiencies i associated with any of the specific External Source issues.

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l Second, the'CPRT will investigate and determine where possible the root cause of each found safety-significant deficiency or adverse trend of non-safety-significant deviations or design j observations and analyze the generic implications of each root

- cause in order to determine the extent of any additional i construction, design or testing efforts that might be i deficient for the same reasons. .It must be recognized that an

! investigation of " root cause" can be an iterative process and I in some cases will end with a determination that no single j definitive root cause can be found. However, where a root i .

cause is found it will assist the CPRT in identifying potential generic implications, thus establishing a scope for a further review and definition of appropriate corrective

! actions.*

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• When a deficiency is discovered, investigation into the probable )

cause initially may suggest many possibilities as contributing l

l causes. In some cases, these can be narrowed down to one most i likely candidate. If the investigation shows no further i

! possibilities, we can define the " root cause" as the event or i decision which is the most likely cause of the identified  ;

j deficiency. This may, for example, lead to a finding that the

deficiency was due to errors in the instructions. However, if i further investigation in the same area of design, construction or I testing shows similar errors in the instructions, it may be l determined that the author of the instructions is the real " root

c aus e".. Discovery of the second, more extended root cause will

! enable correction of the wider-ranging situation and lead to greater assurance that there are no undetected and uncorrected safety-significant deficiencies associated with the causes of any deficiencies or adverse trends identified by the External Source issues.

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1. INTRODUCTION - OBJECTIVES (Cont'd)

These first two objectives are complementary and each has the potential for expanding the other. The investigation and determination where possible of root cause and evaluation of generic implications may lead to additional areas of the construction, design or testing processes equiring evaluation, and the evaluation of found cafety-significant deficiencies or adverse trends of non-safety-significant deviations or design observations may lead to the establishment of additional root causes and potential generic implications. Similarly, the evaluation of specific deficiencies may lead to the expansion of programmatic issues; and the evaluation of programmatic root causes may lead to the expansion of the review of specific hardware, design or testing activities.

The sum of these two objectives will fully resolve each of the External Source issues, and it will fully bound the safety-significant implications of any identified or found deviation associated therewith.

Based upon an understanding of the potential generic implications associated with several of the External. Source issues, the CPRT recognized that, in order to make conclusive statements regarding the adequacy of the CPSES quality of construction and design, cdditional investigative efforts would likely be needed in certain areas not specifically identified by the External Sources. (The 0 SRT determined that the testing area did not require a self-initiated effort due to the completeness of the testing program review described in the Issue-Specific Action Plans.)

Accordingly, as described below, the CPRT has developed a third program component of self-initiated evaluation that is intetded:

To investigate on a proactive basis additional areas to which the CPRT may ultimately be led in the course of its root cause/ generic implications assessments for External Source issues.

To ensure, as a matter of additional confidence, that the investigative efforts of the CPRT program are of sufficient depth and breadth to parmit the conclusions reached as a result of the first two components to be extended to the balance.of the A/E design scope for the safety-related portions of the plant.

Third, the CPRT will conduct 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 reviews of designs that are representative of the aggregate A/E design O' scope relative to design criteria, disciplines, processes and organizations used in the design of the safety-related aspects

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1. INTRODUCTION - OBJECTIVES (Cont'd) i ) of the plant (refer to Attachment 3 to Appendix A for more detail). The NSSS design scope and the design of equipment-supplied by vendors is not within the CPRT review scope, though interfaces between the A/E and the NSSS vendor will be evaluated. (Refer to Appendix A for more information.)

4 In the conduct of these two self-initiated evaluations, the CPRT will also investigate and determine where possible the root cause of each identified safety-significant deficiency or-adverse trend of non-safety-significant deviations or design observations. The implications from the root cause(s) will be.

analyzed to determine the extent that other construction or design activities could be' deficient for similar reasons.

! The accomplishment of these three objectives in accordance with the 1 CPRT charter and program principles will permit the CPRT to reach conclusions about.the adequacy of the design, construction and testing of CPSES, regardless of the extent to which quality of construction, design adequacy or testing may have.been challenged by the External Scurce issues or by the self-initiated

! investigation.

This document contains the CPRT Program Plan, which governs all l CPRT activities. TUEC has been responsive to NRC comments in the l areas of CPRT scope, CPRT activity execution and the makeup of the 4

CPRT Senior Review Team. By its very nature, the CPRT Program Plan l has not been and will not be a static document. As situations l arise, the conduct and scope of CPRT activities will be revised as appropriate.

II. COMANCHE PEAK RESPONSE TEAM (CPRT) CHARTER.

The charter of the CPRT is to develop and implement a program, including third-party investigation and evaluation and/or third- l r party. review and oversight of CPSES Project activities, that will address and respond to the potential safety-related concerns related to the External Source issues, that will accomplish the objectives set forth in Section I above, and that will provide the

! reasonable assurance to TUEC management described therein.

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R;vicion: 3 Pcgs 5 of 45 II. COMANCHE PEAK RESPONSE TEAM (CPRT) CHARTER (Cont'd)

The CPRT organization includes experienced third-party personnel for the purpose of ensuring a fresh and objective perspective in the evaluation and resolution of potential safety-relate'd concerns regarding CPSES. Additional information on the objectivity criteria utilized in the selection of CPRT personnel and the composition of the CPRT is presented in Sections VII and VIII, respectively.

The scope of the CPRT program is further defined as follows:

- The CPRT will address the specific External Source issues including the logical extension of those concerns based upon its assessment of root causes and generic implications. These investigations may require technical and programmatic evaluations beyond the immediately apparent boundaries of the concerns'. The scope of the CPRT efforts will be expanded as appropriate 1) where safety-significant deficiencies are identified, 2) where adverse trends of hardware deviations or deviations from criteria or design observations are detected and 3) other special cases, e.g., where a non-safety-significant deviation (s) would likely result in an undetected safety-significant deficiency if occurring elsewhere. (See Appendix E for detailro)

- The CPRT will address issues being handled by TUEC in the i 0,- context of ongoing, routine licensing and inspection and enforcement activities for CPSES including SAFETEAM* to the l extent that those issues are directly relevant to the issues within the CPRT scope of review. (SRT Policies and Guidelines describe how these matters are addressed.)

Since Unit 2 is still under construction CPRT activities address Unit 2 in several ways. First, the CPRT activities identified in ISAPs and Discipline Specific Action Plans (DSAPs) include reviews and reinspections of completed design activities and construction hardware for Unit 1, Unit 2 and common areas. (ISAPs and DSAPs are further explained for Section IV below.) For example, hardware populations in ISAP VII.c contain items from Unit 2 completed work. Second, any expansions of the CPRT scope of review due to identified adverse trends, root cause determinations or generic implications evaluations will be conducted in a thorough and complete manner irrespective of Unit 1/ Unit 2 boundaries.

Third, any corrective actions resulting from the CPRT activities, whether specific or programmatic in nature, will be processed in accordance with CPRT Program requirements.

(See Appendix H.)

• SAFETEAM is the allegation (employee concern)' resolution program currently endorsed, functioning and supported by TUEC Senior Management.

R.vicient 3 Pags 6 of 45 II. COMANCHE PEAK RESPONSE TEAM (CPRT) CHARTER (Cont'd)

O V - The CPRT will identify possible implications of its findings that should be considered by TUEC for possible impact on design, construction, testing and maintenance activities after the unit is in operation.

- The Quality of Construction and QA/QC Adequacy Review Team and

- Design Adequacy Review Team will consider those issues closed by the initiating External Source for information regarding potential root cause and generic implications.

The CPRT will consider a specific CPRT concern to be resolved at such time as the Results Report is issued. The period of third-party overview.of corrective actions will vary depending upon the nature of the findings during implementation of the plan. Such CPRT overview activities will be documented either in the Action Plan Results Report or a supplement thereto. (See Appendix H.)

CPRT will consider the CPRT Program to be completed at such time as' each of the Objectives stated in Section I have been accomplished, including CPRT's assessment of the collective significance of identified deficiencies.

III. CPRT PROGRAM PLAN PRINCIPLES (D The CPRT Program is founded on the principles of Q

- Thorough reviews

- - Evaluation'of deviations for safety significance l

- Investigation and determination where possible of root cause(s)

- Evaluation of generic implications

- Evaluation of findings to determine collective significance I

- Specification of corrective actions

- Need for program to be conducted in such a manner that its objectivity and credibility will not be questioned

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Specification of personnel qualifications / training requirements

- Assurance of the quality of program activities

- Documentation of program activities and results. l D.

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III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd)

The CPRT Senior Review Team (SRT) has insisted on the development l and inclusion of these principles'in the Program Plan in order to ensure'that the CPRT and consequently TUEC objectives for the CPRT Program would be satisfied.- A detailed. description of each of these principles follows.. These descriptions are exemplary of the l commitment that the CPRT and TUEC have to resolve all concerns l associated with the design, construction and testing of CPSES.  !

A. Thorough Reviews  ;

The attachments to NRC letters dated September 18, 1984 November 29, 1984, and January 8, 1985 identified specific requests for additional information and provided specific examples of potential deficiencies. Further clarifications to l these concerns have been provided in SSER-7 through SSER-11 and various public meetings between the CPRT and b1C.

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

Accordingly, each issue will be thoroughly evaluated, even if a preliminary assessment indicates.that the specific item cited by NRC-TRT has no safety significance.

Also, in some cases it will be appropriate to expand the investigation that TRT or another External Source performed in order to explore issues more thoroughly. This will enable the CPRT to obtain a more complete understanding of the safety significance of any identified deviations and the root causes and generic implications of any deficiencies and to achieve a higher degree of confidence in the CPRT Program results.

B. Safety Significance Evaluations

" Safety-significant", for purposes of the CPRT Program, is defined to mean that the identified discrepancy, if 4 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 structure level *. The results and bases for safety ,

significance evaluations will be documented in each action plan working file and summarized in each Results Report.

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• This definition which is employed in the CPRT Program for purposes

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o f sample expansion, is more restrictive than that usually applied to the term " safety-significant" for regulatory purposes or in common. parlance, in that it ignores redundancies that do exist in real life. [ Compare 10CFR50, Appendix A (Introduction, " Single Failure"); 10CFR50.55(e)(1) . ] Identification of a deviation as

" safety-significant" for purposes of the CPRT Program, therefore, is not necessarily equivalent to a statement'that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.

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Rcvicient 3 Pega 8 of 45 III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd)

() C. Root Cause Determinations Root cause will be investigated and determined where possible for all adverse trends of deviations and/or design observations and for all deficiencies identified through the CPRT Program. Such determinations will assist CPRT in identifying potential generic implications, establishing appropriate expanded scopes of review and defining appropriate corrective actions.

ISAPs and DSAPs include tasks that will investigate and determine where possible the. root.causes of identified deficiencies. These tasks are oriented both at specific testing of any initial root cause hypotheses as well as more general exploratory efforts that will lead to formulation and testing of new root cause hypotheses as the action plan is implemented. Each action plan Results Report will provide a description of the actions used to investigate and where possible, determine root causes.

D. Generic Implications Evaluations At such time as the root causes of identified safety-significant deficiencies or adverse trends of non-safety-significant deviations or design observations have been O determined, an evaluation will be performed to identify any associated potential generic implications. Such evaluations will enable the CPRT to determine whether they represent isolated occurrences, non-isolated or generic weaknesses within a particular area or generic weaknesses that are programmatic in nature.

The results of such evaluations, in conjunction with an assessment of the safety significance of the deviations, will enable the CPRT to define appropriate expanded scopes of review and to identify appropriate corrective actions for the specific deficiency and for the same circumstances / situation which might allow the same deficiency to be repeated.

E. Collective Significance Evaluation The collective significance evaluation will focus on the integrated impact of the identified deficiencies, both specific and programmatic, on the design, construction and testing of CPSES.

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Rcvisicn 3 Pcg2 9 of 45 III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd)

) This evaluation will be based primarily on the information developed through the safety significance evaluations,. root cause determinations and generic implications evaluations. It will include a determination as to whether the existence of multiple, apparently isolated and relatively minor.

discrepancies 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 activities at CPSES Units 1 and 2.

F. Corrective Actions Appropriate corrective actions including physical plant modifications will be defined to resolve all specific and programmatic deviations and deficiencies identified by the CPRT during the course of this review and evaluation program.

The duration of third-party overview of corrective actions will vary depending on the nature of the findings discovered during implementation of each plan. (See Appendix H.)

In addition to corrective actions designed to resolve speci'ic deficiencies, actions will be identified to prevent future occurrence at CPSES Units 1 and 2. Such actions will be l developed using the results of the evaluations of root causes, generic implications and collective significance.

Accordingly, the focus of these corrective' actions will be to O3 resolve weaknesses that are generic or programmatic in nature.

In general, the corrective action to be taken will be to bring the plant into conformance with the commitments made in the FSAR and other licensing documents; however, alternatives may be used subject to NRC approval. Where such. alternatives are i used, appropriate bases and justification will be provided.

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l Where known, the precedents (at other comparable nuclear i plants) for using the alternative criteria will be provided. l G. Objectivity Due to the importance TUEC has placed on maintaining the objectivity of the CPRT Program,Section VII in the CPRT Program Plan is devoted to this topic.

H.- Personnel Qualifications / Training The Review Team Leader (RTL) is responsible for the selection-I of qualified personnel-to perform third-party activities based on individuals' technical competence and subject to.the ,

objectivity guidelines noted'in Section III.K and VII below. j igg Third-party personnel working on CPRT activities will receive

(\j training on the provisions the CPRT Program Plan deemed

-essential to the executions of this work by each RTL. Where

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III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd) applicable, additional training to procedures developed for action plan activities and/or existing CPSES QA program procedures will be provided to individuals involved with inspection, records review / evaluation and testing .(other than preoperational) activities.

I. Sampling i

The CPRT Program utilizes reinspections of hardware, QA

' documentation reviews, drawing and specifications assessments, interviews and programmatic assessments singly or in combination to implement the CPRT principle of thorough reviews in each of the action plans. The results of implementing these actions plans, including root cause/ generic implication assessments as findings dictate, will form the basis for the reasonable assurance conclusions that the CPRT Program will make at its conclusion.

4 Given that the CPRT Program was designed purposefully to i' assess the CPSES design, construction, testing and QA/QC programs of record, and not to replace them, the SRT decided l

that reviewing a sample of the hardware, records, documents,  ;

j etc. would provide sufficient data to draw conclusions about i the programs of record. Consequently, consistent sampling 1 application guidelines were developed for use in various action plans.

4 Appendix D, "CPRT Sampling Approach, Applications and Guidelines", contains the sampling applications guidance used in action plans where sampling is applied. Dr. Fred Webster

, of Jack Benjamin & Associates is the CPRT Adviser on

. engineering statistics. Dr. Webster's responsibilities- in 5

this role. include providing an objective evaluation of the l l' adequacy of the design of each sampling application and '

ensuring consistency in the interpretation of results.

J. CPRT Program Records In order to ensure that an auditable record of the CPRT .)

Program is available, the documentation described below will ,

be developed ~and maintained.

CPRT Central File -

l The CPRT. central file will be maintained by the CPRT Program Director. At the: completion of. the CPRT Program, it will

-contain CPRT-generated documentation, including the action

[ plan working files maintained by~each RTL during the. conduct l i- of the program. During the conduct of the program, the CPRT l central file will contain the following material- ,

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R2vicient 3 Pags 11 of 45 III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd)

- A copy of the Program Plan submitted to the NRC and any subsequent revisions thereof.

- A copy of the individual ISAPs and DSAPs submitted to the NRC and any subsequent revisions thereof.

- A copy of each Action Plan Results Report.

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- Individual ISAP and DSAP working files for all action plans which have been completed (i.e.,' Action Plan Results Reports reviewed and approved by the SRT).

- Copies of CPRT Policies and Guidelines and revisions thereto.

- SRT meeting minutes.

- SRT comments on Results Reports.

- Collective Evaluation Reports.

- Collective Significance Report.

CPRT Working Files Working files will be maintained by th'e RTLs for each action I plan under their cognizance until such time as the action plan has been completed. At that time, the action plan working file will be transferred to the CPRT central file. The specific material contained in.each action plan working file will vary, depending upon the nature of the associated action plan. Where applicable, it will contain, at a minimum, the following material:

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 of the action plan, including any y associated documentation related to the evaluation of such results i

R; vision 3 Pcg2 12 cf 45 III..CPRT PROGRAM PLAN PRINCIPLES (Cont'd)  ;

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O( ,,e - Copies of procedures or checklists utilized in the performance of inspections Copies of letters, memoranda, or reports documenting the results of record reviews performed as part of the action plan, including any associated documentation related to the evaluation of such results

- Copies of or references to procedures or checklists utilized in the performance of record reviews Copies of records of personnel qualifications and of records of training for personnel participating in the implementation of the action plan

- Copy of Action Plan Results Report sent to SRT and resolution of SRT comments thereon.

K. Assurance of CPRT Program Quality The CPRT SRT is committed to assuring the quality of CPRT Program activities and results. The SRT's commitment to quality is manifested in the CPRT Program principles and the CPRT Third-Party Quality Assurance Program described in

s Appendix G. The SRT has and will continue to evaluate the activities and results of the CPRT Program against these program principles and Appendix G, thereby assuring the quality of the CPRT Program.

The SRT established the following additional ~ governing principles to ensure the quality of the work performed under  ;

the CPRT:

The members of the CPRT have full and complete access to all plant areas, documentation, calculations, files and personnel as deemed necessary to execute their

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responsibilities.

The RTLs, subject to review and approval  !

I by the SRT, have the authority.and responsibility to establish the scope and content of ISAPs and DSAPs.

Analyses and calculations will be performed either by an organization not previously responsible for the technical subject area for the CPSES Project or by the i originating organization with an overview by a l third-party organization.

Inspections will be performed either by qualified f ~s inspectors not_previously affiliated with the CPSES

() Project and.not~ currently affiliated with TUEC or its principal contractors for the CPSES Pr'oject or by qualified inspectors who were not personally involved in the in~spection activities in question, with third-party overview on a sampling basis.

R vision: 3 Pcg2 13 of 45 III. CPRT PROGRAM PLAN PRINCIPLES (Cont'd) )

p

(,) - Selection of personnel for inspection activities will be mutually agreed upon-by the responsible RTL and the RTL for the QA/QC Review Team.

- Records reviews and evaluations will be performed-either by third-party personnel or by CPSES Project personnel with a third-party overview on a sampling basis.

- Testing and NDE activities (other than preoperational testing) will either be conducted and test results will be certified by third-party personnel or conducted by the CPSES Project with an overview by the third-party.

- The CPRT will not perform inspections, calculations or designs of record for CPSES. These will be performed as required by the appropriate CPSES Project organization with appropriate overview by the third-party.

- The actual implementation of CPRT-recommended corrective action -- usually either a change in a CPSES program or a modification or repair to installed hardware -- is a CPSES Project activity and will be overviewed by CPRT as described in Appendix H. l V("'g IV. PROGRAM STRUCTURE AND METHODOLOGY Program Structure This Program Plan is the charter for all CPRT activities.

Appendices A and B describe the Design Adequacy Program (DAP) and Quality of Construction and QA/QC Adequacy Program (QOC) respectively. Specific actions to be accomplished in response to-the TRT and other External Source issues and in the QOC area are contained in the action plans contained in Appendix C. Each TRT issue is addressed in one or more ISAPs-and/or DSAPs. In the QOC area, the ISAPs are categorized as either issue responsive or:

self-initiated.

The tasks to be accomplished in the DAP are described in the l DSAPs contained in Appendix C. Each DSAP addresses both issue responsive'and self-initiated activities as is appropriate in the discipline in question.

l l

i l

R1 vision 3 Paga 14 of 45 l

.IV. PROGRAM STRUCTURE AND METHODOLOGY (Cont'd) p Program Methodology A. The Issue-Responsive ISAPs and DSAPs For the ISAPs and aspects of DSAPs that respond to specific

. External Source issues, the Design Adequacy Program and Quality of Construction and QA/QC Adequacy Program Plans describe and the ISAPs and DSAPs reveal a range of evaluative approaches. Selection of an approach depends on the nature of the specific issue being responded to. In general, however, the methodology will result in identification of the issue in technical terms, identification of any deviations, and evaluation of the deviations for safety significance leading to an identification of any deficiencies. Third-party oversight and specification of corrective action to resolve deficiencies will be in accordance with Appendix H.

~

In -

addition, root causes will.be established where possible for

~

deficiencies, and the generic implications of all root causes will be investigated.

The Design Adequacy Program Plan (Appendix A) recognizes that it may be more efficient and expedient for a given design area to be completely reanalyzed than it is to address specific issues. It also recognizes that proceeding directly to hardware modifications may be more expedient and less costly b}

~g than the analyses required to demonstrate conclusively either that the original hardware is qualified or that it is not. It has already been determined to employ these approaches in the cases of large bore piping and pipe supports and cable-tray supports. TUEC has retained the firm of Stone & Webster Engineering Corporation to perform a complete piping and pipe support reanalysis. Similarly, TUEC has retained Ebasco Services Corporation and Inspell Corporation to reanalyze the cable tray supports. CPRT will overview both efforts and report its concurrence with the reanalysis in its action plan results reports on each issue.

B. The Self-Initiated Efforts The self-initiated effort in the QOC area is a sample reinspection of essentially the entirety of the safety-related hardware in the plant. . Populations of hardware representing the various types of construction activities will be determined. A random sample will be drawn from the entire population. Another sample will be drawn from a subset of the population which is determined on an engineering basis to be more important to safety. The size of both samples will be j set consistent with Appendix D. The sampled items will be inspected to criteria reviewed by the Design Adequacy Review Team, and the analysis of' selected deviations for safety l O significance will be reviewed by the Design Adequacy Review l Team. -Design deviations or deficiencies identified by the l QA/QC Review Team will be transferred to the Design Adequacy l Review Team for evaluation.

R2 vision: 3 P g2 15 of 45 1V. PROGRAM STRUCTURE AND METHODOLOGY (Cont'd)

The self-initiated effort in the design adequacy area is similarly global. Here a multiple step process was used to select a' set of systems, structures and components for detailed design review and then to confirm that the selected set (supplemented as necessary by other design reviews) enveloped all of the design processes, disciplines and organizations involved in the design of safety-related CPSES systems, structures and components.

Deviations constituting either safety-significant deficiencies or adverse trends of non-safety-significant deviations or design observations will be evaluated for root cause and generic implications. The root causes and generic implications will be pursued through a number of techniques that may include additional'reinspections. The result of this work will be reasonable assurance that no undetected safety-significant hardware deficiencies exist. These efforts will upon implementation envelope any issue that has been or could have been raised about the design, quality of construction and testing at CPSES.

V. CPRT PROGRAM PROCESS The overall process for the development and implementation of th'e O CPRT Program and associated action plans have been presented in the preceding sections.-

Additional information related to the development of ISAPs and DSAPs is presented in Attachments 3 and 4 respectively. Whild each action plan-is unique, the programmatic guidelines set forth in Attachments 3 and 4 and the action plan review and approval process ensure that each action plan is developed and implemented in a manner that meets CPRT Program objectives and-principles. Each action plan includes a description, where applicable, of the following:

Scope and methodology Identification of procedures and checklists Participating personnel Qualifications of participating personnel

- Training of p'articipating personnel Sampling plan Relevant standards C< -

Applicable acceptance criteria

Rsvision: 3 l Paga 16 of 45 l V. CPRT PROGRAM PROCESS (Cont'd)

(D

( ,,/ -

Applicable decision criteria.

Additional information related to developing action plan results reports is presented in Attachments 5 and 6. The programmatic guidelines set forth in_ Attachments 5 and 6 and the Results Report review and approval process ensure that the following subjects are adequately addressed where appropriate during the implementation of each action plan:

- Thorough investigation of the issue

- Evaluation of the safety significance of any identified deviations Identification of root cause of identified deficiencies and adverse trends of non-safety-significant deviation and design observations

- Determination of potential generic implications of identified deficiencies and adverse trends of non-safety-significant deviations and design observations and a description of how they were addressed

- Determination and overview of implementation of necessary corrective actions to resolve identified deficiencies and O. deviations, both specific and programmatic in accordance with Appendix H Identification of necessary action to preclude recurrence in the future.

To the maximum extent possible, the scope of the ISAPs and DSAPs responsive to External Source issues will be based on preliminary assessments of root cause and potential generic implications.

Action plans will be sufficiently broad to identify and assess.

safety significance, root causes and generic implications.

Accordingly, most of the ISAPs and DSAPs will utilize iterative or phased implementation approaches that include an initial phase which is exploratory in nature.

Conclusive determinations of root causes and potential generic implications will be made when possible. The safety significance

~

of identified or potential deviations will also be determined. The scope of the associated ISAP or DSAP will be. reassessed in light of these determinations. If an action plan is determined not to meet program requirements, it will be appropriately revised and/or new action plans may be developed (if appropriate) to ensure that potential generic implications are properly investigated and addressed.

-s V

R vicion: 3 Pega 17 of 45 VI. PROGRAM OUTPUTS f~~%

i t

Each ISAP and each DSAP will produce a Results Report. Each N/

s Results Report will at a minimum identify the found safety-significant deficiencies and programmatic deficiencies, their resolution, any root causes and generic implications and their resolution and any recommendations for programmatic improvements to abate the potential for reoccurrence. (See Attachments 5 and 6 for format.) 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.

In the Quality of Construction and QA/QC Adequacy, Lesign Adequacy and Testing Program Adequacy areas, the results of the various activities will then 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.

Finally, the SRT will develop an overall, integrated Collective.

Significance Evaluation Report as described in Section III.E above.

VII. CPRT OBJECTIVITY GUIDANCE

~

With the exception of the Chairman of the 3RT and the CPRT Program O_,

s Director, the CPRT third-party program organization is comprised of personnel who are affiliated with organizations external to TUEC.

The Chairman of the SRT, Mr. John W. Beck, is the primary interface between TUEC management and the'CPRT. Mr. Beck joined TUGC0 in April 1984. The CPRT Program Director, Mr. Terry G". Tyler, provides day to day coordination of CPRT activities on behalf of the SRT. Mr. Tyler was a third-party consultant working for-Energex Associates, Incorporated prior to joining TUGC0 in October 1985.

The remaining members of the SRT, the CPRT advisers, all five RTLs and third-party personnel assisting the RTLs in various capacities, including issue coordinators, are experienced nuclear-industry consultants who have not been previously involved with the CPSES activities that they are now reviewing.

The selection of CPRT third-party personnel was based on the following criteria:

I

- Integrity of both the individuals and the organizations with which they are affiliated based upon their reputation and standing within_the nucicar industry..

- Objectivity of both the individuals and the organizations with which they are affiliated based upon their demonstrated

('Ns,,) capability and reputation ~for providing objective, dispassionate technical judgments on the basis of technical merit.

R2vieicn: 3 Pags 18 of 45 i

l VII. CPRT OBJECTIVITY GUIDANCE (Cont'd) )

,-~.

ks- - Objectivity of both the individuals and the organizations with  ;

which they are affiliated based upon the lack of previous I involvement in the CPSES project activities in question.  ;

The SRT expects th'ese objectivity criteria shown in Attachment 7 to be fully met for third-party CPRT personnel. Any exceptions will be documented in the appropriate CPRT files. The SRT is )

respansible for assuring compliance with these objectivity criteria l for the CPRT organization down to'the RTL level. Each RTL is responsible for. assuring the objectivity of the third-party personnel they utilize in the implementation of their activities. ,

i l

VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES j i

A. Introduction TUEC established the Comanche Peak Response Team (CPRT) to develop and implement the CPRT program. The CPRT organization as shown in Attachment 2.1 is composed of the following functional positions:

- Senior Review Team - formulates policy and provides overall direction of CPRT activities. j CPRT Program Director - provides day to day coordination of CPRT activities on behalf of the SRT.'

Review Team Leaders - provide technical 1 direction in areas of assigned responsibility including development and management of action plans.

Issue Coordinators assist Review Team Leaders in

- implemen; ng action plans.

Advisers to the CPRT - provide advice to the CPRT in areas of their specific expertise.

Detailed descriptions of the interfaces between the parties participating in the CPRT Program are provided in Appendix F.

The CPRT interfaces with CPSES project personnel through the Assistant Project General Manager CPSES-1 for the TUGC0 and other personnel resources necessary to implement the action plans. This relationship is shown in Attachment 2.1. Also, the SRT interfaces with Vice President Nuclear Operations on l CPRT activities that could affect the TUGC0 operations program and with the Assistant Project General Manager Unit 2 on CPRT l activities that could affect engineering.and construction activities on CPSES Unit 2.

'e

R;vicion: 3 P:gs 19 of 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd)

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' The overall reporting of CPRT.and CPSES activities is'to the Executive Vice President of~TUGC0 as shown in Attachment 2.2.

The CPRT functional positions are described in further detail in the following sections.

B. CPRT Team Members -- Roles and Responsibilities

1. Senior Review Team A Senior Review Team, consisting of a senior TUCCO line manager and senior nuclear industry consultants, has been-established with overall responsibility.for the development and implementation of the CPRT Program.

The SRT consists of the following members:

Mr. John W. Beck, Vice President of TUGC0 Dr. John H. Buck, Consultant  !

Dr. Anthony R. Buhl, Consultant; Vice President, International Technology Corporation Mr. John L. French, Consultant; Vice President, Management Analysis Company Mr. John C. Guibert, Consultant; Manager, Nuclear Safety & Licensing, TERA Corporation Mr. Warren E. Nyer, Consultant; President, Nyer Incorporated The specific responsibilities of the SRT include the I following:

- Development of the CPRT Program Plan, and any subsequent revisions thereof.

- Establishment of CPRT Program standards for personnel qualifications and objectivity.

- Selection and assignment of RTL and of the CPRT Program Director.

- Review and approval of action plans, and subsequent revisions-thereof.

- Review and approval of corrective actions l g l .

recommended by RTLs in accordance with Appendix H.

l l

R;visicnt 3

< Pags 20 of 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd) p - Monitoring the status of CPRT Program implementation.

- Review and approval of " safety significance" and " root cause" determinations and " generic implications" assessments for' activities '

classified as deficiencies in accordance with Appendix E, including evaluations of the adequacy of the action plans to address these i matters.

~ Review and approval of Action Plan Results Reports.

- Monitoring the establishment and implementation of CPRT Third-Party QA Program described in Appendix G.

- Review and approval of collective e. valuation reports prepared by the RTLs for the Design Adequacy, Quality of Construction and QA/QC Adequacy, and Testing Adequacy Programs.

Development of the'overall CPRT Program

(%, Collective Significance Evaluation Report.

U - Advising the Executive Vice President of TUGC0 regarding the adequacy and status of the implementation of the CPRT Program.

- At the completion of the CPRT Program, advising the Executive Vice President of TUGC0 regarding the conclusions of SRT as to whether there is reasonable assurance that CPSES is designed and constructed such that it is capable of being operated without undue risk to the public.

Mr. Beck is chairman of the SRT and serves as the principal' interface with the NRC Staff's CPSES Program Director for CPRT/TRT matters.

The SRT chairman will from time to time assign additional responsibilities to other SRT members.

2. CPRT Program Director The CPRT Program Director is an ex-officio member of the SRT and has overall responsibility for providing A day to day coordination of CPRT activities. These 'l V activities include all aspects of the CPRT Program with t

. . _- .- =- _ _ - . . . - - .

Rsvision: 3

-Pags '21 of 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd).

the exception of policy direction.which can only come from the SRT and technical direction of action plan development and implementation. activities which are the responeibility of assigned Review Team Leaders.

The CPRT Program Director is Mr. Terry G.' Tyler of TUGCO.

3. Review Team Leaders Review Team Leaders have been assigned to develop and manage the implementation of the action plans within each of the. general areas evaluated by the NRC's TRT and the design adequacy area. Each of the RTLs is a member l of an organization external to TUEC.

l The specific RTL assignments are as.follows: l Mr. Howard A.' Levin; Vice President. TENERA Corporation; l I RTL for the civil, structural and mechanical areas; and i Review Team Leader for the design adequacy area.

i Mr. John L. Hansel; Director, Vice President, j Engineering Services, Evaluation Research Corporation; RTL for quality of construction and QA/QC program adequacy areas.

Mr. John J. Ma11anda; Consultant, Management Analysis Company; RTL for the electrical / instrumentation area.

Review Team Leader for the protective coatings area -

l

- no longer needed due to declassification of coatings in SSER-9.

Mr. James E. Rushwick, Consultant; RTL for the testing programs area.

The specific responsibilities of the'RTLs include the following: .

Serving as the principal interface with NRC in their respective areas for the purpose of. ensuring that additional clarifying information is obtained (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 i action plans within their area are provided.

2 i

. . . . _ _ . _ _ _ ..a.___ _ _,____._u_..__. _ _ . _ _ , . , . . , . . . _ _ -. _

R vicion: 3 Pega 22 cf 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd) s,,) - Development of ISAPs or DSAPs within their area, and any subsequent revisions thereof, using the format and content guidelines set forth in Attachment 3 and Attachment 4 respectively.

- Ensuring that CPRT third-party personnel implementing the action plans are properly trained and meet CPRT program standards for personnel qualifications and objectivity.

- Assignment of issue coordinators as required.

- Identifying and obtaining necessary third-party l resources to implement the action plans within their area.

- Ensuring that the action plans within their area are being implemented appropriately.

- Advising the SRT and the CPRT Program Director on the implementation of the ISAPs and DSAPs within their area.

- Determining " safety significance" of dev'iations identified during implementation of their action plans and determining where possible the " root causes" and f)x " generic implications" of identified deficiencies within

( ,,

their area; ensuring that these determinations are adequately addressed in the associated action plans ot; ensuring that the action plans are appropriately revised.

- Identifying and recommending corrective actions per-Appendix H.

- Identifying and recommending necessary actions to preclude future occurrence per Appendix H.

, Developing Action Plan Results Reports, using the format and content guidelines set forth in Attachment 5 and 6 as appropriate. l

- Maintaining an action plan working file for each action plan within their area.

Transferring action plan working files to the CPRT central file at such time that each action plan is completed-(i.e., Action Plan'Results Report reviewed and approved by the Senior Review Team).

- Additional RTL responsibilities as specified in Appendices E, F, G, and H.

V(-'S

R2vicion: 3 Paga 23 of 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd)

~4. Issue Coordinators In order to assist the RTLs in implementing the acti;n I plans within their area, they have been authorized to assign issue coordinators for each of their ISAPs or DSAPs, if required. Review Team Leaders also have the I option of assigning themselves as issue coordinator for some or all of the action plans within their area.

The criteria for selection of issue coordinators is essentially the same as that for selection of RTLs.

Issue coordinators are responsible for assisting the RTLs in issue-specific activities as directed by the RTLs.

5. CPRT Advisers l

Realizing the breadth and importance of topics the CPRT l Program covers, the SRT established the policy of utilizing' advisers in various areas of expertise at various levels within the CPRT organization as

=

appropriate. Advisers retained to date include:

Drs. Paul Ibanez Vibration testing and analysis, and George Howard, system simulation and information, ANCO Engineers theory, seismic analysis, computer applications i Dr. William J. Engineering analysis and design.

Hall, University structural engineering, structural of Illinois mechanics, fracture' mechanics, engineering. criteria development for major projects John M. Biggs Structural engineering, structural

{

and Myle J. mechanics and dynamics, fracture l Holley,' firm of mechanics, nuclear power plant Hansen, Holley analysis and design and Biggs Dr. Edwardo Structural engineering, engineering

.Kausel, mechanics, dynamic analysis, soil-Massachusetts structure interaction 1 Institute of Technology J

I 1

. R vision: 3 ,

-Pcgs 24 of 45 VIII. CPRT ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES (Cont'd)

() Everett Rodabaugh ASME Component design, piping /

equipment analysis and design Timo Karppinen ASME supports design, piping system qualification Gerald Slagis ASME piping analysis and design Dr. Daniele Engineering statistical analysis, Veneziano probabilistic analysis, civil Massachusetts engineering Institute of Technology William M. Rice Electrical, I & C design and equipment applications, IEEE, ANSI and ANS Standards testing, installation and licensing Dr. Fred A. Engineering, probability and Webster statistics Jack R. Benjamin Associates,.

Consulting Engineers O Other consultants will be utilized as the need arises based upon program requirements.

4 O

i

R vicion: 3

?tge 25 of 45 ATTACHMENT 1

.C)h

(, CHRONOLOGY OF EVENTS The Nuclear Regulatory Commission (NRC) established a Technical Review Team (TRT) to review certain aspects of the Comanche Peak Steam Electric Station (CPSES). The purpose of the TRT was to evaluate certain technical' issues and allegations of improper construction practices at CPSES. In July 1984, the TRT began onsite activities as part of its review plan using a team divided into five groups: electrical /

instrumentation, civil / mechanical, QA/QC, coatings, and testing program.

On September 18, 1984, a public meeting was held in the NRC's offices in Bethesda, Maryland, at which NRC management and the TRT presented Texas Utilities Electric Company (TUEC) with a request for additional information. This request was based on the results of the TRT efforts to date in the electrical / instrumentation, civil, and. testing program areas. The TRT stated that they required additional information in order to make a determination of the safety significance of certain concerns.

The TRT request for information was documented in an attachment to an NRC letter dated September 18, 1984. The request was divided into three primary areas and several sub-areas, each representing a subject of concern to the TRT.

) TUEC founded the Comanche Peak Response Team (CPRT) and developed a program plan a,nd individual action plans for each of the issues identified in the September 18, 1984, letter. The program plan and the

' Issue-Specific Action Plans (ISAPs) were submitted to the NRC by letter dated October 8, 1984. Subsequently, public meetings were held at the NRC's Bethesda, Maryland, offices on October 19 and 23 at which TUEC made verbal presentations of the program plan and the action plans, obtained verbal NRC comments and provided clarifications by answering questions.

On November 29, 1984, NRC-TRT sent a letter to TUEC containing potential open issues and requesting additional information for the resolution of i allegations and concerns related to mechanical, piping, and

miscellaneous topics. The CPRT developed ISAPs to fully investigate and resolve these concerns. NRC's letter to TUEC also. contained the status of the evaluation of coatings allegations. i On January 8, 1985, the NRC issued a letter to TUEC informing them of the TRT's findings in the construction QA/QC area. In the letter NRC '

i requested a program and schedule for completing a detailed and thorough assessment of the QA issues contained therein. The CPRT developed

'ISAPs to fully investigate and resolve these concerns.

i In mid-January 1985, the NRC issued Supplement to the Safety Evaluation )

. Report (SSER)-7 on electrical / instrumentation and testing findings.

CPRT revised action plans as necessary to reflect additional insights

(( _

l presented in the SSER.

l l

I l

R;vicient 3 Pcg2 26 of 45 ATTACHMENT 1 (Cont'd)

On January 17, 1985, a public meeting was held in the NRC's offices in Bethesda, Maryland, at which NRC management discussed the contents of the January 8 letter with TUEC and the CPRT.

On February 7, 1985, CASE, TUEC and the CPRT met with the NRC Contention V Panel in Arlington, Texas. The CPRT presented the scope and findings -

in the implementation of the electrical, testing, civil / structural,

.QA/QC and mechanical action plans to date. At this meeting Mr. Spence, President of TUGCO, announced to the NRC that the CPRT would'be investigating design adequacy as a part of their charter. Also, at the same meeting, CASE had a dialogue with the Contention V Panel on many of the CPRT issues.

In mid-February 1985, NRC issued SSER-8 dealing with civil, structural and miscellaneous areas. CPRT revised action plans as necessary to reflect additional insights presented in the SSER.

,On February 26 and 27, 1985, the CPRT met with the NRC-TRT at Comanche Peak to discuss TRT concerns in the piping and pipe support area and to discuss conceptual CPRT activities.in this area.

]

On February 28, 1985, the CPRT met with the NRC-TRT at Comanche Peak to

/~' describe the electrical Issue-Specific Action Plans and implementation

( results to date.

On March 5, 1985, the CPRT met with the NRC-TRT at Comanche Peak to discuss the approach to be taken to resolve the QA/QC issues raised in the January 8, 1985, letter.

i On the morning of March 6, 1985, the CPRT met with the-NRC-TRT at Comanche Peak to describe the testing ISAPs and implementation results to date.

On the afternoon of March 6, 1985, the CPRT met with the NRC-TRT at Comanche Peak to describe the civil / structural ISAPs and implementation results to date.

On March 7, 1985, the CPRT met with the NRC-TRT at Comanche Peak to describe the mechanical ISAPs and implementation results to date.

On March 14, 1985, the CPRT met with Cygna in San Francisco to understand the full extent and breadth of their concerns which have i arisen from their conduct of'the CPSES Independent Assessment Program.

In mid-March 1985, NRC issued SSER-9 declassifying protective coatings at CPSES. Based on the findings of this SSER'the CPRT eliminated the-RTL position for protective coatings position.

O

l Rsvision: 3 j

'P:g2, 27 of 45 ATTACHMENT 1 (Cont'd)

On March 23, 1985, the CPRT met with CASE in particular Messrs. Falsh and Doyle, to hear first hand their concerns in the pipe and pipe support area.

In late-April 1985, NRC issued SSER-10 dealing with mechanical and piping issues. CPRT revised action plans as necessary to reflect additional insights presented in the SSER.

On April 23, 1985, TUGC0 submitted a draft revision of the CPRT Program Plan and final revisions of the electrical, civil, structural, testing, and miscellaneous action plans to NRC for review.

In late May 1985, NRC issued SSER-11 on QA/QC issues. CPRT has revised action plans as appropriate to reflect insights provided in the SSER.

3 On June 13 and 14, 1985, TUCCO met with NRC in a public meeting in 4

Arlington, Texas, to discuss CPRT activities in the design adequacy and quality of construction and QA/QC program adequacy areas.

In early July TUCCO submitted revision 2 of the CPRT Program Plan and

! associated ISAPs and DSAPs related to Design Adequacy, Quality of Construction and QA/QC Adequacy and Testing Adequacy Programs to NRC.

On August 9, 1985, NRC transmitted their NRC Staff Evaluation of the l CPRT Program Plan - Programmatic Comments to TUEC.

On September 17, 1985, TUGC0 met with NRC in a public meeting in Bethesda, Maryland to discuss visual inspection of welds thru paint.

J On September 30, 1985, NRC transmitted NRC Staff Evaluation of the CPRT Program Plan - Detailed Comments'to TUEC.

On October 10 and 11, 1985, TUGC0 met with NRC in a public meeting in Granbury, Texas to discuss the basis for establishing homogeneous hardware populations in the Quality of Construction and QA/QC Adequacy

~

Progrnm and the Stone and Webster pipe and pipe support reanalysis program.

On November 5 and 6, 1985, TUGC0 met with NRC in a public meeting in Granbury. Texas to status CPRT implementation and discuss the results of recent NRC audits of the CPRT Program.

On November 22, 1985, TUGC0 submitted responses to NRC's comments on the CPRT Program. l 4 O i

O O O TueC0 / CPRT OPERATNHIS C P R T- SRT V P NUCLEAR OPERATIONS CPSES-2 / CPRT J.W. SECK- Chelt.

---

INTERFACE I J.C. GulBERT A P G M - C'PSES 2~

APSM- CPSES I y A.R.SUHL i ' W.E. NY E R R.E. CAMP J. H. B UC K T G. T YLER

( EX OFFICIO)

CPRT ADVISOR Q i F. W E BSTER - N o N 8 C E

n b" N n ELECTRIC AL TESTlHS REVIEW COATINGS REVIEW QU ALITT OF CIVIL /STRUCT.1 DESIGN H R EVIEW TE AM LEADE.9 TEAM LEADER CONSTRUCTION MECH.1 MISCELL ADEOUACT O .

TEAM LEADER TEAM LEADER R EVIEW REVIEW ~

i TEAM LE ADER TEAM LEADER O l J.J. MALLANDA J. RUSHWICK -

J.L. H ANSEL H.A. L EVIN H. A.LE V I N

~ ~ ~

'SSER-S NEGATED ' FURTHER ORG. FURTHER ORG,"

, NEED FOR LEADER DETAILS St APP.B DETALS 38 APP. A

?E 1 THE TUGCO AND CPSES-2/CPRTINTERFACE WAS CREATED TO KEEP OPERATIONS AND CPSES-2 ADVISED OF POTENTIAL PROGRAMMITIC CHANGES (QA & OPERATIONAL) WHICH WILL 5h mg j

COME OUT OF C PRT ACTIVITIES. oo a..

2 OVERALL DIRECTION OF CPSES ACTIVITIES ON CPRT ACTION PLANS COMES FROM THE SRT. * '

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Revision: 3' Paga 29 of 45 l

l ATTACHMENT 2.2 CPRT ORGANIZATION CHART ks >

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RIvisien: .3 Pcg3 30 cf 45 ATTACHMENT 3 O

\s / ' ISSUE-SPECIFIC ACTION PLAN FORMAT ,

4 ITEM MUMBER (Short Title)

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC

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

- Develop a separate action plan for each numbered TRT item.

2.0 ACTION IDENTIFIED BY NRC Verbatim statement of NRC - directed action as stated in the encicsure to the NRC issue transmitted Ictter.

3.0 BACKGROUND

Relevant information which clarifies the issue definition.

^

Relevant' information to . provide additional perspective and understanding of the issue (including consideration of relevant information before the ASLB).

- An explanation (where applicable) of why CPRT has decided to pursue the approach described under Section 4.0 below, where e alternative approaches were available.

i 4.0 -CPRT ACTION PLAN

- Scope and Methodology.

f

- Describe approach (phased, if applicable).

- Tasks to be performed without conditions.

- 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 (where applicable and where this has already been

i. (~~S determined).

U

R;vicion: 3 P:ga 31 of 45 ATTACHMENT 3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

- Describe how potential generic implications are being considered (where applicable and where this has already been determined).

Procedure (s) to be used.

- Reference existing procedures.

- Describe any new or revised procedures.

- Participants Roles and Responsibilities.

- Which organizations are involved.

Scope for each organization.

Identify lead individual. 1 Qualifications of Personnel.

1 I

State qualifications of personnel 0

implementing the action plan. l Reference these qualifications to existing requirements.

Discuss training of personnel which will be conducted.

Sampling Plan If performing a 100% review, state that'a 100% review is being done.  !

- If sampling is used, provide' information relevant to the sampling plan, and provide i justification for the sample size.

- Describe any other features of the' sam eling plan (e.g. random sampling of the universe, random sampling of each discipline, etc.).

- Provide the definition of a " reject".

Reference Appendix D for Sampling Guidelines O

Rsvision: ~

3 Pags 32 of 45 ATTACHMENT 3 (Cont'd) 1 4.0 CPRT ACTION PLAN (Cont'd)

- Standards / Acceptance Criteria

- Dascribe the standards (e.g., FSAR, IEEE, Regulatory. Guides, etc.) against which you are performing the review.

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.

- Describe the criteria for closing out.this .

item (this is related to the standards /

q acceptance criteria and the criteria for subsequent phases).

O 1

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Rsvision: 3 Paga 33 of 45 ATTACHMENT 4 DISCIPLINE SPECIFIC ACTION PLAN FORMAT ITEM NUMBER NOTE: Discipline Specific Action Plans (DSAPs) are to the Design Adequacy Program as Issue-Specific Action Plans are to resolution of TRT Issues and the Quality of Construction and QA/QC Adequacy Program. .However, since no specific design issues have been-raised by NRC the ISAP format was not applicable.

1.0 PURPOSE

- Statement of what the DSAP will cover within a particular discipline.

- Discussion of concerns within the discipline that the DSAP will address.

2.0 SCOPE

- Areas within a discipline that have been questioned in s_

External Sources that will be reviewed.

- Self-initiated review to help bound extent of occurrence of External Source issues within discipline.

3.0 BACKGROUND

- Detailed discussion of background for identification External Source issues and determining scope of self-initiated activities.

4.0 CPRT ACTION PLAN

- Scope and Methodology.

- Describe approach (phased, if applicable).

1 - Tasks to be performed without conditions.

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

"If we find "x", then we will take the following additional action...").

t (yl

- Tasks to be performed as part of an expanded review (where applicable and where this has already been

! determined).

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Rsvision: 3 P:g2 - 34 of 45

. ATTACHMENT 4

'~' (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

- Describe how potential generic implications are being considered (where applicable and where this has already been determined).

Procedure (s) to be used.

- Reference existing procedures.

- Describe any new or revised procedures.

- Sampling Plan

- If performing a 100% review, state that a 100% review is being done.

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

Describe any other features of the sampling

~

plan (e.g. random sampling of the universe, p/

\s ,

random sampling of each discipline, etc.).

- Provide the definition of a " reject".

Refence Appendix D for sampling guidelines.

Standards / Acceptance Criteria

- Describe the standards (e.g., FSAR, IEEE, Regulatory. Guides, etc.) against which you are perferming the review.

Decision Criteria

- Describe the criter.'a 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.

- Describe'the criteria for closing out this item (this is related to the standards /

acceptance. criteria and the-criteria for-subsequent phases).

1

Rsvision: 3 Paga 35'of 45 ATTACHMENT 4 (Cont'd) 5.0 ORGANIZATION AND RESPONSIBILITIES

- Participants Roles and Responsibilities..

- Which organizations are involved.

- Scope for each organization.

- Identify lead individual.

i Qualifications of ?ersonnel.

- State qualifications of personnel implementing the action plan.

- Reference these qualifications to existing

' requirements.

l

- Discuss training of personnel which will be conducted.

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_ , . _ _ . . . , . - . - . , , - _ _ _ s. . , ,, , , , . , _ . . . - , . . . , . - , ., . . . , _p.. , . . . , . ,3

Ravicions 3 Psg2 36 of 45 ATTACHMENT 5 ACTION PLAN RESULTS REPORT FORMAT ITEM' NUMBER (Short Title)

1.0 DESCRIPTION

OF ISSUE (Reference Source, including.page number)

(Generally, this will be the same as the Action Plan - unless an explanatory sentence or two is needed to put the concern more properly into focus) 2.0 ACTION IDENTIFIED (Reference Source, including page number)

(This section will provide the actions that the responsible external source (e.g., NRC Staff) stated was necessary to resolve the issue. Generally, same as Action Plan. For actions not raised by external sources, this section is not applicable.)

3.0 BACKGROUND

(Generally, this will be the same as th~e Action Plan. However, if

('N needed to provide clarity, this Section may be expanded or modified to provide a historical or technical perspective that will appropriately focus the staff's stated concern.)

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology (Generally, this will be the same as the Action Plan.

However, if additional major actions / initiatives not listed in the original Action Plan were taken they should be noted here.

An explanatory sentence or two regarding modifications or expansions to the Action Plan, if any, may be appropriate.)

4.2 Participants Roles and Responsibilities (Same as Action Plan except where changes were made. These changes should be noted with explanation.)

4.3 Oualifications of. Personnel (Same as Action Plan except where changes were made. These l changes should be noted with explanation.)

O V

R: vision: 3 i Pcgs 37'of 45 ATTACHMENT 5 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Acceptance Criteria (Same as Action Plan except where changes were made. These changes should be noted with explanation.)

4.5 Decision Criteria (Same as Action Plan except where changes were made. These changes should be noted with explanation.)

5.0 IMPLEMENTATION OF ACTION PLAN-AND DISCUSSION OF RESULTS* l Section 5.0 is designed to provide a concise description of the implementation of the action plan and a discussion of the results to include at a minimum:

t (1) A summary of the action plan implementation. (A flow chart may be used where necessary.)

(2) Evaluation (e.g., safety significance) and categorization of Os findings (i.e., finding, design observation, discrepancy, deviation, deficiency, programmatic deviation, programmatic deficiency), as necessary, to determine the need for root cause and generic implications evaluations. (The bases for these evaluations must be addressed.) If the number of findings are large,' consideration should be given to categorizing the findings and addressing them in an Attachment to avoid confusion.

(3) Root Cause and Generic Implication Evaluation. Where deficiencies, programmatic deviations, adverse trends of design observations, or programmatic deficiencies'are found, root cause and generic implication evaluations must be performed. Iterative actions and alternatives used to identify root causes should be included along with the bases for any conclusions reached.

i

! (4) Evaluation of results against action plan and decision criteria, and decision to expand or not expand effort as  ;

appropriate.

(5) Implementation of any expanded inspection / action. plan (to include topic numbers 2-4, above, as appropriate).

(O

_)

• For additional information see Supplemental Guidelines on page 39 of this document.

I t

~- e ,. ~

i Rsvisient 3 Pago 38 of 45 ATTACHMENT 5

) (Cont'd) l

%/

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

(6) Identification and discussion of recommended corrective action

.(including the status of-implementation, where applicable) for the deviations, deficiencies, programmatic deviations and programmatic deficiencies categorized above.

(7) Out-of-scope findings. If unrelated findings (i.e., not directly related to original' issue (s)] are encountered during the implementation of the Action Plan, they should be addressed in a separate subsection including resolution or referral for resolution and, as appropriate, evaluation, categorization, generic and root cause evaluations and corrective action (see items 2-6, above). Handling such findings separately in this manner will avoid confusion regarding the resolution of the central issue of concern. If, however, addressing unreinted findings separately in this manner significantly disrupts the orderly, sequential presentation of action plan implementation, discussion of these findings can be fully integrated into this section.

6.0 CONCLUSION

S This Section is designed to present specific conclusions regarding the issue raised by the staff and any appropriate "overall" conclusions reached as a result of implementing the Action Plan.

7.0 ONGOING ACTIVITIES l l

In this Section describe any relevant activities still in pro 8ress. I 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE-This Section is designed to address actions taken to preclude future occurrences of any deviations or deficiencies addressed in this document. Such actions may include training, procedural j changes, etc. j l

Rsvisient -3

, Prgs 39'of 45 ATT,iCHMENT 5

/ (Cont'd) k--

SUPPLEMENTAL GUIDELINES FOR Section 5'.0 i

I. OVERALL FORMAT While the precise format for Section 5.0 is dependent upon the particular issue addressed and actions involving its resolution, at a minimum each topic noted above should be addressed. Where details of any topic involve numerous items or are convoluted in nature and disrupt the flow of the report, they should be included in an attachment. To provide general guidance'concerning format, a further discussion of some possible format styles follow:

1. Action Plans which include several phases or expanded steps.

To facilitate an understanding of the process, the-format for this type of action plan may need to involve a sequential discussion of the actions eventually resulting in resolution of the issue. It -ould involve (1) a discussion of implementation of Phase I, (2) an evaluation-(e.g., safety significance) and categorizations of findings, (3) root cause-and generic implication evaluations if necessary, and (4) the bases for expanding the sample and/or proceeding to Phase II.

O Phase II would then be discussed in the same manner, leading to the implementation of Phase III, etc.

2. Action Plans involving issues which are addressed by actions discussed in another Action Plan.

Where the actions which resolve the issue are addressed in another Action Plan Results Report, this section does not need to repeat the sequence of action, etc. It must however, reference the other Results Report and provide a discussion of the relevant topics noted above (e.g., evaluation of findings and classification and root cause and generic implications, as appropriate).

i

3. ' Action Plans involving two. separate. issues.

In such_ cases, each issue should be handled separately to minimize possible confusion.

II. ROOT CAUSE AND GENERIC IMPLICATIONS s

l A number of action plans were specifically designed to respond to l concerns identified by the NRC-TRT. Such concerns, which have been l documented in letters to TUGC0 from the NRC and in subsequently-issued SSERs, were accompanied by required actions specified by

{"'}/

s_, NRC. In some of these cases such NRC specified actions included explicit requirements to investigate the potential generic implications of the NRC-TRT findings, as well as the minimum required scope for such investigations.

Rsvision: 3 Pags 40 of 45 ATTACHMENT 5 (Cont'd)

}

II. ROOT CAUSE AND GENERIC IMPLICATIONS (Cont'd) l In some cases, such NRC-specified scopes of investigation appear to have been intended either to address a specific root cause hypothesized by the NRC-TRT or to envelope a range of possible root causes hypothesized by the NRC-TRT. In addition, in some cases the ISAPs developed by the CPRT in response to these NRC directives included scopes of investigation to address additional potential root causes hypothesized (in advance) by the CPRT.

Consequently, the possibility exists that the results of a CPRT investigation may demonstrate that the hypothesized root causes and/or hypothesized generic implications are not substantiated.

Similarly, the possibility also erfsts that the CPRT investigations of NRC-TRT concerns may not identify any discrepancies that, if classified in accordance with Appendix E to the CPRT Program Plan, would be assigned a classification that requires a root cause or generic implications assessment or'the definition of'necessary corrective actions (e.g., a programmatic deviation, a deficiency, or a programmatic deficiency).

In the event that the results of a CPRT investigatory effort

(N

\._-) demonstrates that the above-mentioned possibilities have actually occurred, the associated Action Plan Results Report should reflect this determination in the discussion of results section and in the conclusion section.

In addition, the root cause/ generic implication section should indicate that the hypothesized root causes were-not substantiated and that no additional discrepancies were identified that required further evaluation. If a specific root cause has been determined for the finding documented by the NRC-TRT (whether or not such a determination is required by Appendix E), it should be reported along with a conclusion, based on the scope of the CPRT investigation effort, that the situation is either isolated in nature or the situation is not indicative of an adverse trend.

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R:visient 3 Pcg2 41 of 45 ATTACHMENT 6-

-- DISCIPLINE-SPECIFIC RESULTS REPORT FORMAT 1.0 EXECUTIVE

SUMMARY

AND CONCLUSIONS i Include purpose, scope, results, and conclusions in summary form. l 2.0 SCOPE This section describes the scope of the report and, therefore, the j'

scope of the design to which the conclusions are applicable. The interfaces between the discipline covered by this report and other disciplines should be addressed.

I 3.0 EXTERNAL SOURCE ISSUES ,

3.1 Description This section should describe the external issues covered by this Results Report and relate the issues to the action 1 plan (s) that resolve them.

3.2- Methodology and Results

(

This section describes the methodology applied to the resolution of the external source issues. It should describe the activities undertaken to evaluate the issue, the i classification of the issue (observation, deviation, or deficiency), and the method and extent of third-party activities. Where generic implications or. trending required expansion of the scope or approach from that presented in the action plan, a detailed description should be provided. This  ;

section may be organized in a manner deemed appropriate by the discipline coordinator. For example each issue could be treated as a separate subsection within 3.2 and a discussion prepared for each. Alternatively the section may be arranged by source of the issue (Cygna, CASE, NRC, etc.) or by grouping related technical issues.

3.3 Conclusions l This section presents the conclusions found by the third-party relative to external source issues only, i

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Rsvicion: 3.

Paga 42 of 45 ATTACHMENT 6 (Cont'd)

(

4.0 SELF-INITIATED REVIEW 4.1 Scope This section discusses the scope of the self-initiated review and the basis for that scope. Specifically it should address

! the evolution of that scope from that presented in Revision 2 of the CPRT Program Plan, through the changes resulting from Phase 3 of the scope development process and from implementation of the action plan, to the final (Phase 4) scope.

4.2 Methodology This section describes the methodology applicable to the self-initiated review. It should concentrate on how the general requirements of the program plan were applied to the specific discipline covered by the report. It is not necessary to repeat information contained in the action plans, although enough information must be provided to allow a reviewer (e.g., NRC or public) to obtain an understanding of the work that was done. Where appropriate, lists of documents

() reviewed, references used, etc. should be provided.

4.3 Findings

4.3.1 Deficiencies List all deficiencies found together with a description of the deficiency, the corrective action, root cause (if known), generic implications, and other relevant data.

4.3.2 Deviations with Adverse Trends' Discuss those deviations ~found as a result of action-plan implementation that were analyzed to be part of a

' trend. Specifically, this section should address the nature of the deviations, the bases for reaching a conclusion that a trend exists, an analysis of the trend, and the corrective action taken.

4.3.3 Other Deviations A discussion of other deviations should be provided that describes the nature of those deviations and the bases for concluding that they were not deficiencies and that no trend exists. Any corrective action taken

[/}

A-m as a result of resolving the deviation should be.

discussed.

i RIvision: .3 P:gs 43 of 45 ATTACHMENT 6

() (Cont'd) 4.0 SELF-INITIATED REVIEW (Cont'd) 4.3.4 Observations with Adverse Trends i Similar to 4.3.2.

i a

j 4.4 conclusions Draw conclusions on the adequacy of the design within the i subject discipline.

j 5.0 CORRECTIVE ACTION i

. This section discusses corrective action in a broader context than that in Section 4.0. That is, this section should discuss the corrective action necessary to prevent problems from recurring.

! This section should also describe the bases for the third-party concluding that the Project has understood and will implement the corrective action.

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6.0 CONCLUSION

S

[O This section should present the conclusions drawn from the implementation of the action plan, consideration of its findings, i and~ implementation of corrective action.

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R:vicien: 3 Pcg3 44 of 45 t

l ATTACHMENT 7 l 1

CPRT OBJECTIVITY' QUESTIONNAIRE l

1. Name

2. Position on CPRT i

3. Name of current employer

4. Date this questionnaire is completed

5. Do you hold any stock or other securities of Texas Utilities l Company?

6. Have you ever been a director, officer, or employee of Texas Utilities Company or any of its subsidiaries *?

4 7.: Have you ever entered into a contract, whether oral or written,

, with Texas Utilities Company or any of its subsidiaries or with

another person, firm, or corporation who has acted as a contractor

for the Comanche Peak project other than a contract relating to j

your involvement in the current CPRT program?

8.. Would the answer to any of the above questions be "yes" if answered by any member of your immediate family (father, mother. spouse, .

son, or daughter)?

9. Have you been promised any additional compensation or reward or anything of value by anyone, contingent ; cae position you take on any issue being considered by you in the CPRT program?

10. Do you know of any reason, whether inquired about in this l questionnaire or not, which would affect your ability to be completely objective in performing any of the tasks assigned to you l under the Comanche Peak CPRT program?

1 l 11. Would the answer to any of the above questions be "yes" if answered j by your current employer?

12. If the answer to any one or more of the above' questions was "yes" then please fully explain each such "yes" answer, by number, on the reverse side of this questionnaire. Attach additional sheets to provide further information, if necessary.

l i

Signature

• Subsidiaries of Texas Utilities Company are Texas Utilities l Electric Company, which has four divisions: Texas Power & Light i

i O Company, Texas Electric Service Company, Dallas Power & Light Company, and Texas Utilities Generating Company; Texas Utilities Mining Company; Texas Utilities Fuel Company; Basic Resources Inc.;

l and Chaco Energy Company.

i

! - - _ . _ _ _ _ _ _ _ . _ . . _ _ - . . ~ . _ , - , , _ _ - . _ . _ _ - _ , , . _ . - - . , _ . _ < - - . _ . - , ~ , _ . . . . . , _ _ . _ _ . . , - - - - - - . _ ,

R:visien: 3 Pcgs 45 of 45 ATTACHMENT 7 (Cont'd)

CPRT OBJECTIVITY QUESTIONNAIRE I (Continuation Sheet) l l

l Daniel Construction Company l

The following is ongoing work being performed by Daniel Construction Company for CPSES TUGC0 and other TUCCO operations.

1. Daniel Construction Company, Greenville, SC

a. 1985 - provides some QA/QC personnel to work as a part nf TUGC0 QA/QC Program. Work currently ongoing.

2. Daniel Construction Company, Greenville, SC

a. 1984 - provides maintenance services to non-nuclear operations of TUGCO. Work currently ongoing.

O l

1

R2visient 1 Pag 2 1 of 39 APPENDIX A DESIGN ADEQUACY PROGRAM PLAN TABLE OF CONTENTS SECTION PAGE I. INTRODUCTION - OBJECTIVES 3 II. ELEMENTS OF THE PLAN 5 A. The-Design Adequacy Discipline Specific 5 Action Plans

1. Initiatives Related to Specific External 6 Source Concerns

2. The Self-Initiated Design Evaluations 9 l

3. Action Plan Initiatives 13

4. The Piping and Pipe Support and Cable Tray / Conduit Support Design Verification 15

5. Root Cause and Generic Implications 15 B. Design Adequacy Collective Evaluations 16 l-C. Inter-Relationship of Program Elements 16 D. Relationship to Other CPRT Activities 17 E. Design Adequacy Review Team 17 III. END PRODUCTS 18 O

Ravision: 1 Paga . 2.of 39 l;

APPENDIX A DESIGN ADEQUACY PROGRAM PLAN l TABLE OF CONTENTS (Continued) i 4

SECTION PAGE

Attachments:

4

1. Inter-relationship Between the CPSES Design and 20'

) Construction Process and CPRT Program Plan l Activities k '

2. CPRT Design Adequacy Evaluation Me'thodology for 21 External Source Issues

) 3. Self-initiated Evaluation Initial Scope Matrices 22

4. Scope Development Process 23 4 5. Trending and Generic Implications Evaluations 41 f 6. CPRT Design Adequacy Program Organization 49 i

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Revision: 1 Ptgt 3 of 39 4

APPENDIX A i - vn DESIGN ADEQUACY PROGRAM PLAN I. INTRODUCTION - OBJECTIVES Concerns regarding the construction and construction process at

. CPSES have been raised by a number of sources external to Texas Utilities. These sources are: the NRC Staff Technical Review Team reports ("TRT"), the NRC ASLB proceedings on the CPSES operating license ("ASLB"), the NRC Staff's Supplemental Safety Evaluation Reports ("SSERs") and its Construction Assessment Team (" CAT") and Special Investigation Team (" SIT") reports, certain Inspection Reports issued by NRC's Region IV staff ("RIV"), and the Cygna Independent Assessment Program ("IAP"). Most of these issues have addressed concerns regarding the adequacy of the construction of installed hardware and the adequacy of the construction QA/QC program, but certain of the issues concern the adequacy of the CPSES design and/or the adequacy of the CPSES design process.

The CPRT has been charged with responding to and resolving open TRT, ASLB, SSER, CAT, SIT, RIV and IAP issues (collectively, these are sometimes referred to herein as the " External Source" issues),

and with advising Texas Utilities management whether there is reasonable assurance that CPSES is capable of being operated l' without undue risk to the public. This Design Adequacy Program

, Plan (DAP) has been formulated by CPRT to accomplish that objective as it relates to the adequacy of the CPSES design and the adequacy of the CPSES design process. The DAP has three components: l

First, the CPRT will evaluate each of the specific design and *

! programmatic design process issues raised by the External Sources. It will determine the nature of any safety-significant design or design process deficiencies and the corrective actions necessary to resolve them. This aspect of

< the DAP will lead to the conclusion that there is reasonable l assurance that there are no undetected and uncorrected safety-significant design deficiencies associated with any of the

External Sources issues.

4 Second, the CPRT will investigate the root cause of- each found safety-significant deficiency (or trend of non-safety significant design deviations or observations) and analyze the l generic implications in order to determine the extent of any additional design efforts that might be deficient for similar reasons. This aspect of the DAP will lead to the conclusion l that there is reasonable assurance that there are no undetected and uncorrected safety-significant design deficiencies attributable to any of the root causes of safety-i sign *ficant design deficiencies associated with any of the External Source issues.-

j These two components of the DAP are cortplementary and each has- l the potential-for expanding the other. The evaluation of root l

R;vicion: 1 Pag 2 4 of 39 APPENDIX A D (Cont'd)

(d I. INTRODUCTION - OBJECTIVES (Cont'd) cause and generic implications may lead to additional areas of l

the design or design process requiring evaluation, and the evaluation of found safety-significant design deficiencies (or trends of non-safety-significant deviations or observations) l

! may lead to the establishment of additional root causes and potential generic implications. Similarly evaluation of specific design issues may lead to the expansion of

.! programmatic issues, and evaluation of programmatic root causes may lead to expansion of the reiiew of specific designs.

The sum of the first two components of the DAP will fully l resolve each of the External Source issues, and it will fully bound the safety-significant implications of any identified or found deficiency in either the CPSES design or the CPSES design process. It will also permit CPRT to make a statement about the adequacy of the design of CPSES. l For additional confidence, however, the CPRT will also conduct a self-initiated evaluation of selected additional design areas. These areas have been selected such that, when s aggregated with the design investigations conducted in response to the External Sources issues, the investigation will have covered all of the significant design disciplines, activities and processes employed during the design of the balance of plant (BOP)*. Attachment 1 graphically l demonstrates complete coverage of both the design and

• The NSSS design (Westinghouse design responsibility) and the individual designs of equipment supplied by vendors are not within the CPRT review scope. Westinghouse has an NRC-approved Design Quality Assurance Program. In addition, the Westinghouse'NSSS design has been thoroughly reviewed and audited on numerous occasions by independent and/or outside individuals and groups.

(A review of the NSSS design by CPRT would not be productive or meaningful to the questions on design adequacy at hand.) Other safety-related equipment suppliers have provided equipment over a number of years to numerous plants. The functionality and design adequacy of their equipment have been demonstrated through use'in operating plants. In addition, the equipment is typically required by specification to be or have been performance tested in the shop l

and/or in the field. Vendors supplying ASME components also have ASME QA programs which undergo periodic surveillance. The interface between the A/E and the NSSS and other vendors will be evaluated by reviewing the specified requirements promulgated by p() the A/E and the congruence of documentation supplied by vendors to  ;

demonstrate conformance to specifications. i l

1

_~ . _ .

R;visient 1 Pcg2 5 of 39 APPENDIX A (Cont'd)

I. INTRODUCTION - OBJECTIVES (Cont'd) construction processes at CPSES by showing the inter-i relationship between these CPSES processes and the CPRT Program Plan activities including the DAP and Quality of Construction and QA/QC Adequscy Program (QOC). The addition of the self-initiated evaluation component will lead to the conclusion that there is reasonable assurance that there are-no undetected ~and uncorrected safety-significant design 7

deficiencies at CPSES, regardless of the exten* to which the design or design process may have been questioned by any of I the External Sources.

Implementation of the DAP is by execution of Discipline Specific l Action Plans (DSAPs), the methodology of which is described herein, and by the preparation of the results reports and a DAP collective l evaluation report described in "End Products."

II. ELEMENTS OF THE PLAN A. The Design Adequacy Discipline Specific Action Plans l The design adequacy DSAPs contain tasks falling into three categories:

- The Category 1 DSAP tasks address specific CPSES design issues (other than piping and pipe supports'anu cable trays / conduit supports), either regarding the adequacy

! of the design or of the design process, that have been identified by the External Sources or that have been identified by the CPRT in the course of evaluating External Source issues for other (i.e., hardware)

Concerns.

- The Category 2 DSAP tasks implement th' CPRT's self-initiated design evaluations (for areas other than piping and pipe supports).

Typically, single DSAPs contain initiatives that are designed both to respond to specific concerns in a given design area and to implement a portion of the self-initiated evaluation in the same area.

- The Category 3 DSAPs include special piping and pipe supports and cable tray and conduit supports programs l )

that will result in a significant level of reanalysis. I n,

u These reanalyses will be performed for the Project by outside organizations who have had no responsibility for the original design. The analytical process and l ,

1 the design criteria will be reviewed by l

CPRT third-party personnel. l l

l

R viciont 1 P ga 6 of 39 APPENDIX A

w. (Cont'd) 4 v

II. ELEMENTS OF THE PLAN (Cont'd)

The DSAPs are organized by the following design disciplines:

Civil / Structural Piping / Supports i Mechanical Systems and Components Electrical / Instrumentation & Control Systens and Components.

I i

The DSAPs themselves are included in Appendix C of the CPRT Program Plan.

i 1. Initiatives Related to Specific External Source Concerns

! A six-step methodology is employed to respond to

. External Source issues. The logic governing execution i of this methodology is provided as Attachment 2.

l Identification of Issues is accomplished by a systematic review of the documents containing the External Source issues for concerns implicating either the CPSES design or design process. The documents

! reviewed include:

NRC Special Inspection Team (SIT) Report NRC Special Review Team (SRT) Report l

I -

NRC Construction Appraisal Team (CAT) Report I -

NRC Technical Review Team (TRT) Reports '

NRC Supplemental Safety Evaluation Reports (SSERs)

URC Region IV Inspection Reports Cygna Independent Assessment Program (IAP)

Documents ASLB proceeding documents including transcripts, exhibits, motions, filings and

Board Orders. ,

Transcripts of meetings involving the NRC, CASE, Cygna, and TUEC.

C.-) .

Revicient 1 P:g2 7 of 39 APPENDIX A (Cont'd)

II. ELEMENTS OF THE PLAN (Cont'd)

Other documents referenced from the above documents that have relevance to design or the design process.

Where a review of the document by a member of the Design Adequacy Review Team reveals a potential design concern, the concern is entered in the DAP Tracking System . This process is controlled by procedures and ensures thoroughness in the issues screening process, control over the issue resolution process and the sorting of related issues for efficient resolution.

Where during the review of External Source documents described above, an identified issue has previously been resolved.to the satisfaction of the source, the Design Adequacy Review Team will review the resolution.

, The issue will be considered resolved with no further initiatives if determined to be consistent with existing knowledge including consideration of generic implications. However, relevant information will be p retained for use in trending and generic implications

\j evaluations.

l As potential issues are identified, the Design Adequacy Review Team will review documentation pertinent to the.

l issue. The Design Adequacy Review Team may also make a preliminary evaluation of'available documentation, including engineering walk-downs, to qualify potential issues and to identify those issues requiring further review.

Definition of Issues requires that determinations be mrde about the adequacy of available documentation, identification of the potentially affected hardware and the nature of the programmatic issues (i.e., design processes, design organizations and organizational interfaces) involved. The objective of this effort is to define the issue sufficiently to allow a determination of whether cdditional evaluations are required or.whether direct corrective action is warranted based on the available information. The data obtained in this effort are also used as input into l root cause and generic implications' evaluations. .,

Development of the Action-Plan occurs once the issue has been sufficiently defined. Where an issue appears

\

to be isolated, an Issue-Specific Action Plan (ISAP),

or additional tasks within a DSAP may be devoted to

.that L aue alone. Where the issue appears to have a

R:vicient 1 Pcga 8 cf 39-APPENDIX A (Cont'd)

, II. ELEMENTS OF THE PLAN (Cont'd) potentially cumulative effect with other issues, tasks will be developed that permit an integrated solution to the set of potentially cumulative issues. Where identified, apparent or suspected root causes may be j employed in determining the scope of an ISAP or DSAP.

This process has already identified two areas in which

a sub-program, each consisting of multiple tasks,-is

appropriate

one sub-program deals with all issues 4

relating to piping and pipe supports and the other covers cable trays, conduits and their supports.

In developing action plans it may be determined that it is more efficient to proceed directly to a corrective action program (such as for the modification or replacement of hardware) than to proceed with further engineering evaluation that might qualify the existing

, hardware.

Implementation of Action Plans will employ one or more of the initiatives (section II.A.3) to evaluate the  !

(O/ adequacy of the CPSES designs and design processes. All

. implementation will be performed by third-party personnel meeting the CPRT criteria for objectivity or will be performed by the project and overviewed by

' third-party personnel. (All analyses that will become

a design basis evaluation of record fall into the

, latter category). This step will include an f

investigation of root cause and generic implications of deficiencies and adverse trends to define fully the

, need for corrective action.

Corrective Actions will be determined in the case of design deviations and safety-significant hardware i deficiencies. All hardware with safety-significant deficiencies will be modified or replaced. All non-safety-significant deviations from design commitments will result in modification of the hardware to conform to the design commitments or acceptance of the deviation through an appropriate non-conformance evaluation process or justified modification of the design commitment.

1 Results Reporto will be prepared as described below in "End Products."

This methodology for resolving External Source issues is in the process of implementation and will continue l

Revisient' 1

Pass .9 cf 39

APPENDIX A

1 - (Cont'd) l .

i l II. ELEMENTS OF THE PLAN (Cont'd) l i 'until the completion of the DAP to ensure resolution of. ,

such issues including any issues that may be identified j by external sources during the execution of.the DAP.

I Implementation of the Category 1 DSAPs will provide i

reasonable assurance that there are no undetected and '

I uncorrected safety-significant design deficiencies  ;

related to the External Source issues (or attributable j to the same causes as any such deficiencies). 1 j Implementation of the Category 1 DSAPs will also  ;

provide input into the collective evaluations of design

j of CPSES and the design process employed at CPSES.

! 2. The Self-Initiated Design Evaluations

} -

)<- Determination of Scope  !

} The self-initiated design evaluations extend beyond the  !

, scope of the External Source issues and permit the  !

j conclusions reached regarding the existence of  !

! undetected and uncorrected safety-significant design deficiencies to be extended. The self-initiated scope j is sufficiently broad to include verification of all .

essential engineering processes or design activities of 4

the A/E safety-related scope of design for CPSES (i.e., -{

whether executed by- Gibbs & Hill. TUGC0 or other  ;

contractors). This verification will either be made l directly by the DAP or by validation by DAP personnel

~

j that previous independent reviews are sufficiently [

4 comparable in required scope,' depth and quality such -!

that the aggregate of qualified reviews is  !

l encompassing. The focus of the DAP methodology is on

{ verification of end products (i.e., designs represented j on drawings and specifications) of these engineering

processes or design activities rather than the quality

} assurance program and associated' documentation which is '

{ typical of industry QA audit evaluation scopes.

j Designs will be selected for review if representative of'an end product of an engineering process or design activity. Confirmation that a design' meets specified-design criteria and commitments will constitute' design ,;

verification and reasonable assurance that the  ;

associated engineering process or design activity was  ;

executed adequately. Coverage of the essential. '

] processes or design activities coupled.with the DAP . I verification of designs representative of,these

! O-I 1

L < )

l R;vicion! 1 Peg 2 10 of 39 l APPENDIX A r

O (Cont'd)

II. ELEMENTS OF THE PLAN (Cont'd) i processes will provide the bases for extrapolation of

] results to other designs as the processes producing these designs will have been confirmed.

The four-phase DAP scope validation program is

. described in detail within Attachment 4 of this Appendix.

Phases 1 and 2 of the DAP scope development process provided an initial scope of review, identifying a set i of review areas and two safety systems (i.e., auxiliary

)

feedwater system, and onsite electrical power system) and selected civil / structural topics. Completion of

, these two phases provided a point of departure for the I DAP,-enabling initiation of preparatory activities such i as procedure-and checklist development, familiarization with the CPSES design and identification of design populations.

i I

, Phase 1 involved a systematic review of the scope of l j Independent Design Verification Programs ("IDVPs")'and Integrated Design Inspections ("IDIs") conducted at other nuclear power plants and a comparison of both the scope (breadth and depth) and findings of previous

, design assessments conducted at CPSES (which are

themselves a source of the Category 1 DSAPs) to the i

initial scope contemplated under this DAP. This

. activity provided confirmation that when aggregated, l the initial design assessments'to be conducted under

! this program cover the safety-significant design areas l l and disciplines at CPSES.

Phase 2 involved an evaluation of selected systems to l

confirm that these.are representative of other l safety-related systems and that conclusions drawn may be later extrapolated. A profile of general characteristics for safety-related systems (e.g. design '

i critetia, hardware types, organizations, interfaces, etc.) was developed for nine safety-related systems and a comparison made.

It was determined that the initial ccope of the DAP was comparable to the scope of any IDVP or IDI performed j for licensing purposes to date, and that the selected f-~s systems were representative of the plant's safety

() related systems.

4 k

b

- - . . - - . , - . . - . - . - - - . - - . .c -- . . ,

R;viciont 1 Pcg2 11 of 39 APPENDIX A p (Cont'd) b II. ELEMENTS OF THE PLAN (Cont'd)

Phase 3 has recently been completed, involving an  !

analysis of the actual design processes, organizations and~ activities in the initial scope versus the l processes, organizations and activities in the aggregate A/E design scope performed at CPSES. This phase was dev' eloped to confirm the breadth of the l initial scope (or identify necessary expansions) and establish the minimum depth necessary for extrapolation of the results to the entirety of the BOP design process associated with safety-related systems, components and structures. Changes in scope have been identified to cover additional review areas and activities performed by design organizations other than Gibbs & Hill. Attachment 3 to this Appendix lists scope matrices for each discipline, identifying specific design activities from which the DAP will select designs for review. The actual scope matrices are contained in the respective DSAPs. The depth will be documented through the development of detailed checklists described below.

Phase 4 of the scope development process will involve

, evaluation of the findings of the DAP, execution of I

root cause and generic implication evaluations and investigations and determination of collective significance. Any further expansion of scope necessary to achieve the requisite degree of extrapolation will l then be determined.

In the aggregate, this scope determination process I ensures that design processes, organizations and activities employed with respect to safety-related designs at CPSES will be reviewed, that any required expansions of the self-initiated review scope will be identified and that the final scope will be sufficient to permit the accomplishment of the DAP objectives.

Self-Initiated Methodology The self-initiated design review process parallels the design process upon which ANSI N45.2.11 is based. For each area of self-initiated design evaluation, the applicable design criteria (e.g., regulations. FSAR J

commitments, codes, standards and other bases) are

, identified, recorded and reviewed using checklists for l

consistency and completeness. In addition to ensuring completeness of the review process and the traceability

Revicient 1 P g2 12 of 39 APPENDIX A (Cont'd)

O II. ELEMENTS OF THE PLAN (Cont'd) of items reviewed, checklists are used to document I design criteria;to be verified, the verification scope and references to documentation and deviation reports.

The criteria are then used to review the. design analyses, calculations, engineering evaluations and implementing documents (e.g., flow diagrams, control and instrument diagrams, logic diagrams, etc.) to assess whether the des'gn.i criteria have been correctly applied, whether the engineering analyses ~and evaluations have been adequate and whether the design t inputs have been correctly translated into design j outputs (drawings and specifications including vendor l'

documentation). Conformance with these design output requirements is verified in part by the Design Adequacy .

Review Team and in part by the QA/QC Review Team as

indicated on Attachment 1. Where particular design i

aspects are clearly demonstrated by the CPSES testing ,

program, test results may be used to replace or j complement a design review-for those particular design aspects.- Fabricator and supplier documentation is l verified by the Design Adequacy Review Team as part of J

the review of design output documents and site construction documentation and physical-installation is verified by the QA/QC Review Team.

i l The specific procedures to be employed in each of the i self-initiated design evaluations are contained in the j DSAPs that govern each evaluation.

Implementation of.the Category 2 DSAPs extends the scope and enhances the confidence of conclusions

! regarding the adequacy of the CPSES design and design

{ process. It is expected to provide information that

, will be useful in the root.cause assessments to be l l perforced in the execution of Category 1 DSAPs, and it j may provide an early focus on additional design i evaluations to which the CPRT would be driven as a l result of the execution of the Category 1 DSAPs. When implemented, the stif-initiated reviews will provide l reasonable assurance that there are no undetected and uncorrected safety-significant design deficiencies at CPSES (whether or not related to External Source issues).

i j 3. Action Plan Initiatives Each of the DSAPs will employ one or more of the l following initiatives:

l I

i

^

R2visicn: 1 Pag 2 13 of 39 APPENDIX A (Cont'd)

II. ELEMENTS OF THE PLAN (Cont'd)

Verification of Project Evaluations Where an issue to be addressed in a DSAP has already been reviewed and evaluated by the Project, the Design l Adequacy Review Team may elect to verify such previous work in lieu of undertaking an original evaluation. l Where validation is employed, it will be accomplished pursuant to appropriate and pre-defined criteria.

Engineering Evaluations I

An engineering evaluation is~a study that is typically more qualitative than either the special studies or reanalyses described below and is employed typically to determine conformance with industry practice or analytical techniques (as opposed to a'particular analysis). All engineering evaluations will resalt in documented bases for the conclusions reached.

Engineering Walkdowns i

() An engineering walkdown differs from an. inspection in that it is conducted by engineering personnel rather than quality control personnel. Engineering walkdowns are used where engineering decisions, based on

. predefined criteria, must be made in the course of the walkdown. Where employed by an action plan..the accion plan will define the objectives for the walkdown and ensure that the walkdown is conducted in accordance with appropriate procedures.

Hardware Inspections i

DSAPs may require the performance of inspections by quality control personnel to obtain or confirm quantitative design information. Such-inspections will either be performed or overviewed by the QA/QC Review l Team in accordance with CPRT reinspection procedures.

l Specini Studies l

Special studies are analyses that differ in one or more respects from the standard analysis of record for the 1

O  ;

)

R;vicion: 1 Pego 14 of 39 APPENDIX A (Cont'd)

O II. ELEMENTS OF THE PLAN (Cont'd) design. Special studies may be used to evaluate whether a design deviation or deficiency exists or as an alternative to the production analysis to demonstrate the adequacy of an existing design.

Testing Testing, combined with analysis, may be.used to determine the adequacy of existing designs or to provide additional data as input to a design reanalysis.

Direct Hardware Modification CPRT may determine in some cases that hardware modifications designed to obviate an asserted or identified deficiency should be implemented directly, (

without attempting to qualify the existing design.

This initiative will be employed on the basis of the relative efficiencies of analysis versus modification, the significance of identified deficiencies and the O total engineering and construction effort involved.-

Reanalysis on a Sampling Basis Reanalysis on a sampling basis (e.g., Project conduit support verification) may be employed to determine the existence or extent of design deviations. Such sampling will be conducted in accordance with the CPRT Sampling Approach, Applications, and Guidelines (see Appendix D to the CPRT Program Plan) and may be supplemented by a sample based on engineering judgment.

Where statistically based sampling is employed, sufficient controls will be employed to ensure the appropriateness of populations and sample selection. l Complete Reanalysis of Affected Design The CPRT may determine that, either because of identified deficiencies or to promote efficiency, a complete reanalysis of the affected design should be conducted. It has already been determined that this initiative will'be employed in the area of piping and pipe supports as described below. In-such cases sampling is not employed and the reanalysis may be employed by the Project as the design or analysis of record.

R vision: 1 Pcgo 15.of 39 APPENDIX A p (Cont'd)

II. ELEMENTS OF THE PLAN (Cont'd)

4. The Piping and Pipe Support and Cable Trays / Conduit Support Design Verification The areas of piping and pipe supports and cable trays and. conduit supports are areas in which it has already been determined that a significant level of reanalysis, as defined below, will be performed. To perform the qualification of piping and pipe support I designs, TUCCO has retained Stone & Webster Engineering Corporation (SWEC). To perform the cable tray supports l reanalysis, TUCCO has retained Ebasco and Impell.

TUCCO Nuclear Engineering (TNE) will perform the conduit supports design verification. The piping and pipe support qualification ef fort will be performed using SWEC's established methodologies. The cable tray supports design verification will be performed using Ebasco's established methodologies.

As'a Project effort, these programs will be subject to the CPSES quality program requirements. In addition, (N these programs will be reviewed by the Design Adequacy

\ Review Team for concurrence with the resolution of identified issues, criteria employed and implementation of criteria. The Lesign Adequacy Review Team will also l investigate the root cause and generic implications of these issues. In the areas where 100% verification is being performed, the assessment of generic implications is only for the purpose of identifying potential problems in other design areas.

5. Root Cause and Generic Implications Regardless of the' initiatives employed, all deviations 'I from design commitments will be recorded. Deviations will be assessed by the review team for safety significance, i.e., the potential for the deviation to lead to hardware that would not perform its intended safety function. A detailed discussion of the CPRT oafety significance evaluation process'is provided in Appendix E of.the CPRT Program Plan. In the case of '

all safety-significant deficiencies (or adverse trends l of non-safety-significant design deviations or observations as defined in Appendix E to the CPRT Program Plan), the review team will investigate the root cause or causes, and for each root cause p identified, the review team will determine the d potential generic implications and the potential l

l 1

R';vicient 1 Pega 16 of 39 APPENDIX A p (Cont'd)

V i II. ELEMENTS OF THE PLAN (Cont'd) I i

existence of other, previously undetected safety-significant design or hardware deficiencies.

Additional evaluations may be required to determine the bounds of the root cause.or existence of the generic implications in terms of potentially affected designs.

The Design Adequacy Review Team will note opportunities l for improvement of quality,. management or engineering programs and make recommendations for corrective action, as appropriate. Details of the DAP. trending l and generic implications evaluation process are provided as Attachment 5 to this Appendix A.. l B. Design Adeauaev Collective Evaluations The results of the DSAP implementation will be the subject of a collective evaluation of the overall adequacy of the CPSES design and the adequacy of the CPSES design process. The collective evaluation will include a critical assessment within disciplines and across disciplines, potentially suggesting previously unidentified potential root causes or generic implications and/or requiring the performance of additional design evaluations. The results of the collective evaluation will be reported separately in the DAP Collective l Evaluation report.

, C. Inter-Relationship of Program Elements The discipline structure of the DAP through implementation of l DSAPs provides the focus for drawing conclusions relative to the adequacy of_ designs produced by the respective ~

disciplines. DSAPs include tasks addressing both External Source issues and self-initiated evaluations and use this information as input for assessing both design adequacy and root causes. Trending, generic implications and root cause assessments for discipline-specific issues are initially conducted at the discipline level by CPRT third-party.

personnel to maintain the necessary technical perspective. l l Results of these assessments are identified to the i  !

Programmatic / Generic Implications Coordinator for evaluation of potentially multi-disciplinary generic (i.e. broader and l collective significance) implications. Root causes potentially attributable to programmatic elements of the i design process are provided to the QA/QC Review Team Leader.  !

He will identify any quality p'rogram weaknesses requiring h)

V .

improvement and make recommendations for both ongoing and future programs. The Design Adequacy Review Team will I

i

R; visions l' Paga 17 of 39 APPENDIX A

/'"N (Cont'd)

U II. ELEMENTS OF THE PLAN (Cont'd) supplement these recommendations by addressing engineering work processes, management of these processes and the effectiveness of implementation of the design QA program.

D. Relationship to Other CPRT Activities To ensure the effective pursuit of potential root causes, issues that may relate to design adequacy that are identified

, during execution of the QOC or TRT-ISAPs will be referred to l the Design Adequacy RTL. .Similarly, issues that may relate to the QOC that are identified during execution of the DAP will l be referred to the QA/QC Review Team Leader. Hardware inspections, as-built verification programs and walk-downs conducted under the auspices of either program are coordinated for the purposes of ensuring thoroughness and consistency, as well as' schedule and other economies.

The Design Adequacy Review Team will perform safety significance evaluations of hardware deviations in areas that are the subject of investigation by the Design Adequacy Review Team. In other areas identified by the QA/QC Review Team, the

.( safety significance evaluations will be performed by the Safety Significance Evaluation Group (SSEG) described in Appendix B. The results of such evaluations will be transmitted to the Design Adequacy Review Team for review and comment to ensure consistency, data input and collective design evaluation as' described previously. Any safety-significant design-related deficiencies identified by SSEG shall require evaluation by the Design Adequacy Review Tean.

Inspection criteria for hardware reinspections conducted by the QA/QC Review Team will be transmitted to the Design Adequacy Review Team (or to another Review Team involved in the specific area) for review and comment. Other information transfer interfaces are described in detail in Appendix F of the CPRT Program Plan.

E. Design Adequaev Review Team The Design Adequacy Review Team is the organization established by the CPRT to implement the DAP. The. Review Team l is headed by the Review Team Leader, Mr. Howard A. Levin, who has the responsibility-for implementing this program plan,  ;

subject only to the direction of the SRT. l The Design Adequacy Review Team organization is divided into

("N . the Programmatic / Generic Implications Evaluation area and the

(). following four discipline areas: l I

i

l Rsvisient 1 Paga 18 of 39 l

APPENDIX A es (Cont'd)

II. ELEMENIS OF THE PLAN (Cont'd)

Civil / Structural Piping / Supports

. Mechanical Systems and Components Electrical / Instrumentation & Control Systems and Components Attachment 6 depicts the organizational structure of these l areas, identifies the third-party individual responsible for each and indicates the interfaces between the discipline and the Project and among the Design Adequacy Review Team l personnel. Each DSAP identifies additional personnel charged with specific responsibilities for implementing the action plan tasks and for maintaining the required interface with other third-party and Project personnel.

III. END PRODUCTS The implementation of the DAP will result in the following end l products:

f%

'sg' - Individual DSAP Results Reports which will address all Category 1 and Category 2 DSAP. tasks. Results reports will provide documentation of identified safety-significant deficiencies and trends of non-safety significant deviations, conclusions regarding root cause(s) and generic implications and required corrective action.

l-

- A third-party CPRT results reports concurring in the criteria, process used, and implementation for the piping and pipe supports and cable tray and conduit supports design verification efforts. These reports will also address the root cause 'and generic implications of the identified issues.

In areas where 100% verification is being performed, the assessment of generic implications is only for the purpose of identifying potential problems in other design areas.

- A final Design Adequacy Program Report documenting a Collective Evaluation related to the adequacy of the CPSES design program, including the identification of any necessarv improvements related to future CPSES design activities and to l CPSES plant operations and the adequacy of the CPSES design, including the identification of corrective' actions necessary to resolve any identified safety-signifi(2.4t design-deficiencies.

O

Rsvision: 1 Pags 19 of 39 APPENDIX A

} (Cont'd)

J ATTACHMENT l INTER-RELATION 5 HIP BETWEEN Tif CPSES DESIGN AND CONSTRUCTION PROCESS AND TFE CPRT DESIGN ADEQUACY, QUALITY OF CONSTRUCTION Am QA/QC ADEQUACY PROGRAMS dI db l seCFR SD. AP80csE a l

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Revision: 1 Page 20 of 39 h APPENDIX A (Cont'd)

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Ravision: 1 Page 21 of 39 b

APPENDIX A l.- s (Cont'd) 4 -

^

j ATTACHMENT 3 l .SELF-INITIATED EVALUATION j SCOPE MATRICES i 1. Civil / Structural Review Matrix

- See Attachment 1 of DSAP VIII.

2. Mechanical Systems and Components: Review Matrix

- See Fig. X.1 of DSAP X. .

3. Electrical, Instrumentation and Control Systems and Components:

, a. Electric Power System Review Matrix i

l - See Fig. XI.1 of DSAP XI.

4 1 b. Instrumentation and Control Systems Review Matrix

- See Fig. XI.2 of DSAP XI.

4 i

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l RI, vision: 1 Pags 22 of 39 l

~<

APPENDIX A (Cont'd)

ATTACHMENT 4 SCOPE DEVELOPMENT PROCESS 1.0 PURPOSE It is the goal of the DAP to provide. reasonable assurance that  !

safety-significant design deficiencies have been detected and resolved. To accomplish this goal, the DAP must be a comprehensive l program that provides reasonable assurance of detecting significant issues that may be presently unidentified. This attachment to the DAP addresses how the initial scopes of the DSAPs were developed I and provides the bases for evaluating.the breadth and depth of the final DAP, including consideration of the results of DSAP l implementation. A four-phase process has been established.

2.0 INITIAL SCOPE IDENTIFICATION - PHASE 1 The initial scope identification was conducted through a review of Independent Design Verification Programs (IDVP) and Integrated Design Inspections (IDIs) conducted at other nuclear power plants for licensing purposes. The IDVPs reviewed were those performed on the Midland and Diablo Canyon nuclear power plants. (This s

' selection was based upon the breadth and depth of these programs.)

The IDIs reviewed were for the Perry, Callaway, Byron, Seabrook,

! and Shearon Harris nuclear plants. A collective list was made of l l the design areas addressed in each of these-IDVPs and IDIs. This l list was then compared against previous CPSES design reviews. Those j reviews include all four phases of the IAP conducted by Cygna; the SIT, SRT, CAT and TRT reviews _ conducted by the.NRC and the INPO evaluation conducted by Sargent & Lundy for TUGCO. The profile thus developed addressed the breadth of the reviews already conducted on CPSES. the. depth of those reviews and the associated findings. A comparison of the intended DAP scope with the-evaluation of previcus CPSES reviews demonstrated that:

the scope of the initial review is comparable to that of other IDVPs and IDIs adequate depth was applied in the initial ~ scope of review.

I

Rzvision: 1 Page 23 of 39 APPENDIX A

("')

V (Cont'd)

ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT 3.1 System Validation - Phase 2 After determining that the initial scope was comparable to'IDI and'IDVP scopes for other projects, a documented basis for confirming that the selected systems are representative of the systems at Comanche Peak was developed. This determination was made by developing a list of safety-significant system l

-design characteristics and comparing characteristics applicable to the AFW and electric power systems against other safety systems in an effort to determine that selection of the AFW and electric power systems provides a representative sample of CPSES safety systems. The selected characteristics included the general design criteria, internal and external interfaces involved in the design of the systems, types of components, system requirements and types of design activities. The systems selected for comparison with AFW and electric power included service water, CCW, containment spray,

(N RHR and ECCS. This review demonstrated that the AFW system

(,,) and the electric power systems provide a good profile.of the safety-related systems at CPSES and are generally representative. The civil / structural area was not included in the scope'of this evaluation. Coupled with the comprehensive

. cable tray and conduit supports program, it was determined that a representative initial self-initiated evaluation selection had been made through selection of concrete, steel and HVAC and other support design in various areas of the plant.

3.2 Engineering Process Validation - Phase 3 As noted above, a determination was made that the selected systems were representative of the safety-related systems, structures and components at the plant. In order to reach a conclusion regarding the ability to extrapolate results, it is also necessary to know whether the design processes and activities in the design of those systems, structures and components were sufficiently similar to the aggregate of the design processes and activities of the balance of the A/E scope to allow such extrapolations to be made.- It was also necessary to develop a final scope of work.that addressed-the

-depth to which the reviews will be made.

f Phase 3 established the methods of. validating the initial scope (rs) and expanding that scope where necessary.

~

RIvision: 1 ,

I P gs 24 of 39 APPENDIX A (Cont'd)

G ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMEhT (Cont'd)

Phase 3 required the evaluation of a significant volume.of information which served as input to a process of identification of a finite number of " homogeneous design activities" (HDAs) that are used to ensure that the DAP has adequate breadth. Additionally, the HDAs have characteristics that are used in the selection of specific designs of systems,

. components and structures to ensure that the DAP has adequate ~

depth. The results of the DAP design verifications will be used to extrapolate conclusions to the remainder of the A/E safety-related scope of design.

In view of this important role, HDAs are continuously validated throughout the implementation phase of the DAP as the review team evaluates more information relevant to the CPSES design that could not practically be assimilated during the phase 3 imp 1~ementation phase. This aspect is discussed later.

s Phase 3 used_a systematic process to identify HDAs on the basis of readily available information. This process required the application of experience on the part of DAP perscnnel and judgments to determine whether or not similarity existed within each EDA with respect to the following five atttibutes:

Criteria Design considerations, approach and methodology.

Organization / discipline.

Design control process. ,

Design interfaces.

! Where significant differences were judged to exist in any of these attributes for any activity, as discussed below, the activity was redefined such that there was similarity with respect to these attributes.

(V I

l Rtvision: 1 Paga 25 of 39 APPENDIX A O (Cont'd)

V ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd)

The standards that are applied to the determination of similarity for each attribute are:

3.2.1. Design Criteria This attribute includes design criteria that belong to the same category (or type) and may be viewed as having similar considerations and application. The criteria are considered to be within the same category if differences would not cause a meaningful change in the analysis or calculational approach. For example, applicable criteria associated with above ground atmospheric storage tanks include codes / standards requirements, configuration, wall thickness, materials, venting and level measurement. These criteria are of a similar type for various tanks, even though the specific numerical values of design parameters are

/D different.

O 3.2.2 Design Considerations, Approach and Methodology This attribute includes design or analysis approaches / methodologies or mechanics'in implementation.

of the design such that meaningful differences in design complexities or considerations are not contained within the subject design activity. Two examples illustrate how potential differences in. methodology' arc discernible. In the first example, the performance of pressure-drop calculations for water, boric acid, fuel.

oil and steam (before phase-change considerations) are similar based upon a common approach and execution of similar steps in the analytical. process. The parameters used in the calculations are different, but do not cause a meaningful change in the calculational approach;.thus, homogeneity in design considerations, approach and methodology is established. In the s'econd example, the performance of seismic analysis-by equivalent static methods, spectral or time-history analysis utilize ~ common input parameters (e.g., seismic input motion, damping, etc.); however, homogeneity is not established as the analyses clearly require different design considerations, approach and A methodology.

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R1 vision: 1- l Page 26 of 39~

! APPENDIX A

(~'i (Cont'd)

\,. l ATTACHMENT.4 (Cont'd) 3.0 SCOPE DEVELOPMENT'(Cont'd) 3.2.3 Organization / Discipline This attribute addresses the consideration for the same organization or discipline performing the particular design activity. If all other attributes of a potential HDA are confirmed, yet multiple organizations originate similar designs, then such designs from each organization are identified for verification. For example, if Gibbs & Hill and TNE performed a similar type of design, the design performed by each organization is considered separately. For design performed by Gibbs & Hill, this attribute is also taken to the design-discipline level, and no further, unless it is determined that a discrete sub-unit of a L discipline functioned independently. If separate Gibbs

& Hill disciplines performed similar types of design over time, the design performed by each discipline will be reviewed unless information is provided which

{'S s ,) demonstrates that the same controls were used for both cases and thereby resulted in comparable design.

, During phase 3, a specific review of Gibbs & Hill organizational changes was made to determine the effect on homogeneity. An initial determination was made that the organization was stable over the duration of the project with respect to any meaningful impact on the execution of design. This determination will be confirmed during implementation of the'DAP. All other organizations are considered to have been-responsible for their activities for a limited scope and over a short period compared to the~ overall ~ project duration.

Thus, organizations other than Gibbs & Hill are not deemed a candidate for further breakdown.

3.2.4 Design Control Process This attribute provides that similar control procedures were used for the design process which governed the performance of the subject design activity. Elements which are considered in this context include personnel

~

qualifications, design origination, reviews, verification, approvals and interface requirements.

The Gibbs & Hill design control procedures underwent

(,~ .

R vision: 1 Page.27 of 39 APPENDIX A

("'

V (Cont'd)

ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd) some revisions over the life of project; however, the design control process is considered similar unless the revisions included meaningful changes which may have effected the quality of the design end product. During phase 3, design control was cencluded to be consistent

-at the programmatic level; however this will be further confirmed during the DAP as details of implementation of Gibbs & Hill's' process are determined. For other design service contractors, their limited scope and relatively short period of performance do not warrant addressing this attribute for their scope of design because such conditions are judged to provide reasonable consistency in the design control process.

Accordingly, definition of HDAs by organization provides sufficient breakdown'with respect to design control homogeneity for design organizations other than Gibbs & Hill.

O k,) 3.2.5 Design Interface (s)

This attribute applies to discipline design interfaces within Gibbs & Hill and addresses the consistency in communications of substantive design information -

relative to information transfer and provisions for design input. (Substantive design information is information essential in developing the design.) -It also addresses consistency in cross-discipline review responsibilities where relevant. .The focus of attention for design interfaces is to-identify meaningful. changes which may have affected the design process and thereby the quality of the design end product. For example, if the requirements for cross-discipline design reviews changed over the life of the project, the DAP review would need to' address

~

the related design activity for different periods in time.

The process of determining HDAs required examination'of the following document categories to establish the CPSES design ,

baselines.

-~s i

.n ,

RLvisient 1 Pags 28 of 39 1 1

APPENDIX A '

( .

(Cont'd)

. ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd)

FSAR Regulatory Guides Standard Review Plans

. .- IE Bulletins Generic Letters SER plus supplements i

External Source issues plus applicable testimony and other related documents Equipment lists.(including related vendors and specifications)

Gibbs & Hill document indices for calculations, specifications, and drawings I

Gibbs & Hill design criteria lists TNE document indices for calculations, specifications, and construction-completed TNE engineering packages Lists of organizations (other than Gibbs & Hill, TNE and the NSSS) and their' design' scopes, which performed design for CPSES.

Review of the above for criteria, types of analyses, calculations, drawings, and equipment regulatory requirements, TUGC0_ commitments, issues of concern and participating design organizations (including design interfaces) provided sufficient input to construct a list of design activities for evaluation under-the DAP that reflects the engineering tasks involved in the design and construction of CPSES. To focus these document reviews and enhance the. expertise applied, the Phase 3 scope development process was' performed on a discipline basis (mechanical, civil / structural, electrical, and I&C). Collectively, the comprehensive nature of-the.

documents reviewed allowed a global picture of the CPSES

("% design to be developed.

't

,, a

Rsvicion: 1 Paga 29 of 39 APPENDIX A

("' (Cont'd)

V) ATTACIDfElfr 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd) l After the HDAs were defined on a discipline basis, the activities were further reviewed to identify:

Givens j -

Overlap between discipline lists, i.e., duplication Gaps between discipline lists, i.e., assumed other i

discipline's responsibility Appropriate conditions for further consolidation relative to defining broader HDAs Expansion, as appropriate, relative to defining more narrow, or new, HDAs.

In addition, these secondary reviews assured consistency

'Sg between disciplines in the application of the HDA concept and in the formatting of the matrices.

A "given" is a design activity which is considered correct and is not under question, i.e., the activity is not subject to review under the DAP.

The following generic " givens" have been identified based on justification which is provided at the program level:

Internal NSSS design scope

~

NSSS design output interface reg'uirements-(i.e., their validity is not questioned)

Internal design scope by equipment vendors (excluding

~

vendors who only supplied to CPSES)

Vendor design output interface requirements (i.e.,

their validity is not questioned)

Codes, standards, regulatory requirements, etc. (i.e.,

their validity is not questioned)

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Rsvision: 1 Paga 30 of 39 APPENDIX ~A

/~'s . (Cont'd)

ATTACHMENT 4~

(Cont'd)

, 3.0 SCOPE DEVELOPMENT (Cont'd)

Vendor material, perf.ormance, analysis, and test data

~(i.e., their validity is not questioned)

Design output from other Gibbs & Hill or TUGC0 design disciplines, i.e., each DAP discipline will review the scope of its counterpart (electrical will not question input from civil)

Postulated accidents and protective actions as defined in the CPSES FSAR Areas addressed by External Source issues that were resolved to the Source's satisfaction Attributes related to plant siting and site suitability Unresolved industry generic issues.

In addition to generic " givens", the DAP disciplines identified " candidate givens" based on satisfying each of the following requirements:

The design-relate'd item received an independent technical review in the past.

, The subject independent review had no question, to the Design Adequacy ~ Review Team knowledge, about its quality, objectivity, reviewer expertise, or results.-

The independent review was comparable in scope and-depth to that which would have bscn be performed if execute'd under the DAP.

Before initiating the actual DAP reviews, these

" givens" were called " candidates" because some level of review was required by the DAP disciplines to make the determination that a " candidate" met the criteria of a "given". The DAP properly took credit for that review, though often small by comparison.

O(-/ .

R& vision: 1 Pags 31 of 39 l APPENDIX A

~ [~ (Cont'd)

\.

ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd)

The-following guidelines were utilized to identify

" candidate givens":

Credit was not taken for-the Cygna review for the purpose of identifying " candidate givens".

A previous review of a " candidate given" by the NRC was not mandatory, but added otrength to justifying a "given" depending on the depth and breadth of the review documented by the NRC.

The quality, depth, and breadth assigned to previous reviews of " candidate givens" were based on the responsible DAP discipline review of related documents, e.g., documented reports from other A/Es, engineering / consultant firms or the NRC.

'N -

A number of standard industry issues which receive 4

s extensive NRC review / inspection / audit (including litigation)'were identified'as " candidate givens" and' evaluated further for the necessary attributes: relative

~

to scope, depth, etc., example candidates include Control Room Design Review, and human factors.

If TUGC0 had prescribed a resolution for a generic issue under consideration by_the NRC or the~ industry, and that resolution was going to be subject to special NRC or industry reviews / programs of sufficient intensity to provide confidence in the final disposition, that design area was defined as a " candidate given".

Cases may.have arisen where a design area had been reviewed by others as described above; however, the subject review was not considered to stand alone. The scope, depth and results of these reviews could be used to better focus and/or moderate the DAP: review of the subject design areas. Additionally, if a DAP review was moderated, the subject design area should not have had a history of being a problen issue for CPSES or the nuclear industry.

7-~x The results of Phase 3 consist of a listing, by discipline, of

! ,) HDAs to be reviewed under.the DAP and engineering evaluations of how Phase 3 was executed. 'The HDA are listed in a matrices which are included in DSAPs VIII, X and XI. These matrices

] are listed in Attachment 3 of this Appendix. These matrices

RIvisicn: 1 Paga 32 of 39 l

APPENDIX A e'~s . (Cont'd)

-f l'

\m /

ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd) illustrate the review scope as represented by HDAs. The HDAs have been grouped into topical areas within which review checklists will be developed.

The checklists correlate design criteria with specific documents (and associated design scope) to be reviewed. The product of the successful completion of this phase of scope determination, is confirmation of.the minimum depth and breadth of the DAP and a confirmation of the ability to extrapolate results of the DAP to other safety related systems, structures and components.

The ability of the DAP to extrapolate results is essential and must be confirmed during implementation of the DAP.

Accordingly, DAP design verification of selected examples of work performed within an HDA and the subsequent extrapolation of conclusions to all work represented by the HDA depends upon

~g - the following three considerations:

d -

Confirmation that within each HDA reasonable similarity exists regarding the five attributes of HDAs and that further subdivision of the HDA would not result in meaningful new information affecting the extrapolation of results.

Selection of specific designs for review within each HDA that are considered to be representative'and a good test of the HDA with due consideration given to the

" vertical-slice" approach (a key element in the DAP approach).

Selection of an appropriate number of specific designs for review within each HDA to ensure proper coverage of larger populations where a potential variability may exist du2 to a long period of performance and many designers.

In order to confirm the validity of each HDA, the following method is applied during DAP implementation:

- The design documentation relevant to the HDA is-identified (these documents are expected to be primarily calculations and evaluations).

C,)

- A minimum of five documents is selected from the set of~

. identified documents. The selected documents are scanned to identify if they: reveal differences in the

Rsvicion: 1 Paga 33 of 39 APPENDIX A

- ~3 (Cont'd)

ATTACHMENT 4 (Cont'd) 3.0 SCOPE DEVELOPMENT (Cont'd) five attributes important to HDAs such that additional HDAs may be required. The items. selected are distributed approximately even through the period of performance of the work as indicated by the current revision date of the documents. (Note: Where the +

document population is large - e.g. greater.than fifty (50) - or where it appears, based on the. scanning, that the opportunity exists for multiple design 4

methodologies, the number of documents to be scanned i

will be increased until the reviewer has confidence that homogeneity has been established or it is clear that the HDA should be subdivided.)

- A checklist is completed to document the review of documents scanned and the. conclusion reached by the reviewer regarding the validity of the HDA. Where it is determined that an HDA should be subdivided because -

4

(

t

.of differences in any of the five attributes, the RDA will be redefined as appropriate. Checklists will then be prepared for the new HDAs after the relevant documents have been scanned.

Where appropriate, the confirmation of the validity of HDAs will be conducted on a group of related HDAs. In any case, sufficient documentation will be prepared to demonstrate, when reviewed as a complete package, that each HDA is made up of sufficiently similar activities that a review of any example -

of the work within the design activity is an adequate test of the HDA and that the results may be extrapolated.

4.0 SCOPE EXPANSION In the conduct of the DAP, it may be necessary to expand scope, after the completion of the validation of the initial scope, to accomplish one or more of the following:

investigation of ~ treads of deviations or observations investigation of root causes l -

identification of the random or programmatic nature of deficiencies

(~

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1 ~

assurance that areas reviewed bound design concerns in such a

~

manner that reasonable assurance exists that all deficiencies-within those limits have been identified.

~. --

RIvicion: 1 -l Paga:34 of 39 APPENDIX A (Cont'd)

U,A ATTACIRIENT 4 (Cont'd) 4.0 SCOPE EXPANSION (Cont'd)

Certain conditions exist wherein scope expansion is a requirement.

These include the existence of:

deficiencies one or more deviations that would be likely to result in undetected safety-significant deficiencies if occurring elsewhere identified root causes that can affect design ectivities t

outside or inside the scope of review If any of these conditions is present, the scope of the design review will be increased to the extent necessary to achieve reasonable assurance that deficiencies have b'een identified. The exact nature of the expanded scope will depend upon the nature of the potential root cause. As a minimum, 'the scope would be j extended to similar designs or design processes.-

5.0 FINAL SCOPE DETERMINATION - PHASE 4.

The final scope determination for the design adequacy program is the summation of the initial scope as validated per paragraph 3.2 (above) and.any scope additions resulting from deficiencies or trends of deviations or observations identified in the-course.of l action plan inplementation. Thus, the ultimate scope of the DAP depends on the deviations and deficiencies found during its conduct.

i

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l Rsvision: 1 Paga 35 of 39 l

APPENDIX A l

(% (Cont'd)

ATTACHMENT 5 TRENDING AND GENERIC IMPLICATIONS EVALUATION PROCESS 1.0 PURPOSE The DAP~ employs a systematic process for identifying and evaluating-trends and generic' implications. This systematic process.

implements the CPRT commitment to investigate the generic implications of deficiencies in the area of design. The process is intended to:

Identify and evaluate any trends in observations, or in deviations from design criteria, or commitments that indicate a possibility of adverse impacts on the design of safety related systems, structures and components ~

Determine whether identified deficiencies in design have generic implications and effects, and if so the extent of these effects Ensure that adverse impacts on hardware that result from generic effects are evaluated and' resolved Identify corrective action necessary to preclude recurrence of each deficiency.

2.0 SCOPE The scope of trending and generic imp'lications evaluations  !

encompasses all deficiencies and identified adverse' trends in External Source issues, discrepancies, observations, deviations and deficiencies to determine potential generic implications.

related to design adequacy. . Potential. generic implications may have been identified either within the DAP or by External-Sources, which may or may not have' closed the issues that they raised.

3.0 DESCRIPTION

External Source issues, discrepancies, observations, deviations, and deficiencies are evaluated to determine whether trends exist in the data and, if so, whether the trends are adverse, as defined in Appendix E to'the CPRT Program Plan. Design deficiencies and identified adverse trends are evaluated to determine whether root causes can be identified and whether any-commonalities indicate generic implications. Generic implications found are evaluated to

Rsvision: 1 Paga.36 of 39 APPENDIX A

,- s (Cont'd)

ATTACHMENT.5 (Cont'd)

3.0 DESCRIPTION

(Cont'd) establish their bounds of applicability, effects on adequacy of design of safety related systems, structures and components and any

1. necessary corrective action in design programs, processes, or t controls to prevent recurrence. Generic implications are considered resolved and will be closed when associated boundaries are determined, root causes are investigated, corrective action is

. developed, and its implementation is overviewed to the extent

determined appropriate in.accordance with Appendix H. Corrective

,' action may apply to both hardware and programmatic aspects as

appropriate. A flowchart of the generic implications evaluation process is depicted in Figure 1. Figure 2 shows the interreintionship between the generic implications evaluation process and other parts of the CPRT. These evaluations will be documented in appropriate DAP reports.

4 lO i

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. . , . . v.. --e .- ...r.- a

Rcvision: 1 Page 37 of 39 l

APPENDIX A I (Cont'd)

,  %)

FIGURE I GEPERIC IMPLICATIONS EVALUATION PROCESS OVERVIEW SOURCES OF ISSUES e EXTERNAL e SELF. INITIATED EVALUATIONS l

i F DAP TRACKING SYSTEM f (IR/DIR) )

l l

i r i TREND EVALUATION (PROGRAMMATIC AND SAFETY StGNIFICANT) 9 F CENERIC IMPLICATIONS OF DEFICIENCIES AND ADVERSE TRENOS IN DEVIATIONS /

OBSERVATIONS IN DES!CN ADEQUACY e

3 f MULTIDISCIPLINARY DISCIPLitE SPECIFIC 1 P ROOT CAVE i

1 I UMaTING BOUNDARIES i

1 P 1 F CORRECTr/E ACTION CORRECTIVE ACTION TO FOR HARDWARE PRECLUDE RECURRENCE t

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Revision: 1 l Paga 38 of 39 APPENDIX A

% (Cont'd)

FIGURE 2 GENERIC IMPLICATIONS EVALUATION PROCESS SOURCES OF lePUT APO lbFORMATION FLOW ISSUE SPECIFIC m ,

ACTION PLANS f DESIGN.RELATED OBSERVATIONS, DEVI ATIONS, DEFICIENCIES, e ROOT CAUSES CENERIC .

IMPLICATIONS GENERIC EFFECTS ON PROGRAM

• HARDWARE DESIGN AND d k'

- PROGRAMMATIC DESIGN-RELATED ISSUES DISCIPLINE SPECIFIC 0 ACTION PLANS CONSTRUCTION DESIGN RELATED DEVIATIONS -->

GUAllT Y m

& OA/OC '

GENERIC ISSUES IN ACTION PLANS

+--- CONSTRUCTION OR OA/OC l

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l 1

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v. [

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i ATTACHMENT 6 CPRI DESIGN ADEQUACY PilOGtAM OHGANIZATiON TERA Du(E C T iif POHilt4G8 COFFORATE CPRT SENIOR

.-a=== aNIERFACE52 mat 4AG MENT REVEW TEAM D. Devia, President I I I

DE$sGN ADEQUACY DAP OUALITY PROGRAM, GA/QC REVIEW A55 URAN .- fEVIEW TEAM TEAM LEADER o,t u LEADER Aw H. Lewin

== 5 >

I I i nm cot 6 PROKCT DE54CN ADEQUACY iY ION p QN U

C 4i 00 8 - MANAER SI Ot - 94TERFAG COORDINATOR n ENGatEER F. Dougterty MANA&R 5.karprak *H

a. Ti-+-

m c,,, R. M.i- 2. ~ 3x I

a u

I A u >

a I i I I I I SYSTEMS DesceptyE PROCHAMMATIC/

ENC #EERING Cat (W H T/ DAP SITE EPERIC mat 4AGR COMMOtawEALTH ENGatEERING COORDINATORS MANAGER M GR 4 DISCIPLits DSAP C N TOR i

- M MANAM MENT F. Schofer A*

Vill C. Mart," E. thchwand

-IX T. 5nyder l l X XI J.V ece EL Rice I I I I MECHANICAL ELECTRICAL, goggg CivlL/ STRUCTURAL PIPING /SLETORT5 SYSTEMS AND - INSTHUMENT ATION qg (SEE NO ($E IX) IPL T 5

1. LINE PROKCT MANAGEMENT DIRECTIOtt CONTHOL. y$

(SEE DSAP X) COMPOPENTS D15CIPs itE

2. SEE CPRT PROGRAM PLAN, APP. A APO DSAPs VIII, IX, X APO XI FOR MOHE DETAIL. *7 wr (SEE D5ar* ).) eo D

1/27/86 Oa

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Rsvision: 3 Pags 1 of 17.

I APPENDIX B 4

QUALITY OF CONSTRUCTION AND.QA/QC ADEQUACY PROGRAM PLAN Table of Contents I. INTRODUCTION - OBJECTIVES . . . . . . . . .. . . . .2  :

II. ELEMENTS OF THE PLAN . . . .. . . . . . . . . . . .5 I A. Quality of Construction and QA/QC Adequacy ISAPS . . . . . . . . . . . .5

)

\

) .1. ISAPs Related to Specific External Source Concerns . . . . . . . . .5 i

! 2. Self-Initiated ISAP . . . . . . . . . . . .7

! B. Quality of Construction and 1 QA/QC Adequacy Collective Evaluations . . . . .10 C. Inter-Relationship of the Elements of the Plan . . . . . . . . . . . . . . . . . . . .10 D. Relationship to Other CPRT Activities . . . . .10 E. QA/QC Review Team . . .. . . . . . . . . . . .11 III. END PRODUCTS . . . . . . . . . . . . . . . . . . . .12 i

4 j ATTACHMENT 1 . . . . . . . . . . . . . . . . . . . . . . .13 i

j ATTACHMENT 2 . . . . . . . . . . . . . . . . . . . . . . .14 i

ATTACHMENT 3 . . . . . . . . . . . . . . . . . . . . . . 15 ATTACHMENT 4 . .. . . . . . . . . . . . . . . . . . . . .16 i ATTACHMENT 5 . . . . . . . . . . . . . . . . . . . . . . 17 i

l i

- - . _ - . . -, ._ .. _ , _ _ _ _ - - _ . . _ . . _ . ~._.___.-- . . - - -

, ___..-- .. . __ _ __ _-_ ._, __, . _ . . __ ~ . _ _ ._____ .

Ravision: 3 '

Page 2 of 17 APPENDIX B QUALITY OF CONSTRUCTION AND QA/QC ADEQUACY PROGRAM PLAN'

! I. INTRODUCTION - OBJECTIVES

! Concerns regarding the adequacy of the CPSES con'struction.QA/QC  :

I program and the adequacy of the constructed safety-related ~ l t

hardware have been raised by a number of sources external to Texas i Utilities. These' sources are the NRC Staff Technical Reviqr Team t i

reports ("TRT"), the NRC ASLB proceedings on the CPSES operating license-("ASLB"), the NRC Staff's Supplemental Safety Evaluation i Reports.("SSER's"), the NRC Staff's Construction Assessment Team i (" CAT") and Special Investigation Team.(" SIT") reports, certain _ .

1 Inspection Reports issued by NRC's Region IV staff ("RIV"), and the ,

Cygna Independent Assessment Program.("IAP"). The CPRT has been '

charged with responding to and resolving the open TRT, ASLB,.SSER, l CAT, SIT, RIV and IAP issues (collectively, these concerns are l sometimes referred-to herein as the " External Source issues"), and i

$ with advising i'exas Utilities management whether there is-reasonable assurance that CPSES has been constructed such that it i is capable of being operated without undue _ risk to the public.

i This Quality of Construction cnd QA/QC Adequacy Program (QOC).has

'. been formulated by CPRT to accomplish that objective as it relates to the adequacy of the CPSES construction QA/QC. program and the adequacy of the installed hardware. .The_QOC has three components: l 4

First, the CPRT will evaluate each of the specific hardware and-programmatic concerns' raised by the External Source issues. It i will determine the nature.of any safety-significant-hardware .

deficiencies and the corrective-actions nec'essary to resolve-them'.

1- This aspect of the QOC will lead to the conclusion that'there is i

! reasenable assurance that there are no undetected and' uncorrected. ,

safety-significant, hardware deficiencies associated with any of the External So'irce issues.

Second, the CPRT will determine the root cause of each discovered .!.

safety-significant deficiency (or trend of non-safety-significant l hardware deviations) and analyze the generic implications of each' q

! root cause in order to determine the extent of any additional- ~

l hardware that might be deficient for the same-programmatic reasons .

and to determine if changes need to be made in. ongoing programs to ~

prevent recurrence in the future. This aspect of the QOC will lead l j to the conclusion _that there is reasonable assurance that there are

.no undetected and uncorrected safety-significant hardware-deficiencies attributable to any of the root causes of safety-significant hardware deficiencies. identified by any of the' External l Source issues. i I

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Rsvision: 3 -

Page 3 of 17 APPENDIX B (Cont'd)

1. INTRODUCTION - OBJECTIVES (Cont'd)

These two components are complementary and each has the potential for expanding the other. The evaluation of root cause and generic implications may lead to additional atens of hardware requiring l evaluation, and the evaluation of discovered safety-significant l hardware deficiencies (or trends of non-safety significant deviations) may lead to the establishment of additional root causes and potential generic implications. Similarly, inspections of hardware and evaluation of any discovered safety-significant l deficiencies (or trend of non-safety significant deviations) may lead to the expansion of reviews of programmatic issues, and the evaluation of programmatic root causes may lead to the expansion of hardware inspections.

The sum of the first two aspects of the QOC will fully resolve each {

of the External Source issues, and it will fully bound the safety-significant implications of any External Source-identified l or found deficiency in either hardware or the CPSES construction  :

QA/QC program, d l

For additional confidence, however, the CPRT will also conduct, as O a self-initiated third component, a statistically based l reinspection of the balance of the hardware within the scope of the QA/QC program. This additional component of the QOC will permit the two conclusions described above to be extended to the entirety of the safety-related hardware in the plant, and the sum of the three program components will also permit CPRT to make a firm _

statement about both the adequacy of the hardware at CPSES and the adequacy of the QA/QC program employed during.its construction. _

Implementation of this QOC is by execution of Issue-Specific Action Plans (ISAPs), the methodology of which is described herein, and by the preparation of the results reports described in "End Products." i During the conduct of the Design Adequacy Program Plan (DAP)

(Appendix A), the Design Adequacy Review Team may identify areas of l concern involving the design control processes required by 10CFR50, Appendix B, Criterion III. When ruch concerns are raised, they will be provided to the QA/QC RTL for evaluation. This evaluation

~

l will be conducted either jointly or by the QA/QC RTL. The -

evaluation will include an assessment of the significance of the concern and, if required, analysis for root cause and generic implications. The results of these evaluations will be included in the collective evaluation report for the adequacy of the QA/QC program.

m

. ^ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

I Rsvision: 3 Pags 4 of 17 APPENDIX B (Cont'd)

}

I. INTRODUCTION - OBJECTIVES (Cont'd)

To assure that issues / concerns from External Sources are addressed, a matrix will be developed that provides a cross reference between each issue / concern and the action plan (s) that address it. This matrix will also serve as an aid in-the collective evaluation process. The matrix format will present information such that each valid concern can be' tracked to the appropriate criteria of 10CFR50 Appendix B and/or hardware area, and tracked to the ISAP or DSAP covering the concern.

4 During this development phase, personnel from the QA/QC Review Team assigned to develop this matrix will work with ISAP/DSAP Issue Coordinators and others to determine which ISAP/DSAPs need to be modified or supplemented in order to cover these concerns. The team will review source documents in detail to ensure that identified problems with any substance are included in the matrix.

The external sources are the following:

SSER's

- NRC January 8 letter O)

(.- - NRC SIT Report, February 15, 1983

- NRC CAT Report, April 11, 1983

- Cygna Report

- ASLB Proceedings

- MAC Report.

- Lobbin Report

- Teledyne Report

- NRC-SRT Report

- Region IV Inspection Reports During the course of CPRT activities the matrix will be' kept current to incorporate status'of ISAP/DSAP results and to ensure that concerns have been satisfactorily closed. The matrix is a convenient tracking tool relating ISAPs to the concerns identified ,

in'each of the external documents. External source issues / concerns which are identified as a result of this process and which are.not i adequately addressed by existing ISAPs will be addressed either in l

{s,)' revisions of existing ISAPs'or in new ISAPs. .

1

Rsvision: 3 Paga 5 of 17

~

APPENDIX B

'(Cont'd)

, '[k I. INTRODUCTION - OBJECTIVES (Cont'd)

Concerns which have been raised and subsequently closed out by the External Source that raised the issue will be considered for information when-conducting root cause and generic implication-analyses.

II. ELEMENTS OF THE PLAN 3 A. Quality of Construction and QA/QC Adequacy Program ISAPs L The QOC ISAPs fall into two categories: >

- The Category 1 ISAPs address specific CPSES construction QA/QC issues, either regarding hardware or regarding aspects of the QA/QC program, that have been identified by the External Sources. This includes any

~

additional construction QA/QC concerns identified by the CPRT through its evaluation of those issues.

- 'The Category 2 ISAP implements the CPRT's self-initiated hardware reinspection / documentation

> review program that addresses all safety-related construction work activities at CPSES not fully reviewed by the Category 1 efforts noted above.

A listing of these ISAPs, by category. is provided as Attachment 1. The ISAPs themselves are included in Appendix C of the CPRT Program. Plan.

1. ISAPs Related to Specific External Source Issues

/s appropriate for the specific. issues being considered, each of the Category 1 ISAPs will employ one or more of the following evaluative approaches:

Reinspection of hardware is-conducted for several purposes. It is a direct method of establishing the 4

existence and extent of any safety-significant deficiencies in installed hardware. Reinspections may also serve as a measure of the effectiveness of the QA/QC program employed'during-construction.

Reinspections are conducted-in accordance with the principles of statistical inference as described in Appendix D to the CPRT Program Plan, with any g TN appropriate adjustments, which have been set forth in '

\_, the specific ISAPs.-

iI

-e--g- ~-w+ r---, - y-

R2 vision: 3 Pags 6 of 17 APPENDIX-B I 7s s'

( (Cont'd)

's.

II. ELEMENTS OF THE PLAN (Cont'd)

Reinspections are for well-defined attributes to-  ;

well-defined criteria and are conducted or monitored by-qualified third-party inspectors.

Review of hardware documentation is employed to develop information relaten to inaccessible hardware, to supplement limited or visual re-inspection, and/or to verify proper application of process controls that are not measurable or recreatable.

Walkdown inspections are employed to establish the as-built condition of installed hardware.

Data collected from other CPRT Review Team action plans are, in some cases, directly applicable to hardware or programmatic issues being evaluated by QOC Category 1 ISAPs. Where a potential for overlap is perceived, coordination of data collection promotes expedition, economies and consistency.

g

' Engineering analysis and evaluation will be used to

' determine similarity of operations, processes or personnel. In some cases of inaccessible or,,non-recreatable attributes, an evaluation of similar hardware or processes will provide indirect information about the attrib'utes. " Inaccessible" is defined to mean a condition where extensive dismantling would be required to gain access for direct reinspection, such as in the case of piping, reinforcing steel or conduit that is embedded in concrete. "Not recreatable"cis defined to mean a condition where a process or event cannot be recreated, such as pull. force during cable pulling, interpass weld temperature or receiving inspection. The baser for decisions on inaccessibility will be documented for each population and records maintained which identify the hardware items and attributes determined to be inaccessible.

Review and verification of TUGCO-corrective action I programs may be used, where appropriate in the judgment ]

of CPRT, in cases where TUGC0 has already implemented a program designed to evaluate and correct a specific previously-identified concern'that overlaps a. concern being investigated by the QA/QC Review Team. Where validity of the TUGC0 program is established, its results will. provide additional data employed in the

'\~ collective evaluations.

l l

s LRavision: '3 1P aga 7 of 17 APPENDIX B (Cont'd)

[()

1 II. ELEMENTS OF THE PLAN-(Cont'd)

All valid hardware deviations will be evaluated for safety significance in accordance with' Appendix E. - The l evaluations are~ performed by.the Safety Significance Evaluation Group (SSEG), except where it 'is known that 4

another Review Team is.already. involved in detailed

, investigations in the same~ area,.in which case that Review Team will perform the evaluation. s '

Design-related deviations identified ~by SSEG will be l evaluated by the Design Adequacy Review Team.

The CPRT will seek to determin.e, where possible, the I root cause of safety-significant deficiencies. Where a root cause can be established,-the generic implications of the root cause will be evalua'ted to determine if other areas of hardware might contain safety-significant deficiencies attributable to the

~

same root cause. Additional hardware evaluations may be required to establish root cause, to determine the bounds of the-root cause or to determine the generic implications.

/ Attachment 2 is a generic logic diagram for'the' Category,1 ISAPs.

! . Implementation of the Category 1 ISAPs will provide j reasonable assurance that there are no undetected and

uncorrected safety-significant hardware deficiencies

related to issues raised by the-External Sources (or attributable to the same causes~as any such deficiencies). Implementation of.the Category 1 ISAPs '

will also provide input into the collective evaluations

~

of the quality of construction'of hardware installed at CPSES and of the-adequacy of1the CPSES construction QA/QC. program.

2. Self-Initiated ISAP 1

The Category 2-ISAP.is a;CPRT~self-initiated hardware-reinspection / documentation review of all safety-related; construction work" activities conducted by the.various -l contractors at CPSES. It' addresses all areas of~ l

-safety-related hardware including those areas that have- l not been identified as areas-of concern by External Sources. This self-initiated action, though not i- necessary to respond to orfto resolve fully the External Source issues, represents the'uost direct,-

~

5 O.- reliable, achievable and' expeditious method of' providing additional c'onfidence_that any currently,~

unidentified concerns'related to the quality of.

I construction of the hardware' installed'at,CPSES will have been' identified,' evaluated and resolved.

4 Rsvision: 3' Paga. 8 of 17 APPENDIX'B

() (Cont'd)

II. ELEMENTS OF THE PLAN (Cont'd)

' Proceeding directly to the self-initiated action insures no significant loss of time in the event that

}' one or more of-the areas to be evaluated would have I ultimately been required to be evaluated as a result of

' the-root cause and generic implications assessments made pursuant to one of the Category 1.ISAPs. This l-action also provides. data useful to resolve concerns l t

that might exist regarding potential-adverse impactsoon the quality of the installed hardware at CPSES j

attributable to (a) potentially inadequate.

qualifications of historical QC inspectors whose l

qualifications were not evaluated by the CPRT in ISAP'

! I.d.1 or (b) potential occurrence of harassment or intimidation of QC inspectors.

To summarize the approach taken, the. logic diagram for l the Category 2 ISAP.is presented in. Attachment 3.

Installed safety-related hardware will.be categorized into populations based on experience._ Within these

' populations reasonably homogeneous ~ work activities (HWAs) will be identified. -Quality characteristics

! (attributes) pertinent to the acceptance of work-i within each HWA will be determined and the quality of i

the installed work will be verified -(by sampling) for:

I each attribute.

To establish the HWAs, major. work activities ~are

identified and assigned to civil / structural,

! electrical, and. mechanical discipline engineers. These i discipline engineers then conduct an evaluation of 4

these major work activities by reviewing applicable drawings and specifications; codes and standards; work and inspection procedures; and by identifying the organizations, crafts and inspection groups who conducted the work. ..The work activities are normally l

associated with~ safety,related hardware items. To 4 finalize the HWAs, each one is evaluated to-ensure that j each associated attribute is homogeneous.within the subset of the population to which it applies. For this

~

j.

evaluation, homogeneity is based on similarity.of acceptance criteria, codes and standards, and organizations / crafts / inspection groups. The' grouping l of-hardware items into reasonably homogeneous work i

activities and associated homogeneous attributes provides the basis for. justifying a sampling approach to screen deficiencies, and for gaining information 3

s/ about the quality of the work activity.

i

- _ . _ - _ _ . _ _ __ __ _ _ _ . . ~ _ _ _ . - - . _ ~ . , _ _

Rsvision: 3 P2g2 9 of 17 n )

II. ELEMENTS OF THE PLAN (Cont'd)

A preliminary listing of approximately thirty (30) hardware populations containing the identified homogeneous work activities has been developed and is contained in the Category 2 ISAP (ISAP VII.c). These populations are intended to contain all safety-related construction work activities at CPSES. The final HWAs will be defined after each attribute has been evaluated for homogeneity. A check will be made to ensure that all safety-related plant components,. systems and-structures are addressed by the final HWAs.

Each attribute of each of the HWAs will be reinspected and/or reviewed for samples of the hardware. Two.

separate random samples will be selected from each population in accordance with the guidelines of Appendix D. For each attribute, applicable subsets of the population samples will be identified of a size'to provide a 95/5 statistical screen (per Appendix D) on the HWA attributes *. One sample will be selected from q the entire population of items. The other sample will be selected from a subset of the-population defined as having greater importance to safety. Decisions regarding expanded investigation will be based on'.the identification'of safety-significant hardware deficiencies or the identification of potentially adverse trends of non-safety significant deviations detected in.the initial sample.

The evaluation of hardware included in the selected samples _will be performed primarily through physical reinspections of safety-significant attributes.

Inaccessible or non-recreatable attributes will be assessed and new items selected or documentation i reviews conducted as necessary. The bases for decisions on inaccessibility will be documented for each population and records maintained which identify the hardware items and attributes determined to be inaccessible.

Implementation of the Category 2 ISAP will provide. ,

reasonable' assurance that.there are no undetected and uncorrected safety-significant hardware deficiencies (whether or not related to External Source $ssues), and will provide input to the Collective Evaluations i described below.

, V

• For exceptions where this level'6f statistical screening cannot be attained, the basis for acceptance will be docume*nted and I justified. ]

I i

Rsvicion: 3 Paga 10 of 17

-i APPENDIX B (Cont'd) fv)

II. ELEMENTS OF THE PLAN (Cont'd)

B. Quality of Construction and 0A/0C Adequacy .

l Collective Evaluations

'The results of the ISAP implementation will be the subject of j two Collective Evaluations:

.- A collective evaluation of CPRT. findings, observations and conclusions that relate to the adequacy of the CPSES construction QA/QC program. Potential sources of.

input to this collective evaluation include. CPRT Action l Plan Results Reports.

- A collective evaluation of CPRT findings, observations l and conclusions that relate to the quality of the installed hardware at CPSES. Potential s,ources of input to this collective evaluation include CPRT Action' Plan Results Reports.

Each of the collective evaluations may identify previously

,-s unidentified potential generic.icplications and/or require the

/

') performance of additional hardware reinspections/ document

~~/ reviews.

2 The results of each collective evaluation will be separately reported, and the two collective evaluations form the basis for a Summary Report on the entire QOC. l C. Inter-Relationship of the Elements of the Plan The inter-relationships of the elements of the QOC, including l their inter-relationships with other CPRT Program Plan elements, are summarized in Attachment 4.

D. Relationship to Other CPRT Activities To ensure the effective pursuit of potential root causes, information that may relate to design adequacy that is identified during implementation of this plan is referred to l the DAP RTL, and information that may relate to constru'ction QA/QC that is identified during execution of the DAP is referred to the QA/QC RTL. Hardware inspections, as-built verification programs, and walk-downs conducted under the auspices of either program are coordinated in order to ensure thoroughness and consistency, to-improve. schedule, and to take advantage of other economies.

m e

1 Rsvisions. 3 Pega 11 of 17 l

1 APPENDIX B f- g (Cont'd)

Q II. ELEMENTS OF THE PLAN -(Cont'd)

The DAP RTL will review the selection of safety-significant.

attributes for inspection and will review selected safety significance evaluations of identified construction deviations. Design deviations or deficiencies identified by'

~

the QOC will be transferred .to the DAP for evaluation.

The QA/QC Review Team will review CPRT action plans so that appropriate coordination is achieved and relevant information is exchanged. The QA/QC Review Team will also review t.2 CPRT Action Plan Results Reports to ensure that any potential concerns related to construction QA/QC have been identified.

E. QA/QC Review Team The QA/QC Review Team is the organization established by the CPRT to implement the QOC. Attachment 5 depicts the organizational structure of the QA/QC Review Team. -l-The QA/QC Review Team is headed by the Leader, Mr. John Hansel, who has the responsibility for implementing the QOC,_

' / subject only to the direction of the SRT. Mr. Hansel is assisted by a deputy, Mr. Jon Christensen.

Reporting directly to the RTL are key individuals responsible for administering the technical aspects of the QOC ISAPs,

' performing root cause and generic implications analysis and assisting in the 00C Collective Evaluations. Inspectors performing the hardware reinspections are organized into the three principle disciplines (mechanical, electrical / instrumentation and civil / structural), each of which is led by a Level III inspector. All inspectors are qualified as Level II or Level III in accordance with ANSI N45.2.6 and Regulatory Guide 1.58.

The evaluation of hardware deviations for safety significance will be performed by the Safety Significance Evaluation Group, which is comprised of third-party engineers from Stone 6 ktsster. In some cases, safety significance evaluations will be performed by other CPRT Review Teams.

! Each QOC ISAP identifies an Issue Coordinator charged with the responsibility for implementing the ISAP and for maintaining the required interface with other Issue Coordinators and RTLs.

All QA/QC Review Team staff are third-party personnel who have I ) satisfied the CPRT criteria for objectivity, i \s /

Ravision: 3 Pags 12 of 17 APPENDIX B 1

() (Cont'd)

III. END PRODUCTS The implementation of QOC will resul't in the following end l products:

- Individual Action Plan Results Reports for Category 1 and Category 2 ISAPs.

- A. Collective Evaluation Report related to the adequacy of the CPSES construction QA/QC program, including the identification

]- of any necessary improvements related to. future.CPSES construction activities and to CPSES plant operations.

- A Collective Evaluation Report related to the quality of the installed hardware at CPSES, including the identification of i'

. corrective actions necessary to resolve any identified safety-significant hardware discrepancies.

- A Summary Report that integrates the results of the two

. . Collective Evaluation Reports and sets forth the CPRT.

conclusions related'to the objectives of the QOC. l

< O i

4 i

i.

I

. . . . _ . _ . - . _ , . . . - .- _, - m ., . ~ . . . , . .

Rzvision: 3 Paga 13 of'17 APPENDIX B

(

(Cont'd)

LIST OF CATEGORY I AND II ISSUE-SPECIFIC ACTION PLANS i

ATTACHMENT 1 i

t I. Category I - ISAPs Related to Issue Identified by External Sources A. QA/QC Programmatic Issue-Specific Action Plans I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Tests I.d.3 Craft Personnel Training l 4

VII.a.1 Material Traceability VII.a.2 Non-conformance and Corrective Action Systems i VII.a.3 Document Control VII.a.4 Audit Program and Auditor Qualification i VII.a.5 Periodic Review of QA Program VII.a.6 Exit Interviews VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation B. 0A/QC Hardware Related Issue-Specific Action Plans.

VII.b.1 Onsite Fabrication VII.b.2 Valve Disassembly VII,b.3 Pipe Support Inspections VII.b.4 Hilti Anchor Bolt Installation

! VII.b.5 (Deleted) j II.- Category II - ISAPs Related to Self Initiated Reinspection /

• Documentation Review Program VII.c Construction Reinspection / Documentation Review Plan 1

4 v v , y- . - , , - - - - - -- ,,e , ,

Rsvision: 3 i Page 14 of 17 APPENDIX B O. (Cont'd) i l

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l ATTACHMENT 5 REV. I QA/QC REVIEW TEAM ORGANIZATION QA/QC REVIEW TEAM LEADER J. L. H ANSEL i-TRAINING PROCEDURES &

AND QUALITY ASSURANCE CERTIFICATION SUPERVISOR '

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ENGINEERING n5 INSPECTION RECORDS EXTERNAL SOURCE dE DEPUTY PROGRAM MANAGER SUPERVISOR MANAGEMENT ISSUES DEPUTY "w C. SPINKS ~

J.L. HANSEL ( ACTG.) C.M. THOMPSON J.D. CHRISTENSEN I i l l l l l l 1 1 CONSTRUCTION SAFETY , SIGNIFICANCE PROGRAMATIC HARDWARE COLLECTIVE EVALUATION EVALUATION ISSUES ISSUES EVALUATION ENGINEERING S UPERVISOR - SUPERVISOR SUPERVISOR SUPERVISOR A. PATTERSON J. ADAMS R B. ORTSTADT M. OBERT J. JONES i .

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Page 1 of 4 4

4 APPENDIX C

\ ACTION PLANS l

TABLE OF CONTENTS I

l i

ACTION PLAN TITLE i

! Electrical ISAPs

! I.a.1 Heat-Shrinkable Cable Insulation Sleeves i

Inspection Reports on Butt-Splices I.a.2 I.a.3 Butt-Splice Qualification 4

I.a.4 Agreement Between Drawings and Field i Terminations

~

I.a.5 -

NCRs on Vendor Installed Amp Terminal Lugs I.b.1 Flexible Conduit to Flexible Conduit i Separation I.b.2 Flexible Conduit to Cable Separation I.b.3 Conduit to Cable Tray Separation-j I.b.4 Barrier Removal Civil / Structural ISAPs '

I.c Electrical Conduit Supports II.a Reinforcing Steel in the Reactor Cavity i

! II.b Concrete Compression Strength l II.c' Maintenance of Air Gap Between Concrete Structures.

II.d Seismic Design of Control Room Ceiling Elements II.e Rebar in the Fuel Handling Building i

!O 1

l l

1

P gs 2 of 4 APPENDIX C ACTION PLANS TABLE OF CONTENTS (Continued)

ACTION PLAN TITLE Testing ISAPs III.a.1 Hot Functional Testing (HFT) Data Packages III.a.2 JTG Approval of Test Data III.a.3 Technical Specification For Deferred Tests III.a.4 Traceability of Test Equipment III.b Conduct of the CILRT III.c Prerequisite Testing III.d Preoperational Testing IV. Reserved for Protective Coatings, however, SSER-9 declassified protective coatings and O negated the need for a protective coatings ISAP. Paint quality concerns are being ,

addressed'under the Quality of Construction Program.

Mechanical ISAPs V.a Inspection for Certain Types of Skewed Welds in NF Supports i

V.b Improper Shortening of Anchor Bolts in Steam '

Generator Upper Lateral Supports V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic l Category 1 Buildings l I'

j V.d Plug Welds V.e Installation of Main Steam Pipes j

VI,a Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall l VI.b Polar Crane Shiciming l

, - - - . - , . -ev,

l Pag 1s 3 of 4 l

4 APPENDIX C ACTION PLANS TABLE OF CONTENTS l (Continued) j.

. ACTION PLAN TITLE i

QA/0C ISAPs

] I.d.1 QC Inspector Qualifications

! _ I.d.2 Guidelines for Administration of QC Inspector i Test 1 I.d.3 Craft Personnel Training I

VII.a.1 Material Traceability

VII.a.2 Non-Conformance and Corrective Action System VII.a.3 Document Control VII.a.4 Audit Program'and Auditor Qualification VII.a.5 Periodic Review of QA Program 4

VII.a.6 Exit Interviews VII.a.7' Housekeeping and System Cleanlinese l VII.a.8 Fuel Pool Liner Documentation VII b.1 On-Site Fabrication j VII.b.2 Valve Disassembly VII.b.3 Pipe Support Inspections

) VII.b.4 Hilti Anchor Bolt Installation VII.b.5 DELETED VII.c Construction Reinspection / Documentation i Review Plan i

1 i ,

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. _ . _ _ . . .. _ ~ _ - - _ . _ _ . . _ _ . - _ . . . _ . _ . . _ _ . _ . _ _ _ . _.

Pcgm 4.of 4 1

APPENDIX C f g

ACTION PLANS l

TABLE OF CONTENTS i

(Continued)

ACTION PLAN TITLE DSAPs

~

VIII Civil / Structural Discipline Specific Action l'

Plan i

) IX Piping and Supports Discipline Specific j Action Plan 1

3

{ X. Mechanical Systems and Components Discipline Specific Action Plan.

t l XI Electrical /I&C Systems and Components i Discipline Specific Action Plan I

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Electrical ISAPs I.a.1 Heat-Shrinkable Cable Insulation Sleeves i

l I.a.2 Inspection Reports on Butt-Splices I.a.3 Butt-Splice Qualification l

I.a.4 Agreement Between Drawings and Field Terminations

. I.a.5 NCRs on Vendor Installed Amp Terminal Lugs i

I i I.b.1 Flexible Conduit to Flexible Conduit i

Separation

! I.b.2 Flexible Conduit to Cable Separation I.b.3 Conduit to Cable Tray Separation

I.b.4 Barrier Removal i

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ACTION PLAN i

li ISAP I a.1 j

Title:

Heat-Shrinkable Cable Insulation Sleeves l-4 i

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k Revision No. 4 Reflects Coments Description On Plan I Prepared and Recomended by:

Review Team Leader Date $b i

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j Approved by:

Senior Review Team (k&).

Date I HlV6 I

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R5vicient 4 Pcg2 1 of 7 3AP I.a.1 Heat-Shrinkable Cable Insulation Sleeves

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797,-Supp1e' ment Number 7, Page J-29)

"...the lack of awareness of where the heat-shrinkable sleeves should be installed, as reflected in the QC inspection form, when the high percentage of missed and/or improperly documented

! inspections requiring witnessing, indicated that craft and inspection personnel lacked familiarity with these procedural requirements. This apparent lack of familiarity may be indicative of poor training."

4 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item

6. (d)(1), Page J-31) i "TUEC shall accomplish the following actions prior to fuel load:

Provide additional QC inspector training with respect to the areac in which nuclear heat-shrinkable sleeves are required on splices and ensure that (1) such sleeves are installed where required. . ."

3.0 BACKGROUND

I Heat-shrinkable insulation sleeves are required for the following:

- Uninsulated butt-splices Class 1E 480 V and 6.9Kv motor terminations

- Cable reduction splices (Drawing 2323-El-1701 Detail

13) .

- Electrical penetration assembly cable connections (Drawing 2323-El-1702 Detail 32)

The requirements for these installations and additional engineering considerations are appended to the construction ,

procedure.

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? Peg 2 2 of 7 ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The plan consists of two basic parts. The objective of Part 1 is to clarify procedural requirements and provide additional training to TUGC0 Craft and QC inspectors with respect to the insta11acions for which nuclear heat-shrinkable sleeves are required.

The objective of Part 2 is to provide reasonable assurance that nuclear heat-shrinkable sleeves are installed where required. This will be accomplished via a secapling program, which is designed in accordance with Appendix D of the Program P.1.an.

4.1.1 Part 1 - Procedure Revision and Additional Training ,

The following subtasks will be implemented in order to clarify the requirements as to where installation of nuclear heat-shrinkable sleeves is required:

- Revise construction installation procedure t EEI-8, " Class IE and non-Class 1E Cable Terminations" to clearly identify

' installation requirements for nuclear heat-shrinkable sleeves including hold points for g process control.

- Revise inspection procedure QI-QP-11.3-28,

" Class 1E Cable Terminations" to clearly

identify locations where nuclear heat ,

shrinkable sleeves are required.

Revise inspection forms co ensure that applications involving nuclear heat-shrinkable sleeves can be properly documented.

The following subtasks will be implemented in order to provide additional TUGC0 Craft.and QC inspector training:

- Train craft personnel to the revised procedures.

! - Train and certify inspectors to the revised procedures in accordance with CP-QP-2.1,

• • O " Training and Certification of Inspection Personnel".

I R;vicient 4 i P:g2 3 of 7 l l

ISAP I.a.1 l

/ (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Part 2 - Sampling, Records Review and Inspection A records review vill be initiated to provide reasonable assurance that programmatic deficiencies did not occur to preclude the installation of nuclear heat-shrinkable sleeves where required. A sample of records from the population of inspection reports corresponding to all locations where heat-shrinkable sleeves are required will be selected in accordance with the guidelines of Appendix D and reviewed. A sample review is considered to be a reasonable approach for the following reasons:

- No programmatic deficiencies have been identified in this population to date.

The population of locationa where heat-shrinkable insulation. sleeves are required is homogeneous. Specifically, each member simply consists of a location where a heat-shrinkable sleeve is required and the process s by which sleeves are specified to be installed is the same for all required locations.

4 4.1.2.1 Identification of Required Sleeves i

l The first step in this records review will be to identify the population of all locations where nuclear heat-shrinkable sleeves are required. Nuclear heat-shrinkable sleeves are installed on electrical penetration assembly pigtails, motor leads, electrical devices with pigtails and cable reduction l splices (splices from one size cable to a smaller one in order to facilitace termination). The population of required installations which has been identified is 1359.

4.1.2.2 Random Sampling The sampling plan will be designed to provide a 95/5 acreen in accordance with the guidelines of Appendix D, and will result in reasonable assurance that programmatic

\ deficiencies'do not exist in the population.

Ravicien: 4 i Pcg2 4 of 7 i

ISAP 1.a.1 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) )

The sample size, which will be used in  ;

accordance with Appendix D. is 60, with a )

rejection number of zero (i.e., the tritical region is one or more deficiencies found in the sample). The sample items will be reviewed to ensure that systems which are important to safety are represented. If not, additional samples from such systems will be selected.

If any inspection record does not reflect the installation of a heat-shrinkable sleeve, the hardware will be visually inspected. If the heat-shrinkable sleeve was not installed because it was not required, this member of the sample population will be discarded and replaced by the member determined by the next random number. If the heat-shrinkable cleeve was installed but the inspection report does not meet the acceptance criteria of Section

, s 4.5, this will constitute a defective sample.

11 the heat-shrinkable sleeve was required l but not installed, this will be counted as a defective sample and the sleeve'will be properly installed.

1

• If one (1) deIJciency is found, a root cause evaluation of the deficiency will be s

performed, and a sample expansion per Appendix D will be initiated.

If the number of deficiencies discovered in the original sample is two or more, or a potential root cause is identified as programmatic, a 100% record review of the pJpulation will be performed.

4.1. 'a Cable Reduction Splices Cable reduction splices are used as needed to facilitate termination and, as such, do not have specific quantities and locations identified on project drawings. . There are twelve (12) known cable reduction splices and thus 12 such locations requiring nuclear l heat-shrinkable sleeves are included in the population l identified to date.

R;viciont 4 P:gs 5 of 7 ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

In order to ensure that.all possible locations for aable reduction splices are considered, an additional seven (7) cables and twenty-six (26) pieces of l l

equipment containing cable configurations possibly requiring reduction splices will bc visually inspected ,

to confirm that reduction splices were not used in the l termination. These are all of the items for which it may have been necessary to reduce the size of the cable j

to facilitate termination. Upon identification of any splice in these cables or pieces of equipment, the inspection reports will be reviewed to verify the reports document that the sleeves were installed.

4.1.4 Use of Results l

If discrepancies are found, Non-conformance Reports will be issued to document the finding and initiate corrective action. Results of the actions under this Plan will be evaluated to establish root causes and to

! identify appropriate corrective action.

4.2 Participants Roles and Responsibilities I i

The organizations and personnel that will participate in this effort are described below with their respective work scope.

4.2.1 TUCCO Comanche Peak Project 5 4.2.1.1 Revise inspection and construction procedures. Retrain craft and inspection I personnel.

4.2.1.2 Review drawings, schematics and interconnection diagrams to identify locations where nuclear heat-shrinkable sleeves are required.

4.2.1.3 Process NCRs that may be generated due to this action plan.

4.2.1.4 Personnel dr. W. I.'Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Provide the CPRT QA/QC Review Team with a

!. Sampling Plan.

I

Rsvision: 4 \

Peg 2 6 of 7, f,

ISAP I.a.1 (Cont'd)

J 4.0 CPRT ACTION PLAN (Cont'd) .

4.2.2.2 Review the revised inspection and construction procedures to verify that the installation requirements for heat-shrinkable sleeves are clearly identified.

4.2.2.3 Review the inspection reports and NCRs, if any.

4.2.2.4 Determine root cause, generic implications and safety significance.

4.2.2.5 Personnel (prior to October 18, 1985)~

Mr. M. B. Jones, Jr., Review Team Leader i

Mr. E. P. Stroupe, Iccoe Coordinator 4.2.2.6 Personnel (starting October 18, 1985)

Mr. J. J. Ma11anda, Review Team Leader

~

Mr. J. R. Pearson, Issue Coordinator i

Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser -

4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Select samples to be reviewed.

i 4.2.3.2 Review inspection reports for compliance with the acceptance criteria. ,

4.2.3.3 " Conduct physical inspections, in cases where the inspection report does not indicate that a project inspection was performed.

l 4.2.3.4 Personnel

- Mr. J. L, Hansel, Review Team Leader - QA/QC I

4.3 Qualification of Personnel l

Where tests or inspections require tie use of certified T

inspectors, qualification at the appropriate level will be to

, ,/ the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear l

R: vision 4 l Pcg3 7 of 7 f 1

C nt d) 4.0 CPRT ACTION PLAN (Cont'd)

Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.

I Third-party participants in the implementation of this action plan will meet the p rsonnel qualification and objectivity

. requirements of ths CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable prificiples of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

! 4.4 Procedures 4.4.1 Instruction No. QI-003, " Procedure for Class 1E Heat- l Shrinkable Cable Insulation Sleeves - CPRT Action Item O I.a.1".

4.5 Acceptance Criteria l 4.5.1 The acceptance criterion for the inspection reports l review is that the inspection reports contain documented evidence that the sleeves have been installed.

i 4.5.2 The acceptance criterion for any required physical l inspection is that the nuclear heat-shrinkable sleeve be installed where required. n physical inspection is required if the criterion in 4.5.1 is not met.

4.6 Decision Criteria 4.6.1 If the inspection report review does not contain j evidence that the nuclear heat-shrinkable sleeve was installed, a physical inspection will be made to determine if the material was both required and l

installed.

4.6.2 If the number of deficiencies found in the sample of.60 is one (1), the sample size will be increased as O

V required by Appendix D.

4.6.3 If the number of deficiencies found in the original sample of 60 is two (2) or more, a 100% records review will be performed.

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.a.2

Title:

Inspectior. Reports on Butt-Splices Revision No. 4 Reflects Comments Description On Plan O Prepared and Reconsended by:

Review Team Leader '

Date l b I

l l

Approved by:

Senior Review Team ('kd h. . ;

Date r l3-+lfs l

O

R vicien: 4 Pcg3 1 of 7 ISAP I.a.2 Inspection Reports on Butt-Splices l l

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7. Page J-29)

"...the TRT reviewed the QC Inspection Reports for 12 butt-splices and found the following:

- Nine of these splices were documented ol the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure.

- Six of the nine incorrect forms containe'd handwritten notes by the inspector indicating that he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.

- The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.

- For three splices which were documented on the correct forms, the forms all contained an "N/A" (not applicable)' handwritten by the inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed."

2.0 ACTION IDENTIFIED BY NRC '(NUREG 0797, Supplement Number 7, Item 6.(d)(2) and (3), Page J-31)

"TUEC shall accomplish the following actions prior to fuel load:

... ensure that ...(2) all QC inspections requiring witnessing for splices have been performed and properly documented, and (3) all butt splices are properly identified on the appropriate design drawings and are physically identified within the appropriate panels."

3.0 BACKGROUND

The practice of butt-splicing cables in panels was allowed on l a limited basis, as specified in Section 8.1.5.2.4 of Amendment 44 to the Final Safety Analysis Report. The butt-splice that is utilized is the AMP Preinsulated Environmental Sealed Splice. Since this splice connector is preinsulated, ON an additional heat-shrinkable sleeve is not required.to be added when used in a mild environment.

Rsvisiont 4 Pag 2 2 of 7 ISAP I.a.2

() (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The. objectives of this action plan are to assure that butt-splices are properly identified on the appropriate design drawings, are physically installed where required, and that required inspections have been performed and properly

' documented.

N The scope of this action plan includes all butt-spliced Class 1E essential and associated cables which are spliced with the AMP insulated butt-splice connectors. This action plan is divided into three sequential phases.

4.1.1 Phase I Phase I consisted of a review of an in-process, post-installation and final Inspection Reports for the twelve (12) cables reviewed by the TRT. This review is to determine if required documentation for splice witnessing existed and is acceptable.

Preliminary review of the butt-splice documentation by TUGC0 substantiated the NRC concerns, and thus initiated Phase II..

4.1.2 Phase II Phase II will consist of the following items:

- Review all drawings and design change documents involving butt-splices of safety

.related cables in the control room and cable r

spreading room of Unit 1 to assure that the <

splices are documented _in the design l(

l document. j l

l l

l 1

Ravicient 4 Pcg3 3 of 7 ISAP I.a.2 (Cont'd)

(

4.0 CPRT ACTION PLAN (Cont'd) i

- Inspect all these cables to ensure that the drawings correctly reflect the as-built l condition, that the splices meet the FSAR and installation requirements, and that the )

requirements of the SER are met. This i inspection'will include a documentation l review of these spliced cables' inspection reports to ensure that the splices were inspected and found to be acceptable per Quality Inspection Procedure, QI-QP-11.3-28,.

" Class 1E Terminations". If the drawing does

' not reflect the as-built condition of the cable, the drawing will be revised to show the actual hardware configuration.

- Butt-splices which are rejected during the evaluation of these inspections will be replaced. The removed splices will be pullout tested to determine the acceptability of butt-splices where certain attributes cannot be determined (e.g. the depth of O conductor penetration or if use of the proper crimp tool is indeterminant). The test will be conducted in accordance.with U.L. Standard 486C, Section 13, Pullout Tests. Prior to the test the splices will be radiographed to determine the depth of insertion.

- To be reasonably sure that no undocumented-butt-splices exist, the population of Class 1E cabinets' in the control room and cable spreading room where butt-splices are not supposed to exist will be inspected on a sample basis to confirm that no splices are present. These inspections will be as thorough as. allowable without separating wire bundles or dismantling equipment. The plan will use a sampling approach which is designed to provide a 95/5 screen in accordance with Appendix D.

Phase II will also accomplish part of Action Plan I.a.3 by inspecting for splices located adjacent to and pressing against each other in the same wire bundle.

/ .If more.than one butt-splice.is found which is not

\ properly installed (i.e., not fully inserted, incorrect i tool used, wires curled back or incorrect insulated splice used) Phase III will be initiated by TUGCO.- l

R:visien: 4 Pcg2 4 of 7 ISAP I.a.2 O

b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Phase III l Phase III will be the identification and inspection of all other essential circuits where AMP insulated butt-splices may have been used for equipment terminations (i.e. pi'gtails on solenoids, electrical devices, etc.) or splicing of cables in both Units 1 and 2 which were not inspected in Phase II. Non-conformance Reports will be issued to identify and initiate inspection'of the balance of these essential cables that could have butt-splices installed. The.

writing and processing of these NCRs will be done by TUGCO. In the event that Phase I~.I is initiated, the CPRT will overview this activity.

4.1.4 Use of Results Results of the actions under this plan will be evaluated to establish root causes and to identify appropriate corrective action.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope.

4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Review drawings and design changes.

4.2.1.2 Assist the Review Team Leader in identifying cables to be inspected for butt-splices.-

4.2.1.3 Process NCRs that may be generated due to this action plan.

4.2.1.4 Assist the Review Team Leader in devising pullout test methodology.

4.2.1.5 Prepare pullout test procedure.

l 4.2.1.6 Personnel Mr. W. I. Vogelsang, TdGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review inspection reports and NCRs, if any.

Rsvisien: 4 Peg 2 5 of 7 ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)'

4.2.2.2 Review and approve the pullout test procedure.

4.2.2.3 Review and evaluate the pullout test results.

Approve the test report. Determine any on-going corrective actions.

4.2.2.4 If Phase III is initiated, overview the TUGC0 identification and inspection effort described in 4.1.3.

4.2.2.5 Determine root cause, generic implications and safety significance.  !

4.2.2.6 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.7 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Prepare the inspection procedure.

j 4.2.3.2 Inspect butt-splices for compliance with acceptance criteria.

4.2.3.3 Perform overview inspection (see Section 4.2.2.4) as determined by the Electrical Review Team Leader.

4.2.3.4 Personnel l ,

Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Advisers l 4.2.4.1 Review pullout test procedure.

i I

I

Rsvision: 4 Psg2 6 of 7 ISAP I.a.2 (Cont'd)

\

4.0 CPRT ACTION PLAN (Cont'd) 4.2.4.2 Supervise pullout test.

4.2.4.3 Personnel Mr. L. D. Bates, Electrical Engineering Aaviser 4.3 Qualification of Personnel Where tests or in'.pections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear l Power Plants". CPRT third-party inspectors will be. certified to the requirements of the third-party employer's Quality Assurance Program, and specifically. trained to the CPRT Program Plan.

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing O procedures.

Other participants will be qualified to the requirements of

~

the CPSES Quality Assurance Program or to the specific requirements of CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures 4.4.1 Instructions QI-002, "CPRT Action-Item I.a.2, j Inspection on Butt-Splices and CPRT Action Item I a.3, Butt-Splice Qualifications".

4.4.2 I.a.2/I.a.3-001, " Butt-Splice Pullout Test Procedure".

4.5 Acceptance Criteria 4.5.1 The acceptance criteria for the butt-splice. inspection are that the inspection attributes given in Section 4.2 of CPRT Quality Instruction, CPRT Action Items I.a.2 and I.a.3, Instruction No. QI-002, Revision 4 be met.

4.5.2 The acceptance criterion for the drawings is that they f-~s

( reflect the as-built condition of butt-splices in Class 1E essential and associated cable. l 1

l I

l l l

R vision 4 Pags 7 of 7 l- ISAP I.a.2 (Cont'd)

O 4.0 CPRT ACTION PLAN (Cont'd) l 4.5.3 'The acceptance criteria for the pullout tests will be l l specified in the test procedure.

4.5.4 The acceptance criterion for the review of an inspection report is that-the report indicates that the splice,was witnessed. Non-conformance Reports will be  !

issued for any inspection reports which do not meet this criterion. l 4.6 Decision Criteria 1

4.6.1 Failure of one butt-splice in Phase II to meet the l acceptance criteria of 4.5.1, 4.5.2, or 4.5.4 will initiate Phase III, which will be performed by TUGCO.

4.6.2 Finding any butt-splice in Phase II in the cabinets which are not supposed to contain butt-splices will require sample expansion and/or 100% inspection in accordance with Appendix D.

O f

O

COMANCHE PEAK RESPONSE TEAM N

(h ACTION PLAN ISAP I.a.3

Title:

Butt-Splice Qualification Revision No. 4 Reflects Comments Description On Plan Prepared and Recommended by: [,h/A-Review Team p Leader Date b l Approved by:

Senior Review Team OLy. k,,/ _ -

. 7 Date i 2 4 f ff.

,O

Rsvisions. 4 Pags 1 of 6 ISAP I a.3 Butt-Splice Qualification

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG 0798, Supplement Number 7, Page J-28)

"The practice of butt-splicing cables in panels was allowed on a limited basis, as specified in Section 8.1.5.2.4 of Amendmen't 44 to the Final Safety Analysis Report (FSAR). The NRC staff reviewed Texas Utilities Electric Company's (TUEC's) justification for permitting butt-splices inside panels (correspondence from M.

Srinivasan, NRC Power Systems Branch to B. J. Youngblood, NRC Licensing Branch, July 30, 1984), and concluded that the practice is acceptable on a limited basis, subject to the following conditions:

- That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used,

- That the wire splices used are qualified for anticipated service conditions, and

- That splices are staggered within the panel so that they are

( not adjacent to each other in the same wire bundle and pressing against one another."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7, Item

6. (b), Page J-31)

"TUEC shall accomplish the following actions prior to fuel load:

Develop adequate installation and inspection procedures to reinspect all existing butt-splices to ensure (1) tt 2 operability of those circuits which contain butt-splices in panels, (2) that the wire splicing materials and methods used are qualified for  !

anticipated service conditions, and (3) that splices are staggered within the panel.so that they are not adjacent to each other in the l same bundle."

i I

3.0 BACKGROUND

l l

In order to address the issues identified by the NRC, the following should be considered:

N - During plant preoperational and startup testing all electrical circuits are required to be tested and~ '

retested, if reworked, in accordance with-Startup 4

Rsvizion: 4 Pag:n 2 of 6 ISAP I.a.3' (Cont'd)

(ah

3.0 BACKGROUND

(Cont'd)

Administrative Procedures (SAP)-6 " Control of Work on Station Components After Release From Construction to TUGC0"; SAP-22 " Retest Control"; and XCP-EE8 " Control Circuit Functional Testing". These tests provide the necessary verification that the spliced circuits are functional.

- FSAR amendment 44 was issued to encompass the use of butt-splices in panels. The NRC's "The Safety Evaluation Of Field Splices Inside Control Panels",

dated. September 14, 1984, sets forth the NRC guidance that splices be staggered in panels. .This additional guidance from the NRC will be used in the implementation of this action plan.

O .

4.0 CPRT ACTION PLAN 4.1 Scope And Methodology The objectives of this action-plan are to develop adequate procedures to assure that continuity checks are made on all circuits in which. splices are placed,-and that splices are staggered or separated to comply with the additional NRC guidance.

The objectives of this action plan also include the review of the qualification of the AMP Pre-Insulated Environmental Seal Splice to assure it is qualified for its expected service condition.

The following tasks will be implemented to achieve the above

~

objectives:

Procedural revisions

- Additional craft and inspector training

- Inspection of cable bundles for touching splices Review of qualification data l

l

Rsvicion 4 Pags 3 of 6 ISAP I.a.3 (Cont'd)

(

4.0 CPRT ACTION PLAN (Cont'd) 4.1.1 Procedure Revisions The following. specific subtasks will be completed:

- Revise Construction procedure EEI-8, " Class IE and non-Class 1E Cable Terminations" to require a continuity check of all circuits in which splices are placed and to require that splices are staggered or separated to comply with the additional NRC guidance.

- Inspection procedure QI-QP-11.3-28, " Class 1E Terminations" to add the attributes necessary.

to ensure that continuity checks are made and that splices are staggered or separated.

4.1.2 Craft and Inspector Training The following subtasks will be implemented:

- Train craft personnel using the revised O' procedures.

- Train and certify inspectccs.

4.1.3 Inspections In accordance with the requirements of Action Plan I.a.2 cable bundles containing splices will be inspected to ensure that no splice in a bundle is adjacent to and pressing upon another splice.

Corrections to the configuration of the bundles will be made where splices are found to be adjacent to and pressing upon one another.

4.1.4 Qualification Data A qualification data package, based on vendor documentation and site specific requirements, will be developed for'the butt-splices. A third-party l engineering review of the qualification data package will be conducted. If it is determined that the AMP insulated butt-splices are not qualified for the Comanche Peak service conditions the butt-splices will be replaced with qualified butt-splices.

O t- / l l

r

R; visions. 4 Pags 4 of 6 i

ISAP 1.a.3

/~'} (Cont'd)

(m / l i

E 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 Use of Results l Results of the' actions under this plan will be evaluated to establish root causes and to identify appropriate corrective action. g 4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in-this effort are described below with their respective work scope.

4.2.1 TUGCO Comanche Peak Project 4.2.1.1 Revise construction and inspection procedures. Retrain craft and inspection personnel.

4.2.1.2 Ptocess NCRs that may be generated due to this action plan.

l 4.2.1.3 Prepare qualification data package.

4.2.1.4 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator I

4.2.2 Electrical Review Team I

4.2.2.1 Review the revised inspection and construction procedures to assure _that the requirements for a continuity check and i ' staggered splices are included.

! 4.2.'2.2 Review of training documentation to ensure that adequate retraining of craft and inspection personnel was performed.

4.2.2.3 Review the NCRs and Inspection Reports, if any.

i 4.2.2.4 Determine root cause, generic implications and safety significance.

4.2.2.5 Personnel (pr'ior to October 18. 1985)

Mr. M. B. Jones, Jr... Review Team Leader-Mr. E.- P. Stroupe, Issue Coordinator

Rsvision: 4 Paga 5 of 6 ISAP I.a.3

/G (Cont'd)

(_)

4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.6 . Personnel (starting October 18, 1985)

Mr. J. J. Mallanda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CERT - QA/QC Review Team 4.2.3.1 Inspect cables containing butt-splices for compliance with acceptance criteria.

4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Adviser 4.2.4.1 Review the qualification data package to ensure that the splices are qualified for the Comanche Peak service conditions.

4.2.4.2 Personnel Mr. L. D. Bates, Electrical Engineering Adviser 4.3 Qualification of Personnel

-Where tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel for Nuclear l Power Plants". CPRT third-party inspectors-will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the CPRT Program Plan.

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedu-es.

Rsvision: 4 P ga 6 of 6 ISAP I.a.3

- [] (Cont'd) k.)

4.0 CPRT ACTION PLAN (Cont'd)

Other participants will be qualified to the requirements of the CPSES Quality Assurance' Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures Instruction QI-002, "CPRT Action Item I.a.2, Inspection Reports on Butt-Splices and Item I.a.3, Butt-Splice Qualifications".

4.5 Acceptance Criteria 4.5.1 The acceptance criterion for butt-splice stagger in cable bundles is that splices are either staggrrtred or separated so that they do not touch'one another.

4.5.2 The acceptance criteria for the qualification data package are that it provides justification for the use O of butt-splices.for their specified service conditions and meets the revised TUGC0 procedural requirements and l

the applicable IEEE standards for equipment qualification. Third-party engineering review and' l concurrence is required.

4.5.3 The applicable IEEE Standards are: 323-1974, J83-1974 and 344-1975.

4.6 Decision Criteria

! 4.6' 1 If-any cable bundles have splices which are not staggered or ceparated, the bundle _ configurations will be corrected.

4.6.2 If it is determined that the splica2 are not qualified for_their service conditions, they will be replaced with qualified splices.-

O

COMANCHE PEAK RESPONSE TEAM 7s h ACTION PLAN ISAP I.a.4

Title:

Agreement Between Drawings and Field Terminations Revision No. 4 Reflects Comments Description On Plan Prepared and Recommended by: J. ' ,

Review Team []

Leader Date ~

Approved by:

Senior Review Team (hd,b1 Date I 5

'w)

Rsvisiont 4 Pags 1 of 8 i

ISAP I.a.4

' Agreement Between Drawings and Field Terminations

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-29)

"...the TRT selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to drawing requirements. This inspection revealed that six cables (five of which are safety-related) were not terminated in accordance with current drawings. These six cables are:

- E0139880 in panel CP1-ECPRC3-14*

- E0110040 in panel CP1-ECPRTC-16,

- 'E0118262 in panel CP1-ECPRTC-16,

- NK139853 in panel CP1-ECPRCB-02 (non-safety),

- EG104796 in panel CP1-ECPRTC-27, and

- EG021856 in panel CPX-ECPRCV-01."

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item Number 6 (c), Page J-31)

"TUEC shall accomplish the following actions prior to fuel load:

Reinspect all safety-related and associated terminations in the control room and in the termination cabinets in the cable spreading room to verify that their locations are in accordance with all current de-ign documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak Steam Electric Station (CPSES)."

3.0 BACKGROUND

The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUGC0 l Engineering. The engineering review has considered design changes and temporary modifications authorized prior to the TRT identification.

i j

• The TRT notified TUEC that the panel identified as CP1-ECPRCB-14

\ should be CP1-ECPRCB-04.

Rsvicion: 4 Paga 2 of 8 1

ISAP I.a.4 f'

N (Cont'd)

3.0 BACKGROUND

(Cont'd)

The results of this review are as follows:

One cable (E0139880) was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the conductor termination details. This drawing was corrected, and other similar drawings were checked to ensure that this condition does not exist elsewhere.

One cable (E0110040) was found to be properly connected in accordance with the document revision in effect at the time the termination was made. However, a subsequent drawing revision changed the color code of the conductor for no apparent reason. This drawing error was detected and corrected prior to the September 18, 1984, letter from the NRC to TUGCO.

One cable ~(E0118262) contained a drafting error at the time of the TRT inspection, (two green conductors shown). The cable was functionally correct as landed. The drawing error has been corrected.

D)

(, One cable (EG104796), a two conductor cable, was found to have wires interchanged on the terminal points. This connection has no polarity requirement. Thus, the interchange of wires had no affect on the operability of the circuit. The physical terminations have been corrected to match the drawing.

One cable (EG021856) was found t'o be a designated " spare" per a properly issued design change document (DCA 19948, Rev'ision 1). However, the interconnection drawing for one end of the cable still showed the cable to be terminated which indicates that the review and drawing update cycle was incomplete.at that time. The cable has been deleted from the current revision of the interconnection drawing.

One cable (NK139853), a non-safety cable, the orange and yellow / orange pair of conductors had been designated as spare,

~

but left terminated. However, the vendor-side conductors had been removed from the terminal blocks. The subject conductors have also been removed from the terminal blocks. l In summary, E0139880 Drawing error - correctly terminated l E0110040 Drawing error * - correctly terminated j i

E0118262 Drawing error - correctly terminated

• Corrected prior to September 18, 1984.

l Rsvision: 4 Pag 2 3 of 8 J ISAP I.a.4 (Cont'd) d("'N 3.0 3ACKGROUND (Cont'd)

EG104796 Interchanged conductors - functionally correct EG021856 Incomplete Design Change Authorization -

cable not required NK139853 (non-safety) spare conductors terminated'-

functionally correct.

In the course of normal practices, aftqg construction has been completed and the equipment is in the startup cycle, a wiring check is done per Prerequisite Test Instruction XCP-EE-8. Any design changes required as a result of this testing are controlled and requested in accordance with the Startup Procedure for Design Requests (CP-SAP-14). Additionally, the change may be implemented as a temporary modification which is controlled by CP-SAP-13, Startup Procedure For Temporary Modifications.

O 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to assure that the safety-related and associated cable terminations in the control room and cable spreading room are in accordance.with current design documents. I 1

The following task will be implemented to achieve this objective:

Inspection of terminations 4.1.1 Inspection Program I

An inspection program employing random sampling will be

~

initiated which will enable a determination to be made

/ with reasonable assurance of whether the essential l (,,T) Class 1E conductors in the control room and cable spreading room which interface with the Alternate Shutdown Panel are terminated in accordance with the applicable drawings.

Rsvision: 4 Paga 4 of 8 I

ISAP I.a.4 (Cont'd) b['V

.4.0 CPRT ACTION PLAN (Cont'd)

A sample inspection is considered to be a reasonable approach for the following reasons:

1) No programmatic deficiencies have been identified in this population to date.

2) The population is homogeneous with respect to

- the attribute of agreement with drawings.

4.1.1.1 Population Identification The first step in the sampling program will be to identify the population of all essential Class 1E terminations in the control room and cable spreading room that are in circuits which interface with the

' Alternate Shutdown Panel in Unit 1. This population of " safe shutdown" terminations will be taken from over 14,000 Class 1E terminations in these two rooms.

The " safe shutdown" terminations have been chosen as a sub-group of the population of all Class 1E terminations due to their crucial role in plant safety. Since there are no product or process _ differences between this sub-group and the remainder of the Class 1E terminations, this approach will allow for an investigation, which focuses on safety, while still attaining an engineering i ' assessment of the quality of the larger population.

4.1.1.2 Random Sampling.

The sampling plan will be designed in accordance with the guidelines of Appendix D, and will result in reasonable assurance that

. programmatic deficiencies do not exist in the j population.

This plan employs a 95/1 screen, which is I significantly more conservative than the 95/5 screen which is used in the majority of the ISAP's in which a sampling progrrm is f

employed. The decision to enforce this.

t y

higher standard (which increases sample sizes by approximately a factor of five) was made by the Electrical Review Team Leader.

"! - - - - - - - - - - - - - - , - - - , - - , - - - - , --m_- -"-'s W

Rsvision: '4 l Paga 5.of 8 l ISAP I.a.4 O .(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Based on the preliminary determination of a population size of 3812, the minimum sample size according to Appendix D is 300 with a rejection number of zero (i.e., the critical region is one or more deficiencies found in the sample). If one (1) deficiency is found, a root cause evaluation of the deficiency will be performed, and a sample expansion in accordance with Appendix D will be undertaken.

If the number of deficiencies discovered in the original sample'is two (2) or more, or a potential root cause is identified as programmatic, a 100% reinspection of all l essential and associated terminations in the Control Room and Cable Spreading Room of Unit I will be performed.

4.1.2 Use of Results Results of the actions under this Plan will be evaluated to establish root causes and to identify appropriate corrective action.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope.

4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assist the Review Team Leader in identifying I the Class 1E terminations which interface with the Alternate Shutdown Panel.

~

'4.2.1.2 Process NCRs, if any, generated as a result of this action plan.

4.2.1.3 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1- Review sample plan, NCRs and inspection Os reports, if any.

1 I

1 l

1

Rsvision 4 Paga 6 of 8

% ISAP I.a.4 l (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Evaluate inspection results and specify  !

additional inspections, if required. l 1

4.2.2.3 Determine root cause, generic implications and safety significance. I l

4.2.2.4 Personnel (prior to October 18, 1985)

Mr. M.~B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda, Review Team-Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect termination for compliance to acceptance criteria.

4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC i

.4.2.4 Third-Party Adviser 4.2.4. 1 Provide input to the Sampling Plan.

4.2.4.2 Personnel Dr. F. A. Webster, Statistics Adviser 4.3 Oualifications of Personnel Where tests or inspections require the'use of certified inspectors, qualifications at the appropriate level will be to  !

the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personne? at Nuclear 'l' Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality ~

Assurance Program, and specifically trained to the CPRT Program Plan.

l

Rsvision: 4 l Page 7 of 8 I ISAP I.a.4 I%,/

~) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Third-party participants in the implementation of this action ,

plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.  !

l Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures 4.4.1 Instruction QI-001, " Procedure.for Class.1E Cable Terminations Inspection - CPRT Action Item I.a.4".

4.5 Acceptance Criteria 4.5.1 Inspections The acceptance criterion for the termination inspection is that either:

- The termination is physically in agreement with the drawing (a conductor of a larger size than that shown on the drawing is also acceptable), or

- The termination is not in agreement with the

. drawing but is functionally correct (e.g.,

connected to an electrically common point, wires reversed in circuits with no polarity requirements) 4.6 Decision Criteria 4.6.1 If any terminations are not acceptable per Section 4.1.2, the sample size will be increased, in accordance

'with Appendix D or a 100% reinspection will be performed, as described in Section 4~.1.1.2.

4.6.2 For cases where terminations are not in agreement with the drawings, either the drawings or the terminations will be corrected.

O G .

i Rsvicion 4 I Pags~ 8 of 8 1

ISAP I.a.4 l

() (Cont'd) I I

4.0 CPRT ACTION PLAN (Cont'd) 4.6.3. If the number of deviations in the original sample is two (2) or more, or a potential root cause is identified as programmatic, such that it is required to ,

reinspect all " Safe Shutdown" terminations, then all Class lE essential and associated terminations in the i Unit 1 Control Room and Cable Spreading Room will be-inspected.

~

4.6.4 If it is necessary to reinspect all Class IE eseential and associated terminations in the Unit 1 Control Room and Cable Spreading Room and more than.14 (0.1% of approximately 14,000 Class 1E essential terminations) defective terminations are found, then all Class IE essential and associated terminations in Unit 1

- Unit 2, and common will be reinspected.

/

I O

l l

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.a.5

Title:

NCRs On Vendor Installed Amp Terminal Lugs  !

l i

l l

l i

i i

k

Revision No. 4 Reflects Comments Description On Plan j

O, Prepared and j

-Recommended by: ,

..y-- -

Review Team Leader Date Approved by:

Senior Review Team h d. b >m Date SYYS' r

(

h2 vision: 4 Paga 1 of 7 i i

l ISAP I.a.5 )

o

\~- NCRs On Vendor Installed Amp Terminal Lugs I

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-30)

" Allegation AQE-36 involved vendor-installed AMP Product l Corporation (APC) terminal lugs in ITT (sic) Gould-Brown Boveri, g 6.9 Kv switchgear being excessively bent in the area between the ring and the barrel. Dae TRT discovered 16 NCRs (E-84-01066 through E-84-01081) issued early in April 1984, which documented this condition. The TRT review of TUEC action taken regarding these NCRs revealed the following:

- The NCRs described the APC lugs either as being bent in excess of 60 degrees or twisted.

- The documented record of a telephone conversation between TUEC '

and the representative of the lug manufacturer (reference letter VBR-16624) stated that lugs bent to 90 degrees one time were to be considered acceptable; that lugs. bent to 120 degrees could be acceptable after utilizing an engineering

~

evaluation by the end-user; and that although lugs bent to 120 degrees would not-maintain their full mechanical strength, O they.would maintain their electrical characteristics. This acceptance criteria for field bent lugs was changed by APC due to the dispositioning of NCR E-84-00972 regarding the General Electric (GE) motor control center (MCC) thermal overload relay replacement program.

The TRT findings regarding the disposition of these NCRs were as follows:

The disposition block of the NCR form stated that many of the lugs were " determined not to pose an equipment serviceability problem." However, there was no reference to or evidence of an engineering evaluation, i as required by the lug manufacturer prior to a change in the acceptance criteria on NCR E-84-00972.

t

- Only the " bent" condition of the lugs was addressed by both the vendor representative and TUEC engineering.

• Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to

" twitted" lugs.

The TRT determined that these NCRs were improperly dispositioned in )

that the full scope of the identified problem was not addressed and j the "use-as-is" dispositions were not adequately justified." l y e ,

- 'mm"

R2 vision: 4 Paga 2 of 7 ISAP I.a.5

()

(Cont'd) 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item 6,(a), Page J-31)

"TUEC shall accomplish the following actions prior to fuel load:

Reevaluate and redisposition all NCRs related to vendor-installed terminal lugs in ITT (sic) Gould-Brown Boveri switchgear, taking l into consideration the effects of twisted as well as bent lugs, and perform and document the results of engineering analysis to justify any resulting "use-as-is" dispositions."

3.0 BACKGROUND

I The issue involves bending of AMP ring tongue terminals. In 1981, during the process of terminating (landing) conductors it became. obvious that under certain configurations it was impossible to land conductors without bending the AMP, ring tongue terminal. Accordingly,' _rown & Root Engineering contacted AMP Special Industries, a subsidiary of AMP

() Incorporated, for guidance in. bending of AMP ring tongue terminals. The response (vendor letter VER-16624), which formed the basis for acceptance criteria at CPSES, stated that AMP terminals could be bent one time to 60'.

In the first quarter of 1984 when a GE thermal overload re. lay was being replaced, it was noted by TUGC0 that the AMP ring l 1 tongue terminals had to be bent 90' to 120* to install the relay. Because this violated.the criteria for bending established in 1981, a Non-conformance Report (NCR E-84-00972) was issued. Shortly thereafter, during a scheduled TUGC0 QC l

inspection of ITE Gould-Brown Boveri Switchgear, it was noted that soma of the vendor-installed AMP ring tongue terminals L were bent in excess of 60* and/or twisted.

NCRs were issued to document the condition (NCRs E-84-01066 through E-84-01081). These are the NCRs identified by TRT as giving rise to this issue.

L i In responding to the NCRs, in April 1984 AMP once again was I contacted and the existing situation (including the criteria established in 1981) was discussed. AMP responded that the ring tongue terminals could be bent two (2) times to 45* or one (1) time to 90'. Further, AMP stated that bending more l than 90' and up to and including 120' is acceptable if the O product user evaluated the specific application by considering the length of conductor to be supported by the terminal and

_/

I

Ravision: 4 Paga 3 of 7 ISAP I.a.5 (Cont'd)

3.0 BACKGROUND

(Cont'd) the susceptibility of the final' installation to vibration.

AMP also advised that, while a ring tongue termintal bent more than 90* still maintained electrical characteristics, it'would I not maintain full mechanical strength. This.information was documented in telephone conversation record CPPA 38,241, which was provided to AMP for review.

T TUGC0 judged that the AMP criteria gave appropriate guidance to the concerns raised regarding bent and/or twisted lugs. _In applying these criteria, TUGC0 decided that the terminals in question would be replaced if the bending was in excess of 90*

i or the terminal showed signs of fatigue (e.g., flaking, i cracking or other physical discontinuities).

At the time, TUGC0 did not discuss the term " twisted" with i AMP. This was due.to TUGC0 Engineering's evaluation that the term " bent" appropriately described the physical configuration of the small AMP ring tongue terminals and that TUGC0 QC's 1 description of " bent and twisted" connoted a situation to which the AMP criteria applied. (As_it turns out, anything

.other than bending requires excessive force and could not be i

done by hand. Terminals described as being twisted were judged by TUCCO Engineering as being bent in a manner not exactly perpendicular to the axis of the terminal, a condition consistent with physically landing the conductors by hand.)

Based on this information, the NCRs were dispositioned as follows prior to the TRT review:

- NCR E-84-00972 - An engineering evaluation was conducted by TUGC0 as part of the NCR disposition approving bending the AMP terminals associated with the '

GE relay in excess of 90* but less than 120*. (The TRT did~not state any concern with this evaluation.)

~

- NCRs E-84-01066 through 01081 - Each -terminal in question had been inspected by Engineering and where it-had been reflected in resulting documentation that the bending had been in excess of 90* or the terminal' i showed signs of fatigue (e.g., flaking, cracking or other physical discontinuities), the terminal had been replaced. ,The decision to replace all of the terminals bent in excess of 90* had been based on the fact that it was not necessary for installation to bend the terminals more than.90*, and replacing them would negate the need for an engineering analysis to O justify their acceptance. However, the vast majority of the terminals, incidding most-noted in the NCRs to l

e

.j f '

Rsvicion 4 Pcg3 4 of 7 ISAP I a.5 O (Cont'd)

3.0 BACKGROUND

(Cont'd) be " twisted", had been dispositioned "use-as-is". The basis for the "use-as-is" disposition had been stated in the NCRs-as follows:

"The current Manufacturer's position is that terminals may be bent one time to 90', and up to 120' with engineering evaluation.

Engineering has reviewed the following terminals in question .... It'is our determination that these terminals do not pose an equipment serviceability problem and may be used as is."

Because all terminals bent greater than 90* had been l replaced, engineering evaluations were not required.

i (Note that TUGC0 QE approved the above disposition.)

While it was TUGCO's position that the stated.

dispositions were technically correct, and that the AMP l

criteria on bent lugs encompassed the concerns regarding bent and/or twisted lugs, the TRT was concerned.that the NCRs did not clearly provide justification for the "use-as-is" disposition. To resolve its' concerns, the TRT directed that the NCRs related to the bent and/or twisted terminals in the ITE Gould-Brown Boveri switchgear be reevaluated and redispositioned.

l l

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to reevaluate and redisposition all NCRs related to vendor-installed terminal lugs in ITE Gould-Brown Boveri switchgear to take into O consideration twisted as well as bent _ lugs, confirm the a'cceptability of the "use-as-is" dispositions, and have AMP substantiate their change in acceptance criteris.

R: vision: 4 Paga ~5 of 7 l

ISAP I.a.5 (Cont'd)

'.0 4 CPRT ACTION PLAN (Cont'd)

The following tasks will be implemented to achieve this objective:

- _Redisposition all NCRs to justify the actual l 1

disposition.

- Obtain a vendor analysis of.the bent and twisted lugs.

4.1.1 Disposition of Non-Conformances All Non-conformance Reports on bent and twisted ring tongue terminals (NRCs E-84-01066 thru E-84-01081) will be redispositioned. The redispositioned NCRs will more clearly state the observed condition of the ring tongue terminals and the engineering justification for "use-as-is". The initial disposition of these NCRs did not allow any ring tongue terminal which were " bent or twisted" more than 90* to remain in service.

4.1.2 Vendor Analysis l n

U AMP will be requested to provide documented analycis to substantiate the change from a 60' bend being acceptable to a 90' bend being acceptable. This analysis will include an evaluation of " twisted" ring tongue terminals.

4.1.3 Use of Results Results of the actions under this Plan will be evaluated to establish root causes and to identify appropriate corrective action, if required.

4.1.4 Related Activities An evaluation of the general practice of dispositioning of NCRs is included in Action. Plan VII.a.2, "Non-conformance and Corrective Action Systems".

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this i effort are described below with-their respective work scope. l 1

4.2.1 TUGC0 Comanche Peak Project.  !

I 4.2.1.1 Process NCRs identified in this action plan.

Rsvision: 4 Paga 6 of 7 ISAP I a.5 l (g- g,) (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd)-

4.2.1.2 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review the final disposition of the NCRs.

4.2.2.2 Review and approve the AMP analysis.

4.2.2.3 Determine root cause, generic implications, and safety significance.

4.2.2.4 Personnel (prior to October 18, 1985)

Mr. M. B. Jenes, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985)-

Mr. J. J. Mallanda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr.~M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance program, and specifically trained to the CPRT Program Plan.

Third-party participants in the implementation of this action plan will meet the personnel qualification requirements of the l

l l

CPRT Program Plan and its implementing procedures. ,

1 Other par'icipants t will be qualified to the requirements of I the CPSES Quality Assurance-Program or to the-specific s- . requirements of the CPRT Program Plan. Activities performed by other 'than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of.CPRT Program Quality", of the CPRT Program Plan. i 1

l I

l

I Rsvision: 4 Pags 7 of 7 ISAP I.a.5

() (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures Not applicable 4.5 Acceptance Criteria The acceptance criteria are-as follows:

The NCRs must be properly dispositioned by either justifying the "use-as-is" disposition or requiring replacement of the

. terminal' lugs.

4.6 Decision Criteria The decision criteria are: ,

4.6.1 If the justification for using ring tongue terminals bent up to 90* can not be provided, they will be replaced.

4.6.2 If the justification for using twisted ring tongue L terminals can not be provided, they will be replaced.

O

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.b.1

Title:

Flexible Conduit to Flexible Conduit Separation.

Revision No. 4 Reflects Comments Description On Plan

(

L/ Prepared and Recommended by: .-w - _ ----

Review Team Leader Date i

Approved by:

Senior Review Team t h2. h1 Date l Af SC

i

'Rsvision: 4 Paga 1 of 10 l l

l ISAF I.b.1 Flexible Conduit to Flexible Conduit Separation  !

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, page J-42)

"The TRT could find no evidence that an analysis was performed to support the practice that allowed certain separate. safety- and nonsafety-related flexible conduits inside control room panels to be in direct contact with each other or to be separated by less than 1 inch, as required by Section 5.6.2 of IEEE Standard 384..."

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Item 6.(a),

page J-43)

"TUEC shall accomplish the following actions prior to fuel load:

Reinspect all panels at Comanche Peak Steam Electric Station, in addition to.those in the main control room for Units 1 and 2, that contain (1) redundant safety-related conduits,'or (2) safety- and nonsafety-related conduits. TUEC shall either correct each violation of the separation criteria or demonstrate by analysis the acceptability of the conduit as a barrier for each case where the minimum separation is not met.

This analysis shall be accomplished in accordance with the requirements specified in Section 5.6.2 of IEEE Standard 384-1974. Furthermore, in the event.that the acceptability of the conduit as a barrier cannot be demonstrated, TUEC shall correct the engineering drawings and related documents to indicate the revised minimum separation of conduits inside the panel for each case."

3.0 BACKGROUND

In the control boards, many dual train hand switch modules are installed. Prefabricated cables are routed from the l termination cabinets in the cable. spreading room to the back' of these modules. It is necessary to leave slack in the control boards for these prefabricated cables in order to accommodate removal, testing, and/or. adjustment of the handswitches.- In maintaining separation between redundant traina and between Class lE and non-Class lE cables, slack cable presents difficulties.

O d

R; vision: 4 P2gs 2 of 10 ISAP I'.b.1 0 (Cont'd)

3.0 BACKGROUND

(Cont'd)

This same situation has arisen elsewhere in the nuclear industry and was successfully resolved by the installation of SERVICAIR flexible metallic conduit

• as a barrier. After obtaining IEEE 323-1974 and IEEE 344-1975 qualification data for the SERVICAIR material and after discussions with the- l supplier of the control boards, design change documents were issued to use this material as a barrier for low voltage and signal cables inside control panels. (It has since been determined that the above qualification does not provide sufficient documentation to qualify SERVICAIR flex as a barrier.) i SERVICAIR flex was originally _ proposed as a solution for separation problems involving prefabricated cable service loops for dual train hand switch modules in the control room main control panels. When the project criteria was modified to allow the use of SERVICAIR flex, its use was specified for-

-all Reliance supplied panels, which include the control room control boards and vertical panels.

CII Preliminary investigations indicate that the majority (approximately ninety-five percent) of the SERVICAIR flex is

located in the control room contro1' boards and vertical panels. Therefore, the testing, analysis and inspections to determine the suitability of SERVICAIR flex as a barrier will be based on the circuits and configurations present in the main control boards and vertical panels. A 100% examination of all panels with two or more trains will be performed by CPRT to identify if there are any cases of SERVICAIR' flex outside the main control boards and vertical panels. On a case-by-case basis, the applicability of the separation criteria developed for SERVICAIR flex in the control boards and vertical panels for any additional cases of SERVICAIR flex will be determined. For Unit 2,. installation procedures and QC inspection procedures will be. revised to ensure that the l final panel configuration meets the specified requirements.

The control boards can basically be divided into 4 sections (see Figure 1):

A - Control switch modules (for motors, switchgear and solenoid valves) and amplifier box for sound-powered telephone system B - Instrument controllers - flow, pressure, level control,

() etc. (may include items from "A" above)

• The flexible conduits used for separation inside control room panels is SERVICAIR flexible metallic conduit (SERVICAIR flex). l A

e

Rsvision: 4 Page 3 of 1.0

!~ ISAP I.b.1 (Cont'd) 3.0 BACKGROUh3 (Cont'd)

C - Meters, indicators, recorders, CRT and monitor lights D - Annunciator TD C

j

, /c Figure I s Control Board Side View Wiring which terminates in Sections A and B is mostly modular prefabricated plug-in type and requires cable' slack for flexibility in maintenance and service of the switches.

Consequently separation is most difficult to maintain in this area. Wiring in Section C is predominantly by the. control board manufacturer and 6" separation or rigid barriers have been provided where' required. Wiring in Section D is also modular, containing a single multi-conductor prefabricated cable which supplies 24V power to each annunciator light box.

The vertical panels are of similar design except for the .

absence of the benchboard section, recorders, CRT and monitor lights.

r i

, +. - ,... .

R visiont 4 Pzgo 4 of 10

-s s

ISAP I.b.1 (Cont'd)

(]

4.0 CPRT ACTION PLAN 4.1 Scope'and Methodology The objectives of this action plan are 1) to determine by testing and analyses the minimum acceptable separation between two cable trains within SERVICAIR flex and 2) to reinspect.all panels which potentially could violate the final separation criteria.

The following tasks will be implemented to achieve these objectives:

- Analyses

- Testing to determine adequacy of SERVICAIR flex as a barrier

- Inspections for adequate separation

- Procedure / Drawing Revisions-() - Examination of other panels for SERVICAIR flex As noted above, the majority of the SERVICAIR flex is located in the control room control boards and vertical panels.

Therefore, the analyses,. testing,' and inspections described above will be based on the circuits and configurations present in these areas. The remaining Unit 1 and common panels with two or more trains will be examined by CPRT tc determine the location of all SERVICAIR flex.

1 4.1.1 Analyses ,

An_ analysis will be prepared for circuits in the control boards and in the vertical ~ panels X-CV-01 and X-CV-03 for which existing protection (exclusive of the SERVICAIR flex) precludes the need for.any spacial separation or qualified barrier (s). .The analysis for the main control board will address specifically the modular wiring to control switches where the required cable slack creates difficulties in maintaining fixed spacial separation. Other circuits which commonly traverse the switch module wiring area will be included in the review and documt. cation.

Analyses, backed up by the test results, will be I T performed to determine the adequacy of SERVICAIR flex

-/ as a barrier. These analyses will'be based on the heat transfer characteristics of the cable and SERVICAIR.

flex and will apply to this action plan (SERVICAIR flex to SERVICAIR flex) and Action Plan I.b.2 (SERVICAIR flex to cable).

~

Ravision: 4 Paga 5 of 10 ISAP I.b.1 o

() .(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Test Program 4

A two-part test prcgram will be conducted in accordance with approved test procedures to determine'the adequacy l of the SERVICAIR flex as a fire barrier. The first test is designed to determine the adequacy of the-SERVICAIR flex to provide a path for a short-circuit current without damage to cables in adjacent or

! ~ touching SERVICAIR flex.

The second test is designed to determine the ability of >

j the SERVICAIR flex to act as an effective barrier '

between cables within SERVICAIR flex.under overload or

] short circuit conditions and opposite train exposed I cables or opposite train cables within.SERVICAIR flex.

I i The test procedures will be written and teats conducted such.that they will be generic to the control room control boards and vertical panels. _The procedures for the test program will be approved by the Review Team O Leader prior to implementation of the test program.

4.1.3 Inspections l

l 4.1.3.1 Third-party Inspections Inspections of the Unit 1 control room i

control boards and vertical' panels will.be performed by third-party QC inspectors to i ensure that separation meets the specified criteria in the CPRT third-party inspection l

procedure QI-004. Inspection attributes will be provided by Gibbs & Hill for review and~

approval by the Review Team Leader.

The above inspections will involve all aspects of cable separation including the issues addressed by Action Plan I.b.2 (separation of SERVICAIR flex.to exposed cable) and Action-Plan I.b.4 (missing barriers).

4.1.3.2 .TUGC0 Inspections If the revised separation criteria'(see O Section 4.1.4) differs from the Project criteria used during the most recent TUGC0 inspection, TUGCO's procedures require that a-

Rsvizion: 4 Paga 6 of 10 ISAP I.b.1

() (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) reinspection be performed, regardless of any third-party inspection, for those separation l attributes that have been revised to more restrictive criteria. In the~ event that such. f an inspection is required, the CPRT will l overview this inspection.

4.1.4 Procedure / Drawing Revisions Based on the results of the above analyses and testing, the TUGC0 Project will revise Drawing 2323-El-1702-02,

" Cable and Raceway Separation Typical Details", and any other related documents, to reflect the final separation criteria. Drawing 2323-El-1702-02 provides the separation criteria to be used by construction.

The applicable QC inspection procedures will also be revised to ensure that inspectors are aware of where-SERVICAIR flex can be used, cs well as ensuring that the separation criteria used by the QC inspectors is

() consistent with the. final separation criteria.

The above document changes vill be reviewed by the Review Team Leader.

4.1.5 Examination of Other Panels for SERVICAIR Flex A 100% examination of all panels in Unit I and common with two or more trains will be performed by CPRT to identify if there arc any cases of SERVICAIR flex outside the control room control boards and vertical panels. If any SERVICAIR flex is found, non-conformance Reports (NCRs) will be written by_the CPSES Project and the applicability of the separation criteria developed for SERVICAIR flex in the control boards and vertic~al panels for the additional cases of SERVICAIR flex will be determined on a case-by-case basis, i

4.1.6 Related Documents Drawing 2323-El-1702-02 " Cable and Raceway Separation Typical Details".

O

Rsvision: 4 Paga 7 cf 10 s ISAP I.b.1

() (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.7 Use of Results For Unit 1, all. deviations to the final project separation requiremests noted during the inspection  ;

will be identified : Non-conformance Reports (NCRs) and corrected. 7n Unit 2, installation procedures and QC inspection procedures will be revised to ensure that the final panel configuration meets the specified requirements.

Results of the actions taken under this plan will be.

evaluated to establish root causes and to identify appropriate corrective action.

I 4.2 Participants Roles and Reeponsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope..

4.2.1 TUGC0 Comanche Peak Project O 4.2.1.1 Revise inspection procedures used for plant construction inspection to include new criteria resulting from tests and analyses.

Retrain craft nnd inspection personnel.

4.2.1.2 Revise Drawing 2323-El-1702-02 " Cable and Raceway Separation Typical Details", and any other related documents, to reflect the final separation criteria (see 4.2.5.4).

4.2.1.3 Perform reinspections for the Unit 1 control reom control boards and vertical panels for those separation attributes which.have been revised to a more restrictive criteria as a result of this action plan.

4.2.1.4 Process NCRs that may be generated due to this action plan.

1 4.2.1.5 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team

- N/ 4.2.2.1 Review the analysis, test results and revised inspection procedures.

R vision: 4 Pag 2 8 of 10 ISAP I.b.1

,/) (Cont'd)

U 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Complete 100% examination of all panels with two or more trains to identify cases where SERVICAIR flex is used outside the control room control boards and vertical panels.

4.2.2.3 Review the inspection reports and NCRs,'if any.

4.2.2.4- Review and approve the test procedures.

4.2.2.5 Review changes to Drawing 2323-El-1702-02

" Cable and Raceway Separation Typical Details", and any other relat2d documents, which reflect the final separation criteria.

4.2.2.6 Review documentation of training of-TUGC0 Project inspectors to final separation criteria 4.2.2.7 Overview the TUGC0 inspection of the Unit 1 control room control boards and vertical

') panels described in 4.2.1.3 above.

4.2.2.8' Determine root cause, generic implications and safety significance.

I 4.2.2.9 Personnel (prior to October 18, 1985) 1 Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.10 Personnel (starting 0ctober~18, 1985)

Mr. J. J. Mallanda, Review Team Leader

Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect Unit I control room control boards and vertical panels which have SERVICAIR flex A)

(, for compliance to separation criteria (see 4.2.5.3). '

R".visicn: 4 Paga 9 of 10 ISAP I.b.1

-(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2 Perform overview inspection (see Section 4.2.2.7) as determined by the Electrical Review Team.

4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Adviser l 4.2.4.1 Review test procedures.

4.2.4.2 Supervise the tests.

4.2.4.3 Review the analysis.

4.2.4.4 Personnel Mr. L. D. Bates, Third-Party Adviser l 4.2.5 Gibbs & Hill 4.2.5.1 Perform separation analysis.

4.2.5.2 Prepare the test procedures.

4.2.5.3 Prepare separation criteria for CPRT third-party inspectors.

4.2.5.4 Prepare final separation criteria.

4.2.5.5 Assist in the QC inspections, if required.

4.2.5.6 Personnel Mr. S. P. Martinovich, Senior Electrical

! Engineer 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be cectified to the requirements of the third-party employer's Quality O Assurance program, and specifically. trained to the CPRT Program Plan.

l I

1 l

1

R; vision: 4 Pcg3 10 of 10 ISAP I.b.1 i

/ (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the-specific requirements of the CPRT Program Plan. Activities performed i by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures I

i 4.4.1 Procedure I.b.1-001, '.' Cable /SERVICAIR' Heat Transfer I Test".

4.4.2 Procedure I.b.1-002, "SERVICAIR Short Circuit Test" l 4.4.3 Instruction QI-004, "CPRT Action Item I.b.1 - Flexible Conduit to Flexible Conduit Separation; CPRT Action O- Item I.b.2 Flexible Conduit to Cable Separation".

I 4.5 Acceptance Criteria 4.5.1 The acceptance criterion for the tests will be that the barrier provides adequate protection at the minimum (or less) separation allowed by IEEE-384 (1974), IEEE-420 (1973) and Regulatory Guide 1.75, Revision 1, January 1975.

4.5.2 The acceptance criterion for the as-installed condition l will be that the SERVICAIR flex meets the final separation criteria (see 4.2.5.4).

-4.6 Decision Criteria If the tests and analyses results do not qualify SERVICAIR flex as a barrier, qualified barriers will be installed or 6" l separation will be provided and drawings revised.

O  ;

4 COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.b.2

Title:

Flexible Conduit to Cable Separation 1

Revision No. 4

! Reflects Comments Description On Plan i Prepared and Recommended by: .

t Review Team 4 Leader Date 8M 4 l

Approved by:

Senior Review Team hs _ gj, k u _

i Date //w/ri O

4

l R:vicien: 4 P:go 1 of 12 ISAP I.b.2 O

k/

m Flexible Conduit to Cable Separation

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.

7, Page J-42)

"The TRT determined that the installation of certain safety- or nonsafety-related cables inside control room panels, which were in direct contact with safety-related flexible conduits associated with the other redundant trains (see Table I), was inconsistent with engineering drawings and regulatory requirements... Because acceptability of the flexible conduit as a barrier was not established by analysis, as required by Section 5.6.2 of IEEE Standard 384, the cables must be separated from the conduits inside the panels by a minimum distance of 6 inches, as required by Section 5.6.2 of IEEE Standard 384."

4 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Item 6(b),

Page J-44)

"TUEC shall accomplish the following actions prior to fuel load:

Either correct each of the violations of separation criteria concerning separate cables and cables within flexible conduits

("'N found in contact with each other.inside main control room panels (s,) (Table I) or demonstrate by analysis the adequacy of the flexible conduit as a barrier. TUEC shall also reinspect all remaining panels in the control room and other areas of the plant containing separate cables and cables within flexible conduit and shall take the same corrective actions as those outlined in Table 1.

This analysis shall be accomplished in accordance with Section 5.6.2 of IEEE Standard 384-1974. In the event that the acceptability of the conduit as a barrier cannot be demonstrated.

TUEC_shall separate cables and cables within flexible conduits by a minimum distance of 6 inches, as required by Section 5.6.2 of IEEE Standard 384. Furthermore, TUEC shall correct all appropriate drawings and documents to indicate the revised minimum separation."

3.0 BACKGROUND

1 The deviations of the cables being in direct contact with the SERVICAIR flexible metallic conduit identified under this action I plan are contrary to the project cable separation requirements  !

delineated in Drawing 2323-El-1702-02 " Cable and Raceway Separation Typical Details".

In the control boards, many dual train hand switch modules are installed. Prefabricated cables are routed from the termination

()g

(_ cabinets in the cable spreading room to the back of these modules.

1 It is necessary to leave slack in the control boards for these I I

prefabricated cables in order to accommodate removal, testing, and/or adjustment of the handswitches. In maintaining j

Rsvision: 4 Pcg2 2 cf 12 i

i ISAP I.b 2 l (Cont'd)

3.0 BACKGROUND

(Cont'd) separation between redundant trains and'between' Class 1E and non-Class 1E cables, slack cable presents difficulties.

J This same situation has arisen elsewhere in the nuclear industry and was successfully resolved by the installation of SERVICAIR flexib1'e metallic conduit

• as a barrier. After obtaining IEEE 323-1974 and IEEE 344-1975 qualification data i for the SERVICAIR material and after discussions with the supplier of the control boards, design change documents were issued to use this material as a barrier for low voltage and signal cables inside control panels. (It has since been determined that the above qualification does not provide sufficient docementation.to qualify SERVICAIR flex as a r

barrier.)

SERVICAIR flex .was originally proposed as a solution for separation problems involving prefabricated cable service loops for dual train hand switch modules in the control room main control panels. When the project criteria was modified to allow the use of SERVICAIR flex, its use was specified for all Reliance supplied panels, which include the control-room O control boards and vertical panels.

I Preliminary investigations indicate that the majority l (approximately ninety-five percent) of the SERVICAIR flex is i

located in the control room control boards and vertical panels. Therefore, the testing, analysis and inspections to determine the suitability of SERVICAIR flex as a berrier will

, be based on the circuits and configurations present in the main control boards and vertical panels. A 100% examination l of all panels with two or more trains will be performed by CPRT to identify if there are any cases of SERVICAIR flex outside the main control boards and vertical panels. On a case-by-case basis, the applicabili:y of the separation criteria developed for SERVICAIR flex in the control boards and vertical panels for any additional cases of SERVICAIR flex will be determined. For Unit 2, installation procedures and QC inspection procedures will be revised to ensure that the final panel configuration meets the specified requirements.

i.

The control boards can basically be divided into 4 sections (see Figure 1):

A -

Control switch modules (for motors, switchgear and solenoid valves) and amplifier box for sound-powered

! telephone system The flexible conduits used for separation inside control room panels is SERVICAIR flexible metallic conduit (SERVICAIR flex).

Rsvision: 4 Page 3 of 12 I ISAP I.b_2 (Cont'd)

3.0 BACKGROUND

(Cont'd)

B - Instrument controllers - flow, pressure, level control, }

etc. (may iticlude items from "A" above)

C - Meters, indicators,. recorders, CRT and monitor lights D - Annunciator TD C

B C

Figure 1 Control Board Side View Wiring which terminates in Sections A and B is mostly modular prefabricated plug-in type and requires cable slack for flexibility in maintenance and service of the switches.

Consequently separation is most difficult to maintain in this area. Wiring in Section C is predominantly by the control-board manufacturer and 6" separation or rigid barriers have been provided where required. Wiring in Section D is also modular, containing a single molti-conductor prefabricated cable which supplies 24V power to each annunciator light box.

The vertical panels are of similar design except for the absence of the benchboard section, recorders, CRT and monitor lights.

O V

1 R vision: 4 i Pags 4 of 12 ISAP I.b.2

/O (Cont'd)

'L}

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan are 1) to determine by testing and analyses the minimum acceptable separation between a cable within SERVICAIR flex and an exposed cable of a different train and 2) to reinspect all panels which potentially could violate the final separation criteria.

The following tasks will be implemented to achieve these objectives:

Analyses

- Testing to determine adequacy of SERVICAIR flex as a barrier Inspections for adequate separation Procedure / Drawing Revisions

~'h -

Examination of other panels for SERVICAIR flex (d As notgd above, the majority of the SERVICAIR flex is located in the control room control boards and vertical panels.

Therefore, the analyses, testing, and inspections described above will be based on the circuits and configurations present in these areas. The remaining Unit I and common panels with two or more trains will be examined by CPRT to determine the location of all SERVICAIR flex.

4.1.1 Analyses An analysis will be prepared for circuits in the control boards and in the vertical panels X-CV-01 and X-CV-03 for which existing protection (exclusive of the SERVICAIR flex) precludes the need for any spacial separation or qualified barrier (s). Ths analysis for the main control board will address specifically the modular wiring to control switches where the required cable slack creates difficulties in maintaining fixed spacial separation. Other circuits which commonly traverse the switch module wiring area will be included in the review and documentation.

O

\~-) i l

)

-Ravicion 4 l Pcg2 5 of 12 l l

)

ISAP I.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Analyses, backed up by the test results, will be performed to determine the adequacy of SERVICAIR flex as a barrier. These analyses will be based on the heat transfer characteristics'of the cable and SERVICAIR flex and will apply to this action plan (SERVICAIR flex to cable) and Action Plan I.b.1 (SERVICAIR flex to i SERVICAIR flex).

4.1.2 Test Program A two-part test program will be conducted in accordance with approved test procedures to determine the adequacy of the SERVICAIR flex as a fire barrier. The first

test is designed to determine the adequacy of the i

SERVICAIR flex to provide a path for a short circuit current without damage to cables in adjacent or touching SERVICAIR flex.

0

! The second test fs designed to determine the ability of the SERVICAIR flex to act as an effective barrier

( between cables within SEh7ICAIR flex under overload or short circuit. conditions and opposite train exposed

'(

cables or opposite train cables within SERVICAIR flex.

~

The test procedures will be written and tests conducted such that they will be generic to the control room control boards and vertical panels. The procedures for the test program will be approved by the Re;iew Team Leader prior to implementation of the test program.

4.1.3 Inspections 4.1.3.1 Third-party . Inspections-Inspections-of the Unit I control room I i control boards and vertical panels will be l

performed by third-party QC inspectors to 4

ensure that separation meets the specified

criteria in the CPRT third-party inspection.

I procedure QI-004. Inspection attributes will be provided by Gibbs & Hill for review and approval by the Review Team Leader.

The above inspections will involve all aspects of cable separation including the issues addressed by Action Plan I.b.1 D

s_ ,/ (separation of SERVICAIR flex to SERVICAIR l

' flex) and Action Plan I.b.4 (missing barriers).

l l

_ ~ _ _ . , _ - . - . , _ _ ~ _ . . _ -_ _ _

i Ravioicn 4

Pega 6 of 12 ISAP I.b 2

'(Cont'd)

, 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3.2 TUGCO Inspections If the revised separation criteria (see Section 4.1.4) differs from the Project ,

criteria used during the most recent TUGC0 inspection, TUGCO's procedures require that a.

reinspection be performed, regardless of any third-party inspection, for those separation attributes that have been revised to more restrictive criteria. In the event that such I an inspection is required, the CPRT will

' overview this inspection.

i 4.1.4. Procedure / Drawing Revisions }

i' Based on the results of the above analyses and testing, i the TUGC0 Project will revise Drawing 2323-El-1702-02,

" Cable and Raceway Separation Typical Details", and any other related documents, to reflect the final separation criteria. Drawing 2323-El-1702-02 provides the separation criteria to be used by construction.

The applicable QC inspection procedures will also be .

revised to ensure that inspectors are aware of where SERVICAIR flex can be used, as well as ensuring that the separation criteria used by the QC inspectors is consistent with the final separation criteria.

The above document changes will be reviewed by the Review Team Leader, i

4.1.5 Examination of Other Panels for SERVICAIR Flex A 100% examination of all panels in Unit 1 and common with two or more trains will be performed by CPRT to l identify if there are any cases of SERVICAIR flex outside the control room control boards'and vertical panels. If any SERVICAIR flex is found, 1

non-conformance Reports (NCRs) will be written by the CPSES Project and the applicability of the separation criteria developed for SERVICAIR flex in the' control boards and vertical panels for the additional cases of I

SERVICAIR flex will be determined on a case-by-case

, basis.

i 4.1.6 Related Documents Drawing 2323-El-1702-02 " Cable and Raceway Separation Typical Details".

a 4 _ _ - _ . _ . _ . . . _ _ _ _ _ _ . . . - , , _

Rsvicient 4  !

Pag 2 7_of 12 ISAP I.b.2 i

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.7 Use of Results l For Unit 1, all deviations to the final project

' separation requirements noted during the inspection will be identified on Non-conformance Reports (NCRa) i and corrected. .In Unit 2, installation procedures and 4 QC inspection procedures will be revised to ensure that the final-panel configuration meets the specified requirements.

Results of the actions taken under this plan will bi evaluated to establish root causes and to identify l

appropriate corrective action.

I 4.2 Participants Roles and Responsibilities j

] The organizations and personnel that will participate in this effort are described below with their respective work scope.

l 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Revise inspection procedures used for plant construction inspection to include new crir9ria resulting from tests and analyses.

Retrain craft'and.inspeerion perscunel.

4.2.1.2 keviso Drawing 2323-El-1702-02 " Cable and Racecay. Separation Typical Details", and any other related documents, to reflect the final separation criteria (see 4.2.5.4).

4.2.1.3 Perform reinspections for the Unit I control room control boards and vertical penels.for those separation attributes which have been revised to a more restrictive criteria as a result of this action plan.

4.2.1.4 Process NCRn rhet may be generated due to this action pisn.

4.2.1.5 Personnel-Mr. W. 1. Vogelsang, TUGC0 Coordinatot

! 4.2.2 Electrient Revim Tem 4.2.2.1 Reviev *the anntlp,*is, test resultc and revised inspuevien procednres.

R;visient 4-Pcg2 8 cf'12 ISAP I.b.2

,/ (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Complete 100% examination of all panels with two or more trains to identify cases where SERVICAIR flex is used outside the control room control boards and vertical panels.

4.2.2.3 Review the inspection reports and NCRs, if any.

4.2.2.4 Review and approve the test procedures.-

l i 4.2.2.5 Review changes to Drawing 2323-El-1702-02

" Cable and Raceway Separation Typical Details", and any other related documente, which reflect the final separation criteria.

4.2.2.6 Review docume?tation of training of TUGC0 Project insp.': tors to final separation criteria 4.2.2.7 Overview the TUGC0 inspection of the Unit 1 control room control boards and vertical

(}

\_,, panels described in 4.2.1.3 above.

4.2.2.8 Determine root cause, generic implications and safety significance.

g 4.2.2.9 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.10 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda, Review Team Leader Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect Unit I control room control boards and vertical panels which have SERVICAIR flex

,( - for compliance to separation criteria (see i 4.2.5.3).

R ;vieicnt 4 P gs 9 cf 12 l

ISAP I.b.2 )

p

\

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2 Perform overview inspection (see Section 4.2.2.7) as determined by the Electrical Review Team.

4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC

~

4.2.4 Third-Party Adviser 4.2.4.1 Review test procedures.

4.2.4.2 Supervise the tests.

4.2.4.3 Review the analysis.

4.2.4.4 Personnel Mr. L. D. Bates, Third-Party Adviser 4.2.5 Gibbs & Hill 4.2.5.1 Perform separation analysis.

4.2.5.2 Prepare the test procedures.

4.2.5.3 Prepare separation criteria for CPRT third-party inspectors.

4.2.5.4 Prepare final separation criteria.

4.2.5.5 Assist in the QC inspections, if required.

4.2.5.6 Personnel Mr. S. P. Martinovich, Senior Electrical Engineer 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality gy Assurance program, and specifically trained to the CPRT Program Plan.

I j

~

R;vicicnt 4 Pcga ~10 of 12 ISAP I.b.2-O- (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan.' Activities performed by other than third-party personne1'will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures, 4.4.1: Procedure I.b.1-001, " Cable /SERVICAIR Heat Transfer Test".

4.4.2 Procedure I.b.1-002, "SERVICAIR Short Circuit Test" 4.4.3 Instruction QI-004, "CPRT Action-Item I.b.1 - Flexible O

V Conduit to Flexible Conduit Separation; CPRT Action Item I.b.2 Flexible Conduit to Cable Separation".

4.5 Acceptance Criteria 4.5.1 The acceptance criterion is that the SERVICAIR flex be shown by testing and/or analyses to be an acceptable l barrier as provided by IEEE-384 (1974),'IEEE-420 (1973) and Regulatory Guide 1.75,' Revision 1, January, 1975.

4.5.2 The acceptance criterion for cable to SERVICAIR flex separation is that the cable-and flexible conduit not touch each other and that the separation provided meets the requirements stipulated in Drawing 2323-El-1702-02,

~

" Cable and Raceway Separation Typical Details" (see Section 4.2.1.2).

4.6 Decision-Criteria If the tests and analyses'results do not qualify SERVICAIR

.; flex as an acceptable barrier, qualified barriers will be j installed.or 6" separation will be provided and drawings revised.

O i

R;vicient 4 l 4

Pcg2 11 of'12 ISAP I.b.2 (Cont'd)

O Table 1*

Safety or Nonsafety-Related Cables in Contact with Other Safety-Related Conduits in Control. Room Panels

1. Control Panel CP1-EC-PRCB Containment Spray System Cable No. Train Related Instrument EG139373 B (green) Undetermined E0139010 A-(orange) Undetermined

2. Control Panel CP1-EC-PRCB Reactor Control System i Cable No. Train Related Instrument EG139383** B (green) Reactor manual trip switch l E0139311 A (orange) Undetermined E0139310 A (orange) Undetermined EG139348 B (green) Undetermined

3. Control Panel CP1-EC-PRCB Chemical & Volume control System Cable No. Train Related Instrument EG139335 B (green) LCV-112C E0139301 A (orange) Undetermined E0139305 A (orange) LCV-112B -

NK139605 Nonsafety CSALB-6AB (in bundle)

4. Control Panel CPI-EC-PRCB Auxiliary Feedwater Control System Cable No. Train Related Instrument E0139753 A (orange) FK-2453A E0139754 A (orange) FK-2453B EG139756 B (green) FK-2454A EG139288 B (green) FK-2454B EG145780 B (green) FK-2460A EG145781 B (green) FK-2460A A0138622 A (orange HS-2452G-H Assoc.).

g -NK139647 Nonsafety HS-2383

• From NUREG-0797, Supplement 7, Table 1, Pages J-39-40.

i ** The correct number is EG139352 i

i

' ' Revision: . 4

Pess 12 of l'2 4- -

'ISAP.I.b.2.

(Cont'd)

I f Table 1(Cont'd)

Cable No. Train Related Instrument  ;

j EG140309. - B (green) PK-2324

! EG139757 B (green)- PK-2328

! NK13957 Nonsafety HS-211A i

i -

l i

e

$. r I

i I )

+

t '

l l

i I

I i

. l l

l i

l l

t I

i COMANCHE PEAK RESPONSE TEAM ACTION PLAN l

ISAP 1.b.3 I

Title:

Conduit'to Cable Tray Separation Revision No. 4 Reflects Coments Description On Plan Prepared and j Recomended by: .,_ __

Review Team ,

Leader Date E b Approved by:

Senior Review Team [h _ c j k,j_

Date /f3 Yf O

R;viciont 4 ]

Pcg3 l'ef 5  !

ISAP I.b.3 Conduit to Cable Tray Separation

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY'NRC (NUREG-0797, Supplement No.

7, Page J-42)

'"The TRT found no evidence that the existing.C&H' analysis for .

establishing the criteria for a 1-inch separation between rigid '

conduits and cable trays, as stated in G&H Electrical Erection .

Specification 2323-ES-100, had been evaluated by the NRC staff for Comanche Peak. This analysis should have been referenced in the FSAR."-

t 2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7 Item 6(e),

Page J-44)

"TUEC shall accomplish the following actions prior to fuel load

Submit to the NRC'the analysis. substantiating the acceptability of the criteria stated in G&H electrical erection specification i governing the separation between_ separate conduits and cable trays.

This analysis shall be supported with the necessary documentation in sufficient detail to perform an independent evaluation of how

~

these criteria were established based on the analysis."

O

3.0 BACKGROUND

Raceway separation criteria utilized in Gibbs & Hill i electrical drawings and specifications.were based upon the requirements of IEEE 384-1974 and Regulatory Guide 1.75 i (Revision 1, 1/75). Although very specific criteria are i provided in the standard and regulatory guide for separation j between cable trays, the interpretation and application of i that criteria for separation between conduits and cable trays is not specified.

3 Documents internal to'Gibbs & Hill'were prepared to establish j the engineering interpretation of required separation between

] conduits and cable tray in accordance with established criteria in the standard and regulatory guide. These  !

documents were not submitted to the NRC staff for review i because the interpretation was not considered a deviation to

the standard or regulatory guide, but was considered documentation supporting the implementation of these requirements. It is industry practice to not submit such implementing documents to the NRC.

i

_/

l l

R;vicien: 4

- Pega 2-cf 5 ISAP I.b.3

N (Cont'd)

(J

)

i i

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to substantiate the acceptability of the criteria governing the separation between conduits and cable trays, and submit the evaluation and 3

supporting documentation to the NRC.

To achieve tiiis objective, the following tasks will be implemented:

) - Prepare Gibbs & Hill report compiling criteria Review report to substantiate separation criteria Submit report to NRC *

't l

4.1.1 Report Preparation Gibbs & Hill will prepare a report for TUGC0 presenting the methodology and criteria used in applying IEEE-384(1974) and Regulatory Guide 1.75 (Revision 1, January 1975) to conduits requiring separation from 2

redundant cable trays. Included will be a copy of a Sandia Report (" Cable Tray Fire Tests", SAND 77-1125C) l which is the primary reference used in establishing the separation criteria.

4.1.2 Report Review The above report will be submitted to the Review Team Leader and his third-party adviser for review.

O

Reviciont 4 Pegn 3 cf 5 i

ISAP I.b.3

/ (Cont'd)

_s k )}

4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Report Submittal to NRC After the report has been reviewed and approved, it and any supporting documents will be submitted by TUGC0 to the NRC for review. An FSAR Change Request will be initiated to provide a description of the cable tray-to-conduit separation criteria in the FSAR.

4.2 Participants Roles and Responsibilities

.The organizations and personnel that will participate in this i

effort are described below with their respective' work scope.

4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assist the Review Team Leader in reviewing the report compiling the Gibbs & Hill criteria.

4.2.1.2 Submit, upon approval, the report to the NRC.

4.2.1.3 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator j 4.2.2 Electrical Review Team 4.2.2.1 Review the report compiling the Gibbs & Hill

criteria.

4 4.2.2.2 Review NCRs and inspection reports, if any.

I j 4.2.2.3 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator l

4.2.2.4 Personnel (starting October 18, 1985)

}

Mr. J. J. Ma11anda, Review Team Leader

)

4 Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser

( Mr. E. P. Stroupe, Third-Party Adviser ,

1

R;vicisnt 4 Pcg2 4 cf 5 ISAP I.b.3 (Cont'd)

V I, 4.0 CPRT ACTION PLAN (Cont'd) 2 4.2.3 Gibbs & Hill 4.2.3.1 . Prepare a report compiling the criteria used in confirming the adequacy of conduit-to-

cable tray separation.

! 4.2.3.2 Personnel i Mr. S. P. Martinovich, Senior Electrical l Engineer 4.2.4 Third-Party Adviser l 4.2.4.1 Review the report compiling the Gibbs & Hill criteria.

4.2.4.2 Personnel Mr. L. D. Bates, Third-Party Adviser l 4

4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of ,

Inspection, Examination, and Testing Personnel at Nuclear ,

' Power Plants." CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality I Assurance Program, and specifically trained to the CPRT t . Program Plan.

1 Third-party participants in the implementation of this action 3

j plan will meet the personnel qualification and objectivity l

requirements of the CPRT Program Plan and its implementing

! procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed i

by other than third-party personnel will be governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures Not applicable.

R:vicion: 4 Paga 5 of 5 E

I ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 1

! 4.5 Acceptance Criteria i

Ihe acceptance criterion for the report is that it demonstrate that the cable tray-to-conduit separation criteria meet the '

intent'of IEEE-384 (1974) and Regulatory Guide 1.75, Revision l 1, January 1975.

4 4.6 Decision Criteria J

l If compliance with IEEE-384 (1974) and Regulatory Guide 1.75,

{

Revision 1, January, 1975 cannot be adequately demonstrated, j -the conduits and cable trays will be modified, as appropriate,

! to achieve compliance'.

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, t i

4 1

l 2

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l I i

\

4 l'

l -- . . - .- .- _.- - . _ - .-_ - -. -.-_-

l 1

COMANCHE PEAK RESPONSE TEAM ACTION PLAN i

j ISAP  !.b.4

Title:

' Barrier Removal I

l-i i

i Revision No. 4 Reflects Comments j Description On Plan l

! Prepared and Recommended by: , .U.*[I Review Team a Leader Date II l

! i i

l .

I 1

1 l Approved by:

Senior Review Team L94 d /ha l' Date /!1 i(= i i

i i

i i

e R;vici;at 4 P ga 1 cf 4

-s ISAP 1.b.4

-'e Barrier Removal

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.

7, Page J-42)

"The TRT determined that the missing barrier (used to separate redundant devices in auxiliary feedwater panel CP1-EC-PRCB-09) and the field wiring not being separated by the required 6 inches (inside panel CPI-EC-PRCB-03) were the only two instances of Class 1E panel-mounted devices in violation of the separation criteria which require corrective action."

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Item No.'s 6(c) & 6(d), Page J-44)

"TUEC shall accomplish che following actions prior to fuel load:

Take corrective measures to provide a barrier in auxiliary feedwater panel CP1-EC-PRCB-09 separating redundant flow and pressure instruments.

Take corrective action to ensure that the required minimum separation of the redundant field wiring identified inside panel-O CPI-EC-PRCB-03 is maintained either by distance or by an acceptable barrier."

3.0 BACKGROUND

Barrier material supplied by the control board manufacturer was removed creating a separation violation (1-CB-09). In addition, field wiring is within one (1) inch of device 1-HS-5574 creating a separation violation (1-CB-03).

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R:vici:nt 4 Pcg2 2 of 4 ISAP I.b.4 f (Cont'd) 4.0 CPRT ACTION PLAN

^

4.1 Scope and Methodology The objective of this action plan is to resolve the identified separation violations.

To achieve this objective, the following tasks will be implemented:

6

- Replace missing barrier material and rework field cables

- Revise maintenance procedures 4.1.1 Rework  !

The barrier material will be replaced and the field cal?es reworked to resolve separation violations.

Non-conformance Reports will be issued in accordance with Engineering Procedure CP-EP-16.0, " Procedure for Resolving Inspection Discrepancies" to assure i

O disposition of these items. TUCCO Engineering will disposition the non-conforming items in accordance with Engineering Procedure CP-EP-16.1, " Processing Non-conformance Reports". Quality engineering and control activities will be carried out under Quality Engineering Procedure CP-QP-16.0, "Non-conformances".

The Review Team Leader will review the NCRs for adequacy. Note that under Action Plan 1.b.1, the Unit I control board and vertical panels, including the NRC l

referenced panels, in the control room are being inspected for additional separation violations and .

missing barriers. For Unit 2, installation procedures and QC inspection procedures will ensure that the final panel configuration meets the specified requirements.

)

l 4.1.2 Maintenance Procedures Revision l Maintenance procedures will be revised to ensure that l

all separation requirements are met following modifications or maintenance activities. The Review Team Leader will review procedure changes for adequacy.

4.1.3 Use of Results l 2 Results of the actions taken under thin plan will be a

(T'I evaluated to establish root causes and to identify appropriate corrective action.

i

R; vision 4 P g2 3 cf 4 ISAP I.b.4~

I (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Farticipants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope.

4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Revise maintenance procedures.

J 4.2.1.2 Process NCRs that may be generated due to this action plan.

.l 4.2.1.3 Personnel i

Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team i

4.2.2.1 Review the revised maintenance procedures.

4.2.2.2 Review NCRs and inspection reports, if any.

4.2.2.3 Determine root cause, generic implications, and safety significance.

g 4.2.2.4 Personnel (prior to October 18, 1985) i Mr. M. B. Jones, Jr., Review Team Leader i

Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985) l Mr. J. J. Ma11anda, Review Team Leader l

Mr. R. J. Bizzak, Issut Coordinator i

{

Mr. M. B. Jones, Jr. , Third-Party Adviser i

Mr. E. P. Stroupe, Third-Party Adviser i 4.2.3 Third-Party Adviser r

1 4.2.3.1 Review the revised maintenance procedures.

4.2.3.2 Personnel  ;

Mr. L. D. Bates, Third-Party Adviser

)

R;vicion 4 P g2 4 ef 4 1

l q ISAP I.b.4 i ) (Cont'd)

'O 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants." CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the h applicable principles of Section III.K.

Program Quality" of the CPRT Program Plan.

" Assurance of CPRT 4.4 Procedures Not applicable.

4.5 Acceptance Criteria The intent of IEEE-384 (1974), IEEE-420 (1973) and Regulatory Guide 1.75, Revision 1 January 1975 will be met per the requirements stipulated in Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details".

4.6 Decision Criteria There are no conditional actions for this action plan because the identified discrepancies will be corrected. Thus, decision criteria are unnecessary.

C

1 O

Civil / Structural ISAPs I.c Electrical Conduit. Supports II.a Reinforcing Steel.in the Reactor Cavity II.b Concrete Compression Strength II.c Maintenance of Air Cap Between Concrete Structures II.d Seismic Design of Control Room Ceiling Elements II.e Rebar in the Fuel Handling Building O

O 1

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,^. COMANCHE PEAK RESPONSE TEAM ACTION PLAN 1

ISAP I.c Titlet Electrical Conduit Supports Revision No. O I 2 3 Revised to Reflect Incorporates . _ __ ._ Reflects Comments Description Original Issue NRC Comments SSER gn Plan Wh$ * '

/* $l/ '

C)

Prepared and )

i Recommended by:

x.vi. T... t.. a. r (Qg;gg  ;

l ./g at-e li, L...- .//fc) i1 / ,. . . .

ose. to/sl84 " 51Id 4 'il/,s iin)fG

/dlEl64 sEI"r*!.UIkT.an O9 be r b Q et. W. & 6 -N a 2,/ _

o,e. n 4 7'N lA //- 7( iistlaf 6/2+/sL l j '

R;vicion: 3 Pcg3 1 cf 14 ISAP I.c Electrical Conduit Supports

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT examined the non-safety related conduit support installation in selected seismic Category I areas of the plant.

The support installation for non-safety related conduits less than or equal to 2 inches was inconsistent with seismic requirements and no evidence could be found that substantiated the adequacy of the installation for non-safety related conduit of any size. According to Regulatory Guide 1.29 and FSAR Section 3.78.2.8, the Seismic Category II and non-seismic items should be designed in such a way that their failure would not adversely affect the function of safety related components or cause injury to plant personnel.

2.0 ACTION IDENTIFIED BY NRC Accordingly. TUEC shall propose a program that assures the adequacy of the seismic support system installation for non-safety related conduit in all seismic Category I areas of t'ne plant as follows:

Provide the results of seismic analysis which demonstrates p)

(

that all non-safety related conduits and their support V systems, satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.

- Verify that non-safety related conduit less than or equal to 2 inches in diameter, not installed in accordance with the requirements of Regulatory Guide 1.29, satisfy applicable design requirements.

3.0 BACKCROUND The issue pertains to non-safety reinted conduits (Train C) which, consistent with FSAR criteria, have not been seismically supported by design based upon the significance to safety. This issue was addressed generically throughout the plant by the TRT with specific interest in documentation justifying the non-seismic installation requirements for the non-nuclear safety related conduit less than or equal to 2 inches in diameter.

The generic issue of non-seinmic support of Train C hardware has been addressed during the construction of CPSES through the CPSES Damage Study Program. This systematic study was

[sO} performed for the interaction of all non-seismic piping and conduit greater than two inches in diameter, equipment, and

Revicicnt 3 Paga 2.cf 14 ISAP I.c 73

! ) (Cont'd) v

3.0 BACKGROUND

(Cont'd) structures with safety-related components in Category I buildings for Unit I and common areas. The support of conduit less than or equal to 2 inches in diameter was assumed to be adequate to assure that the conduit would not result in an adverse interaction during a seismic event. Accordingly, this interaction was not considered by the Damage Study. This assumption was based upon industry practice which recognized the inherent capacity of the anchorage and supports for these relatively lightly loaded installations. Uncontrolled calculations were generated in support of this assumption.

Design document DCA-4693 delineates support classification requirements and DCA-5106 delineates typical support details for Train C conduit two inches in diameter or under.

In accordance with Regulatory Guide 1.29 the CPSES Damage Study was performed to demonstrate that the failure of adjacent non-seismic items due to an SSE would not reduce the functioning of Seismic Category I systems and components, as defined in position C.1.a. through C.I.q. of the Regulatory

- Guide and PSAR Section 3.7B.2.8.

The seismic /non-seismic interaction study, which was performed in 1983, involved the walkdown of 287 rooms. The walkdown of a room was performed in accordance with Engineering Instruction CP-EI-4.0-36 (Control of Seismic and non-seismic Component Interaction Evaluations) with all potential interactions evaluated to the acceptance criteria developed for the study. Methods for resolution of potential interactions of a falling source impacting a nuclear related class target consisted of analysis, evaluation, use of barriers, administrative controls, or addition of seismic supports or restraints. Each of these activities includes pertinent requirements of the CPSES QA program. Maintenance

- of this evaluation is performed in accordance with Engineering Instruction CP-EI-4.0-53 (Maintenance of Damage Study Analysis).

o)

R;vicion: 3 P ga 3 cf 14 ISAP I.c

,q (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to provide a documented basis which demonstrates that Train C (non-seismic) conduit in seismic Category I areas will not have unacceptable seismic interactions with safety related items.

This objective addresses both of the actions identified by the NRC. The CPRT tasks that will be implemented to achieve this objective are

- Evaluation of the CPSES Damage Study Program by third-party personnel (under ISAP II.d).

Since Train C conduit greater than 2-inches was included in the Damage Study Program, this third-party evaluation will provide the documented basis needed to assure that Train C conduit greater that 2-inches in diameter will satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.

O V - Seisafc analysis of a sample of 2-inch and under diameter Train C conduit.

The seismic analysis of a sample of 2-inch and under conduit runs, assuming positive results, will provide a documented basis for the original CPSES Damage Study Program assumption that 2-inch and under Train C conduit will not cause unacceptable interactions with

- safety related items.

4.1.1 Train C Conduit Creater Than 2 Inches in Diameter The CPSES Damage Study Program evaluated all Train C conduit greater than 2-inches in diameter located in seismic Category I areas (approximately 500 runs).

About half of these runs were initially identified by the Damage Study Program as having unacceptable interactions with safety related items. The majority of these interactions (about 2/3) were resolved by the addition of seismic restraints. The remainder were resolved by analysis and evaluations.

The third-party evaluation of the Damage Study Program under ISAP II.d will address the adequacy of this program. Its overall scope and implementation. Since j the CPSES Damage Study Program utilised the same basic approach to evaluate potential seismic' interactions for*

Train C conduit and other non-seismically supported

1 R;viciont 3 Pcg3 4 cf 14 ISAP I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) items, a separate evaluation for Train C~ conduit greater than 2-inches is not necessary. The results of the CPSES Damage Study Program evaluation will be included in the ISAP II.d Results Report.

4.1.2 Train C Conduit Less Than or Equal to 2 Inches in Diameter Two samples of 2 inch and under. Train C conduit will be selected from the Unit 1 and common seismic Category I areas. One sample will be randomly selected and the other will be derived on an engineering basis using selection criteria that are important to seismic behavior. An evaluation based on a sampling approach is appropriate in this case since the intent is to test the original assumption of the CPSES Damage Study that 2 inch and under Train C conduit will not cause unacceptable seismic interactions with safety related items. Sampling from the Unit 1 and common areas is considered adequate since the same installation O criteria were used for Unit 1 and common and the portion of Unit 2 completed prior to the Tall of 1985.

At that time most of the Unit 2 Train C conduit was installed.

l 4.1.2.1 Population and Sample The population of 2 inches and under diameter. Train C/non-sefsmic conduit is represented by approximately 13,500 conduit runs, where a run is defined as a single conduit running between origin and destination (e.g. junction boxes, panels, etc.). Each run has a unique identifying conduit number. The percentage distribution of the population by conduit size breaks down approximately as follows:

3/4"9 - 55%

1" 6 - 17%

1 1/2" 6 - 19%

2" $ - 9%

The random sample is selected frem the 1 1/2 and 2 inch diameter populations, representing a total of approximately 3,700 runs. Sample O,' selection has been restricted to this segment

Revici:n: 3 Paga 5 cf 14 ISAP I.c

( (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) of the population because it is most significant from an engineering point of view due to greater inertia loads during an earthquake. This is evident from the loaded weights of the conduit by size 3/4"O - 1 pound / foot 1" 9 - 2 pounds / foot 1 1/2" 9 - 4 pounds / foot 2" 9 - 5 pounds / foot Supports are classified into three general categories generic (specified on design document DCA-5106), specials, and seismic S-0910, representing approximately a 2/1/0.2 split respectively. The generic supports have several predetermined configurations with recommended dimension tolerances specified. The special supports are designed in the field and usually consist of the generic support configuration with a Os variation to permit fitup under congested field conditions. The seismic S-0910' supports are seismically qualified for use on Class IE, Train A or B, conduit! however, these have been utilized on Train C, non-seismic conduit under limited circumstances.

Individual supports may provide restraint for multiple conduit runs.

The sample plan is consistent with Appendix D and will either provide reasonable assurance that the original assumption of the CPSES Damage Study Program was correct or will detect deficiencies to be investigated and dispositioned. In this case a deficiency is defined as a conduit run which fails to meet the performance requirements outlined in Sections 4.1.2.3, 4.1.2.4 and 4.1.2.5. A sample of 126 conduit runs will be evaluated, with a detection number of two (i.e., the critical region is three or more deficiencies found in the sample).

O

RVicien: 3 Pcg2 6 cf 14 ISAP I.c

( (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

The random sample is selected from the population of approximately 3,738 runs of 1 1/2 and 2 inch diameter conduit using a table of random numbers, thus, providing an equal chance that any single conduit run may be selected, regardless of its identity, physical attributes or quality. Runs, so selected, that are found in the field to be inaccessible for as-builting, will be excluded from the sample for practicality reasons.

Subsequent to the definition of the population of approximately 3,738 runs of 1 1/2 and 2 inch diameter conduit, it was determined that a small number of runs were inadvertently omitted from the population during the drawing takeoff process. All of these runs will be evaluated in accordance with the provisions of this action plan.

i The " engineering" sample of 126 conduit runs will be selected for evaluation based upon the criteria described below. The intent of this selection process is to define a subset i

of the population of conduit runs which is l expected to exhibit more limiting behavior in i a seismic event. An individual conduit run is a candidate for selection based upon its profile against specified attributes. As such, if 5 of the following 9 criteria are met, a run may be selected j Attribute Selection Criteria _

1. Significance to Safety Installed in Areas l Containing Equip- i

ment Required for Hot Shutdown

2. Conduit Size g 1 1/2" 0

3. Total Length > 20' i 4. Span Length OneSpan18'

5. Unrestrained tensch in > 15'

~

1.ongitudinal Direction

R; vision: 3 P ga 7 cf 14 ISAP I.c

[] (Cont'd) v 4.0 CPRT ACTION PLAN (Cont'd)

6. Number of Conduit / ?3 Supports

7. Number of Special > 25% of Supports Supports on Run

8. Congestion Unrelated Hardware Item within 6

( Inches of Run i

l 9. Elevation Upper Half of Building l The statistically based, random sampling i approach provides a clear statistical representation of the behavior of the total l

l populations however, the bias afforded by the engineering sample is judged to provide a more rigorous test of installed hardware.

Thus, the engineering sample providen defense-in-depth evidence supporting

.k-conclusions to be reached.

Rejects identified within the engineering sample (i.e., failing to meet the criteria of Sections 4.1.2.3 and 4.1.2.4) will be dispositioned in a similar manner as described under Option i for the random samples however, expansion of the engineering sample is not contemplated.

4.1.2.2 As-built Physical Configuration Documentation The subject conduit have been field run.

Isometric drawings or support details are not generally available for use in support of the conduit analytical efforts. Field verification of the installed conduit will be performed by CPPE Engineering in accordance with engineering instruction CP-EI-4.0-64, Field Verification of 2" Diameter and Sealler Train C Conduit Support Systems. A third-party will overview this process.

v

R;vici n 3 P go 8 cf 14 ISAP I.c

( ) (Cont'd) v 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.3 Seismic Analysis and Acceptance Criteria The intent of the seismic analysis is to provide quantitative evidence that the conduit support system will perform its intended performance requirements. This simply requires the support system to provide adequate anchorage and support for the conduit such that the conduit does not fall or sway in a manner to cause an intolerable interaction with a safety related item.

The support components will be initially screened using acceptance criteria that are consistent with that applied to Seismic Category II support hardware. (Seismic Category II hardware must remain physically intact; however, not necessarily functional as with Categ'ory I hardware.) Stress in the support members will be compared with 0.9 Ty (o

) (where Fy is the specified minimum yield strength of the material). Anchor bolt factors of safety will be compared to 3.0.

An equivalent static analysis accounting for important modes of behavior will be performed for each selected run. Each support will be considered independently in the vertical and transverse directions. Deflection will also ,

be computed to serve as input into a field walkdown which will verify that unacceptable interactions do not exist.

Later screening may be considered if it is required to verify acceptable performance of runs which do not pass the initial screening criteria. Analytical techniques may be refined and/or linited ductility considered, consistent with the intended performance requirements.

The seismic analysis will be subject to a design review by the third-party.

{} 4.1.2.4 Damage Analysis All selected runs will be considered for interaction with safety related targets due to sway or possible fall in circumstances, if

Revisicn 3 Pcg3 9 cf 14 .

ISAP I.c O

~

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) any, where a run fails to meet anchorage and ,

support performance requirements. This review will be accomplished through a '

walkdown by engineering and overview by the third-party.

4.1.2.5 Population Acceptance Criteria All identified interactions will be evaluated. Any conduit runs predicted to damage safety related targets to failure will be considered as deficient items in the random sample. All deficient runs will either be resupported or restrained as necessary to protect safety related equipment.

If no deficiencies are encountered, the population is accepted based on the '

evaluation of the sample. If one or two O deficiencies are encountered in a sample size of 126 (5cceptance number of 2) the sampling criteria are satisfied ar.d statements can be made about the fre'quency of rejects.

However, acceptance of the population with one or two deficiencies in the sample requires corrective action for these ,

deficiencies as well as root cause, generic  ;

implications evaluations to identify other hardware potentially affected. If these evaluations demonstrate that the observed deficiencies represent a unique condition, not likely to occur elsewhere in the plant, the population can be accepted. If the observed deficiencies are characteristic of a definable subset of the population, this subset would have to be inspected and accepted in order to accept the whole population. If'the observed deficiencies are i not isolated to a unique condition or a subset of the population, then additional inspections up to 100% are required to accept the population.

If the number of deficiencies is greater than l 2 for the random sample of 126, two options are available. Option 1 consists of identifying, based on the experience gaine.d in the analysis, the type of connections,

R vicion 3 Pcg2 10 of 14 ISAP I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) supports and/or geometries that are prone to exhibit similar behavior and appropriately evaluate these or modify them in the whole population including Units 1 and 2. The second Option consists of appropriately expanding the random sample utilizing the same 95 percent confidence level on the 5 percent defective rate criteria mentioned previously. This option will be selected if the cause for rejects is either indeterminate or isolated and without a systematic trend.

If the number of rejects is found to be too large for even an expanded sample, the entire population including Units 1 and 2 will be evaluated. Rejects identified within the engineering sample will be dispositioned in a similar manner as described under option 1 for the random sample; however, expansion of the engineering sample is not contemplated.

The attached logic diagram identifies tasks and the inter-relationship of tasks for resolution of this action plan.

4.2 Participants Roles and Responsibilities The organizations and. personnel that will participate in this effort are listed below with their respective scopes of work.

4.2.1 TUCCO Nuclear, Engineering- (TNE) Civil /Struecural ,

Discipline 4.2.1.1 Scope Sample selection , ;

- As-built documentation Damage analysis Assistance in overall evaluation and  ;

preparation of Results Report j 4.2.1.2 Personnel Mr. R. Hooton TNE Civil / Structural O -

Discipline Supervisor Mr. T. Wright Civil Engineer

i 4

Rcvisiont 3 Pag 2 11 of 14 ISAP I.c i

() (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4 Mr. D. West Field Damage Study Group Supervisor-4.2.2 Gibbs & Hill, Inc.

4.2.2.1 Scope Seismic analysic Acceptance criteria

- Lesign review I

4.2.2.2 Personnel Mr. J. Jan Chief Structural Engineer Mr. P. Huang Principal Structural

Engineer ,

() Mr'. W. Thonguthai Senior Engineer 4.2.3 Third-Party Activities 4.2.3.1 Scope Review of sample selection i

j -

Oversight of as-built documentation

{ process Design review of seismic analysis I -

Overview of field walkdown/ damage

study s ,

,- Review of overa11' conclusions i

Overall evaluation and preparation

! of Results Report 1'

4.2.3.2 Personnel i Mr. H. A. Levin TERA CPRT Civil /

Structural Review Team .

l i

Leader Dr. J. R. Honekamp TERA, TRT Issues Manager i

l

, - . _ _ . , _ ~ _ . _ , . _ . _ . . _ _ . _ _ _ . _ , _ _..

1 1 R:vicion 3 i .

P:go .12 of 14 ISAP I.c n (Cont'd)

)

(xJ .

4.0 CPRT ACTION PLAN (Cont'd)

Dr. C. Mortgat TERA Senior Structural Engineer Dr. F. A. Webster JBA Associate (CPRT Statistics Advisor) 4.3 Qualifications of Personnel Where tests or inspectipns require the use of certified inspectors, qualifications at the appropriate level will be to i

the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear

, Power Plants". CPRT third-party inspectors will be certified

, to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures.

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing

() procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the .

applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures The action plan will be conducted in accordance with applicable CPRT guidelines. In addition, instruction.

CP-EI-4.0-64, Field Verification of 2" Diameter and Smaller Train C Conduit Support Systems, will be used.

4.5 Standards / Acceptance Criteria Compliance with FSAR section 3.7B.2.8 and Regulatory Guide 1.29.

f 4.6 Decision Criteria The as-builting effort will provide two samples one i

I representative of the entire population and the other expected '

to exhibit.more limiting behavior in a seismic event. The

analysis of both these samples will determine whether the j population of two inch and under meets the requirement of l

Rt. vision -3 Pego 13 of 14  ;

1 SAP I.c (Cont'd)  !

i 4.0 CPRT ACTION PLAN (Cont'd) .

j Regulatory Guide 1.29 and FSAR section 3.75.2.8. Favorable

results of this sampling will verify conformance with I

acceptable interaction requirements. Unfavorable findings  !

^

will establish the need for additional review and corrective ~

i actions as discussed in 4.1.2.5. }

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Ravicion: 3 Pago 14 of 14 o ISAP !.c I (Cont'd)

(U ATTACHMENT FLOW CHART ELECTRICAL CONDUIT SUPPORTS 2

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COMANCHE PEAK RESPONSE TEAM Om ACTION PLAN ISAP II.a

Title:

Reinforcing Steel in the Reactor Cavity Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects Cornents Dascription Original Issue NRC Comments SSER on Plan Yf W 1ol5196 Reco e ded by:

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Rsvision: 3 Paga 1 of 8 ISAP II.a r%

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s Reinforcing Steel in the Reactor Cavity

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated a documented occurrence in which reinforcing steel was.omitted from a Unit I reactor cavity concrete placement between the 812-foot and 819-foot 1/2 inch elevations. This reinforcement was installed and inspected according to drawing 2323-S1-0572, Revision 2. However, after the concrete was placed, Revision 3 to the drawing was issued showing a substantial increase in reinforcing steel over that which was installed. Gibbs & Hill Engineering was informed of the omission by Brown & Root Non-conformance Report [C-669). Gibbs & Hil1~ Engineering replied that the omission in no way impaired the structural integrity.of the structure. Nevertheless, the additional reinforcing steel was added as a precaution against cracking which might occur in the vicinity of the neutron detector slots should a loss of coolant accident (LOCA) occur. A portion of'the omitted reinforcing steel was also placed in the next concrete lift above the 819-foot h-inch level. This was done to partially compensate for the reinforcing

, steel omitted in the previous concrete lift and to minimize the overall area potentially subject to cracking.

The TRT-requested documentation indicating that an analysis was

{d)~ performed supporting the Gibbs & Hill conclusion. The TRT was subsequently informed that an analysis had not been performed.

Therefore, the TRT cannot determine the safety significance of this issue until.an analysis is performed verifying the adequacy of the reinforcing steel as installed.

2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall provide an analysis of the as-built condition of the Unit I reactor cavity that verifies the adequacy of. the reinforcing steel between the 812-foot and 819-foot 1/2-inch elevations. The analysis shall consider all required load combinations.

3.0 BACKGROUND

I l

The concrete placement of the reactor cavity wall between elevations 812'-0" and 819'O " was made according to Revision "2" of Gibbs &~ Hill drawing 2323-S1-0572. Subsequent

-~g Revision "3"aof the same drawing added reinforcing steel in

, q) part of the wall that was already constructed in accordance with the prior revision of the drawing. Upon receipt of this i drawing in the-field, SDAR CP-77-6 and NCR-C-669 were issued to document that the concrete placement had been performed to l

4 Rsvision: 3~

Pcgs 2 of 8 ISAP II.a

~N (Cont'd)

3.0 BACKGROUND

(Cont'd)

Revision "2" of the drawing and the reinforcing steel added per Revision "3" was not installed. Gibbs & Hill reviewed the design with respect-to this as-built condition and determined the as-installed reinforcement to be acceptable. The Gibbs &

Hill Structural Job Engineer had these rebars added on

" Revision."3" based ~on engineering judgment to minimize the-possibility of cracking, although calculations for the cavity had not required these bars. The Gibbs_& Hill reply forwarded by GTN-19823 confirmed the as-built condition did not impair the structural integrity of the reactor cavity wall. _ Specific calculations justifying the adequacy.of the reactor cavity were not_ generated by Gibbs & Hill, because the initial design per Revision "2" of the drawing alcng with its design calculations did not require the reinforcement.

O 4.0 CPRT ACTION PLAN .

4.1 Scope and Methodology The objective of this action plan is to assess the design adequacy of the existing as-built condition of reactor cavity wall'and other areas within Units 1 & 2 where rebar were omitted and to' evaluate the engineering / field design change interface. The CPRT tasks that will be implemented to achieve this objective are described in the following paragraphs.

~

An analysis of the as-built reactor cavity wall will be performed to evaluate the adequacy of-installed reinforcing steel considering all applicable loading combinations.

Engineering calculations with applicable assumptions stated l therein will be performed to evaluate the subject wall with

' O "as installed" reinforcing steel between. elevations 812'-0".

and 819'-0 ". A third-party reviewer will verify the adequacy of the calculations.

Rsvicion: 3 Paga .3 of 8 ISAP II.a (Cont'd) w 4.0 CPRT ACTION PLAN (Cont'd)

The circumstances and engineering evaluation that led.to the provision for, and subsequent deletion of, the subject reinforcement in reactor cavity wall will be analyzed in light of design intent and structural integrity of the wall.  ;

In order to consider possible generic implications, all l instances of reinforcement omissions for Units 1 & 2 as documented in project NCRs will be researched. This effort will cover all the s'afety related Class I building structures.

A review of every case will be made to ascertain proper engineering evaluation and documentation exists in support of the disposition of each item. ' Additional documentation will be developed as required to insure appropriate disposition.

To provide increased assurance that all instances of.

reinforcement omissions similar to the subject case were identified, a random sample of pour cards will be reviewed to determine if the current design documents were used during construction. A sample review is appropriate for the following reasons:

The subject case was identified by an NCR and a 100%

review of NCRs documenting other cases of reinforcement omission will be peerformed.

The purpose of the sample review is to test the hypothesis that reinforcement omissions similar to the subject case have been documented by NCRs.

The population of pour cards for. Category I structures is homogeneous with respect to the pre-pour inspection process. Specifically, the inspection procedures require that the drawings used in the inspection be identified on the inspection checklist.

The sampling plan will be designed in accordance with )

. Appendix D and will result in reasonable assurance that rebar omissions similar to the subject case have been identified. j The minimum sample size per Appendix D is 60, with a detection '

number of zero. The acceptance criteria for the pour card review is that for each pour selected, any revisions to the applicable drawings issued after the pour was made do not change the reinforcement in the. selected pour.

An overall review of procedures governing design changes will h be performed to evaluate the adequacy of methods for controlling implemention of design-changes into construction.

i Emphasis will.be placed on.a review of project procedures used

Ravision: 3 Pcgs 4 of 8 1

ISAP II.a (Cont'd)

(~s 4.0 CPRT ACTION PLAN (Cont'd) to convey impending design changes immediately affecting l ongoing construction activity. The effectiveness of  !

procedures controlling such construction activities will be ,

verified by-reviewing implementation of all rebar omission  !

cases and major embedments. The engineering field interface review of major embedments will serve as another " test" of the adequacy of controls implemented by the civil discipline. The flow of activities initiated by engineering to convey impending design changes to the field as well as action leading towards appropriate construction hold will be identified and evaluated.

Upon conclusion of the procedural implementation review of rebar omissions and embedments, a determination will be made of the. potential applicability of any findings to other areas within the civil discipline. The enginearing field design change interface review will be broadened to include further evaluation outside the civil discipline if findings suggest that other disciplines could have similar problems.

/ The overall process for closure of this issue will be reviewed by the third-party reviewer.

~

The attached logic diagram identifies major tasks and the interrelationships of. tasks necessary for meeting the preceding objectives.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their. respective scopes of work.

4.2.1 TUGC0 Nuclear Engineering (TNE) - Civil / Structural Discipline 4.2.1.1 Scope Reviewing project NCRs for rebar omission cases Developing additional documentation if

-required to insure appropriate disposition of rebar omission NCRs.

[T N. /

Reviewing pour card'for rebars

Rsvicion 3 Pcgs 5 of 8 ISAP II.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

- Reviewing pour card for embedments Assistance in procedural review governing design changes and control of construction activities

- Assistance in overall engineering evaluation and development of Action Plan Results Report 4.2.1.2 Personnel Mr. C. R. Hooton Civil / Structural Discipline Supervisor Mr. D. G. Patankar Civil / Structural Lead Engineer 4'.2.2 Gibbs & Hill, Inc., New York, N.Y.

'4.2.2.1 Scope Gibbs & Hill, Inc., Structural Department - will perform the analysis /

design calculations as required under this action plan including the required design review of these calculations.

4.2.2.2 Personnel Mr. E. L. Bezkor- Structural Job Engineer Mr. A. M. Kenkre Structural Squad Leader Mr. S. Sengupta Senior Engineer Mr. C. Zion Senior Engineer Mr. M. N. Shah Senior Engineer 4.2.3 Third-Party Activities 4.2.3.1 - Scope Perform design review of calculations

-[ j prepared by Gibbs & Hill, Inc.

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R vicion: 3-Pags . 6 of 8 ISAP II.a '

s- (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

- Review of engineering / field design change interface.

Overview of NCR and pour card reviews.

- Evaluation of overall conclusions.

- Preparation of Results Report.

4.2.3.2 Personnel Mr. H. A. Levin TERA - CPRT Civil /

Structural Review Team Leader Dr. J. R. Honekamp TERA - TRT Issues Manager Dr. C. Mortgat TERA - Senior Structural Engineer

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Dr. J. Arros TERA - Structural Engineer 4.3 Personnel Qualification Requirements i Where tests or inspections require the use of certified inspectors, qualificatione tr' the appropriate level will be to I the requirements of ANSr445.2.6, " Qualification of i Inspection, Examination, Jed Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors vill be certified to the requirements of the third-party employer's Quality Assurance Program, and tr:sined to the applicable inspection

{ procedures.

Third-party participants in the implementation of this Action

Plan will meet the personnel qualification and objectivity l' requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Progran or to the specific requiremencs of the CPRT Program Plan. Activities performed 1 by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT ,

Program Quality", of the CPRT Program Plan.

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- Pags 7 of 8

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ISAP II.a  !

'(Cont'd) ~t 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures i

Calculations and evaluations performed by TNE Civil i-Engineering and Gibbs & Hill will be~ performed in accordance  !

with the procedures normally applicable-to those activities for CPSES. Third-party activities will be conducted in accordance with applicable CPRT guidelines.

! 4.5 Standards /Accepta'nce Criteria 3

Building Code Requirements for Reinforced Concrete -

]

4 ACI-318-71 and stipulations of section 3.8 of FSAR form the J basic standard / acceptance criteria of calculations performed t

} under this action plan.

l ~4.6 Decision Criteria If the documentation supporting "use as-is" rebar omission approvals is found insufficient, the docueentation will be supplemented as required to provide complete justification for i f

prior cngineering judgements.- ,

t' The results and conclusions of analysis / calculations performed

] and the evaluation of procedures governing the engineering /

field design change interface and the evaluation of implementation of these procedures in two areas of the civil l discipline will provide the basis for determination of the potential applicability to other areas and the need to broaden the review further.

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ISAP II.a (Cont'd) ,

ATTACHMENT REINFORCING STEEL IN THE REACTOR CAVITY 11 ; .

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP II b

Title:

. Concrete Compression Strength Rnvision No. 0 1 2 -3 Revised to Reflect Incorporates Reflects Coments D:scription Original Issue NRC Coments SSER on Plan i

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& (d Prepared and R;v ew Team Leader )  !

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Revicient 3 Paga 1 of 11 ISAP II.b

() Concrete Compression Strength

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated allegations that concrete strength tests were falsified. The TRT reviewed an NRC Region IV investigation (IE Report No. 50-445/79-09; 50-446/79-09) of this matter that included interviews with fifteen individuals. Of these, only the alleger

and one other individual stated they thought that falsification occurred, but they did not know when or by whom. The TRT also reviewed slump and. air entrainment test results of concrete placed during the period the alleger was employed (January 1976 to February 1977) and did not find any apparent variation in the uniformity of the parameters for concrete placed during this period. Although the uniformity'of the concrete placed appears to minimize the likelihood that low concrete strengths were obtained other allegations were raised concerning the falsification of records associated with slump and air content tests. The Region IV staff addressed these allegations by assuming that concrete strength test results were adequate. Furthermore, a number of other allegations dealing with concrete placement problems (such as deficient aggregate grading and concrete in the mixer too long) were also resolved by assuming that concrete strength test results were adequate. The TRT agrees with Region IV that, while the Os preponderance of evidence suggests that falsification of results did not take place, the matter cannot be resolved completely on the basis of concrete strength test results, especially if there is any doubt about whether they may have been falsified. Due to the importance of the concrete strength test results, the TRT believes that additional action by TUEC is necessary to provide confirmatory evidence that the reported concrete strength test results are indeed representative of the strength of the concrete installed in the Category I concrete structures.

2.0 ACTION IDENTIFIED BY NRC Accordingly TUEC shall determine areas where safety-related concrete was placed between January 1976 and February 1977, and i

provide a program to assure acceptable concrete strength. The program shall include tests such as the use of Schmidt Hammer Tests on a random sample of the concrete in areas where safety is critical. The program shall include a comparison of the results with the results of tests performed on concrete of the same design strength in areas where the strength of the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the program for performing these tests to the NRC for review and approval prior to performing the tests.

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R;vicion: 3 Pcg2 2 of 11 l

ISAP II.b 7'~' (Cont'd)

3.0 BACKGROUND

I Falsification of concrete strength tests is alleged to have occurred between January 1976 and February 1977. Air entrainment and slump tests have been reviewed, and no apparent variations were found in the the uniformity of the-parameters for concrete placed during the allegation time frame. Because these parameters were in accordance with the

laboratory approved concrete mix designs this reduces the 4 chances that low concrete strengths were obtained. Concrete compressive strength tests have been used to resolve allegations of falsifications of slump and air entrainment tests and allegations dealing with concrete placement problems (such as deficient aggregate grading and concrete in the mixer too long). Due to the importance of concrete compressive strength tests, the TRT requested that additional testing be performed by TUEC to confirm that concrete strength tests performed on the concrete in question are representative of the actual concrete strength. Therefore, TUEC has decided to implement a program to test the concrete in question for verification of acceptable strength.

I i

4.0 CPRT ACTION PLAN 1

4.1 Scope and Methodology The objective of this action plan is to verify the quality of the concrete in question. The CPRT tasks to be implemented to achieve this objective are:

Define the population of concrete poured during the time period in question and a second population outside of this time period for comparison.

4 Perform Schmidt Hammer Tests on a random sample of concrete from each population.

Rsvisient 3 l Pago 3 of 11- l ISAP II.b (Cont'd)

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4.0 CPRT ACTION PLAN (Cont'd)  !

I

- Compare the results of the Schmidt. Hammer Tests of the ,

two populations'and assess the significance of any i differences observed relative to the design value of I the concrete compressive strength.

These tar,ks are described in-more detail in the following paragraphs.

The relative strengths of concrete poured during the period in l question (concrete at issue, or CAI) and the concrete. poured outside this period (control concrete, or CC) will be compared using the Schmidt Hammer Test as a measure.of strength. The Schmidt (Rebound) Hammer Test, a non-destructive test, will be conducted in accordance with ASTM-C805-79 " Standard Test Method For Rebound Number of Hardene'd Concrete". The Schmidt Hammer is essentially a concrete hardness tester which measures the rebound of a spring loaded plunger after it'has struck a smooth concrete surface..

Using this indirect test of strength, the two populations of concrete will be compared empirically and statistically. In O addition to reporting the raw rebound number data, statistical summaries such as means and variances will be computed. Both parametric and non-parametric distributions may be considered for the two populations. For parametric distributions, goodness-of-fit t.ests will be performed on the samples.

Concrete cylinder data for the two populations will also be obtained, reviewed, and used for reference.

The two populations of hammer rebound ~ values will be compared at the tenth percentile level. The tenth percentile level .1:s selected as a point of comparison based on ACI Standard' 214-65, " Recommended Practice for Evaluation of Compression Test Results of Field Concrete", which gives the general guideline that no more than one in ten cylinder compression tests fall below the design strength.. The population of rebound numbers from the control-concrete will be used to establish a target tenth percentile rebound nusber. The tenth percentile rebound value of the concrete at issue will then be compared with this target value and other target values which

.are fractions of the tenth percentile of the control concrete.

Hypotheses that the tenth percentile rebound number for the CAI is greater than or equal to various target' values will be tested at a minimum level ~of significance of 5 percent.

The reason for considering more than one target.value is based on a preliminary review of data (including cylinder data) which indicates that at the population tenth percentile level

. - t_ _ J

Rsvisi n: 3 Pcgo 4 cf 11 ISAP II.b 7-~g (Cont'd)

V 4.0 CPRT ACTION PLAN (Cont'd) the CAI may be lower than.the CC. How much lower may be quantified by testing hypotheses using different target values which are fractions of the CC tenth percentile rebound value.

In addition, the significance level at which a hypothesis is just accepted will be determined. A higher significance level passed indicates a greater confidence that the hypothesis is true.

If it is determined that the tenth percentile of the CAI rebound values is not sufficiently close to that of the CC, either further testing will be performed to verify that the tenth percentile concrete strength for the concrete at issue is greater than the minimum design strength, or an evaluation will consider the significance of a lower strength concrete.

4.1.1 Test Program 4.1.1.1 Engineering shall determine the areas where concrete was placed in Category I structures between January 1976 and February 1977.

() 4.1.1.2 From these areas, engineering shall determine the number of concrete truck loads for chich part of the concrete of that truck load is exposed and testable.

4.1.1.3 Each truck load identified as exposed and testable will be assigned a unique number.

4.1.1.4 Grid areas corresponding to these truck loads will be selected at random to be tested.

4.1.1.5 The concrete surface in a selected area shall be prepared for testing per ASTM C805-79.

4.1.1.6 The prepared areas shall be tested in accordance with ASTM C805-79.

4.1.1.7 Engineering shal'. determine the areas where concrete was placed in Category I structures between March 1977 and August 1977.

4.1.1.8 From these areas, engineering shall determine the number of concrete truck loads for which part of the concrete of that truck load is exposed and testable.

4.1.1.9 Each truck load identified as exposed and testable will be assigned a unique number.

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R vicions .3 P:ga 5 of 11 ISAP II.b q (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l 4.1.1.10 Grid areas corresponding to these truck loads will be selected at random for testing.

4.1.1.11 The concrete surface in a selected grid area shall be prepared for testing per ASD1 C805-79.

4.1.1.12 The prepared areas shall be tested in i accordance with ASTM C805-79.

4.1.1.13 If necessary, concrete of known strength (determined by compression testing of core samples) will be Schmidt Hammer tested to calibrate hanuner rebound numbers with concrete strength.. This contingency is

, described below.

4.1.2 Sampling Plan At Comanche Peak concrete placement quality procedures p were based on required air entrainment and slump tests t

to be performed on each truck load. Test cylinders

]. from the first truck load and every tenth truck load thereafter were required to verify quality. These procedures were~ based on ASME-ACI 359 and ACI 318 which reference appropriate ASTM standards. Since the original quality control program was based on the unit of a truck load, TUEC will use a truch load as the unit to be tested in the present quality evaluation. This is consistent with the implicit assumption that a truck load represents the smallest unit of concrete with uniform material properties. The area for testing will

, be limited to the expoesd surface area where the 4

Schmidt Hammer Test can be performed. The ,

determination of the number of truck loads which were placed as exposed testable concrete will be determined ,

as fo11cws: '

Number of truck loads (slabs on ground) =

(l'0" depth X surface area) / 10 yd8 per truck Number of truck loads (suspended slabs, columns, walls) - Total cubic yards / 10 yd 8 per truck For deep slabs placed against the ground, a depth of one foot is used because during placement vibrators were used causing the concrete to flow and level out.

Thus only the truck loads placed the last foot of the l

R:vicion: 3 Pcgo 6 of 11 ISAP II.b m (Cont'd) x 4.0 CPRT ACTION PLAN (Cont'd) slab would be exposed. For suspended slabs between 18 l and 24 inches, the total number of truck loads is distributed equally to the top and bottom halves of the slab. .cor suspended slabs between-24 and 46 inches, i the voluoe of concrete is split into three equal l quantities, with one third at the top, one third on the l bottom, and one third in the middle of the slab. Only l the top and bottom layers are assumed to be testable.  ;

I j Engineering has determined that there were 326 concrete placements in Category I structures between January j 1976 and February 1977. Of these, 198 were identified as being accessible for surface testing. It has been-i determined that the total number of truck loads I corresponding to exposed surface concrete is approximately 1305. A similar number of truck loads will be used to define the population of-concrete not l in question. Both concrete populations will be i randomly sampled to a sample size of at least 100. 'The '

number 100 was chosen as an upper bound on a practical sample size for the statistical comparison of the two j populations and is not based on Appendix D.

4.2 Participants Roles and Responsibilities

{ The organizations and personnel that will participate in this

, effort are described below with their respective scopes of work.

4.2.1 TUGC0 Nuclear Engineering (TNE) - Civil / Structural i Discipline

! 4.2.1.1 Scope Concrete population determination J

Sample selection Locate test' areas and prepara operational i -

Assistance in evaluation of test

, data and preparation of Results Report 4.2.1.2 Personnel Mr. R. Hooto1 TNE~ Civil / Structural i Discipline Supervisor J

UcvBcSent U 1 Pago 7 cf 11 ISAP II.b (Cont'd)

O 4.0 CPRT ACTION PLAN (Cont'd)

Mr. C. Corbin Civil Engineer 4.2.2 Brown & Root ,

4.2.2.1 Scope Prepare concrete test surfaces 4.2.2.2 Personnel Craft personnel as required 4.2.3 Third-Party Activities 4.2.3.1 Scope Review of sample selection Perform hammer tests Document tests Review test data Review and statistical evaluation of test results t Preparation of Results Report 4.2.3.2 Personnel Mr. H. A. Levin TERA, CPRT Civil /

Structural Review Team Leader Dr. J. R. Honekamp TERA. TRT Issues Manager Dr. F. A. Webster JBA Associate ,

.(CPRT Statistics Advisor) l Dr. D. Veneziano MIT Professor of Civil l Engineering (Engineering Statistical Consultant)  ;

Mr. G. Lagleder SWRI Manager (Testing ar.d  ;

Inspection)  ;

O '

tfvU5Eent U Pcg3 8 of 11 ISAP II.b (Cont'd)

O 4.0 CPRT ACTION Pl.AN (Cont'd) 4.3 Personnel Qualification Requirements Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures.

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

1 Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities perforned by other than third-party personnel vill be governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Acceptance Criteria Three possible hypothesis tests will be considered for the evaluation of hammer rebound data, and one (or ones) selected with the most power. The three test methods include:

4.4.1 Method A tests whether the tenth percentile rebound value of the CAI is greater or equal to the target l value of the CC, where both populations are assumed to be normally distributed.

NOTE: The target value is defined as the tenth percentile or a fraction of the tenth percentile value.

4.4.2 Method B tests whether the percentage of rebound values in the CAI population above the target value of the CC is greater or equal to 90 percent. In this test the CC population is assumed to be normally distributed for purposes of establishing the target value (which may be defined as the tenth percentile or a fraction thereof),

but the distribution of CAI rebound values is unspecified (non-parametric).

4.4.3 Method C tests whether individual CAI rebound data values belong to the same distribution as the control

LDvBsBcn U Pcg3 9 of 11 ISAP II.b (Cont'd)

O 4.0 CPRT ACTION Pl.AN (Cont'd) concrete rebound values. No assumptions are made regarding either populatian distribution (non-parametric).

Although the power functions for these three methods are not directly comparable, preliminary indications are that both Methods A and B should be utilized, since they are of similar power when the CAI rebound data is assumed normally distributed in Method B. Method C appears to have very little power, and will therefore not be used to evaluate the data.

Based on the sample outcomes for the two concrete populations, a test statistic will be computed and the hypotheses regarding the concrete at issue will either be accepted or. rejected at the 5 percent level of significance. In addition, the level of significance at which the hypotheses would just be accepted will be determined.

If after reviewing the results of these hypothesis tests and the cylinder data, the CAI population is found to be significantly lower than the CC population at the tenth O percentile level, then a decision will be made to either calibrate the Schmidt Hammer Test to concrete of known strength, or to test cores from'the CAI.

If it is decided to calibrate the Schmidj; Hammer Test, concrete samples of known strengths and of similar age as the concrete in question will be used to calibrate the hansner rebound values.

The rebound values for the concrete in question, will then be converted to cylinder strengths taking into account the uncertainty in the conversion. If the tenth percentile strength is greater than the einimum specified the design strength, f', it will be concluded that the strength of the C

concrete in question is acceptable. If not, additional alternatives (e.g. analysis or further testing) will be considered.

Any such decisions will be documented as a revision to this action plan.

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ISAP II,b l l - (Cont'd) t ,

] 4.0 CPRT ACTION PLAN (Cont'd) i

! 4.5 Decision criteria  :

1 t i The action identified by the NRC (Section 2.0) will be j considered complete after all Schmidt Hammer Tests have been .

j completed, the results statistically. analyzed, and the two l

! concrete populations compared.

l If the comparison indicates a significant difference in the l two populations, then a decision will be made to further evaluate the CAI in accordance with Section 4.4.

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP II c

Title:

Maintenance of Air Gap Between Concrete Structures Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects Cormlents Description Original Issue NRC Coments SSER on Plan I

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ISAP II.c .

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Maintenance of Air Gap Between Concrete Structures  ;

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1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC l 1 1 The TRT investigated.the requirements to maintain an sir gap ,

between concrete structures. Based on the review of available  !

inspection reports and related documents, on field observations, '

i and on discussions with TUEC engineers, the TRT cannot determine whether an adequate air gap has been provided between concrete structures. Field investigations by Brown & Root QC inspectors indicated unsatisfactory conditions due to the presence of debris j in the air gap, such as wood wedges, rocks, clumps of concrete.and j rotcfoam. The disposition of the NCR relating'to this matter

! states that the " field investigation reveals that most of the ,,

j material has been removed." However, the TRT cannot determine.from j this report (NCR C-83-01067) the extent and location of.the debris j j remaining between the structures.

}

Based on discussions with TUEC engineers, it is the TRT's i I understanding that field investigations were made but that no l permanent records were maintained. In addition .it is not apparent i

that the permanent installation of elastic joint filler material ,

("rotofoam") between the Safeguard Building and the Reactor '

Building, and below grade for the other concrete structures, is '

consistent with the seismic analysis assumptions and dynamic models

, used to analyze the-buildings, as these analyses are delineated-in l l the Final Safety Analysis Report (FSAR). The TRT, therefore, concludes that TUEC has not adequately demonstrated compliance with j

j FSAR Section 3.8.1.1.1, 3.8.4.5.1, and 3.7.8.2.8, which require

} separation of Seismic Category I buildings to prevent seismic j interaction during an earthquake.

f 2.0 ACTION IDENTIFIED BY THE NRC 5 Accordingly, TUEC shall: l l

Perform an inspection of the as-built condition'to confirn '

l that adequate separation for all seismic Category I structures  !

j has been provided. "

I -

Provide the results of analyses which demonstrate that the presence of rotofoam and other debris between all concrete structures (as determined by inspections of the as-built.  !

conditions) does not result in any significant increase.in seismic response or alter the dynamic response characteristics ,

of the Category I structures, components and piping when 4

1 compared with the results of the original analyses.

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Rsvicicn 3 Pcg3 2 of 10 ISAP II.c (Cont'd) 0-~.

3.0 BACKGROUND

l TUGC0 has committed in the FSAR to provide separation between buildings to prevent unacceptable seismic interaction during an earthquake.

Rotofoam was used as a concrete forming method to provide the design separation until November 1977 when Gibbs & Hill notified Brown & Root of the need to maintain an air gap free of rotofoam in most locations. Design documents permit permanent installation of rotofoam for specific locations.

4 Based upon the difficulty of removing rotofoam, Brown & Root was advised to modify concrete forming procedures to provide the specific gap between structures using metal formwork instead of rotofoam. Elevations at which rotofoam was required to be removed were identified, Halliburton was contracted to effect the removal process, and the removal was inspected and documented by QC. The QC procedures were then revised to ensure that the seismic gap was in accordance with-the. design drawings. However, Inspection Reports subsequent 1

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to the removal process have identified rotofoam and other types of debris in areas where the design drawings require air gaps.

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1 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to assure that the condition of the air gaps.between concrete structures is adequate to prevent significant interaction during a seismic event. The CPRT tasks that will be implemented to achieve this objective are:

Inspect the condition of the seismic air gaps to O*

identify those. areas which are not in compliance with the design drawings.

Revision: 3 Paga 3 of 10 ISAP II.c (Cont'd) 4.0 CPRT ACTION PLA'N (Cont'd) i For all areas which do not comply with the design drawings, either correct the condition or provide an-4 evaluation which demonstrates that the condition meets the FSAR commitments.

Provide a final as-built inspection for al'1 areas which required correction.

t Provide an analysis which demonstrates-that any elastic material or debris remaining in the' gaps does not

result in a significant adverse effect on the seismic response of Category I structures, components or piping.

The attached logic diagram-identifies major tasks and-the interrelationship of tasks necessary for meeting the preceding objectives.

The following general sequence will be used to resolve the

' issue:

j' -

QC inspections of the seismic gaps between Category I j

structures and between Category I and non-Category I structures for both Unit I and Unit 2 will be reperformed and documented. With.the aid of special video equipment.

QC will inspect the existing-conditions of the double-walled building separation gaps.* These inspections will verify the separation l gap width and will locate and identify the size and ,

type of materials in the separation gap to the extent practical. A sufficient level.of detail will be provided in the findings to support a decision to l-either remove existing debris o'r analyze its acceptability. Video tapes will be available that provide viewing of the double-walled separation gap conditions.

Inspections will also be performed on. single-walled building separation gaps ** which will identify the as-built ~ conditions, i.e.. existence of elastic joint fillers, fire protection seals, flashing, etc.

1 Double-walled building separation gaps are separation gaps'between '

two buildings which have a solid wall (except-for openings from one building to the other) on each building face for the full height of a specific separation gap..

• • Single-walled building separation gaps are separation. gaps between l two buildings where one building has a solid' wall (except for l l openings) for full height of a specific gap and the opposite

! building provides. gap walls only at slab, beam, column, or wall l ends. l 1

Pags 4 of 10 l ISAP II.c (Cont'd) l O' 4.0 CPRT ACTION PLAN (Cont'd)

T'hese activities will be overviewed by Southwest Research Institute (SWRI), a third-party organization.

The'as-built conditions will be reviewed to ensure acceptability with design requirements. Any

. unacceptable conditions noted will'be corrected or an analysis performed to' support the acceptability of the j

- conditions.

- The new as-built inspection documentation will be i reviewed with available construction documentation and past inspection records to assess the sequence of events leading to the existing condition and the cause. >

Based upon the as-built inspecticn, a decision will be l mcde to either remove any debris encountered in the l separation space through vacuuming or other methods or l evaluate the significance of the as-built condition to i the design basis.

As necessary based upon the results_of the previous

three steps, an analysis will be performed using j revised stiffnesses (or spring values) based on the ,

j actual debris characteristics and locations. The

re-evaluation will determine the change in frequency

! from the original fundamental mode and evaluate i

structural interaction. effects. The significance of any change in frequency or interacticn will be

,2 determined as it applies to buildings, components, and-piping.

1.

i The original analyses were based on clear gaps between  ;

the_ buildings; subsequently, Gibbs & Hill evaluated

! portions of the separation areas for.the effects of the' l j . presence of rotofoam~(where it could not be removed).  !

l These earlier evaluations as well as any determined

, necessary as-part of the effort described above will.be subj u t to design review by a third-party.

Engineering.will issue necessary instructions for-removal of debris which significantly impact the l

3 original design calculations or debris-to be removed xein t an a t i n si n ,

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QC will document the final as-built conditions and SWRI will overview this process.

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Rsvisient 3 Pcg2 5 of 10 ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

- After receipt of QC documentation verifying removal and the final as-built condition, the engineering calculations performed as part of this action plan will be revised as necessary to reflect.the final as-built )

conditions..

Engineering and QA/QC will review project procedures for establishment of requirements for maintenance of adequate separation conditions.

- Engineering will evaluate the need to update the FSAR to reflect the as-built condition.

Engineering will evaluate the cause of the existing condition and its applicability to other areas of the plant. Based upon these findings, a decision will be made to expand the evaluation and implement appropriate actions.

Issues relevant to construction housekeeping methods are being addressed as part of the response to NRC,

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January 8, 1985 letter on construction QA/QC issues (See CPRT Action Plan Number VII.a.10, Housekeeping).

A third-party will review conclusions reached on cause and applicability to other areas as well as the acceptability of the final as-built condition.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of  !

work.

4.2.1 TUGCO Nuclear Engineering (TNE) - Civil / Structural Discipline 4.2.1.1 Scope Coordinate as-built and perform ,

evaluations to determine further  ;

removal requirements l 1

Assist design engineer'in final analysis and conclusions 1

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Rovicicn 3 l jhj Pogs 6 of 10 ISAP II.c (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd).

Issue design changes as required to document permanent items remaining in gaps; disposition Non-conformance Reports (NCR) relating to this matter l Assist in preparation of Results Report 4.2.1.2 Personnel Mr. C. R. Hooton TNE Civil / Structural Discipline Supervisor Mr. M. Wells Engineering Specialist j

4.2.2 Gibbs & Hill, Inc. , New York, N.Y.

4.2.2.1 Scope Perform calculations for effect of the as-built conditions on the O- seismic response and structural behavior 4.2.2.2 Personnel Mr. E. L. Bezkor Structural Job Engineer Mr. A. M. Kenkre Structural Squad Leader 4.2.3 TUGC0 Quality Assurance 4.2.3.1 Scope Inspect separation for compliance with documents and document findings Document general debris location and type before or during craft removal Document final as-built condition including location, type, and approximate size of permanent debris or rotofoam

() 4.2.3.2 Personnel Mr. P. Halstead Quality Engineering Supervisor (Acting)

,. Ravicien: 3 Pego 7 of 10 ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.4 Brown & Root, Inc.

4.2.4.1 Scope Area preparation for QC Inspections and Craft support as required for-implementation and completion of CPRT Action Plan for this issue

- Removal of debris as directed by engineering and QC Installation of required seals upon completion of verification activities 4.2.4.2 Personnel Craft personnel as required 4.2.5 Third-Party Overview 4.2.5.1 Scope Perform design review of calculations prepared for the effect of the as-built conditions on the seismic response and structural behavior Overview of inspection activities Review of inspection documentation Evaluation of overall conclusions Preparation of Results Report

4.2.5.2 Personnel Mr. H. A. Levin TERA, CPRT Civil / Structural Review Team Leader Dr. J. R. Honekamp TERA, TRT Issues Manager O

k/

s Mr. P. Turi TERA, Senior Mechanical.

Engineer i

R:vicion: 3

. Pegs 8 of 10 ISAP II.c (Cont'd) i

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.4.0 CPRT ACTION PLAN (Cont'd)

Mr. G. Lagleder Southwest Research Institute 4.3 Personnel Qualification Requirements Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to  !

the requirements of ANSI N45.2.6, " Qualification.of  ;

Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures.

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or'to the specific O5 requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

1 .

i 4.4 Procedures i

QC inspections will be performed in accordance with procedure QI-QP-11.0-3 and associated operational. travelers for Unit I and Unit 2 areas. This procedure will provide criteria for inspecting separation dimensions, documenting both permanent and removed debris, and maintenance of the inspected conditions. Results will be documented on Inspection Reports.

Craft will prepare areas for inspecting and for cleaning out of debris. Existing site procedures will~be used for these activities, primarily issuance of inspected Item Removal Notices (IRN) for removal of permanent seals.

4.5 Qualification of Personnel The QC inspectors performing the separation verifications and j as-builts will be trained in the applicable requirements of procedure QI-QP-11.0-3. The minimum QC certification level l

O necessary for this activity will be Level I. This procedure has been revised to include as-built inspection and maintenance of the separation condition as well as l

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Revision: 3 Pag 2 9 of 10 i

ISAP II'.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) verification of the design separation requirements. The l inspectors to be used in the action plan were not involved in previous final separation verifications.

4.6 Standards / Acceptance Criteria 4.6.1 All air spaces are acceptable per the FSAR provided that separation requirements shown on the design drawings (including ACI tolerances) are met. QC inspection reports will be prepared documenting these areas.

4.6.2 Specific areas have been approved on the design drawings for permanent installation of elastic joint filler; engineering analysis will be provided justifying this material. QC inspection reports will document rotofoam presence in these areas.

4.6.3 Remaining areas that contain debris not accessible for removal will be evaluated by engineering based on the trie, size and location indicated on the inspection

(. reports.

4.7 Decision Criteria The engineering analysis for the final as-built condition will document the degree to which debris may affect dynamic response characteristics of the structures. If the engineering analysis reveals a significant. modification of response, the response will be quantified by analysis and response values will be compared to the original response values for determining separation acceptability. Upon evaluation of any change in frequency and structural behavior as compared to the original values, the necessity for further evaluation of components and piping'will be considered. ,

The evaluation of the root cause of this issue will determine what course of action is taken to assess the potential i

applicability to other areas of the plant.

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R:vicien 3 Pega 10 of 10 ISAP II.c (Cont'd)

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ATTACHMENT MAINTENANCE OF AIR CAP BETWEEN CONCRETE STRUCTURES I

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN l

ISAP II.d

Title:

Seismic Design of Control Room Ceiling Elements Revision No. 0 1 2 3 Revised to Refleci. Incorporates Reflects Coments D7scripeion Original Issue NRC Coments SSER on Plan W$$

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R vicient 3 Pego 1 of 16 ISAP II.d Seismic Design of Control Room Ceiling Elements

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated the seismic design of the ceiling elements installed in the control room. The following matrix designates those ceiling elements present in the control room and their seismic designation:

1. Heating, Ventilating and Air Conditioning - Seismic Category I

2. Safety-Related Conduits - Seismic Category I

3. Nonsafety-Related Conduits - Seismic Category II

4. Lighting Fixtures - Seismic Category II

5. Sloping Suspended Drywall Ceiling - Non-Seismic

6. Acoustical Suspended Ceiling - Non-Seismic

7. Louvered Suspended Ceiling - Non-Seismic According to Regulatory Guide 1.29 and FSAR Section 3.7B.2.8, the seismic Category II and non-seismic items should be designed in such a way that their failure would not adversely affect the 3

functions for safety-related components or cause injury to operators.

For the non-seismic items (other than the sloping suspended drywall ceiling), and for nonsafety-related conduits whose diameter is 2 inches or less, the TRT could find no evidence that the possible effects of a failure of these items had been considered. In i addition, the TRT determined that calculations for seismic Category l II components (e.>;., lighting fixtures) and the calculations for i the sloping suspended drywall ceiling did not adequately reflect the rotational interaction with the non-seismic items, nor were the fundamental frequencies of the supported masses determined to assess the influence of the seismic response spectrum at the control room ceiling elevation would have on the seismic response of the ceiling elements.

2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall provide:

The results of seismic analysis which demonstrates that the non-seismic items in the control room (other than the sloping suspended drywall ceiling) satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.7B.2.8.

An evaluation of seismic design adequacy of support systems l for the lighting fixtures (seismic Category II) and the

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suspended drywall ceiling (non-seismic item with modification) l which accounts for pertinent floor response characteristics of i the systems.

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Rsvicion: 3 Pega 2 cf 16 ,

[  !

ISAP II.d (Cont'd)-

2.0 ACTION IDENTIFIED BY NRC (Cont'd)

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- Verification that those items'in the control room ceiling not installed in accordance with the requirements of Regulatory Guide 1.29 satisfy applicable design requirements, i

- The results of an anal'y sis that justify the adequacy of the

non-safety related conduit support system in the control room

] for conduit whose diameter is 2 inches or less.

1 The results of an analysis which demonstrate that the foregoing problems are not applicable to other Category 11 and I non-seismic structures, systems and components'elsewhere in the plant.

l

3.0 BACKGROUND

i i ,

3.1 Discussion of Specific Technical Issue i

i i Regulatory Guide 1.29 states: "Those portions of structures. l systems, or components whose continued function is not required but whose failure could reduce the functioning of any l plant feature included in Items 1.a through 1.q above to an '

i unacceptable safety level should be designed and constructed

so that the SSE would not cause such failure." Specifically l Item 1.n states

"The control room, including its associated.

vital equipment, cooling systems for vital equipment, and life l support systems, and any structures or equipment inside or 1 outside of the control room whose failure could result in incapacitating injury to the occupants of the control room." '

f' The specific issue. involves the ability of the control room ceiling and other non-safety related ceiling elements, i.e.

conduits and lighting fixtures to remain in place during a i' seismic event thus avoiding.the potential of disabling operators due to its failure. Portions of the ceilicF are non-seismic, non-safety related and do not have provisions of l seismic Category II installations which are seismically i supported or. restrained as described below.

i j In reviewing the design of the control room ceiling the TRT has requested that analyses be provided which demonstrate that the provisions of Regulatory Guide 1.29 and FSAR section 3.78.2.8 have been satisfied for all non-safety related items.

!, This request encompasses the architectural ceiling system and

!- non-safety related conduit whose diameter is two (2) inches or

less.

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R;vicion: 3 P2g2 3 cf 16 1

ISAP II.d (Cont'd)

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3.0 BACKGROUND

(Cont'd)

The TRT has requested that seismic calculations for the support systems of the lighting fixtures and the suspended gypsum ceiling in the control room reflec' all loading conditions that would be experienced due .o a seismic event.

In addition, an analysis has been requested by the TRT to show that the present design of the attachment of gypsum to its frame will ensure separation will not occur during a seismic event.

3.2 Description of Existing Ceiling and Other Ceiling Elements

! The control room ceiling at the location of the control board

) area proper is comprised of three (3) ceiling systems. Refer

to the isometric sketch shown in Fig. II.d-3.

The ceiling system directly adjacent to the control boards at elevation 839'-6" has suspended louvered panels with exposed l grid utilizing interlocking main and cross tees for panel j support. The louvered ceiling is directly below the lighting fixtures above the control boards and is supported by 12 gauge, minimum, cold drawn wire attached to the seismically j

l O restrained unistrut lighting support grid l'-0" above. The 2'-0" x 4'-0" louvered ceiling panels are supported by the l main and cross tee grid and by closure strips at edge j intersections. Above the louvered ceiling, at the location of

, the lights is mineral acoustical tile which rest on the light j ffxture flanges with tee sections installed perpendicular to 4

the light fixtures for end of tile support.

I The second ceiling system, a sloping gypsum wall, is near the center of the control board area and extends from elevation 839'-6" to the underside of the above floor. This sloping gypsum wall was originally constructed as non-seismic and non-safety related. The construction used Ib" supportirg channels attached to the underside of elevation 854'-4" floor I

slab with a 16 gauge C channel secured with 2-3/8" O Hilti

, Kwik Bolts. The vertical 1 " channel supports for attaching

the horizontal furring channels is attached to the supporting I channels at the bottom of the wall. The upper attachment for the lh" vertical channel is by a bolted connection to a 16 gauge C channel secured to the underside of elevation 854'-4" floor slab with 2-3/8" O Hilti Kwik Bolts. The bolted connections used k" 9 bolts. The lh" channels are by U. S.

Gypsum, constructed of cold rolled 16 gauge st.sel with 19/32"  :

flange and th" depth. Horizontal " hat shaped" ft. ring i 3

O channels are placed on l'-0" C to C for attaching te 3/8" l l b gypsum panels. The horizontal furring channels.are s,' cured to ,

4 the support channels with galvanized furring channel clips. '

! Ravioicn 3 Pcg2 4_of 16 i

j ISAP II.d j (Cont'd)

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3.0 BACKGROUND

(Cont'd) l

! A review of the ~ aass involved in the slopirig gypsus wall

! determined that seismic restraint was necessary to assure ,

! integrity of the ceiling system during a seismic event. To  !

i provide assurance.that the sloping gypsum wall framework would l

{ remain in place during an SSE, restraints were added by '

! attaching stainless steel cable through alternating horizontal j furring channels next to each vertical 1 "' channel. The six j 1/8" stainless steel cables are suspended from two (three j each) angles which are anchored to the underside of elevation ,

854'-4" floor slab. In addition the furring channel ~

f attachment to the vertical channels was reinforced by adding 2-k" self tapping sheet metal screws at each intersection.

The 3/8" sypsua board is attached to the sloping wall furring channels with 1" type 5 bugle head screwr, on 12" vertical and j 7" horizontal spacing. Screw attachments..of this type, in f gypsua panels meeting ASTM C-36 requirements typically exhibit

! 60 pound pull out each.

1 i

The sloping gypsus wall was evaluated for acceptability and lO j

compliance with Regulatory Guide 1.29._ Based on the original design and addition of seismic restraint cables, and considering the quantity and pull out strength of the screw

attachments securing the gypsua panels, the sloping gypsua j wall was considered acceptable as restrained.

/ ,

l The third ceiling system is at elevation 847'-2" in the center

!' of the control board area. This ceiling is again the louvered ceiling configuration which is supported by suspending the

, main tees from the seismically restrained unistrut lighting j support grid above. Suspension of the main tees is by 12

gauge, minimum, cold drawn wire. The 2'-0"x4'-0" louvered 1

ceiling panels are supported by the main and cross tees grid and closure-strips at sloping wall intersection.

j All lighting fixtures in the control room complex are j seismically restrained in accordance with the restraint i details shown on Gibbs & Hill drawing 2323-El-1704-01. The j lighting fixtures located in the control board area proper are 1

also attached to-seismically restrained unistrue grid l framework. The seismic ^ restraint of these fixtures and i members was deemed necessary to ensure compliance with the

{ ' requirements of Regulatory Guide'1.29.

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R:vicicnt 3 P:go 5 cf 16 ISAP II.d (Cont'd)

3.0 BACKGROUND

(Cont'd) 3.3 Approach Selected TUEC has reviewed the issue raised by the TRT, and a decision has been made to remove and replace the control room ceiling in the interest of an expeditious resolution. A recent l

. assessment of the ceiling design indicates that the structural integrity of the three systems could be demonstrated, but the process would be time consuming. Details of such evaluations involve modeling assumptions or test configurations for which

. it is anticipated that technical consensus would be required.

l Since such details are not likely to be discussed in published

literature or regulatory communications, the resolution could delay closure of the issue. The approach taken to the ceiling '

redesign is to establish a design which can readily be qualified seismically and to subject the design to a third-party review.

Action Plan Item Number I.c addresses the other specific i technical issue, 2 inch and smaller non-seismic conduit.

In addition to the specific technical issues there were

' O questions raised by the NRC regarding the general methods utilized for addressing potential damage to safety-related items caused by non-Category I items. This aspect was discussed during the October 23, 1984, public meeting regarding the plan for responding to TRT issues. Based on '

that meeting CPRT has elected to conduct a third-party design verification of'the damage study program to address generic a

implications of the two specific technical issues previously l identified. The verification effort will include an assessment of the control room lighting fixtures and all other plant architectural features, for example non-seismic partitions, other architectural ceilings, doors, etc.

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan are:

Assure that the control rcom ceiling, including equipment and fixtures attached to or located in the space above the ceiling, satisfies the seismic

, interaction provisions of Regulatory Guide 1.29 and Q

v FSAR Section 3.7B.2.8.

R3visi:n 3 Paga 6 of 16 ISAP II.d (Cont'd)

O 4.0 CPRT ACTION PLAN (Cont'd)

- Assure that the seismic interaction provisions of Regulatory Guide 1.29 have been properly impicmented for other Category II and non-seismic structures,

< systems and components elsewhere in the plant.

These objectives encompass.the actions identified by the NRC and will be impir.mented as three related but distinct tasks:

l

- Seismic design of the new control room ceiling.

- Verification of seismic damage assumptions for 2 inch and smaller conduit Verification of seismic damage study methods and implementation, including non-seismic architectural features review The first task is restricted to a technical resolution of the

, specific issue regarding seismic interaction from control room ceiling as identified by the TRT. The second task is 1 incorporated in its entirety within Action Plan Item I.c. The

third task is being undertaken to evaluate generic implications of the issues raised in the first two tasks, and

to independently verify the adequacy of the resolutions.

3 Design changes, based on necessity or expediency, might result to address results of the verification effort.

4.1.1 Ceiling Element Design The original design of the ceiling systems was based on i the premise that failure of architectural features with small masses would not be adverse to the occupants of the control room. Although a preliminary design assessment by the Project supports the position that l the design complies with Regulatory Guide 1.29, that assessment relies on that same judgment. In lieu of efforts directed at developing confirmatory analysis to further support the position and to finalize the structural evaluation, TUEC has elected to remove and replace the ceiling to preclude unacceptable seismic interaction. Figure II.d-1 is a flow diagram for activities associated with the design effort. The major steps are discussed in the following subparagraphs.

i

/N 4.1.1.1 The existing ceiling structure has been I removed and a new ceiling, which can be readily qualified seismically, will be

R;vioicn 3 Pcg3 7 of 16 ISAP II.d

p (Cont'd)

V

)

4.0 CPRT ACTION PLAN (Cont'd)

! installed. The seismic design of the new I ceiling structure, including attached l architectural features will be reviewed by j the third-party.

4.1.1.2 The process.for evaluation of potential seismic interactions among components above j the new control room ceiling or between these components and the ceiling structure will be reviewed by the third-party.

i 4.1.2 Conduit of Diameter Less than or Equal to 2 Inches I See I.c Action Plan.

4.1.3 Damage Study Verification

, The third task of the II.d Action Plan to resolve the TRT issues is directed at a determination of the extent j to which similar aspects of the Unit 1 damage study g program could require technical resolution.

l

\

Additionally if technical issues develop, the plan includes a course of action to determine the

applicability to Unit 2 and resolve them for both j units. ,

j The seismic /non-raismic interaction s:udy, which was performed, in 151's. involved the walkdown of 287 rooms.

All potential interactions were evaluated to the ac.ceptance criteria developed for the study. Methods for tenolution of potential interactions of a falling source impacting a nuclear safety class target consisted of analysis, evaluation, use of barriers, administrative controls, addition of seismic surports or restraints. Each of these activities includes pertinent requirements of the CPSES QA Program.

The design of the ceilings in the control room was predicated on the position that failure of architectural features with small masses would not 4

adversely affect the occupants of the control room and, consequently, the safety of the plant. On this basis, i

Engineering advised the Damage Study Group that the control room architectural features in question should not be evaluated as part of the Damage Study Program.

O V Therefore, these features were not evaluated by the

, Damage Study Group. Exclusion of other areas of evaluation due to similar inputs and assumptions is a focal point for the Damage Study verification.

- - _ - _ _ _ - . . - _ = _ - - _. .- _

R;vicion: 3 P:ga 8 cf 16 ISAP II.d '

I (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) y The activities in this phase include a project review of all plant architectural features, and design

, modification, if required, to resolve resulting concerns. The preliminary TUEC assessment of the l entire damage study area indicates that if omissions exist they would most likely be in that aspect of the t

program. Also included in the action plan is an extensive third-party evaluation of all aspects of the Unit 1 Damage Study Program. The major steps are j discussed in the following subparagraphs. Refer to ,

Figure II.d-2 which is a flow chart of activities.

4.1.3.1 Architectural. features e.g., doors, ceramic

tile, gypsum board, etc., were not viewed as

! structural in nature therefore considerations i such as seismic qualifications may l inadvertently have been omitted.

] A TUEC evaluation will be performed on i architectural specifications and drawings to identify non-seismic sources to be evaluated i in accordance with Regulatory Guide 1.29 and .

l FSAF. Section 3.75.2.8. Any architectural features in Units 1~and 2 which are

, determined to have a potential for seismic

! interaction will.be either modified or subjected to a damage study assessment. ,

4.1.3.2 A third-party review of the architectural

features evaluation will be performed j including verification oft l

The entire structural assessment

{ which is perforred by CPPE-TUCCO to j determine which architectural i features have a potential for j seismic interaction.

l

- The damage study of all architectural features which potentially cause seismic interactions.

j - A design review of all resolutions

to unacceptable interactions i

including review of all drawing revisions which result.

t

=. . . -.

R:visient 3 P.:g2 9 of 16 ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

! 4.1.3.3 Procedures and methods for conducting the seismic damage stsdy will be evalusted by a

third-pirty including a review of interfaces I between the damage study group and other i disciplines which either provide input for i the evaluation or act upon the damage study group's reconunendations. This evaluation will examine whether there are other generic areas in addition to the architectural features which may have been omitted.

i

) 4.1.3.4 Selection criteria have been established by 1 the Project to identify the set of all j

non-Category I systems, structures and components which are considered for seismic ints.raction with safety-related items.

3 One of these criteria is that Category II l,

, items are excluded because they are supported or restrained to preclude seismic interaction. The design criteria for ,

{ Category II items and all other selection i j criteria used by the Project will be

subjected to third-party review. The ,

I detailed Category II criteria will be

compared with Category I criteria and I j- methodology as well as the more general .

Category II FSAR commitments. Where the i Category II criteria are not the same as 4

Category I or are less detailed, the l acceptability will be assessed based on engineering principals applicable to the I

specific methodology.

4.1.3.5 ThebasisusedbytheProjectfordetermining-l

, the physical interactions of items identified a in Section 4.1.3.1 will be subjected to i third-party review.

! 4.1.3.6 Criteria for evaluation of the consequences j of interactions will be subjected to third-

party review.

4.1.3.7 Implementation of the methods for performing l the damage study will be design reviewed in a

third-party engineering audit of the Project l

documentation, including as necessary i

! engineering walkdowns of selected interactions. The engineering audit will

?

I

Revisi:n: 3 P:ga 10 cf 16 ISAP II.d t

(Cont'd) l 4.0 CfRT ACTION PLAN (Cont'd) assess adequacy of documentation and validity l of engineering conclusions. Included within l this task is a review of the way in which l classified and declassified rooms were

! distinguished and addressed.

The audit will focus on those implementing documents which are most substantially supported by engineering judgements as distinct from simple calculation or direct application of rules. Based on a complete review of the various methods for categorizing interactions as acceptable, cases will be selected to check the l

implementation of each method.

, 4.1.3.8 A third-party comparative damage assessment will be performed in the selected rooms to assess the consistency with which interactions were identified. The rooms will be chosen based on a selection criteria which O consider the following aspects:

Functional and physical aspects of the systems and components within

. the space Importance of components and systems to safety '

Representativeness of the room from the standpoint of physical proximity of potentially interactive items Balance of types of non-seismic items, i.e. architectural. conduit piping, equipment 4.2 Procedures To Be Used In addition to the applicable analysis, design, construction and QC procedures which will be used to implement the control room ceiling modifications, procedures direct',y applicable to the damage study will be used. They are TNE-0C-23, l

" Maintenance of Damage Study Analysis" and CP-El-4.0-63, l O " Review of Architectural Specifications and Drawings to Identify Non-Seismic Sources".

Revisient '3 Pcas 11 of 16 ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Participants Roles and Responsibilities The following organisations and personnel will participate in this effort 4.3.1 TUGC0 Nuclear Engineering (TNE) ani Gibbs & Hill 4.3.1.1 Scope

- Perform architectural features evaluation (4.1.3.1)

- Recommend and implement design modifications resulting from architectural review or third-party verification of damage study program

- Design new control room ceiling l

- Assist in preparation of Results 4.3.1.2 Personnel Mr. C. R. Hooton TNE Civil / Structural Discipline Supervisor .

Mr. M. Wells Engineering Specialist Mr. D. A. West Damage Study Engineer Mr. J. Eichler Gibbs & Hill, Panager of

' Civil / Structural Department Mr. E. Beskor Gibbs & Hill Structursi Job Engineer Mr.'M. Pope Gibbs & Hill, Structural Engineer 4.3.2 Brown & Root, Inc.

4.3.2.1 Scope

- Install new control room ceiling

- Provide as-built data on architectural features

Feviciont 3 Pcga 12 ef 16 ISAP II.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.3 TUCCO Quality Assurance 4.3.3.1 Scope

- - Inspect control room ceiling modifications

- Inspect other modifications 1 resulting from damage study interaction resolution l

4.3.3.2 Personnel I

Mr. P. Halstead Quality Engineering

] Supervisor (Acting) 4.3.4 Third-Party Activities

) 4.3.4.1 Scope i

()

- Review of control room ceiling analysis and design (4.1.1.1) a 4 -

Review of architectural features evaluation (4.1.3.2)  :

1 i

! - Review seismic damage study i i procedures and criteria (4.1.3.3, j 4.1.3.4, 4.1.3.5 and 4.1.3.6)

- Desiga review implementation of l damage study procedures (4.1.3.7)

Perform independent damage study walkdown (4.1.3.8) ,

- Prepare Results Report

! 4.3.4.2 Personnel Mr. H. A. Levin TERA CPRT Civil /

i Structural Review Team Leader i Dr. J. R. Honekamp TERA. TRT Issues Manager

) Mr. D. Witt TERA Senior Mechanical Engineer g,- - - - . . - . - - - - -- ,-- -+- , -, - . - , -, - . , . . . , - - - , - - - - -

,r.---

Revicisn 3 Pcga 13 cf 16 ISAP II.d (Cont'd)

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4.0 CPRT ACTION PLAN (Cont'd)

Mr. P. Streeter TERA Senior Mechanical Engineer 4.4 Personnel Qualification Requirements ,

4 t Project personnel involved in the design, installation and inspection of the new control room ceiling and the architectural features review will be qualified to applicable project proccdures and the requirements of the CPSES QA Program. Third-party personnel will meet the qualification j requirements of the CPRT Program Plan.

4.5 Standards / Acceptance criteria j The FSAR will be used as the base document for establishing

. acceptance criteria. Where the criteria in the FSAR requires

! increased detail to define specific requirements not covered

! by the standards and regulatory guidance referenced in the l TSAR, the basis will be established engineering principles applicable to the same or similar situations.

() 4.6 Decision criteria The control room ceiling design will be rodified if it is determined that its behavior during a seismic event may lead l to unacceptable interactions with safety related items or have a potential of interfering with operators in the control room.

1 The Damage Study / Architectural Features evaluation will

' establish whether or not the plant design conforms with requirements of Regulatory Guide 1,29 and FSAR secticn 3.78.2.8. Any identified deficiencies will be evaluated and corrected as necessary to meet these ccentements.

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Figure II.d-1 CONTROL ROOM CEILING DESIGN CHANGE I

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP  !!.e i

Title:

Rebar in the Fuel Handling Building i l

Revision No. 0 1 2 3 i

Revised to Refleci Incorporates Reflects Coments oescription Original Issue NRC Coments SSER on Plan ytpcJtaa Iols ItV O Prepared and Rev Tess i.eader & } W E o.e. io/s-le4 ' kc u

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Rebar in the Fuel Handling Building v

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated an alleged instance of unauthorized cutting of rebar associated with the installation of the trolley process aisle rails in the Fuel Handling Building. The claim is that during installation of 22 metal plates in January 1983, a core drill was used to drill about 10 holes approximately 9 inches deep. The TRT reviewed the reinforcement drawings for the Fuel Handling Building and determined that there were three layers of reinforcing steel in the top reinforcement layer of the slab. This reinforcement layer consisted of a No. 18 bar running in the east-west direction in the first and third layers, and a No. 11 bar running in the north-south direction on the second layer. (See Figure 1) The review also revealed that the layout of the reinforcement and the trolley' rails l was such that the east-west reinforcement would interfere with the drilling of holes along only one rail location. However, if 9-inch holes were drilled, both the first and third layers of No. 18 reinforcement would be cut. Design Change Authorization No. 7041 was written for authorization to cut the uppermost No. 18 bar at

only one rail location, but did not reference authorization to cut I the lower No. 18 bar. DCA-7041 also stated that the expansion bolts and base plates may be moved'in the east-west direction to I

avoid interference with reinforcement runninF in the north-south direction. The information, described in D0A-7041, was substantiated by Gibbs & Hill calculations. If the ten holes were actually drilled 9 inches deep, then the allegation that the reinforcement was cut without authorization would be valid.

4 2.0 ACTION IDENTIFIED BY NRC Accordingly TUEC shall provides Information to demonstrate that only the No. 18 reinforcing steel in the first laysr was cut, or Design calculations to demonstrate that structural integrity is maintained if the No. 18 reinforcing steel on both the first and third layers was cut.

3.0 BACKGROUND

It is alleged that during the drilling of holes for installation of the Hilti Kwik bolts for process aisle trolley j rails at E1. 810'-6", 10 holes were drilled approximately 9 l inches deep. This depth would cut through top and bottom l

l

R;vicient 3 Paga 2 of 9 ISAP II.e (Cont'd)

3.0 BACKGROUND

(Cont'd)

(1st and 3rd layers) of the east-west No. 18 reinforcing steel located in the top reinforcement of the concrete mat. No. 18 reinforcing steel also runs longitudinally along the aisle rails in the east-west direction but without a potential for interference since the Hiltis and rail do not line up. The governing design document (DCA #7041) authorized cutting of only top (1st layer) No. 18 bar at only one rail location. It is evident from a review of drawings that reinforcement would be encountered at only one rail location in east-west direction due to the spacing of rebars running east-west compared to the spacing of rails and Hilti bolts. The design required the rail base plates to be so located in east-west direction to avoid cutting of 2nd layer of No. 11 rebar which runs in the north-south direction. A field inspection has verified that at one location in the east-west direction, the 1st and 3rd layers of rebar could have been cut, based upon-the size of Hilti bolt installed.

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan are to:

Assess the structural integrity of the slab in the subject case.

Assure that other cases where cutting of reinforcement bar was authorized for the installation of Hilti bolts or where drilled-in shear lugs were used, did not-compromise the integrity of the structure due to the unauthorized cutting of additional bars.

The CPRT tasks to be implemented to achieve this objective are described in the following paragraphs.

~-)

Ravicient 3 P:go 3 of 9 ISAP II.e

,, (Cont'd)

V 4.0 CPRT ACTION PLAN (Cont'd)

Design calculations will be generated to demonstrate that the-structural design requirements of the concrete mat at elevation 810'-6" will be met. assuming a No. 18 bar in the 3rd layer is cut.

The adequacy of procedural controls governing rebar cutting either at Hilti or core bore installations will be reviewed.

These activities will include control of rebar cutting machines, craft procedures, inspections and proper engineering authorization.

All the cases from Unit 1 & 2 where rebar cutting was requested for installation of Hilti bolts will be studied. A determination of the possibility of additional (i.e.

unauthorized) rebar cut will be made based on reinforcement pattern in slab or wall vis-a-vis embedment depth of the Hilti bolt installed. Field inspection will be conducted in such I

cases to verify actual installed embedded length of Hilti bolts.

The Hilti bolt installation work performed by the construction-i i

[ }'

\'-

crew that installed the subject 'Hilti' bolts, will be reviewed over a period of eight months (i.e. time period that the crew worked together) surrounding the subject installation. This review will include installations where I rebar cut authorization was requested by this crew and a potential violation of such authorization by this crew while installing Hilti bolts.

In addition, pipe supports in Units 1 and 2 which utili' zed shear lugs (rods) installed by core drilling will be investigated for the possibility of rebar cutting.

The attached logic diagram identifies tasks and the inter-relationship of tasks for resolution of this action plan.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this

effort are described below with their respective scopes of work.

O v

Reviciont 3 Pcg2 4 cf 9 ISAP II.e (Cont'd)

A U

4.0 CPRT ACTION PLAN (Cont'd) 4.2.1 TUGC0 Nuclear Engineering (TNE) - Civil / Structural Discipline -

4.2.1.1 Scope Will perform design calculations documenting the adequacy of the elevation 810'-6" mat Will review controls for cutting rebar

-Will evaluate work of subject construction crew and selected review of other rebar cut situations Will assist in overall engineering evaluations and development of j Action Plan Results Report.

4.2.1.2 Personnel j

O Mr. C. R. Hooton -TNE Civil / Structural Discipline Supervisor Mr. D. G. Patankar Civil / Structural Lead Engineer Mr. S. A. Raz Structural Engineer-4 4.2.2 Gibbs & Hill - Site Design Review Team i

4.2.2.1 Scope Site design Review Team will design review calculations performed by CPPE Civil Engineering i

4.2.2.2 Personnel Mr. B. Wilcoxson Design Review Group Supervisor Mr. B. K. Bhujang Structural Group Lead l

Mr. R. P. Shah Principal Engineer I

O

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R:vicient 3 Pass 5 cf 9 l

ISAP II.e (Cont'd)

O

-Q 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 Third-Party Activities 4.2.3.1 Scope Overview inspection to dete'mine r

actual lengths of Hilti bolts used, where rebar cutting was required for Hilti bolt installation Review of analysis / calculations to verify adequacy of elevation 810'-6" mat Review of procedural controls for rebar cutting Verification of implementation of installation by subject crew and other rebar cut situations Overall evaluation of resolution of action plan

(}

Preparation of Results Report.

4.2.3.2 Personnel Mr. H. A. Levin TERA, CPRT Civil /

Structural Review Team Leader Dr. J. R. Honekamp TERA, TRT Issues Manager Dr. C. Mortgat TERA, Senior Structural Engineer l

Dr. J. Arros TERA, Structural Engineer Mr. G. Lagleder Southwest Research Institute 4.3 Personnel Oualification Requirements Where tests or inspections require the use of certified

~

inspectors, qualifications at the appropriate level will be to O the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified e e m --w

R: vision: 3 Pcg3 6 of 9 ISAP II.e (Cont'd)

O 4.0 CPRT ACTION PLAN (Cont'd) to.the requirements of the third-party employer's Qualicy Assurance Program, and trained to the applicable inspection procedures. '

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants.will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Pregram Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures Calculations and evaluations performed by CPPE Civil Engineering and Gibbs & Hill will be performed in accordance with the procedures normally applicable to those activities O for CPSES. Third-party verification activities will be conducted in accordance with applicable CPRT guidelines.' A procedure will be developed for inspection of Hilti bolt ~

installations where embedded length of Hilti bolts is to be determined.

4.5 Standards / Acceptance Criteria I

ACI-318-71, Building Code Requirements For Reinforced Concrete and stipulations of FSAR Section 3.8 formed the basic standards and acceptance criteria for original design of concrete mat at El. 810'-6" in Fuel Handling Building which are documented in Calculation Book No. SFB 102C, Section 1.

The design calculations generated with this action plan will i be consistent with the original design criteria.

4.6 Decision' Criteria The results and conclusions of analysis / calculations performed.

as well as conclusions drawn from:

Review of procedural controls on rebar cutting ,

activity, j O' -

Review of situations where rebar cutting was necessary for Hilti bolt installation, and I l

l

Rsvision: 3 Pags 7 of 9 ISAP II.e  !

(Cont'd)

O l 4.0 CPRT ACTION PLAN (Cont'd)

Review of work performed by subject construction crew will determine the acceptability of the as-built condition of

~

the subject case as well as the potential applicability to other areas. Any other unauthorized rebar cuts will be evaluated. Procedural controls will be revised to strengthen.  !

rebar cutting operations if determined appropriate.

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O ATTACHMENT REBAR IN THE FUEL HANDLING BUILDING

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Mechanical ISAPs i

V.a Inspection for Certain Types of Skewed Welds in NF Supports '

V.b Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports V. c . Design Consideration for Piping Systems i

Between Seismic Category I and Non-Seismic

, Category I Buildings V.d Plug Welds V.e Installation of Main Steam Pipes VI.a Gap Between Reactor' Press'tre Vessel

! Reflective Insulation and the Biological Shield Wall io

VI.b Polar Crane Shimming 1

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i COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP V.a

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Title:

Inspection for Certain Types of Skewed Welds in NF Supports l

Revision No. 0 1 2 .

t Revised to Reflec$eflects Commenus

Description Original Issue NRC Coments on-Plan

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R vision: 2 Pass 1 of 9 q ISAP V.a Inspection for Certain Types of Skewed Welds in NF Supports

1.0 DESCRIPTION

OF IS'"F IDENTIFIED BY NRC The TRT investigated inspection procedures of Brown & Root (B&R) for velds in pipe supports designed to ASME III Code, Subsection NF. The TRT found that no fillet weld inspection criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural members, or (2) two members with curved surfaces or curved cross sections, such as a pipe stanchion (a section of pipe used as a structural member) welded to another pipe stanchion or to a curved pipe pad. Notice that for type 2 [those defined in iten (2) above], the effect of curvature at the veld connection induces +

skewed considerations, even though the two joining _ members are physically perpendicular. The Brown & Root veld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed welds; however, the TRT found that QI-QAP-11.1-28 did not include weld inspection criteria for type 2 skewed welds. Although the TRT was told by Brown & Root personnel that procedure QI-QAP-11.1-26 for piping weld inspection was used, since such weld connections were similar in configuration to a

, s pressure boundary stanchion attachment veld, no evidence

' documenting the use of this inspection procedure was provided to the TRT. According to records reviewed by the TRT, these welds were actually categorized as "all other welds" rather than " skewed welds" on the required QC checklist. Instead of using fillet weld gauges for measuring the size of nonskewed welds, welders were supposed to use a straight edge and a steel scale for measurement of a type 2 skewed weld, as described in QI-QAP-11.1-28 In addition, due to the variable profile along its curved weld connection, the weld size-should have been measured at seteral different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type 2 skewed welds are a violation of ASME Code for NF supports

' committed to by TUEC in FSAR Section 5.2 I and a violation of' Criterion XVII in Appendix B of 10CFR50.

The TRT reviewed weld ~ inspection procedures, weld data cards, and visually inspected several type 2 skewed welds in randomly sampled NF supports where pipe stanchions were used.- Although the small sample of welds inspected by the TRT are acceptable. .due ta deficiencies in Inspection Records and the apparent lack of inspection criteria, the TRT is not certain whether other type 2 skewed welds were-inspected properly. This is a generic irsue involving many NF supports in various safety related systers. . The lack of documented inspections and criteria for type 2 ske.ed welds

4. in NFl supports represents a safety concern regarding the pessible N-~ existence of under-sized welds in supports which are required to resist various' design loads.

I

R vicion: 2 Pega 2 of 9 p._ ISAP V.a (a} (Cont'd) 2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall Revise Brown & Root weld inspection procedures CP-QAP-12.'1 and QI-QAP-11.1-28 to properly address type 2 skewed welds of stanchion to stanchion and stanchion to pipe pad.

Provide evidence to verify that previous inspections of these types of skewed welds were performed to the appropriate

. procedures.

3.0 BACKGROUND

3.1 Information Regarding the History of Fillet Weld Inspections The methods for QC inspection of~ type.2 skewed fillet welds and the written procedures describing the methods and means of documenting the inspections have changed during the-construction of the CPSES project. The significance'of such changes and their history ~will be evaluated as part of this s

action plan. The significance of changes in the inspection methods and the forms for documenting the Inspection Results will be evaluated. A summary of those aspects most pertinent to the formulation of this action plan follows.

On Septenber 3, 1982, Revision 12 of inspection procedure .

QI-QAP-11.1-28 " Fabrication and Installation Inspection of Safety Class Component Supports" was issued. This established

-inspection methodology which addressed type 2 skewed fillet velds. Inspections performed prior to that date were generally not performed using such methods. However, by that stage of construction, most of the welds for.NF supports had already.been inspected.

On March 18, 1983, Revision 5 of~ inspection procedure CP-QAP-12.1, "ASME Section III Installation Verification and N-5 Certification", was issued. A program was initiated to reinspect all NF welds using a checklist created in the revision. The documentation for those reinspections was the checklist, because the Weld Data Cards, which had documented individual welds, was the record of initial inspection. As a result, the documentation for the reinspection is not specific to individual welds, instead it covers all the welds for the support. The CP-0AP-12.1 checklist had two entries for the welds; one for skewed welds, another for all other welds. On

(N

\_,) the CPSES project, type 2 skewed welds are termed " stanchion welds"; therefore, supports with stanchion welds and no other

R vision: 2.

Paga 3 of 9 7 s ISAP V.a

( ) (Cont'd) v

3.0 BACKGROUND

(Cont'd) skewed welds had no entry or "N/A" under the checklist item

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for skewed welds. Although the project intended that the reinspection program would ensure proper inspection of all the type 2 skewed fillet welds, the records in themselves cannot provide conclusive evidence of this. The source of the difficulty is the stated ambiguity of terminology for skewed' welds in combination with the documentation method.

Given the methods of inspection for type 2 skewed fillet welds

, prior to. September 3, 1982 and the circumstances of the reinspection docunentation, it does not appear that a review of documentation in itself can be used to verify the adequacy of methods.used for welds initially inspected prior to September 3, 1982.

Initial ~ inspections performed af ter September 3,1982 were controlled by the procedures which included updated inspection 1

' methods. Additionally, documentation of inspections underwent significant upgrade. As before, the documentation of skewed fillet welds which were also pressure boundary welds is' weld I \ . specific using Weld Data Cards. After D'ecember 15, 1982, weld

' mapping was instituted for non-pressure boundary fillet welds yielding weld specific documentation. These post-September 1982 records may therefore serve as sufficient information to document which methods were used,'even with the ambiguity of terminology for skewed welds. In addition to the procedures discussed above, inspection procedure QI-0AP-II.1-26 "ASME Pipe Fabrication and Installation Inspections" was used-directly or by reference to define' inspection methods for 4

Type (2) skewed fillet welds, and it will be included in the procedural assessment task.

F 3.2 Inspection of Full or Partial Penetration Welds The inspection attribute which is the technical focus of this issue is the geometric and dimensional characteristics of the fillet weld.in locations where simple fillet gauge measurement is not possible. .In general, a similar inspection attribute does not exist for full or partial penetration welds, i

However, if such welds call for reinforcement, the inspection of the dimensional aspects of the reinforcement is similar to a fillet veld inspection. Such reinforcement is not commonly i used for skewed welds but where they are used, the action pisn-will include them.

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Ravicion: 2 Paga 4 of 9 3 ISAP V.a

) (Cont'd) d 4.0 CPRT ACTION PLAN The objective of this a'ction plan is to assure that the aP-built size of Type 2 skewed welds on NF pipe supports meets the design requirements.

A review of inspection procedures and documentation methods indicates a need.for a program which will assess the documentation methods and verify on a random sampling basis, that welds meet the design requirements. Some of.the post-September 1982 records do provide sufficient documentation' attest to the quality of individual type 2 skewed velds. However, due to the time phased implementation of the procedure revisions described in Section 3.1, sample reinspection of the entire population of type 2 skewed welds is considered to be more effective than a document review combined with sample reinspection of the part of the population that has ambiguous inspection records. The attached logic diagram ~ depicts the process as described in Section 4.1.

4.1 Scope and Methodology 4.1.1 The chronology of inspection methods documented in

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s-procedures will be developed to correlate the period of time and specific procedure revisions for inspection of type 2 skewed welds. This will include a description-of methods and inspection documents required.

The chronology will be used to identify all revisions of procedures for which inspections were performed that have not been superceded by subsequent inspection.

4.1.2 Inspection procedures QI-QAP-II.1-26, QI-QAP-ll.1-28 and CP-QAP-12.1 will be reviewed to determine if the method of inspection that was included for type 2 skewed weld inspections was adequate to address the unique aspects of skewed weld dimensional configurations. The assessment of' adequacy will be a third-party activity.

Based on the review, the procedures will be revised to incorporate any modifications necessary to assure the inspection methods address any unique aspects of the skewed-veld configuration. Additionally, clarifying direction and appropriate cross reference will be .

provided, as required, to ensure a clear understanding of the requirement to treat all type 2 welds as skewed welds.

The physical significance of any procedural changes will be evaluated by a third-party.

R; vision: 2 Pags 5 of 9 ISAP V.a

/~'N (Cont'd)

U 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 To assess the adequacy of inspection procedure implementation and to verify that design requirements were met, a random sample of type 2 skewed welds I (excluding pressure boundary welds, _which are not at issue)_ from Unit 1. Unit 2 and common will be selected

for review of inspection documentation and reinspection to current inspection procedures. A sampling evaluation is appropriate since the objective is to determine if the procedural ambiguities related to the measurement of type 2 skewed welds actually resulted in the production of. undersized welds'.

4 The sample plan will be designed in accordance with Appendix D and will either provide reasonable assurance ,

that type 2 skewed welds meet design requirements or will detect deficiencies to be investigated and dispositioned. The minimum sample size according to Appendix D is 60, with a detection number of zero j

(i.e., the critical region is one or more deficiencies found in the sample). In~this case a deficiency is

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defined as a weld which exceeds the ASME Code allowable (s)) stress levels.

If one or more welds are found not to meet design requirements (i.e. undersized relative to that noted on design documents), an analysis will be made to determine the ability of the weld to carry its design loads in accordance with.ASME code requirements. If it is determined that the weld exceeds code allowable stress levels, a decis' ion will be made to either expand the sample'or go to 100 percent reinspection of type 2 skewed fillet welds. If it is determined that all undersized welds meet code allowable stress levels, an l evaluation of the need for additional inspection will be performed based on the observed trends in the-weld inspection data.

4.1.4 Physical reinspection of the random sample will be conducted by third-party inspectors from Evaluation Research Corporation (ERC). The-inspection criteria used will be based on the revised procedures resulting from the procedure review discussed in 4.1.2.

l 4.1.5 The results of the procedure review, physical

measurements and evaluation of. results will be used to '

assess root cause and generic implications. Any -;

physical modifications and. procedural changes required will be identified and corrective action initiated.

QA/QC programmatic aspects which may be implicated by

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Rqvicion: 2 Peg 2 6 of 9 ISAP V.a

(} (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the results of the root cause and generic implication determination will be addressed under the' Quality of Construction, QA/QC Adequacy Program.

4.1.6 All critical aspects of the review program will be overseen and verified by third-party. The attached logic diagram identifies the specific activities which are included in the. third-party overview and verification.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are listed.below with their respective scopes of work.

I 4.2.1 Comanche Peak Project Engineering-

] 4.2.1.1 Scope s -

Chronology Procedure review Procedure revision Assist in programmatic evaluation 4.2.1.2 Personnel Mr. C. Moehlman Project Mechanical Engineer 4.2.2 Third-Party Overview 4.2.2.1 Scope 1

Assess procedural adequacy Verify sample selection Review reinspection instructions Reinspection of welds (ERC)

Verify inspection evaluations l

Overview evaluation of safety significance

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i R;visicnt 2 Pagn .7 of 9 ISAP V.a (Cont'd)

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4.0 CPRT ACTION PLAN (Cont'd)

Evaluate cause, significance and applicability Preparation of Results Report 4.2.2.2. Personnel Mr. H. A. Levin TERA Corporation -~ CPRT Mechanical Review Team Leader Dr. J. R. Honekamp TERA Corporation - CPRT TRT Issues Manager

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Mr. C. Spinks Evaluation Research Corporation Dr. F. A. Webster Jack Benjamin 5 Associates (JBA), - CPRT Statistics Advisor x_ / Mr. R. L. Shipp TERA Corporation, Senior Materials and Welding Engineer 4.3 Personnel Qualification Reauirement Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to.

the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified .

to the requirements of the third-party employer's Quality ,

Assurance Program, and trainea to the applicable inspection '

procedures.

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and' objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the f'- applicable principles of Section III.K. " Assurance of CPRT

(,,]j Program Quality", of the CPRT Program Plan.

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Rsvision: 2 Paga 8 of 9 ISAP V.a

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l i 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Standards / Acceptance Criteria The criteria for evaluating the acceptability of any weld determined to be less than specified are as defined in the ~

ASME Boiler and Pressure Vessel Code Section III. The criteria for accepting the sample of. reinspected welds are

] described in section 4.1.3 of this ISAP.

4.5 Decision criteria l

The results and conclusions of the physical re-inspection of randomly selected type 2 skewed welds will provide the basis for any modifications required to meet the design requirements. Any nececsary modifications to meet design.

requirements will be initiated. An assessment of the generic implications will be included as part of the Results Report,

, addressing the potential applicability to other areas of the plant. .

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R;vicion 2 Pcgo 9 of 9 Q ISAP V.a Q (Cont'd)

ATTACHMENT INSPECTION FOR CERTAIN TYPES OF SKEWED WELDS IN NF SUPPORTS 7 .

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l COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP V,b Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports i

Revision No. 0 1 2 Revised to Reflec Reflects Comeni.s Description Original Issue NRC Coments on Plan O Prepared and i Recommended by: '/

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R;viciont '2 Pcgs 1 of 9 ISAP V.b T

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Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT was informed that some anchor bolts in the steam generator upper support beams were shortened during installation to les's than the length shown on the design drawing without proper authorization. The TRT was told that the bolt cutting incident occurred either because the hole of the anchor device was. filled with debris, or the threaded portion of the bolt had concrete mix stuck to it. There are 18 bolts at each end of each of 4 beams, totalling 144 bolts. There is one beam for each steam generator.

The bolt threads into an anchor device embedded in the concrete

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wall. The acceptable bolt length or the length of bolt available for threading into the anchor ~ device is vital to ensure structural' capability of the support beams.

1 The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation practices. . The TRT was told that ultrasonic testing of these types of bolts was not a procedural requirement; however,-TUEC was unable to provide any other installation records for TRT review. The TRT concludes that

. such unauthorized bolt cutting and lack of' installation inspection records is a viola' tion of QA procedures and Criterion XVII in Appendix B of 10CFR50. Since the support beams are essential to provide lateral restraint for the steam generator during a LOCA or seismic event, adequate anchoring capability of the bolts has safety significance and, as a result, appropriate measures are needed to. ensure conformance with General Design Criterion 1 of 10CFR50.

2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall provide evidence, such as ultrasonic measurement results, to verify acceptable-bolt length. Should unauthorized bolt cutting be verified. TUEC shall:

Replace shortened bolts with bolts of proper length, or provide analysis to justify the adequacy of shortened bolts as installed.

Provide justification ~or propose measures to ensure that no similar concern exists for bolting.

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• R,vicion 2 Pcg2 2 of 9 ISAP V.b (Cont'd) v

3.0 BACKGROUND

The TRT investigated the allegation of unauthorized anchor bolt shortening for the Steam Generator Upper Lateral Support Beams. As part of that investigation TUGC0 was requested to provide the installation and-Inspection Records for the subject beams; however, the records could not be located in the permanent plant records vault. Non-conformance Report, NCR-M-84-100384 was issued by TUCCO Quality Control to document the lack of Inspection Records.

The disposition of the Non-conformance Report required inspection

of the Unit 1 installation. This inspection included ultrasonic measurement of bolt lengths to determine if the design bolt engagement into the embedded plate was provided. The reinspection has been performed in accordance with Operation Travelers CE-84-192-8902, CE-84-193-8902, CE-84-194-8902 and CE-84-195-8902.

Results from the ultrasonic test to determine bolt lengths indicated insufficient thread engagement in specific locations.

This deficiency was reported on January 17, 1985 to the NRC in accordance with 10CFR50.55(e).

4.0 CPRT ACTION PLAN The objectives of this action plan are to ensure that the anchor l bolts in the steam generator upper support beams meet design requirements, and to review similar installation circumstances to determine if the issue pertains to other designs. The steps are outlined-in the attached logic diagram and discussed in the following sub sections.

4.1 Scope and Methodology 4.1.1 -On the basis of inspections performed on Unit 1 (as identified in Section 3.0), thread engagement was determined to be less than required by design. In addition, an evaluation of the design of the bolted connection and the associated embedment by the third-party has determined that the existing design is not adequate for the specified loading conditions. Gibbs &

Hill is re-evaluating the current design and loading conditions. Revisions to the design or analysis will be reviewed b.y the third-party. The revised design  !

and/or analysis will provide the basis for reinspection and rework, if required, of the SGUL bolts. A similar inspection of Unit 2 will be performed and appropriate action completed depending upon the inspection results.

l

R0vicisnt 2-Pcg2 3 of 9 ISAP V.b

, (Cont'd)

U 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 The bolts and the. blind threaded holes of the embedment will be examined during the process of bolt replacement to assist in the assessment of root cause. Those aspects of the fabrication and installation-process which might.have directly or indirectly influenced the as-built thread engagement will also be reviewed. This includes the review of dimensional tolerances of parts in the assembly such as plate thickness, shim sizes, concrete placement, and bolt length.

4.1.3 In order to assess the potential generic applicability of the bolt thread engagement issue for the as installed condition of designs, other installations dependent of bolt thread engagement will be reinspected for engagement adequacy on a sampling basis. A sample reinspection is appropriate in this case since the objective is to determine if thread engagement deficiencies similar to the SGUL exist in other populations of bolted connections. Two separate populations have been selected for reinspection.

4.1.3.1 Richmond inserts were extensively used, O' primarily in pipe support applications. A program to verify bolt engagement was conducted as part of the plant construction.

The populations of Richmond inserts to be-sampled for reinspection of thread engagement are those utilized in ASME pipe supports in Units 1 and 2. The sampling plan will be designed in accordance with. Appendix D and j will either provide reasonable assurance that l

the design engagement was achieved or will '

detect deficiencies to be investigated and dispositioned. The minimum sample size  ;

according to Appendix D is 60, with a detection number of zero (i.e., the critical region is one or more deficiencies found in j the sample). If cases of inadequate. bolt  !

engagement are identified, a non-conformance i report will be issued and an assessment will I be made to determine the ability of the i

connection to carry its design load. If it is determined that the connection cannot carry its design load (s), a decision will be made to expand the sample with a corresponding increase in the acceptance-n s ,e number, utilize stratified sampling to explore a particular sub-population or go to 100% reinspection. If it is determined that the component (s) can still carry their design

Revisient- 2 Pi:go 4 of 9 ISAP V.b (Cont'd) i O- 4.0 CPRT ACTION PLAN (Cont'd) load (s) for all observed cases of less than design thread engagement, the need for '

additional inspection will be based on an evaluation of trends in the inspection data. [

4.1.3.2 An engineering review of structural /

mechanical drawings will be conducted to identify blind hole bolted connections where l thread engagement is an important design attribute. Project experience will'be l overviewed to identify hardware types where thread engagement problema have been identified in the past. Based on these -

reviews -another population from Units 1 & 2 will be selected. The thread engagement for the sample will be determined in accordance with an inspection plan developed for the type of bolted connections in the sample. A '

similar sampling plan as identified in section -4.1.3.1 will be utilized. Results of this inspection will be reviewed for ,

compliance with the design.

4.1.4 A third-party review will be performed of the process

• by which critical attributes of bolted connections were 7 specified and their. associated inspection criteria and documentation requirements defined. The initial. scope of this effort will be focused on an evaluation of the circumstances that led to the lack of aporopriate '

records for the steam generator ' upper lateral support.

This activity may be expanded to other areas if it is ,

determined that identified program deficiencies may be ,

applicable elsewhere or if problems are identified as a result of the inspections noted under Section. 4.I'.3.

The requirements for engineering approvals and field controls.for bolt cutting will also be reviewed by a third-party.

4.1.5 A third-party overview of all aspects of the action plan will be conducted. The inspection plans for UT of '

installed bolts for structures discussed in Section 4.1.3 will be reviewed. Design calculations which are performed to evaluate bolt engagement required for shortened bolt installations will be reviewed. The' visual inspection of bolts and threaded holes which is '

performed during replacement of the SG upper lateral support bolts will be overviewed by' a third-party.- The O 6

R;vicient 2 Pcg3 5 of 9 ISAP V.b p (Cont'd) -

(GI 4.0 CPRT ACTION PLAN (Cont'd) final assessment of issue significance and applicability to other areas will also be reviewed by a third-party prior to the preparation of a response to '

the issue.

4.1.6 Based on the conditions observed for the steam generator support, the inspection and assessment of the sample of other. bolted connections and the' programmatic and procedural review in subsection 4.1.4. the root j cause and generic implications will be determined. The

, adequacy of the design of the upper lateral support l itself will be addressed separately under DSAP VIII (Civil Structural DSAP).

! 4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this

, effort are listed below with their respective scopes of work. '

l 4.2.1 TUCCO Nuclear Engineering (TNE) Civil / Structural

Discipline

(-

4.2.1.1 Scope Prescribe SG rework 1

Review SG visual examination results +

Review structural details 1

Select samples 1

1 Assist in identification of generic implications, root cause and corrective action I

Assist in preparation of Results Report )

4.2.1.2 Personnel Mr. C. R. Hooton TNE Civil / Structural Discipline Supervisor Mr. T. L. Wright Civil Engineer Mr. C. L. Corbin

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(v~') Civil Engineer.

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Rcvicicn 2 Pag 2 6 of 9 1

ISAP V,b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4 4.2.2 Gibbs & Hill 4.2.2.1 Scope Engineering assessment of thread engagement 4.2.2.2 Personnel 4

Mr. E. L. Bezkor Structural Job Engineer i

Mr. A. M. Kenkre Structural Squad Leader 1

4.2.3 Brown & Root 4.2.3.'I Scope

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Implement bolt replacement reworks 4.2.4 TUCCO QC I

j 4.2.4.1 Scope j

i -

Perform UT of SGUL bolt length Visually inspect SG bolts removed and hole condition t

4.2.4.2 Personnel i

Mr. C. T. Brandt Quality Engineering Supervisor (acting) 4.2.5 Third-Party 4.2.5.1 Scope TERA:

Review process for-defining bolting inspection and documentation

requirements i

Review process for engineering approval of changes to critdcal bolting parameters-4

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R;viciont- 2 Pcg2 7 of 9 ISAP V.b (Cont'd) 4.0 CPRT . ACTION PLAN (Cont'd)

Review Sample Selection Review UT inspection. plan for SGUL 4

bolts Review Inspection' Plans for other samples.

Review design calculations Overinspect visual inspection of SG-I holes and bolts Review and assess root cause and generic implications Prepare Results Report i

ERC:

Inspection of additional samples

() 4.2.5.2 Personnel

$ Mr. H. A. Levin TERA Corporation - CPRT Mechanical Review Team i Leader Dr. J. R. Ho'nekamp- TERA Corporation - CPRT TRT Issues Manager Dr. J. Arros TERA Corporation -

) Structural Engineer Mr. G. L. Lagleder Southwest Research c Institute Dr. F. A. Webster Jack Benjamin &

Associates (JBA), - CPRT' Statistic Advisor Dr. W. Munse University of Illinois i

Mr. M. J. Holley Hanson, Holley & Biggs -

! Structural Engineering ';

Consultant j l

) Mr.-D. Alexander - ERC QA/QC Issue Coordinator l l l

R;vicions 2

~Pego 8 cf 9 ISAP V,b (Cont'd) f-N- \] 4.0. CPRT ACTION PLAN ' (Cont'd) 4.3 Personnel Qualification Requirement

.Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to

the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures.

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be. qualified to the requirements of t

, the CPSES Quality Assuranc'e Program or to the specific .

r'equirements of the CPRT Program Plan. Activities performed .!

by other than third-party personnel will be governed by the '

i applicable principles of Section III.K. " Assurance of CPRT 3

i Program Quality", of the CPRT Program Plan,

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4.4 Decision Criteria / Acceptance Criteria i

Conformance of actual bolt threaded engagement lengths to the required engagement lengths as specified in the revised analyses and/or design prepared by Gibbs'& Hill will determine l the acceptability of the connection installation of the subject case.

If program requirements on inspection'and documentation of-bolted connections are found to be insufficient, the program requirements will be supplemented to provide assurance that bolted connections are subject to QC inspection and documentation requirements reflective of the safety significance of the connection.

The identified reasons that led to the circumstances related to the subject issue and potential findings'from the review of the selected samples will determine what course of action is taken to assess the potential applicability to other bolted connections at the plant.

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1 R;visi n 2 l Pcga 9 of 9 1

ISAP V.b

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COMANCHE PEAK RESPONSE TEAM

( ACTION PLAN ISAP V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings Revision No. 0 1 2 Revised to Reflec". Reflect Comentt Description Original Issue NRC Coments on Plan O Prepared and ,

Recomended by:

Review Team Leader

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R; vision: 2 Psgo 1 of 6 ISAP V.c

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k Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC In April, 1984 the Comanche Peak Special Review Team (SRT), formed and. coordinated between NRR, IE and Region II and IV, performed a limited review of Comanche Peak. The TRT, in reviewing the SRT findings in the area of piping design considerations, has discovered that piping systems, such as Main Steam. Auxiliary Steam and Feedwater, are routed from the Electrical Control Building (seismic Category I) to the' Turbine Building (non-seismic Category I) without any isolation. To'be acceptable, each seismic Category I piping system should be isolated from any non-seismic Category I piping system by separation, barrier or constraint.

If isolation is not feasible, then the effect on the seismic 4

Category I piping of the failure in the non-seismic Category I piping must be considered (CPSES FSAR 3.7B.3-13.1).

For CPSES, FSAR Section 3.7B.2.8 establishes that the Turbine Building is a non-seismic Category I structure and failure is postulated during a safe shutdown earthquake (SSE). The effect of

~

/h Turbine Building failure on any non-isolated piping routed through the Turbine Building from any seismic Category-I building must be considered.

In addition, for non-seismic Category I piping connected-to seismic Category I piping, the dynamic effects of the non-seismic Category I piping must be considered in the seismic design of the seismic Category I piping and supports, unless TUEC can show that the dynamic effects of the non-seismic Category I piping are isolated by anchors or restraints. The anchors or restraints used for isolation purposes must be designed to withstand the combined loading imposed by both the seismic Category I and non-seismic Category I piping.

2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall provide analysis and documentation that the j

piping systems routed from seismic Category I to non-seismic Category I buildings meet the stated FSAR criteria. '

n a

Revicient 2 Paga 2 of 6 ISAP V.c c-(Cont'd) kJ

3.0 BACKGROUND

TUGC0 committed in the FSAR to provide isolation between j seismic Category I piping system and non-seismic pip'ing-systems by using anchors or seismic restraints. The methods used to implement the FSAR commitment differ depending on such parameters as pipe size, location with respect to seismic buildings and location of isolation valves.

Some piping systems have active valves installed at or near the boundary between the seismic and non-seismic portions of the piping run. Furthermore, it is common practice to install ~

an anchor or moment restraint directly to the Category I building structures or indirectly through intervening steel structures.

Other piping systems are seismically isolated by using-an anchor, moment restraint, or a series of supports. The anchors and moment restraints are designed for the combined load imposed by the piping on each side of the device. The seismically qualified portion has a calculated set of loads.

I3

\- /

- The loads from the non-seismic piping are estimated. Where a

' series of supports is used to.imolate the piping, two approaches were employed for determining the loads. First, for larger piping, the practice is generally to locate additional supports in the non-seismic portion of the system and extend the piping.model to include that additional section of piping. The additional supports in the extented region (i.e. non-seismic portion) are designed to carry those loads.

Secondly, for small bore piping, loads are estimated based on a presumed span in the non-seismic piping which would establish a simply calculated fundamental frequency that maximizes the seismic response.

In the specific situation, first identified by the TRT, a portion of auxiliary steam system piping was routed from a seismic Category I building to a non-Category I building. The piping in question was all'non-nuclear safety (NNS) piping (i.e. non-Category I piping); however, the piping was classified as high energy piping. The FSAR.provides optional

' criteria for evaluation of postulated pipe ruptures which can be applied to high energy NNS piping which is seismically analyzed. That option was selected for the noted portion of auxiliary steam piping resulting in a seismic analysis. As initially configured, the support system included an anchor to isolate the seismically analyzed portion from the portion

() -which extended into the non-Category I building. At a later i

R:vicion:- 2 Pag 2 .3 of 6 ISAP V.c

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LJ (Cont'd)

3.0 BACKGROUND

(Cont'd) date, the device was deleted to alleviate thermal expansion stresses in a portion of the piping. The requirement to retain the seismic isolation was not. clear because none of the piping was Category I.

Although the' specific issue raised by the llT deals with Category I systems, based on the situation discussed above the-scope of-the issue is considered to. include any piping system with a seismic analysis boundary. This includes a seismic class change from Category I to non-Category I, but also includes any system in which the seismic model is terminated within a piping run or branch.

i 1

4.0 CPRT ACTION PLAN The objective of this action plan is to assure that piping systems

' routed from seismic Category I to non-seismic Category I buildings meet the FSAR criteria. .This objective has been assigned to the Project Piping and Supports Program with a third party overview ~by the Design Adequacy Program.

4.1 Scope and Methodology The scope of this action plan will therefore be limited to the following activities:

4.1.1 Identification of all Unit 1, 2 and common piping which has a seismic /non-seismic interface. This includes:

Category I piping entering a non-Category I building Piping with a class change from Category I to non-Category I in the piping run Piping runs with attached piping (i.e. small

, ,,-~s branch runs) which have a class change l k) s- l

R;vicion: 2 Pag 2 4 of 6 ITEM NUMBER V.c

'"3 (Cont'd)

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4.0 CPRT ACTION PLAN (Cont'd) '

NNS piping runs which have a portion which is

' seismically analyzed to postulate breaks 4.1.2 A review and discussion of.the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based.

4.1.3 Recommendations to the PPSP and/or the DAP based on 4.1.1 and 4.1.2. Specifically, these will address any potential implications which should be considered during the PPSP and DAP implementation.

4.1.4 Preparation of Results Report incorporating 4.1.1, 4.1.2 and 4.1.3.

I 4.2 Participants Roles and Responsibilities '

i The organizations and personnel that will participate.in this effort are described below with their respective scopes of work.

i ) 4. 2.1- Comanche Peak Project Engineering 4.2.1.1 Scope Identify seismic piping systems with j non-seismic interfaces for site scope.

Review and provide commentary on auxiliary steam pipe situation.

Assist in preparation of Results Report including recommendations to the PPSP and/or the DAP.

4.2.1.2 Personnel Mr.-C. Moehlman Project Mechanical Engineer Mr. H. Harrison Technical Services Supervisor i

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R vision: 2' Paga 5 of 6 ITEM NUMBER V.c (Cont'd) 4.0 'CPRT ACTION PLAN (Cont'd)-

4.2.2 Gibbs & Hill, Inc., New York, New York 4.2.2.1 Scope 1 -

Assist CPPE in identifying seismic piping systems.with non-seismic interfaces (for specific scope of piping analysis problems).-

t Assist CPPE in review of auxiliary i

steam pipe situation.

l 4.2.2.2 Personnel Mr. H. Mentel Applied Mechanics Supervisor 4.2.3 Third-Party Overview 4.2.3.1 Scope I -

Evaluate commentary on auxiliary j steam pipe situation.

4 -

Prepare Results Report including recommendations to the PPSP and/or the DAP.

4.2.3.2 Personnel Mr. H. A. Levin TERA CPRT/ Structural Review Team Leader Dr. J. R. Honekamp TERA TRT Issues Manager i

Mr. P. Streeter. TERA Senior Mechanical Engineer Dr. C. Mortgat TERA Senior Structural

, Engineer

4.3 Personnel Qualification Requirements

Third-party participants in the implementation of this Action Plan will neet the personnel qualification and objectivity J requirements of the CPRT Program Plan and its implementing Os procedures. -l l

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.Ravicion:.

l

, 2  !

Page 6 of 6

. ITEM. NUMBER V.c

, (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Other participants will be qualified to the requirements of- '

the CPSES Quality Assurance Program or to the specific.

I requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

j 4.4 Standards / Acceptance Criteria 1

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Compliance with FSAR Section 3.7B.3.13 will be assessed during PPSP and DAP implementation. Recommendations to the PPSP and/cr the DAP associated with compliance will be identified as part of this action plan.-

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP V.d ..

Plug Welds i

! Revision No. 0 1 2 I Revised to Reflec ; Reflect Comment Description Original Issue NRC Comments on Plan Prepared and , .

).I Recommended by: .

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Review Team Leader ,/ I W - . .

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Senior Review Team Ou ul h > b _ Q,h4_ h _ d h ,1 _

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R:. vision: 2 Pcgs 1 of 12 l i

ISAP V.d Plug Welds

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated alleged generic problems regarding uncontrolled repairs to holes existing in pipe supports,_ cable tray supports and base plates in Units 1 and 2. These holes, which had been'misdrilled during fabrication, were repaired by plug welds.

~

Since these supports are seismic Category I supports and the effects of the welds have not been evaluated, this constitutes a violation of Criterion IX and XVI of Appendix B to 10CFRSO. Region IV inspections have confirmed the existence of such welds in cable

, tray supports located in the Unit 2 Cable Spreading Room.

Although the effects of unauthorized, undocumented and uninspected

. plug welds in some locations (e.g., the webs of I-beam or in structural members in compression) will be inconsequential, their effects in critical locations (e.g., flanges.of I-beams in flexure or in structural members in tension) in critically loaded supports i

or base plates could affect their structural integrity and intended function.

2.0 ACTION IDENTIFIED BY NRC Accordingly. TUEC shall perform one of the following:

Modify its proposed plan to Region IV (TXX-4183 and TXX-4259) to include a sampling inspection of all areas of the plant having plug welds, to include cable tray supports, pipe supports and base plates. Propose alternate methods of inspection where the oblique lighting method is not viable (e.g., locations covered by heavy coats of paint). Perform an assessment of the effects on quality due to uncontrolled plug welds found during the proposed inspection, as modified above.

Submit a report documenting the results of the inspection and assessment to the NRC for review.

Perform bounding analysis to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, cable tray supports and base plates to serve their intended function. Submit a report. documenting the results of the assessment to the NRC for review.

l

R; vision: 2 Pag 2 2 of 12 ISAP V.d (Cont'd)

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3.0 BACKGROUND

l The issue of uncontrolled plug welds was initiated during the ASLB  :

Hearings.(See CASE Exhibit 919 at pages 22-23) At those hearings it was alleged that misdrilled holes in pipe supports and cab le tray supports were welded without benefit of proper engineering authorization or QC inspection. A second aspect of plug welding and inspection which has been questioned was the validity of CC inspection methods utilized to accept authorized plug welds. Both issues were addressed in the testimony presented by TUCCO following investigation of the issues. (See ASLB hearing transcript dated February 23, 1984) The investigation of these issues is summarized briefly below.

3.1. Plug Welding Practices An instance of unauthorized welding was found. The investigation of this specific case showed that the l unauthorized welding was observed and addressed at ' the time it occurred. The hanger was rejected and the responsible foreman removed from his position. For reasons unrelated to the pit g j

welding, all the hangers'of the type which had been rejectec were removed from the plant. This provides sone as,surance

that the specific case observed did not in itself present a I

4 concern; however, further review was necessary to determine ~ ; f other cases existed. Subsequently an NRC inspection team found three cable tray supports with undocumented plug welds.

(Addendum to page 27 of "NRC Staff Testimony on Welding Fabrication Concerns Raised by [ alleger (name withheld)]" (Tr 12146-4/24/84).

a TUGC0 submitted a plan for reviewing the issue to Region IV.

(See Section~2.0) The most likely location of plug welds was anticipated to be the Unit 2 Cable Spreading Room; therefore the sample was limited to that population. This selection had two bases; first, the location was based on the physical plant location corresponding to the allegation, and second, the choice of cable tray supports in lieu of pipe supports was based on the knowledge that plug welds were used for cable tray supports. The approval to use plug welds in cable tray supports was documented with the issuance of a design change authorization, DCA 5347, which authorized the use of plug welds at any location in the cable tray support. No similar DCA was issued for pipe supports. The practice employed for ASME supports was to reject supports with misdrilled holes and i

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Rr,vicien t 2 Pcg3 3~cf 12 ISAP V.d (Cont'd)

3.0 BACKGROUND

(Cont'd) not to repair them.. Although the plan submitted may.have been a reasonable approach, a more comprehensive review is now sought.

The action plan in Section 4.0 concurs with the NRC position by. expanding the population from which a sample is taken. The

' initial direction of the Plan distinguishes between cable tray supports and pipe supports b'ecause it is known that cable tray supports had plug welds and it is anticipated that pipe supports did not. Furthermore, it is known that until i November 10, 1980 the method of documenting QC inspections did not produce a record for each specific plug weld; instead a record of the acceptance of the entire support was produced in accordance with QC procedure QI-QP-11.10-2. The inspection of the plug weld was temporarily documented using a tag attached

~

to the support serving only to inform the inspector responsible for accepting the support that the plug weld had been inspected. This suggests that indeterminate records exist, and weld-specific (versus support-specific) undocumented plug welds will be found in cable tray supports, 4

thereby requiring physical verification.

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In summary, the information currently available indicates that it will be most efficient to first sample ASME pipe supports to ascertain whether plug welds exist prior to initiating an assessment of weld quality. In the case of cable tray supports, it is expected that some plug welds will exist for which no weld specific documentation was retained verifying quality. Physical verification will be required for such Cases.

3.2 Inspection Methods The second area'which was questioned was the QC inspections that were performed. The method was challenged because only the finished weld was visually inspected. .The contention was made that it was difficult to remove the slag from inside the hole prior to welding the second side without using a pencil grinder. It was alleged that pencil grinders were not always available and that QC should have been required to inspect the hole cleanliness prior to welding the second side. However, several welders and foremen from the same work crew testified that they never directed, nor were directed by others, to make questionable repairs. Other welders also testified that there was no shortage of pencil grinders.

1 R vicient 2 Pag 2 4 of 12 ISAP V.d (Cont'd)

3.0 BACKGROUND

(Cont'd)'

TUGC0 then presented test data at the hearing that i

addressed the issue on slag entrapped in the plug weld.

The tests showed that, using normal welding techniques, significant amounts of slag could not be entrapped in

.the center of the weld. Further tests,'in which deliberate attempts were made to entrap slag, showed I

that, even with large amounts of slag in the weld, the -

welded specimens exceeded the minimum strength requirements of the base material.

These tests indicated that when skilled craf tsmen attempted to weld a " worst-case" weld such that major slag inclusions were present in the material, the strength of the resultant weld was well above the required strength.

The NRC Staff supported TUGCOs conclusions i.e. if the plug weld was made well enough not to be readily discernible after surface grinding, the staff testified that the weld'and the surrounding base material would be at least as strong as the design value used for the O

! base material before it was drilled. (See ASLB decision, ASLBP Number 79-430-060L, dated December 12, 1984) 4 f

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l Revision: 2 H Paga 5 cf 12 ISAP V.d

(

g) (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives this action plan are to:

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Provide additional evidence to confirm the absence or presence of unauthorized or undocumented plug welds in-ASME pipe supports and base plates and assess the significance of any plug welds found.-

j -

Assess the significance of undocumented plug welds on the quality of cable tray supports.

The plan is based on a combination.of sample inspections and engineering evaluations. Sample inspections are used to characterize the frequency of occurrence and location of plug welds to be evaluated. Engineering evaluations are used to assess the significance of specific plug welds identified and limitations of the inspection technique. The sample inspections utilize a combination of paint thickness measurements to identify areas of excessive paint thickness requiring removal and oblique lighting to detect suspect weld O,s areas. This technique, based on inspector testing with painted mockup supports, will detect about 85% of the plug welds present.

The atta: bed logic disgram identifies major tasks and the inter-relationship of tasks necessary for meeting the' preceding objectives.

4.1.1 Pipe Supports and Base Plates

~4.1.1.1 Unlike the generic authorization permitting plug welds in cable tray supports (DCA 5347),

ASME pipe supports and base plates required specific engineering authorization.

Accordingly, it is anticipated that unauthorized or undocumented plug welds do not exist in ASME pipe supports and base plates. Therefore, the primary purpose of-the sample inspection of pipe supports and base plates is to assess whether unauthorized or undocumented welded holes exist.

Two random samples of ASME pipe supports and base plates will be selected for inspection.

One sample will be drawn from the' population O representing Unit 1_and common and the second 1

sample from the population representing Unit 2. The use of separate samples for Unit I and common and Unit 2, rather than a i

Revision: 2 P ga 6 cf 12 ,

I ISAP V.d

( (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) single sample of both units, was not based on any expected difference in the frequency of occurrence of plug welds between the two units. The intent was simply to increase the ,

inspection coverage in anticipation of a low frequency of occurrence.

The sample plan is consistent with Appendix D using the minimum sample size of 60 with a detection number of zero. The reinspection will either provide reasonable assurance that unauthorized plug welds are not present in ASME pipe supports or will detect deficiencies to be investigated and dispositioned. The confidence level achievable with this approach is less than described in Appendix D. To improve the reliability of detection of plug welds an initial activity will utilize mock-ups (with a variety of plug welds) to verify and to l refine the detection techniques. .The field V inspectors will be selected based on their performance detecting plug welds in the mock-ups.

4.1.1.2 When a support is identified as containing a suspected hole repair, the paint will be removed around the indication to allow a determination of the existence of the plug weld. If any plug welds are confirmed, a visual inspection of the welds will be made and documented. The record of this inspection'will be compared to documentation of prior inspections to determine if the welds were authorized / documented.

4.1.1.3 If the inspection and document reviev l indicates that one or more of the sampled supports or base plates have unauthorized plug welds, an NCR will be issued and an engineering evaluation will be performed to determine the effect of such welds on the structural integrity of the affected support or base plate.

O V

Revicient 2 Pcg2 7 cf 12 ISAP V.d

/ (Cont'd)

V}

4.0 CPRT ACTION PLAN (Cont'd) 4.1.1.4 If one or more supports or base plates are found to lack structural integrity due to unauthorized or undocumented plug welds, a decision will be made to either expand the sample, utilize stratified sampling or go to 100% inspection.

4.1.1.5 If no undocumented plug welds are found in the random sarple of ASME. pipe supports and

, base plates, it will be concluded.that there l is reasonable assurance that the structural integrity of ASME pipe supports has not been degraded by the presence of unauthorized plug welds. If unauthorized or undocumented welded holes are found, but are all determined, either by inspection or l

engineering evaluation, not to affect the quality of the supports or base plates, an evaluation of the need for additional inspection will be performed based on the observed trends in the Inspection'Results.

1 4.1.1.6 All supports found with unauthorized / l undocumented plug welds will be identified via an NCR and modifications will be implemented if required.

j 4.1.1.7 As part of this investigation, the existing QC inspection and documentation procedures will be reviewed and, if necessary, changes will be suggested.

i 4.1.1.8 A third-party (Evaluation Research Corp.)

will conduct the reinspection. A third-party will also provide an overview of the full

, scope of the effort.

4.1.2 Cable Tray Supports It is recognized that cable tray supports do exist where the documentation specific to the inspection of individual welded holes is indeterminate . Therefore, the primary purpose of the sample inspection of cable tray supports is to determine the frequency and location of such welds in~ order to determine the

' e effects on the quality of the supports.

\,%

Revicion 2 P;g2 8 of 12 ISAP V.d

/N (Cont'd) k--

4.0 CPRT ACTION PLAN (Cont'd)

Randon samples of cable tray supports in both Units 1 and 2 will be selected for inspection and, if necessary, engineering evaluation. The steps involved in this investigation parallel those for the pipe supports and base plates as described in subsections 4.1.1.2 through 4.1.1.6.

4.1.3 Engineering Authorization of Cable Tray Support Plug Welds A third-party review of the design change authorization (DCA 5347) which generically approved plug welding in cable trays will be performed. The review will ascertain whether a sufficient basis existed at the time of issuance. That basis could include structural calculations, tests, o'r justification based on applicable industry codes and standards which are part of the licensing basis.

4.1.4 Documentation of QC Weld Inspections

) The history of programmatic requirements and implementing procedures for QC documentation, as applicable to plug welds, will be reviewed by a third-party. This review will focus on the fact that prior to November 10, 1980 weld-specific documentation was not required by procedure. The review will first assess compliance with the QA program and licensing commitments as documented in the FSAR and then evaluate any lessons learned for future program ecdifications.

4.1.5 Evaluation of Root Cause and Applicability to Other Areas The results of the sampling program for. plug welds and

' the third-party reviews discussed in 4.1.3 and 4.1.4 will be used to formulate an assessment of the root cause for the plug weld issue and to determine generic implications. This evaluation will be made by a third-party as well as an overview of all other tasks.

4.2 Procedures 4.2.1 A procedure is being developed and will be utilized for the inspection of cable tray supports, pipe supports and base plates to identify misdrilled holes that have s .

been welded. This procedure will contain criteria for limits on paint thickness and methods for paint measurement. These criteria will be developed based

' Revisions. 2 Peg 2 9 of 12 1

() ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) upon a test program that will establish limits on paint thickness at which plug welds can be detected via visual. inspection. Inspectors will be specifically ,

trained and qualified for this task.

4.2.2 Inspection of all identified plug welds shall be l

performed utilizing the criteria for visual inspection as delineated in existing QC procedures. For undocumented plug welds, this inspection will become the inspection of record justifying the quality of the installations.

4.3 Participants Roles and Responsibilities The organizations that will participate in this effort are 4

listed below with their respective scopes of work.

4.3.1 Comanche Peak Project Engineering 4.3.1.1 Scope t

Sample Selection 1

Develop Inspection Procedure 1

Evaluate Adequacy of Existing Documentation Evaluate Inspection Results Identify Unacceptable Locations of Welded Holes Provide Engineering Analysis of Plug Welding Acceptability Assist in preparation of Results Report and developeent of Corrective as Required 4.3.1.2 Personnel Mr. C..Hoehlman Project Mechanical Engineer

() Mr. W. Baker Project Welding Engineer

R:visient 2 Paga 10 of 12 ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 Third-Party Activities 4.3.2.1 Scope Review of action plan and Sample Selection l Review of Past Initiatives and i

Evolution of Plug Weld Issues 1

Inspection of Pipe and Cable Tray '

Supports (ERC) 1 Evaluate QC Inspection Methods &

Documentation Requirements Review of TUCCO Engineering Evaluation I

Recommend Procedure Changes if Applicable Preparation of Results Report i

Evaluate Cause and Applicability 4.3.2.2 Personnel i

Mr. H. A. Levin TERA Corporation - CPRT '

I Mechanical Review Team i Leader

} Dr. J. R. Honekamp TERA Corporation - CPRT TRT Issues Manager Mr. C. Spinks Evaluation Research Corp.

CPRT QA/QC Review Team Leader Dr. F. A.- Webster Jack Benjamin &

1 Associates (JBA), - CPRT i

Statistics Advisor Mr. R. L. Shipp TERA Corporation - Senior t

Materials and Welding

• Engineer i

j s_s/ Mr. R. Sanan TERA' Corporation - Issue j Coordinator i

I ,

Revicient 2 P&go 11 ef 12 ISAP V.d

-~3 (Cont'd) ,

d 4.0 'CPRT ACTION PLAN (Cont'd)

• 4.4 Oualification of Personnel Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to ,

the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear ,

Power Plants". CPRT third-party inspectors will be certified "

to the requirements' of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures, k

Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants will be qualified to the requirements of  ;

the CPSES Quality Assurance Progran or to the specific j

requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K. " Assurance of CPRT

()

Program Quality", of the CPRT Program Plan.

4.5 Decision Criteria / Acceptance Criteria The decision criteria and acceptance criteria for pipe '

supports and base plates is outlined in sections 4.1.1.3 through 4.1.1.6. The decision criteria and acceptance {

criteria for cable tray supports is outlined in section 4.1.2

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R.vicisnt 2 P ga 12 of 12 i l

ISAP V.d (cont'd) v ATTACHMENT PLUG WELDS h

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l COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP V.e Installation of Main Steam Pipes Revision No. 0 1 2 Revised to Reflec'; Reflect Comment Description Original Issue NRC Comments on Plan Prepared and ' j Reccmmended by:

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s Installation of Main Steam Pipes

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated an allegation that a Unit I main steam line had been installed incorrectly,and had been forced into proper alignment after flushing operations by use of the main polar crane and come-alongs. It was also claimed that pipe supports had been modified to maintain the line in its forced position and vibrations following detachment of the flushing line could have damaged the main steam line. Based on its investigation, the TRT determined that the alleged incident pertained to restoration of the Unit 1, Leop 1 main steam line to its initial, correct installation position. (The line had shifted during flushing operations due to the weight of the added water and because the temporary supports sagged.) The TRT also determined that the modifications to permanent pipe supports were necessary to provide proper support to

} the main steam line in its restored position (initial designs for and construction of the supports had been based on the shifted position of the line), and, although the alleged vibrations could not be confirmed, their associated stresses might not have damaged the main steam line. (The highest stresses would have occurred in the weaker, temporary flushing line.) The TRT review of the TUEC analysis, performed 1 year after the incident, concluded that the

km analysis was incomplete. An evaluation for the full sequence of events leading up to the incident had not been performed. The TRT  !

review of Gibbs & Hill Specification No. 2323-MS-100 indicated that there were inadequate requirements and construction practices for the support of the main stean line during flushing, and for temporary supports for piping and equipment in general. In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required. The i

deficiencies in the analysis, specifications, and construction l practice identified above constitute a violation of Criterion V of Appendix B to 10CFR50, 2.0 ACTION IDENTIFIED BY NRC i Accordingly TUEC shallt Modify Gibbs & Hill Specification No. 2323-MS-100, and '

, institute procedures for support of the main steam line during flushing and for temporary supports for piping and equipment, in general, to assure that the quality of piping and equipment are not affected.

Perform an assessment of stresses in the portions of the Unit

, ( ,/

(} 1. Loop 1, main steam and feedwater lines that were affected in the sequence of events involved during their initial installation, flushing and final installation. Conditions requiring stress analysis arer

Revision 2 Pcg3 2 ef 8 ISAP V.e

/N (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)

I Flushing condition when the lines were full of water and temporary supports had sagged or settled.

Disconnecting condition when vibrations of the temporary line could have occurred.

Lif ting condition when forces were applied by the polar crane and come-alongs.

These assessments shall be based on appropriate piping configurations involved.

Perform a non-destructive examination of locations in the Unit

1. Loop 1 main steam and feedwater piping where stresses I

greater than relevant stress allowables were exceeded during the conditions of concern identified above.

Review the existing baseline UT examinations for those portions of the Unit 1. Loop 1, main steam and feedvater involved for unacceptable in all theindications.

conditions of concern. identified above.

Review records of hydrostatic testing of the main steam and feedwater line to verify the quality of piping involved in the incident.

Provide similar assessments for circumstances involved in a-lifting incident identified during the TRT inspection for the Unit 1 Loop 4, main steam line.

Provide assessments of effects on quality of safety related piping and equipment which were involved in similar incidents of sagging, settlements and failures, if any, of temporary supports.

Submit the results of analysis, examinations and reviews in a documented report for NRC review.

3.0 BACKCROUND i

The preliminary review of the main stonn line installation issue shows that the NRC description of the situation is l

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generally correct. The allegation itself cppears to bc misleading based upon current knowledge.

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R:vicion 2 P g3 3 cf 8 t ISAP V.e

( )g (Cont'd)

3.0 BACKGROUND

(Cont'd)

In the normal course of completing the installation of the line, it was found that the main steam line as installed on its temporary supports was out of position approximately 3-1/4" vertically and 3" horizontally with respect to the Steam Generator nozzle to which it was to be welded.

Engineering was informed and, subsequently, calculations were reviewed to determine the weight of the line that was out of position. The line was lifted into position in a controlled

manner, using a load measuring dynamometer in series with the main hook on the polar crane. The dynamometer was clearly visible and was observed by the field support engineer and other personnel during the lift. The maximum load was approximately 15 tons. This was consistent with previously calculated estimates of the weight of the line being lifted.

The one lift plus the horizontal displacement with a come-

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along resulted in satisfactory alignment. No further adjustments by bending, heating, or cutting were necessary to obtain a fit.

( A related issue identified by the TRT conc 3rns the welding of temporary supports without a weld procedure specification or by an unqualified welder. The TRT reviewed the requirements for temporary supports, and made v.ilkthrough inspections in both Unit 1 and Unit 2. The TRT established that temporary supports are employed during construction to maintain the required positions and alignments of components during installation until designed supports are permanently installed. Such supports are essentially made up on the cite by construction personnel from available materials which are assembled in a manner to provide the necessary support function. Based on its investigation, the TRT determined that, except for attachment welds to components or permanent plant structures, no written requirements existed addressing veld fabrication of temporary supports.

The TRT included the following required action statement in NUREG-0797 Supplement No. 10. TUEC shall modify Gibbs & Hill Specification 2323-PS-100 requirements and provide procedures for the fabricacion and installation of temporary supports to assure that the quality of piping and equipnent so supported is not adversely affected. This action is related to that required for Mechanical and Piping Category II, allegation AP-13, item 1 (installation of main steam pipes -- See paragraph 2.0 above).

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' ISAP V.e (Cont'd) i s

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i 4.0 CPRT ACTION PLAN l

4.1 Scope j The objectives of the plan are

Perform an engineering investigation of the main steam line and supports including the connection of the

flushing line near the SG to determine the detrimental i

physical effects, if any, of the adjustment of the line to achieve final ficup, i

I Identify the extent of construction practices at the site related to the specific main steam installation I

and to the more general area of temporary supports and determine the nature and extent of detrimental physical effects in other important piping systems.

If detrimental effects are found in~either the main steam line or other systems, the need for remedial action will be determined. If necessary, a suitable program to remedy the damage will be formulated and implemented.

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Rsvicient 2 Page 5 of 8 O' ISAP V.e (Cont'd) 1 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Methodology The specific engineering investigation of the steam line adjustment.will be performed as follows:

Review procedures for pipe erection and placenent of i temporary and permanent pipe supports.

Interview personnel involved with the steam line 4

adjustment.

Evaluate engineering significance of procedures and 4 practices.

Perform an analytical evaluation of stresses and support load changes during steam line movement for

Unit 1. Loop 1, including full parametric variations of possible inputs.

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Establish engineering significance of stress'es and 1

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support loads from previous step.

Review the existing UT examinations and hydrostatic

tests for the affected piping on Unit 1. Loop 1.

I Determine the need for reinspection of portions of the line that may have been highly stressed and identify location for reinspection. If appropriate, recommend and implement reinspection program.

l A generic study of possible damage in other piping, including j the Unit 1 Loop 4 main steam line, will be performed as follows:

Review procedures and specifications for pipe erection and placementlof temporary and permanent pipe supports.

~

1 Review NCRs and Piping Deviation Request Forms (PDRFs) with circumstances similar to the steam line.

Interview pipe installation personnel to determine other piping that had location adjustments made during fitup.

1 Review all other sources of residual stresses to piping j systems such as bending in place, etc.

i- l R:vicion: 2 Page 6 of 8 i

O ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Evaluate the engineering significance of residual stress due to fitup adjustments. Perform comparative j

evaluations relative to other sources of residual l

stress. Consider guidance from' codes and standards, ASME, ANSI, SRP.'etc.

i If required after the above evaluations, specific additional samples of piping fitup will be chosen and specific engineering evaluations performed as with the steam line.

4 Where required, modify Gibbs & Hill Specification l and/or related procedures, to insure that piping in l general (and the main steam piping in particular).and associated equipment are not adversely affected during

) flushing activities and/or by use of temporary j supports.

j The attached logie diagram ~ identifies tasks and the inter-relationship of tasks for. resolution of this action plan.

i 4.3 Participants Roles and Responsibilities j 4.3.1 Comanche-Peak Project Engineering i

4.3.1.1 Scope i

j -

Modification (as required) of procedures and~ specifications for 1

' control of pipe erection, temporary support, hydro / flushing.

J 4

Provide documentation for process and procedure review.

i Assist in preparation of Results Report.

4.3.1.2 Personnel I

Mr. C. Moehlman. Project Mechanical Engineer-l  !!r.-H. Harrison Technical Services

() Supervisor a

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R vicion: 2 Pcg3 7 of 8 ISAP' V.e

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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 Third-Party Activities 4.3.2.1 Scope ,

All activities identified ~in section 4.2 except those identified in 4.3.1.1 will be performed by third-party.

TERA Corporation verification of work performed by RLCA.

4.3.2.2 Personnel

) Mr. H. A. Levin TERA Corporation - CPRT Mechanical Review Team Leader Dr. J. R. Honekamp TERA Corporation - TRT-

"'}

a Issues Manager ,

Mr. P. Streeter TERA Corporation - Senior Mechanical Engineer i

Dr. R.~ L. Cloud

• Principal RLCA Mr. C. I. Browne* Project Manager RLCA i .

! 4.4 Personnel Qualification Requirements l

t Third-party participants in the implementation of this action. l plan meet the personnel qualification requirements of the CPRT f Program Plan (see note relative to Dr. R. L. Cloud-and i Mr. C. I. Browne). '

Other participants will be qualified to the requirenents of the CPSES Quality Assurance Program or.co the specific j requirements of the CPRT Program Plan. ' Activities performed 4

by_other than third-party personnel will be governed by the  ;

applicable principles of Section III.K " Assurance of CPRT 6 Program Quality", of the CPRT Program Plan. l I

• Dr. Cloud and Mr. Browne have recently assumed responsibilities 1

(, assisting the project in the area of piping design. Accordingly, these individuals are no longer associated with the third-party team. Their prior work will be verified in detail by TERA

' Corporation.

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Rovicion: 2 Pago 8 of 8 Il ISAP V.e D' (Cont'd)

ATTACHMENT INSTALLATION OF MAIN STEAM PIPES

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l COMANCHE PEAK RESPONSE TEAM ACTION PLAN RESULTS ISAP VI.a Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall Revision No. 0 1 2 Incorporates Reflect Comnentt Description Original Issue SSER on Plan O

j Prepared and I

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i Recommended by:

Review Team Leader

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R, vision: 2 Pega .1 of 9 ISAP VI.a l Gap Between Reactor Pressure Vessel Reflective l Insulation and the Biological Shield Wall

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated an allegation that the Unit I reactor pressure vessel outer wall was touching the concrete biolregical shield wall.

~

A TRT review of existing documentation and d M + M ens with TUEC personnel indicated that this allegation vg. an

• atual. However, a significant construction deficiency report, submitted pursuant to 10CFR Part 50.55(e), on August 25, 1983, documented that unacceptable cooling occurred in the annulus between the Reactor Pressure Vessel Reflective Insulation (RPVRI) and the shield wall during hot functional testing, apparently because of the existence of an inadequately sized annulus gap and possibly because the presence of construction debris in the annulus. TUEC corrected the situation by modifications to allow increased air flow for proper

~

heat dissipation and by removal of the construction debris. TUEC representatives indicated that testing to verify the adequacy of the cooling flow will take place when additional hot functional testing is conducted. Information gathered by the TRT'during the investigation; indicated that a design change in the RPVRI support ring (i.e., locating the ring outside rather.than inside the

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' insulation) resulted in a limited clearance between the RPVRI and the. shield wall. The TRT review of the 50.55(e) report revealed

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that TUEC failed to:

Address the fundamental issue of the design change impact on annulus cooling flow, and De'termine whether Unit 2 was similarly affected.

2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall:

Review their procedures for approval of design changes to l non-nuclear safety-related equipment, such as the RPVRI, and i

make revisions.'as necessary to assure that such design changes

! do not adversely affect safety-related systems.

Review procedures for reporting significant design and construction deficiencies, pursuant to 10CFR Part 50.55(e),

and make changes as necessary to assure that complete evaluations are conducted.

g -

Provide an analysis which verifies that the cooling flow in

. the annulus between the RPVRI and the shield a v'll of Unit 2 is l adequate for the'as-built condition.

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--. - .. _ - = . .

l R vision: 2 Pag 2 2 of 9 p ISAP VI.a V (Cont'd) l l

2.0 ACTION IDENTIFIED BY NRC (Cont'd) j Finally, verify during future Unit _1 hot ' functional testing that completed modifications to the RPVRI support ring now allow adequate cooling air flow.

The TRT noted that control of debris in critical spac'es between components and/or structures was identified as an issue, both in the investigation of this allegation and the civil / structural area item II.c (Maintenance of Air Gap Between Concrete Structures),

contained in Darrell G. Eisenhut's September 18, 1984, letter to TUEC. Accordingly,- TUEC shall also:

Identify areas in the plant.having critical spacing between components and/or structures that are necessary for proper functioning of safety-related components, systems or structures in which unwanted debris may collect and be undetected or be difficult to remove.

Prior to fuel load, inspect the areas and spaces identified and remove debris.

w Subsequent to fuel load, institute a program to minimize the collection of debris in critical spaces and periodically inspect these spaces and remove any debris which may be present.

3.0 BACKGROUND

During the hot functional testing of cooling flow in the annulus between the reactor vessel and biological shield wall performed during early 1983, an inability to meet the test procedure. criteria'was noted (i.e., measured temperatures were too high) and documented on test deficiency reports TDR-908 and 1221. A review of the. test data led to a remote visual inspection of the area around the reactor vessel to determine the cause of the observed high temperatures and high heat load input to the neutron detector cooling system. The visual inspection revealed that the reactor pressure vessel l reflective insulation support ring extended into the~ annulus area (air flow space) between the concrete-biological shield wall and the reficctive insulation. The flow path was further restricted by debris resting on the support ring and due to- l g eccentricity between the support ring and biological shield-tj

\ wall which resulted in an uneven space.. The Unit I support ring was modified to increase air' flow and to improve air-flow distribution. This was accomplished by providing holes in-the support ring. All construction debris was also removed.

R: vision: 2 Pag 2 3 of 9 s ISAP VI.a (Cont'd)

3.0 BACKGROUND

(Cont'd)

A visual inspection of the Unit 2 annulus was performed during.

the course of this work to determine if a similar condition existed. This inspection _ revealed a similar flow constraint; therefore, the annulus ~was first cleared of debris prior to testing and evaluation of the Unit 2 cooling system. The tests indicated that there was no need to modify the

' insulation support channel as had been done in Unit 1 but that additional heat removal capacity was required. As with Unit 1, this was accomplished by modifying the neutron detector cooling system.

Initial startup test procedure ISU-282A, " Containment and-Feedwater Penetration Room Tempe'rature Survey", was conducted during the late 1984, early 1985 Unit 1 pinnt heatup to satisfy certain deferred preoperational tecting requirements.

Testing was performed to assess RCS pipe penetration concrete temperatures, containment average air temperature, steam generator and pressurizer compartment air temperatures, neutron detector well exhaust air temperatures, and reactor i

g- s vessel support cooling air supply temperatures under hot

() standby conditions (nominal 557'F RCS temperature). The results of the test proved that the containment and reactor vessel area cooling systems perform in accordance with the plant design and technical specifications.

4.0 CPRT ACTION Pl.AN The objectives of this action plan are to:

Evaluate the adequacy of the testing and analysis performed to confirm that sufficient air flow is provided in.the annulus ,

between the RPVRI and the shield wall in both units. j Provide additional assurance that design changes. to I non-nuclear safety. items have not adversely affected

. safety-related systems.  !

Identify areas in the~ plant that have critical spacing where debris could collect and be undetected or difficult to remove,.

confirm that these spaces are clear of significant debris, and provide procedural controls to' assure'that they will remain clear.

The review.of the process for reporting significant deficiencies ,

-(/s) pursuant to 10CFR Part 50.55(e) will be addressed under ISAP

'VII.a.2.

The attached logic diagram outlines the steps in the action plan as described in the following sub sections.

I 1

Rsvicion: 2 l Pcgs 4 of 9 l fN ISAP VI.a

'j

\ (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1 Scope and Methodology 4.1.1 The removal of debris from the annulus between the reactor vessel and the shield wall was performed for both Unit I and Unit 2,'and the portion of the reflective insulation support which had obstructed the flow path on Unit I has been modified to allow for a more evenly distributed air flow. Additionally the Neutron Detector Cooling System which provides the cooling flow has been modified to increase cooling capacity on each unit.

These measures were all conducted as a direct result of the hot functional testing program. The test data obtained subsequent to these modifications will be reviewed and heat transfer calculations. performed, as necessary, to ensure the cooling requirements for both units are met.

f- g 4.1.2 The design control of non-safety-related items, in

(,) itself, is not the primary means by which adverse interactions are addressed. ThrouFh various programs which address interaction, like the Damage Study Program, (See Action Plan II.d) interactions are identified and monitored as design and construction proceed. It is not anticipated that a single procedure for non-safety-related design control could address this design control issue. The focus of the review will be to examine the collective set of procedures, j

programs and related criteria for mitigation of interactions to determine if all the ways in which t non-safety-related items could have significant influence on plant safety are addressed. If procedures and programs which had been utilized are determined to

} be inadequate, they will be modified.

4.1.3 The implementation of procedures and programs will be verified by reviewing design changes involving non-safety-related' items. Criteria for selecting items to be reviewed will be established after completion of the review of history and applicable procedures when the critical _ aspects of the design-processes are known.

Any design changes waich are determined to.have adverse affects on safety-related items will be re-evaluated and modifications performed as required. .The

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( )s occurrence of inadequate implementation will be evaluated to determine the extent of the issue and to develop corrective measures. -

R';vicien 2 Pcg3 5 of 9 g- ISAP VI.a t.

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.4 Procedures for 10CFR50.55(e) reporting are being addressed as part of the response to the January 8, 1985 NRC letter regarding construction QA/QC issues (See CPRT Action Plan for Item Number VII.a.2, 10CFR50.55(e) Reportability). l 4.1.5 The issue of critical clearances will be addressed through a program for identifying potential areas and a review of housekeeping methods'(See Item 4.1.7). A list'will be compiled of critical spaces where debris could accumulate. Project personnel from site and Gibbs & Hill design organizations will provide input.

Those spaces where physical separation is essential to the function of the items in close proximity, e.g. for flow consideration or physical interference, will be identified for subsequent inspection.

4.1.6 The critical spaces identified in'4.1.5 will be  !

verified to be free of debris by conducting QC inspections prior to fuel load. Following these inspections, the list of critical spaces will be -

re-evaluated to establish an ongoing QC inspection 1

program that ensures the identified spaces remain' free of debris. j 4.1.7 Current and past housekeeping methods will be reviewed to determine the reason for accumulation of debris and to ascertain if procedural changes are required at this stage of construction to prevent reoccurre: ice and to factor the.results of the review into operations.

Housekeeping methods are being addressed as part of the response to NRC January 8, 1985 letter on construction QA/QC issues (See CPRT Action Plan for Item Number ,

VII.a.7,-Housekeeping). j 4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are listed below with their respective scopes of work.

4.2.1 Comanche ' Peak Project Engineering 4.2.1.1 Scope Identify history of design change (n

process

Rsvision: 2 Pags 6 of 9 ISAP VI.a (Cont'd) 4.0 CPRT ACTIO'N PLAN (Cont'd)

Review procedures for design change  ;

Select sample and verify implementation Identify potential critical clearances Develop inspection plan for critical clearances Review housekeeping procedures Assist in preparation of Results 3 Report 4.2.1.2 Personnel Mr. C. Moehlman Project Mechanical 4 Engineer

.O 4.2.2 TUGC0 Quality Assurance 4.2.2.1 Scope Inspect critical clearances Verify post-fuel-load housekeeping 4.2.2.2 Personnel Mr. P. Halstead Quality Engineering Supervisor (Acting) 4.2.3 Gibbs & Hill

, 4.2.3.1 Scope i

Review hot functional test data Analyze cooling system performance 4.2.3.2 Personnel Mr. E. Nicolaysen Mechanical Engineer I

l

R2vicion: 2 Paga 7 of 9 ISAP VI.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.4 Third-Party Activities 4.2.4.1 Scope 4

Review cooling system calculations and. test data Review sample for verification Review assessment of design change process Review impact evaluation Review criteria and plan for clearance inspection and its implementation Review modifications to procedures Design review calculations

(}

Overview housekeeping assessment as prescribed-by CPRT Acticn. Plan VII.a.7, Housekeeping Preparation of Results Report 4.2.4.2 Personnel Mr. H. A. Levin TERA Corporation - CPRT Mechanical Review Team Leader Dr. J. R. Honekamp TERA ~ Corporation - TRT I Issues Manager }.

Dr..C. Mortgat TERA Corporation - Senior

. Structural Engineer Mr. P. L. Turi TERA Corporation -

Mechanical Engineer Dr. F. A. Webster Jack Benjamin &

Associates (JBA) - j Statistics Consultant I

i I

_ _ = , .

R;vicion: 2 Pcgs 8 of 9 ISAP VI.a

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V (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Personnel Qualification Requirement I-Where tests or inspections require the use of certified t

inspectors, qualifications at the' appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified  ;

.to the requirements of the third-party employer's Quality j Assurance Program, and trained to the applicable inspection procedures.

Third-party participants in the implementation of this Action l Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing ,

procedures.  !  ;

I Other participants will be qualified to the requirements of-the CPSES Quality Assurance Program or to'the specific requirements of the CPRT Program Plan. Activities performed '

by other than third-party personnel vill ba governed by the applicable principles of Section III.K, " Assurance of CPRT Os Program-Quality", of the CPRT Program Plan.

4.4 Decision Criteria The review of annulus cooling flow analyses and test data.for Units 1 and 2 will document the adequacy of the as-built configuration. The critical clearance program will identify critical spaces, establish engineering criteria for these spaces, and verify the necessary clearances exists before fuel load. The Q.- Non Q interface question pertaining to the ,

design process will be investigated through a review selected j of NNS design changes. The findings'of this investigation will determine the need for, and the extent of, any further reviews.

4.5 Standards / Acceptance Criteria g The acceptance criteria for the review of annulus cooling flow are the CPSES Technical Specification . limits-for exit air temperature. The acceptance criteria for the critical clearance and Q-Non Q interface evaluations are determined by the specific gap / space of the Q-Non Q interface being ,

evaluated. ,

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Rrvisien: 2 Pega 9 of 9 ISAP VI.a (Cont'd)

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V ATTACHMENT GAP BETWEEN REACTOR PRESSURE VESSEL REFLECTIVE INSULATION AND THE BIOLOGICAL SHIELD WALL

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN RESULTS ISAP VI.b Polar Crane Shimming i Revision No. 0 1 2 Incorporates Reflect ,Coments Description Original Issue SSER on Plan  ; i

                                                                                   )

O Prepared and. o Recommended by: jf/

                                                    /

Review Team Leader i f(JrM

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Date 3lll(( A fglpf i J j f77/g e J

                                                                                'l Approved by:

Senior Review Tea'm OA d, /7_1 bad. bl @ -O I_e 9 U V Date %l T .' t ( \ 4 f%f Y8[ /fA 4ffL 0 4

                                                                                .)

R;vicion: 2 Paga' 1 of 8 ISAP VI.b ("T, Polar Crane Shimming , (. l I

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated the installation of the polar crane rail support system by visual inspection, review of associated documentation, and discussions with TUEC representatives and their contractors. Region IV Inspection Report 50-445/84-08; 50-446/84-04 and Notice of Violation, dated July 26, 1984, documented that gaps on the Unit 1 polar crane bracket and seismic connections exceeded design requirements. In Texas Utilities Generating Company responses of August 23, 1984, and September.7, 1984, the gaps were attributed to crane and bolting self-adjustment resulting from crane operation. A site design change (DCA-9872, Revision 4, dated August 24, 1984) was issued to document the acceptability of the gaps in excess of 1/16 inch Thif> were identified in the above NF.C Inspection Report. During further investigation of the allegation that shims for the rail support system of the polar crane had been altered during installation, the TRT observed gaps which may have been excessive between the crane girder and the girder support bracket. Detailed specifications addressing the gap tolerance in the girder seat connections did not exist; however, Gibbs & Hill letter GHF-2207, dated November 28, 1977, stated that the " seated connections will p(,-)s not require shimming since the area in bearing is at least the width of the bottom flange of the crane girder". Contrary to'this Gibbs & Hill assumption, the-TRT observed nine girders with gaps which extended under the bottom flange that reduced the bearing surface to less than the 20-inch flange width stated in the letter. The TRT also observed conditions which indicated that the crane rail may still'be moving in a circumferential direction, that three rail-to-rail ground wires were broken, that two shims have partially worked out from under the rail, and that two Cadwelds were broken. 2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall: 4 Inspect the polar crane rail girdar seat connections for the presence of gaps which reduce the bearing surface to less than the width of'the bottom flange and perform an analysis which will determine whether existing gaps are acceptable or require corrective action. Determine if additional rail movement is occurring and, if so, provide an evaluation of safety significance and the need for g-' corrective action. O) l i

R: vision: 2 Pcg2 2 of 8 ISAP VI,b l (Cont'd) (O)

   ~,

2.0 ACTION IDENTIFIED BY NRC (Cont'd) Perform a general inspection of the polar crane rail and rail support system, correct identified deficiencies of safety significance, and provide an assessment of the adequacy of existing maintenance and surveillance programs.

3.0 BACKGROUND

Polar crane bracket installation was. performed by Chicago Bridge & Iron as part of the containment liner contract scope. The polar crane girders were set in place after the brackets had been tack welded in place. This was to provide permanent alignment during final welding of the brackets to the liner. Shimming of the girder-to-bracket seat connection w'as l performed concurrently with these activities. It was'noted that the seating surface ~of the brackets may have been warped during fabrication. During girder installation, gaps were encountered between f- s mating surfaces at all connections (girder-to-bracket seat._ l ( girder-to-upper-bracket support, and seismic connections). An engineering assessment was conducted to determine the design significance. After field inspection, Gibbs & Hill indicated that girder seat connections would not require shimming since the area in bearing is at least the width.of the bottom flange of the girder. However, Gibbs & Hill required that the upper bracket connections and the seismic connections be shimmed in accordance with sketch SK-82032. This informrtion was forwarded in letter number DALM 209 and later issued as a design change (DCA 9872). An allegation concerning installation practice of these finger shims brought about a reinstallation and reinspection of the shims. It was later determined that the upper bracket and seismic connection gaps had increased. The effect was assessed and DCA 9872 was revised to accept gaps in excess of 1/16 inch which eliminated the need for further shimming. However, during TRT inspection of the polar crane rail sup eft system it was observed that nine girders had gaps in the weat connection which extended under the bottom flange. These gaps are being addressed as part of this action plan. O f

R;vicion 2 Pcgs 3 of 8 l ISAP VI.b I 7 -~ (Cont'd)

    \~,)'                                                                                    l

3.0 BACKGROUND

(Cont'd) l t As-built measurements of the polar crane rail were provided as  ; part of the initial CB&I doc:imentation. These as-builts ' included diameter and elevation of the rail. Friction clamps were added to the rails after installation per DE/CD-S-1855 and DCA 6437. As non-safety-related components, such items received no inspection of bolt tightening. Rail movement i along the circumference was later observed. Rail creep 3 restraints were then designed and installed per DCA 15337. These restraints were found to be ineffective. On closer , inspection it was found that the friction clamp bolts were loosened. These bolts were then torqued under engineering direction. Precise rail location was not documented making l determination of subsequent rail movement impossible. 3 4.0 CPRT ACTION Pl.AN l The objectives of this action plan are to: l

,                 -                                                                        i

} Determine if the gaps in the polar crane rail girder seat  ! connection are acceptable and provide corrective action.where necessary. Determine if circumferential crane rail movement is continuing-i- ~ and, if so, assess its significance and the need for corrective action. Provide additional assurance, through a general reinspection ! of the polar crane rail support system, that any: deficiencies have been identified and corrected.. Assure that the polar crane maintenance and surveillance programs include those aspects of the rail and rail support 4 system that should be periodically reinspected. The specific tasks.to be implemented are discussed in the following subsections.

    /
   .\_ /

R vicion: 2 Pega 4 of 8 ISAP VI.b (Cont'd)

  \~ '                                                                                                 l 4.0 CPRT ACTION PLAN (Cont'd) 4.1  Scope and Meth'odology l                                4.1.1   A review of the history of the crane support system during construction and of its performance.during operation in the construction stage will be conducted.

The design requirements established by.the crane vendor and Gibbs & Hill will be identified and categorized in terms of performance or structural function (e.~g. rail alignment requirement verses structural integrity). 4.1.2 An inspection of the polar' crane rail girder seat-to- I bracket connections will be performed to determine if the gaps present reduce the bearing surface to less

)

than the width of the bottom flange of the girder. A third-party review of the findings will assess the

!                                      safety significance and determine if the design requirements have been met. If found deficient, corrective action to increase the bearing surface will be prescribed. A third-party review of this inspection and any corrective action.will be performed.

() 4.1.3 A measurement-program to determine the extent of polar crane rail movement will be developed. A third-party will develop, execute, and evaluate the program and 4 then determine the cause of the rail movement, assess i the safety significance, and recommend modifications to. correct the problem. Gibbs & Hill will analyze and design any required modifications. A third-party review of the design and-analyses will be performed. l 4.1.4 CPPE will review the existing maintenance and surveillance programs of the polar ~ crane and -rail support systems. . Concurrently, the third-party will make recommendations for any required changes.to these programs. 4.1.5 A general-inspection of the rail and rail support system will be performed to identify any deviations of safety significance. If found deficient, corrective 5 action will be prescribed. A third-party verification  : of the inspection and a review of any' corrective action { will be performed. .: 4.2 Participants Roles & Responsibilities The following organizations and personnel will participate in O this effort:

    --- _ _ _- +---a                                                                         g

Rsvicient 2 Pcga 5 of 8 ISAP VI.b 4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) i 4.2.1 TUGC0 Nuclear Engineering (TNE) - Civil / Structural - Discipline  ! 4.2.1.1 Scope 1 Develop physical measurement plan for girder seat connection bearing. Identify design performance requirements'and construction operational history and performance of polar crane.' Develop design changes and' travelers for rail and bearing modifications. Evaluate and develop surveillance . program for operations. , t Assist in preparation of Results Reports l I Develop and perform a ge'neral inspection of the rail support system. { 4.2.1.2 Personnel Mr. R.~Hooton TNE Civil / Structural I

                                                                    . Discipline Supervisor              l i

Mr. M. Osterman Civil Engineer I 4.2.2- Gibbs & Hill l 4.2.2.1 Scope Analyze and design any required modifications to correct rail movement and te improve bearing. i ! 4.2.2.2 Personnel Mr. E. L. Bezkor Job Engineer-I* Mr. A. M. Kenkre Squad Leader 9 e p g - -, ---,mv~ w vv- -

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Rsvision: 2

                                                                              .Pagt   6 of 8 ISAP VI b I~')                                          (Cont'd)

NJ 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 TUGC0 Quality Assurance

                            ,4.2.3.1   Scope Inspection of crane girder seats
                                                   . Inspection of rail modifications-4.2.3.2   Personnel Mr. P. Halstead             Quality' Engineering Supervisor (Acting).

, 4.2.4 Third-Party Activities 4.2.4.1 Scope

                                           .-      Develop, execute, and evaluate test 1

for rail movement.

  /'                                        -

Determine cause for rail movement and recommend modifications to correct the problem. Overview ' girder seat inspection and general inspection of the-rail support system. 8 Evaluate significance of gaps in bearing area and recommend modifications to improve bearing. Recommend changes to maintenance or surveillance programs. Design review and evaluate ' resolutions, i Prepare Results Report. 4.2.4'.2 Personnel Mr. H. A. Levin ' TERA, CPRT/ Structural Team Leader

  /~'

Dr. J. R. Honekamp TERA, TRT Issues Manager i (-- ' Dr. C. Mortgat TERA, Senior Structural Engineer i

R.vicion: 2 Pcgo 7 of 8 ISAP VI.b f-~s (Cont'd)

 .U 4.0 CPRT ACTION PLAN (Cont'd)

Dr. E J. Hall TERA Consultant, University of Illinois Dr. D. Nyman TERA, Structural Engineering Consultant Dr. R. White TERA, Issue Coordinator 4.3 Personnel Qualification Requirements Where tests or inspections require the use of certified

                               ~

inspectors, qualifications at:the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third party inspectors will be certified g to the req ~uirements of the third-party employer's Quality [ Assurance Program, and trained to the applicable inspection  : procedures.

 ;S               Third-party participants in the implementation of this detion            '

k Plan will meet the personnel qualification and objectivity I requirements of the CPRT Program Plan and its implementing  ; procedures. Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed , j by other than third party personnel will be governed by.the i applicable principles of Section III.K._" Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Decision Criteria l The evaluation of the results of the girder seat inspection l will determine the engineering significance of the presence of the gaps. If necessary, recommendations to improve the [ bearing surface will be made and implemented. Similarly, the program will determine the extent and safety significance of the rail movement. Corrective actions deemed necessary will be implemented. 4.5 Standard /Accentance criteria The applicable standard for evaluation of the crane support system is AISC-1969. v

                                          - -     ,                          ~ ~

R;vicion: 2 Pags 8 of 8 ISAP VI,b (m\/ s (Cont'd) v ATTACHPINT POLAR CRANE SHImiING

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s OA/0CISAPs I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Test I.d.3 - Craft Personnel Training VII.a.1 Material Traceability

;          VII.a.2           Non-Conformance and Corrective Action System VII.a.3           Document Control

VII.a.4 Audit Program and Auditor Qualification VII.a.5 Periodic Review of QA Program ,

VII.a.6 Exit Interviews - VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation VII.b.1 On-Site Fabrication VII.b.2 Valve Disassembly VII.b.3 - Pipe Support Inspections * , VII.b.4' Hilti Anchor Bolt Installation VII.b.5 DELETED VII.c Construction Reinspection / Documentation Review Plan O J

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  )                              COMANCHE PEAK RESPONSE TEAM ACTION PLAN                     l ISAP    I.d.1 TITLE: QC Inspector Qualifications Revision No.              0                   1              2 Revised to ReflectReflect Coment Description        Original Issue    NRC Coments          On Plan a                     yrk Re o    de by:

Review Team Leader Date l lf h 2. $[ ] 2 L/ h(o io/ chi

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R3 vision: 2 Page 1 of 18 (J"'i ISAP I.d.1 QC Inspector Qualifications

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Page J-110)

                 "The TRT examined electrical QC inspector training and certification files, and requirements for personnel testing, on-the-job training, and recertification. The TRT also interviewed selected electrical QA/QC personnel.

The TRT found a lack of supportive documentation regsrding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements. Also, the TRT found a lack of documentation for assuring that the requirements for electrical QC inspection recertification were being met. Specific examples are: One case of no documentation of a high school diploma or General Equivalency Diploma. One case of no documentation to waive the remaining 2 months of the required 1 year experience. b

  \ ,f          -

One' case where a QC technician had not' passed the required color vision examination administered by a professional eye specialist. A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given. Two cases where the experience requirements to become a Level I technician were only marginally met. One case of no documentation in the training and certification files substantiating that the person met the experience requirement." 4 i 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Page J-111) l "Accordingly, TUEC shall review all the Electrical QC inspector training, qualification, certification and re-certification files. ' agcinst the project requirements and provide the information in such a form that each requirement is clearly shown to have been met by each inspector. If an inspector is found to not meet the training, qualification, certification or re-certification requirements, TUEC shall then review the records to determine the adequacy of inspections made by the unqualified individuals and provide a statement of the impact of.the deficiencies noted on the O safety of the project." l l

R; vision: 2 Pege 2 of 18 r w, ISAP I.d.1 ( ,) (Cont'd)

3.0 BACKGROUND

When CPSES received its construction permit TUEC did not have a commitment to ANSI N45.2.6. The original electrical inspector training / certification program requirements were documented in procedure CP-QP-2.1, " Training of Inspection Personnel." This program addressed the applicable requirements of 10CFR50 Appendix B and was applicable to all QC inspectors except those performing ASME inspections. ASME inspectors are certified under a separate program independently reviewed by the ASME Authorized Nuclear Inspector (ANI). CP-0P-2.1 required that inspector knowledge of inspection procedures be demonstrated through written examinations and that inspector proficiency be verified through prescribed on-the-job training. In August, 1981, the inspector training / certification program was reviewed and revised as required-to reflect TUECs cormitment to Regulatory Guide 1.58, Revision-I which endorses ANSI N45.2.6. The revised program continued to provide on-the-job training and examination to assure the achievement of inspector proficiency. In addition, verification of experience and education was performed as a matter of good practice. It is important to note that tue CPSES training and certification procews is unique in that each inspector, regardless of experience, is initially trained, examined and certified to a specific inspection instruction (i.e., cable pulling, meggering, electrical terminations, etc.). This is a j much nore conservative approach than the common practice in the industry, which is certification by-discipline rather than by specific inspection instruction. The. training and certification progran'at CPSES is structured to ensure that regulatory requirements are met through examination prior to the certification process. The certification activities associated with the examples cited ty the TRT were performed in accordance with procedure CP-QP-2.1, " Training of Inspection Personnel," Revisions 12, 13 and 14. All three revisions of the procedure state in part:

                          "The following is the reccamended personnel education 7-~                      and experience for each level.. 0ther factors which may demonstrate capability in a given job are.. . . . . .

('<') satisfactory completion of capability testing.

Revision: 2 Page. 2 of 18 ISAP.1.d.1 O(.,/ (Cont'd)

3.0 BACKGROUND

3.1 Information Supplementing NRC Description of Issue When CPSES received its construction permit TUEC did not have a commitment to ANSI N45.2.6. The original electrical inspector training / certification program requirements were documented in procedure CP-QP-2.1, " Training of Inspection Personnel." This program addressed the applicable requirements of 10CFR50 Appendix B and was applicable to all QC inspectors except those performing ASME inspections. ASME inspectors are certified under a separate program independently reviewed by the ASME Authorized Nuclear Inspector (ANI). CP-QP-2.1 required that inspector knowledge

                 - of inspection procedures be demonstrated through written examinations and that inspector proficiency be verified through prescribed on-the-job training.

In August, 1981, the inspector training / certification program was reviewed and revised as required to. reflect TUECs commitment to Regulatory Guide 1.58, Revision 1 which endorses O ANSI N45.2.6. The revised program continued to provide on-the-job training and examination to assure fthe achievement of inspector proficiency. In addition, verification of experience and education was performed as a matter of good practice. It is important to note that the CPSES training and certification process is unique in that each inspector, regardless of experience, is initially treined, examined and certified to a specific inspection instruction (i.e. ,- cable pulling, meggering, electrical terminations, etc.). This is a much more conservative approach than the common practice in j the industry, which is certification by discipline rather than i by specific inspection instruction. The training and I certification program at CPSES is structured to ensure that regulatory requirements are met through examination prior to the certification process. 1 The certification activities associated with the examples l cited by the TRT were performed in accordance with procedure CP-QP-2.1, " Training of Inspection Personnel," Revisions 12, 13 and 14. All three revisions of the procedure state in part:

                          "The following is the recommended personnel education p                        and experience for each level.. 0ther factors which may V                        demonstrate capability in a given job are.......

satisfactory completion of capability testing.

1 1 R5 vision: 2 Pags 3 of 18 i I [~ ISAP I.d.1 I

 \s-                                      (Cont'd)

3.0 BACKGROUND

'(Cont' d)

Use of the measures outlined in this section to establish that an individual has the required qualifications in lieu of. required education and experience shall result in documented objective evidence (i.e..... record of written test) demonstrating that the individual indeed do'es have " comparable" or

                        " equivalent" competence to that which would be gained from having the required education and experience."

l 4.0 CFRT ACTION PLAN j 4.1 Scope and Methodology The major objectives of this action plan are to address the specific TRT concerns regarding the electrical QC inspector qualifications, and to. provide input into the assessment of the adequacy of quality control inspection by determining whether all current QC inspectors are properly qualified.- O) (_, The methodology for acco'mplishing the major objectives of this action plan is as follows: Phase I. Training, qualification, certification and recertification files for all electrical QC inspectors, for all current ASME inspectors and for the remaining current non-ASME inspectors will be reviewed against project requirements. Phase II. If inspector qualifications are found to be questionable or unverifiable in Phase I they will be further evaluated taking into consideration other appropriate factors. Phase III Finally, work completed by those inspectors whose qualifications could not be verified in

                                   -Phase II will be reinspected.

Review qualification records system for possible improvements. This action plan is closely related to and complements Issue-Specific Action Plan I.d.2, " Guidelines for Administration of (g QC Inspector. Tests". Issue-Specific Action Plan VII.c , ( ,/ " Construction Reinspection / Documentation- Review Plan", will J provide a significant amount of information that also can be 1

                                                                     .Rsvision:  2 Paga 4 of 18

( ')

 \d ISAP I.d.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) used to evaluate the effectiveness of prior inspections performed by the CPSES Project. Data from ISAP VII.c will be sorted by discipline and-the results can be correlated and compared to the results of.this action plan by discipline (i.e., Electrical, Mechanical, Structural, Civil) during the final collective evaluation process. Data from both ISAP's will be used to determine if trends exist and as an input to root cause analysis and generic implication, if required during the overall Collettfae Evaluation Phase.

4.1.1 Phase I - Evaluation of-Inspector _ Qualification Documentation The objective of Phase I is to perform a review of-the available documentLtion of the qualifications of inspectors against project requirements, codes and standards in place at the time of certification. The results of this review will be documented in a clear

    ,                  and concise format which demonstrates the adequacy of

, ~ inspector qualifications. The review will be conducted in two parts. 4.1.1.1 TAG Non-ASME Inspector Review l The review of non-ASME inspector qualification documents will be conducted by the TUGC0 Audit Group (TAG). TAG is independent of the' organization responsible for administering the CPSES QC Inspector training / certification program. The TAG personnel, certified in accordance with DQI-QA-2.1, " Qualification of Audit Personnel," will perform a review of the inspectors certification files. A' checklist with predetermined attributes that reflect project training / certification requirements will be used in the review. 4.1.1.2 ERC ASME Inspector Review- l ERC will conduct a review of the procedures-for certifying / qualifying ASME inspectors to assure compliance with appropriate standards and codes. ERC also will review the

 /%                            certification records of current ASME

(,) inspectors to verify compliance with these

                                                                                     *i procedures and the criteria. established in          j the attached matrix (Attachment 2).      ERC         j reviewers will be qualified as specified in paragraph 4.3.3 of this Plan.

Rsvision: 2 Pago 5 of 18 ISAP I.d.1 (sj'~'g. (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) NOTE: ASME inspectors are personnel who perform surveillance, inspection, examination, or testing of ASME related activities. The ASME inspectors have no Code-authority and are not inspecting fer ASME. A Special Evaluation Team (SET), comprised of external consultants who have no responsibility for administering the CPSES Inspector Training / Certification Program and whose qualifications are described in paragraph 4.3 of this plan..will evaluate the reviews conducted by TAG and ERC to validate the reviews. For both non-ASME and ASME documentation reviews, a specific certification summary form will be generated

for each inspector. The certification summary will provide e listing of the individual's certification versus specific classroom training, on-the-job training s and examinations in addition to education and g,) experience. The form will similarly l'ist levels.of certification beyond Level I.

Inspectors whose qualification documentation is lacking in one or more aspects listed on the certification summary form will be identified for further review during Phase II. 4.1.2 Phase II - Further Evaluation The objective of Phase II-is to evaluate qualifications that could not be verified in Phase I and, based on i these results,' determine whether further evaluation of the inspector qualifications are required during Phase III. SET will evaluate questionable non-ASME 5 ASME l inspector records for. acceptability using the criteria l established in the attached matricies (Attachment 1 and 2) and the following factors, commensurate with industry standards in place at the time of. initial certification: Experience of the~ inspector () v Education of the inspector Formal training at CPSES

Rcvision: 2

                                                                .Pags 6 of 18 ISAP I.d.1 5

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) On-the-job training that demonstrates practical proficiency Examinations that demonstrate procedural knowledge Other valid certifications in related areas Other considerations deemed appropriate by-SET. These considerations will be clearly documented by SET. For certifications prior to August 1981, the'following criteria will be used to evaluate inspector qualifications: TUGC0 procedure CP-QP-2.1 Revision 0 thru Revision 7. 10CFR50 Appendix B, Criterion II. TUGCO procedure CP-QP-2.7 Revision 0 Section 3.0. SET judgment based on ANSI N45.2 and ANSI N45.2.6 which have been industry consensus / practice since 1973. , l Knowledge of the unique method utilized to l limit certifications to specific inspection  ! procedures containing detailed instructions /_- l steps, rather than attempting to certify l personnel in a specific discipline, such as .!

                              " electrical", to perform any and all               l electrical inspections.                           .l Related experience, if noted to have had direct reletionship.to the inspections for which ed :tfied.    (e.g., hands on, power           i pinni tm Truction or QC inspection                  I s;t'v,t y; equivalent to activities for which l

ces .iii. j

                                        .                                         j Inspectors whose qualifications are' found to be

( \ s acceptable will be dispositioned and documented as acceptable without further action. The' basis used by SET will be documented on certification summary sheets, typical of Attachment 3. The certification summary for l

l

                                                                                                  )

Rsvision: 2 Paga 7 of 18 i O, ISAP I.d.1 (Cont'd) I 4.0 CPRT ACTION PLAN (Cont'd) these inspectors will.be updated to reflect the evaluation performed by SET. TUCCO will be requested to provide additional information or verifications on a case by case basis. - SET will perform a review of all ] additional information obtained by TUGC0 to update , certification records. Copies of these records will be-retained in the Project Central File as described in the.CPRT Program Plan. Based on the evaluation by SET, the RTL is responsible for determining if the inspectors, whose c.ualifications to project requirements cannot be demonstrated, will be. further evaluated in Phase III.

!               4.1.3 Phase III - Reinspection i

The objective of Phase III is to evaluate a sample of work completed by those inspectors whose qualifications

                                                              ~

, could not be verified in' Phase II. The purpose of this evaluation is to. determine the following: l - Whether the inspector was properly able to conduct inspections despite weaknesses in his qualification documentation. 1 Whether the inspections resulted in safety-significant deficiencies remaining in the hardware after inspection.  ! j Reinspections will be conducted of the initial work for l i those inspectors whose qualifications are questionable. I ';. A sample review is considered to be a reasonable I approach because studies conducted by human factors personnel from Rockwell' International (1965-67) have shown that employees are more likely to make mistakes during the initial or early stages of a new assignment. As time progresses they become more familiar with their l assigned tasks and the chance of error. decreases. This same approach was taken at other facilities and proved effective in determining if an inspector was qualified to. perform-inspections. I 4.1.3.1 Population O The population to be sampled includes all of the inspections performed by those inspec' tors whose qualifications are questionable. 1

              .     . . ... .     .-,           -     . . - .    .         .    --_-   -       a

Rsvision 2 Page 8 of 18 p) (, ISAP I'.d.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3.2 Engineering Selection Process l Inspection records will be. reviewed to identify all work / inspections that each inspector performed during the first 90 days following the initial certification. This engineering selection of samples, rather than a' random selection from the whole population, is conservative because of the increased likelihood of inspection errors occurring while the inspector was relatively new to the work. The record review of each sample chosen will determine if subsequent work has been performed that would disturb or change the condition of the hardware since the initial inspection. A determination will also be made as to whether the hardware is still accessible and the inspection is recreatable. 4 The definitions of " inaccessible items" and "not recreatable inspections" are contained in Appendix B of the CPRT Program Plan. Each inspection conducted during the first 90 days will be reinspected. In the event that this first sample is too small (less than 50) to make a judgment on his/h'r e qualifications, we will continue in sequential order until the sample is 50 or includes all of the work accomplished by that inspector. 4.1.3.3 Reinspection of Hardware The hardware will_be reinspected using TUGC0 inspectors, presently certified to the procedure (verified by ERC) and not personally involved in the inspection activities in question, with a 100% overview by independent third-party ERC inspectors. The same TUGC0 inspection procedures utilized on the initial inspection will be used for () the reinspection. Care will be taken to assure that the hardware is inspected to the same criteria as that used for the initial

Rsvicion: 2 Pags 9 of 18 s ISAP I.d.1 q_,). (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) , inspection. The objective / subjective  !

                                  - designation of each inspection attribute will    !

be documented. All deviations identified during the reinspection shall be given to

                                  .TUGC0 and processed as a NCR in accordance with site procedures.

4.1.3.3.1 Comparing Results . The results of the reinspection will be compared to the original inspection results in accordance with the following: 4.1.3.3.1.1 Objective Attributes For objective type attributes there must be a 95% or greater agreement rate between the results of the original inspection and the results of-the reinspection. This figure (95%) was chosen based on the fact that O. objective attributes are repeatable and not subject to interpretation nor require judgment. For example, there may be minor errors in the reading of instruments. 4.1.3.3.1.2 Subjective Attributes For subjective type attributes there must be a 90% or greater agreement rate between the results of the original inspection and the results of the reinspection.- This figure (90%) was chosen based on the fact .that subjective attributes are subject to I interpretation and the specific item being inspected will usually be' viewed slightly different by various inspectors. For example, certain weld defects are highly subjective. The results of the reinspection will be compared to the original inspection to determine if this agreement rate is equal to or greater than the requirement, 95% for objective attributes and 90% for subjective

 . f-~                             attributes. If the inspector fails to meet l        j                          this rate, the sample will be expanded to include the next 90 days of work. The same l

f criteria for a minimum sample size of 50 will be applied. t I

R:vicion: 2

   .                                                                         Pag 2 10 of 18      ;

i I (T ISAP I.d.1 ( ,) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3.3.2 Sample Expansion-The same process of reinspection will be-repeated and the cumulative results calculated for a 180 day period. If the inspector fails, (i.e. less than 95% agreement of cumulative results for objective type attributes and/or less than 90% agreement of cumulative results' for subjective type attributes), a 100% reinspection of all the -inspectors work will be conducted. This same process was used at other facilities and proved to be effective in evaluating inspector's performances. The Issue Coordinator in conjunction with the QA/QC Review Team Leader, is responsible for reviewing the results of the Phase III evaluations and determining

 \                       the root cause(s) for the failures of inspectors to meet the 95/90% agreement rate on reinspections for a 180 day period. The root cause(s) along with associated information such as the total number of' inspectors'who failed to meet the 95/90% agreement rate and their disciplines, shall be reviewed versus the current requirements for inspector training and qualification.           Program deficiencies shall be identified and referred to TUGC0 for correction.

4.1.4 Qualification Records System Review  ! In addition to the review of records for individual inspectors, TUGC0 has taken action for an independent l j review to be made to determine the improvements that ' can be made to the qualification records system and procedures. The objective of this review is to ensure that a qualification records system exists that collects qualification data in a clear and concise form I that is easily retrievable. This review will be conducted by Project Assistance Corporation (PAC), a consulting firm under contract to TUGCO, with expertise l in quality assurance, training, and records systems. 4.1.5 Use of Results t 1 O Documentation supporting the entire action plan will be retained and available for audit. The results of this ! action plan will form a portion of the input to the collective evaluations to be conducted to determine the adequacy of the-QA/QC program. _ . . _ _ 4 . . - - . .

l 1 Rsvicion: 2 l Psg2 11 of 18 { y 1 ISAP I.d.1 [s

 \

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 - Participants Roles and Responsibilities 4.2.1 TUCCO Audit Group (TAG) 4.2.1.1 Conduct the initial review.of non-ASME inspector qualification documents as required by Phase I. 4.2.1.2- Personnel will be certified to the requirements of DQI-QA-2.1, " Qualification of Audit Personnel." ] 4.2.2 Special Evaluation Team (SET) 4.2.2.1 Evaluate the TAG and ERC Phase I reviews. 4.2.2.2 Conduct Phase'II evaluations of inspectors where qualification documentation was l inadequate or not available. ' () 4.2.2.3 Personnel Dr. D. G. Anderson, Third-Party Advisor Mr. J. W. Sutton, Third-Party Advisor Mr. M. L. Curland, Third-Party Advisor

   ,           4.2.3 Evaluation Research Corporation (ERC) 4.2.3.1   Review procedures for qualifying / certifying ASME inspectors to' assure compliance with appropriate standards in Phase-1.

4.2.3.2 Review ASME inspector qualification documents in Phase I. Conduct third-party inspections and/or

                                                                   ~

4.2.3.3 provide overview of TUGC0 reinspections. 4.2.3.4 ' Ensure implementation of this action plan. 4.2.3.5 Personnel Mr. J. E. Young, Third-Party Advisor Ms. D. J. Hudson, Third-Party Advisor

Rsvision: 2 Pags 12 of'18 x ISAP I.d.1 i (j

  \                                         (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.4       QA/QC Review Team 4.2.4.1   Determine if inspectors whose qualifications to project requirements cannot be demonstrated

in Phase II will be further evaluated in Phase III.

4.2.4.2 Review results of Phase III evaluations to determine root cause(s) of failures. Refer.any program deficiencies to TUCCO'for correction. 4.2.4.3 Personnel Mr. J. L. Hansel, QA/QC Review Team Leader fs Mr. J. E. Young, Issue Coordinator

' \ ))            4.3     Qualifications of Personnel 4.3.1       The personnel performing the independent assessment in Phase I (TUGC0 QA Audit Group) will be certified to the requirements of I                                      DQI-QA-2.1, " Qualification of Audit 1                                     . Personnel."

4.3.2 Independent third-party inspectors will be certified to the requirements ANSI N45.2.6 and Regulatory Guide 1.58.- 4.3.3 SET personnel will have, as a minimum, 5 years of management / supervisory level experience in QA/QC, and will meet the qualification requirements specified in the CPRT Program Plan and Issue-Specific Action Plans. 4.3.4 ERC personnel will meet the qualification requirements specified in the CPRT Program

                                    . Plan and have expert knowledge in the area of inspector qualification / certification and training.
  \~J

Rsvision: 2 Paga 13 of 18 ISAP I d.1 [\ . - (Cont'd) 4.0. CPRT ACTION PLAN (Cont'd) 4.4 Procedures The following procedures are applicable to this action plan: i I DQI-QA-2.1, " Qualification of Audit Personnel" l CP-QP-2,1, " Training of Inspection Personnel" CP-QP-2.3, " Documentation Within QA/QC Personnel Qualification File" 1 CP-QP-2.7 "TRT Action Item I.d.1 Phase II Special Evaluation Team (SET) QI-QAP-2.1-5 " Training and Certification of Mechanical Inspection Personnel" QI-QAP-2.1-1 " Nondestructive Examination Personnel Certification" 4.5 Standards / Acceptance Criteria Per FSAR. commitments, the following standards / acceptance criteria apply to this action plan: 4.5.1 CPSES Quality Assurance Program Requirements 4.5.2 Regulatory Guide 1.58, Revision 1 4.5.3 ANSI N45.2.6-1978 4.5.4 ASME/ ANSI code requirements 4.6 Decision Criteria There are four-primary decision points in the action plan. At each decision point, criteria are established to ensure that action will continue to be taken on questionable items until an adequate and documented basis exists for disposition.

4. 6.1 - Initial-review conducted in Phase I, Unless an inspector's qualification documentation clearly meets the requirements, the documentation will be referred to SET for evaluation.

l

Rzvision 2 Paga 14 of 18 l l

                                                                                         .l ISAP I.d.1 IT                                  -(Cont'd)

V 4.0 CPRT ACTION PLAN (Cont'd)~ j 4.6.2 Evaluation by SET (Phase II) _ q SET will use Attachments 1 and 2 as a guideline to determine criteria for evaluating whether a basis exists for resolving an indeterminate condition. If not, the inspectors'in question shall be further evaluated (Phase III). 4.6.3 Evaluation-of Phase III Results The QA/QC Review Team Leader will evaluate the results of the Phase III evaluatio'n to determine the necessity of conducting additional reviews of inspector qualification documents beyond those initially reviewed

 =

in Phase I. 4.6.4 Collective Evaluation of Inspector Qualifications The QA/QC Review Team Leader and Issue Coordinator for this ISAP'will perform a collective evaluation of the ' C

   \>

overall results of this ISAP to make a determination of the adequacy of TUGCO's Inspector Certification Program. The results of this evaluation will be factored into the overall collective evaluations (Quality of Construction and adequacy of QA/QC Program) to be conducted during the final stages'of the CPRT Program. l

(~ s w)  ! s (v; CFRTIFICATION LEVELS & OPTIONS QUALIFICAT10!! RLQtITREMENTS 10CCO LEVEL 1 LEVEL 11 IIVEL 111 IKW TO USE THE MATRIX ALT. 1 2 1 1 2 3 4 1 2 3 4 5 6 7 8 IllCH SCHOOL CRADUATE X X X X X EACH COLUMN REPRESENTS A SET OF. ASSOCIATE DFCRFE, RELATED X X X X QUALIFICATION REQUIREMENTS 4 YEARS C01.LECE DECRFE X X X X WHICH, IF MET, WOULD MAKE

  .O RFLATED INSP. EXPER.                       X                                                        THE CANDIDATE CERTIFIABLE.

3 MONTilS RELATED INSP. EXPERIENCE X ALL OF THE X's IN A COLUMN I4JST 6 MONTHS RELATED INSP. BE ET, THUS THERE ARE THREE (3) EXPERIENCE X X ALTE;1 NATIVES OR SETS FOR LEVEL I 1 YEAR RELATED INSP. CERTIFICATION, ANY ONE OF WHICH EXPERIENCE X HICHT APPLY ETC. FOR LEVEL II 3 YEARS RELATED INSP. & III. EXPERIENCE X 5 YEARS RELATED INSP. LEVEL II ALT. I REQUIRES THAT THE EXPERIENCE X INSPEC1DR HAS HAD PRIOR 7 YEARS RELATED INSP. CERTIFICATION MEETING ONE OF WE EXTTRIENCE X ALTERNATIVES UNDER LEVEL I, 12 YEARS RELATED INSP. EXPFRIENCE X " RELA 1TD" EXPERIENCE IS INSPECTION SUFFICIENT NUCLEAR QA EXPERIENCE PER THE PROCEDURE. > 11tAINING X X X hn$ 5 YEARS RELATED INCL. NOTES: ANSI STANDARD N45.2.6, 1978#9$ 2 YEARS Nt? CLEAR X REQUIRES: ns

• 7 YEARS RELATED INCL. o'. *o.

2 YEARS NUCLEAR X 1. 6 YEARS AS A CORRESPOND 1FC LEVEL .

                                                                                                                                                         ~

8 YEARS RET.ATED INCL.'2 II QC INSPECTOR. YEARS QC INSP. & 2 YEARS 2. 2 YEARS AS CURRESPONDING LEVEL C7 NUCIEAR (NUIE 2) X II QC INSPECIOR. 1 YEAR SATISFACIDRY 3. USE OF CORRECTIVE CLASSES NOT PER}ORMANCE'IN CORRESPOND 1NC ADDRESSED. AS A OC TECHNICIAN (NUTE 8) X 4. COLOR VISION TEST NOT ALWAYS 6 YEARS SATISFACIURY REQUIRED. PFPIURMANCE IN ODRRESPONDING 5. PERFORMANCE CAPABILITY NOT AS A QC INSPECTOR (NUTE 1) X MANDATORY AND MAY NOT BE PART C YEARS RELATED EXPERIFNCE ' 0F CERTIFICATION EXAM PROCESS. 2E INCL. 2 YEARS QC INSPECTION 6. OJT DEFENDS ON 11tIOR EXPERIEF:CE $k ( N 2) X AND 00NTERT NOT DEFINITIVE. ~$ PIIYSICAL EXAH1 NATION (NUfE 7) 7. NO SPECIFIC REQUIREENT FOR A "O EYE TFST (VISION) (NUTE 3) X X X X X X X X X 'X X X X X X PHYSICAL EXAM EXCEPT THE EYE h ** COIDR VISION TEST (NUTE 4) TEST. INDOCTRINATION - QA X X X X X X X X X X X X X X X 8. IF "QC TECHNICI AN" & "QC PROGRAPetATIC TRAINING INSPECIDR" HEANS CERTIFIED AS PERFORMANCE DEMDNSTRATION 1EVEL I & II RESPECTIVELY THEN (NUIT 5) THIS COMPLIES WITH ANSI. ON THE JOB TRAININC (N017 6)

(3 G

           -                                                                                                                    \u)       -

i CFRTIFICATION LEVELS & OPTIONS B&R TRAI'INC & CERT., MECff. INSP.

                                                                                          "OR CED" WAS ADDED IN I        II                           III                REV. 1 JAN. '84 IN 2  1 2    3    4     1      2    3   4    5  6  7  8   REV. 5 "QA TECHNICIAN QI-QAP-2.1-5 Rev. 7             I WITH HIGH SCHOOL & ZERO X        X                      X   X X                    EXPERIENCE" WAS ADDED; ttICII SCHOOL CRAD. OR CED AS$0CI ATE IECREE. RELATFD          X         X                               X  X         IN REV. 6 JUNE '84 IT 4 YEARS COIIECE CRAD.                              X                                X  X   WAS DELETED. OTHERWISE X                                                      IMIS MATRIX WAS APPLICABLE 3 MONTHS RELATTIr INSP. EXPER.

6 NDNTHS RF1.ATED INSP. EXPER. X X FROM JAN. 14, 1982 TO DATE. I YEAR RELATED INSP. EXITR. X 3 YEARS RFI.ATED INSP. EXPER. X QI-QAP-2.1-5 REV. 7 5 YEARS RELATED INSP. EXP5'R. X 11/15/84 REFERS TO ANSI 7 YEARS RELATED INSP. EXPER. X M45.2.6 1978 BLT NOT X REC. CUIDE 1.58, 10 YEARS RI' LATED INSP. EXPER. 1 YEAR AS LEVEL I X REV.1, HOWEVER IT 6 YEARS AS LEVEL II X APPEARS To NEET THE REC. 5 YEARS RELA 1TV INSP EXPER. CUIDE REQUIRENEtrIS AT INCLUDING 2 N11CL. X LEAST FOR HICH SCHOOL > 7 YEARS RFLA H D INSP. EXPER. . DIPLOMA, IF.NOT IDR Nm$ IhCLUDINC 2 Nt'C1.. X SPECIFYING ALTERNATES *9% fxCL, CA TRAININC X X X .TO THE RECOP9 ENDED EDUCATION $s

• AND EXPERIENCE CUIDELINE: M o". p.

8 YEARS RE1ATED INSP. EXPER.

• INCLUDINC 2 AUCL. & 2 LEVEL II SEE PAR. 3.2.1 "01WER OR EQt!IVAI.EhT X FACIORS ......".

8 YEARS RELA 1TD INSP. EXPER. INCLUDINC 2 AS LEVEL II OR PRIOR TO JAN. 1982, FfUIVALENT X QI-QAP-2.1-1 REV. 1 EXAM G OSED BOOK CEN'L X X X X X X X X X X X X X X 2/13/81 APPLIED TO BOTH EXAM, Orf74 BOOK SPECIFIC X X X X X X X X X X X X X X NECH. INSPECTORS & NDE EXAM, PRACTICA1. X X X X X X X X X X X X X X PERSONNEL. ITS SCOPE EXAM. EYE. ACUITY & COIOR X X X X X X X X X X X X X X WAS TO NET THE IhTENT OF READING ASSIGNMENT X X X X X X X X X X X X X X ASNT-TC-1-A, ASE CODE SEC FORMAL Cl>SSR00M TRNC OR fitT X X X X X X III DIV 1, AWS DI.I. ANSI 2[ B31.1, AND ANSI M45.2.6 T1m

                                                                                                                                     -r ANST-TC-1A 1975 WAS FI}TRENCED,          *$.

AND "1974 J1'NE EDITION" WAS k ** Q1P911TTED TO (APPARENTLY - E ANT 1975). ASME CODE OF 1974 WAS Q)ttf1TTED TO, AS WAS ANSI M45.2.6 (NO DATE).

Ravision: 2 Peg 2 17 of 18 ISAP I.d.1 (Cont'd) ATTACHMEhT 3 INSPECTOR CERTIFICATION EVALUATION

SUMMARY

Name: SS#: Applicable Education: A /> Manner of Verification: hv Applicable Verified Prior Experience:

                                                  />        \t' V

Initial and Discrepant Certifications: Level CertificAtio Date Certified

                                /AN)
                             /U/
                          < x-(  v
                /

v Diser a les Noted: A o V Signature: Date:

Revision: 2 Page 18 of 18 ISAP I.d.1 (Cont'd) ATTACHMENT 3 (Cont'd) INSPECTOR CERTIFICATION EVALUATION

SUMMARY

(CONTINUED) Name: SS#: Recommended Corrective Action: . A W //

                                                               ~V (NP A      \ V//

Signature: Date: A " i _\\ Corrective Action Taken:

                              /   W N)
                   /           <

b

          /(

j Signatur Date: 1 1 l l l l C Acceptable O unacceptedte Signature: Signature: l Date: Date:  ;

COMANCHE PEAK RESPONSE TEAM

    \

d ACTION PLAN ISAP I.d.2 TITLE: Guidelines for Administration of QC Inspector Test 1 Revision No. 0 1 2 Revised to ReflectReflect Comment Description Original Issue NRC Coments On Plan k,M N k0? fo/r,/r/ 9

=:d e ,

      .. i.. ,.. t..c.r   Qv                 $#~             s
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                           +<wp           4/v/r o.t.                                                      %du
                          /3ech,=t io/ssy 2"I:!"OILTeam               7 h,b    "

(% glj_ l vate 10/Cl2 Y whi/t r " /z+/ec. i l i

Reviciens 2 Paga 1 of 7 ISAP I.d.2 Guidelines for Administration of QC Inspector Tests

1.0 DESCRIPTION

OF ISSUES IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-lll)

        "The TRT found a lack of guidelines and procedural requirements for the testing and certifying of Electrical QC Inspectors.

Specifically, it was found that: No time limit or additional training requirements existed between a failed test and retest. No controls existed to assure that the same test would not be given if an individual previously failed that test. No consistency existed in test scoring. No guidelines or procedures were available to control the disqualification of questions from the test. No program was available for' establishing new tests (except when procedures changed). The same tests had been utilized for the last 2 years." 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-Ill)

         "Accordingly, TUEC shall davelop a testing program for Electrical QC Inspectors which provides adequate administrative guidelines, procedural requirements and test flexibility to assure that suitable proficiency is achieved and maintained.

The deficiencies identified with the Electrical QC Inspections have generic implications-to other construction disciplines. The implications of these findings will be further assessed as part of the overall programmatic review of QC inspector training and qualification and the results of this review will be reported under the QA/QC category on ' Training and Qualification'."

3.0 BACKGROUND

Quality Engineering personnel use procedure CP-QP-2.1,

               " Training of Inspection Personnel", and CP-QP-2.3,
               " Documentation Within QA/QC Personnel Qualification File", to O               comply with ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1. The above mentioned procedures are not overly prescriptive in nature, thus allowing QC personnel to develop

{ examinations appropriate to the specific circumstances.

R2 vision 2 Pag 2 2 of 7 ISAP I.d.2 (Cont'd) (V~'}

3.0 BACKGROUND

(Cont'd) The TRT concluded that the certification review process should provide more detailed information concerning administrative guidelines, procedural requirements, and test flexibility. The availability of such information would. reduce the possibility of not properly verifying the capabilities of the inspectors being tested. s I 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to ensure that the CPSES training and certification program complies with ANSI Standard N45.2.6 - 1978 and Regulatory Guide' 1.58, Revision 1. The specific TRT issue primarily addresses the training and certification program for Electrical Inspectors. In light of the potential generic implication for other QC inspector training and certification, this plan addresses the training and certification program for all CPSES inspectors. The following tasks will be. implemented to achieve the above 4 objective: Review procedures and recommend improvements. Evaluate recommendations and revised instructions. Evaluate effectiveness of changes. 4.1.1 Procedural Review i A Special Evaluation Team (SET) comprised of individuals with no responsibility for administering i the CPSES inspector / certification program will be used 1 l

R: vision: 2

                                                                                                                      -Pcg2        3 of 7 ISAP I.d.2 (Cont'd) f~'}

V 4.0 CPRT ACTION PLAN (Cont'd) to conduct an independent review of procedures CP-QP-2.1, " Training of Inspection Personnel", and CP-QP-2.3, " Documentation within QA/QC Personnel Qualification. File". The qualifications of SET members are described in paragraph 4.3. SET will~be required to make_ recommendations for improvement to TUEC and the QA/QC Review Team Leader. In addition to verifying compliance with the FSAR commitments the following itees will be considered during the SET review of the procedures:

                                                                     -            Method of verifying education and work j                                                                                  experience.

t ! - Methods of determining levels of capability. l

                                                                     -            Method of establishing, controlling, and updating questions to be used in examinations.

Methods of justifying performance for j recertification. Methods to ensure inspectors being examined do not have prior information on the specific examination questions to be used, i.e. that-each examination is a valid measure of the inspector's knowledge of the test subject. Methods on how tests are monitored and for determining test scores.

                                                                      -           Methods for handling retesting of inspectors who have previously failed examinations.
                                                                      -           Methods for ensuring inspectors who have been previously tested and certified are ratested or requalified when significant changes are j                                                                                  made to inspection procedures.

i l - Method of administering training in each specific discipline.

                                                                       -          Methods for determining waivers for OJT.                l Recommendations for improvement will be forwarded to                           l TUEC with copies transmitted to the QA/QC Review Team l

Leader for reconcilation and concurrence. t

Rsvisiens 2-Psgs 4 of 7 ISAP I.d.2 x .(Cont'd) l

i. .

l

4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Evaluate Recommendations and Revise Instructions ]

i TUEC will review the recommendations submitted by SET-i and revise the instructions as.necessary. The QA/QC Review Team Leader shall document his agreement with j the adequacy of the. revised instructions. i Additionally, the following subtasks will be performed:

                                           -      If revised procedures are issued 4                                                 incorporating the recommendations, an
                                                                  ~

evaluation to determine if the comments apply and are reflected in the daughter i . instructions (qualifications of specific inspection personnel) will be conducted by TUEC and be overviewed-by the QA/QC RTL. l' - All inspector certification exams currently 4 in use will be reviewed by TUEC and revised as needed to ensure that they reflect the current requirements. Future examinations 1 will be administered in accordance with these j revised procedures. In addition to the revision of the procedures as requested by the NRC, SET, and the QA/QC j RTL, a review will'he conducted to determine whether other improvements should be made to { the program to enhance training of inspection

!                                                 personne1~. This review will be accomplished j                                                  in conjunction with the qualifications

[ records system review described in ISAP I.d.1.. 4.1.3 Evaluate Effectiveness l. i The effectiveness of procedure changes will be

 ;                                     evaluated by monitoring the Phase II reviews of ISAP j                                       I.d.1. Should any major concerns emerge during the i                                       Phase II reviews of ISAP I.d.1, recommended changes to the procedures will be forwarded to TUGC0 at this point l

of this action plan. 4.1.4 Use of.Results The results of this evaluation will be factored into lO 1 the overall collective evaluations (Quality of Construction and adequacy of QA/QC Program) to be conducted during the final stages.of the'CPRT Program. 1 l .

Rsvision: 2 Paga 5 of 7 ISAP I.d.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants Roles and Responsibilities 4.2.1 Special Evaluation Team (SET) 4.2.1.1 Review the procedures for " Training of Inspection Personnel", and.the " Documentation j within QA/QC Personnel Qualification File" for compliance with standards. 4.2.1.2 Recommend improvements to TUGC0 and QA/QC' 3 Review Team Leader. 4.2.1.3 Evaluate the effectiveness of procedure I changes. , 4.2.1.4 Personnel Dr. D. G. Anderson, Third-party Advisor i Mr. J. W. Sutton, Third-party Advisor

\ ,/ Mr. M. L. Curland, Third-party Advisor 4.2.2 TUEC

4.2.2.1 Review SET recommendations and revise instructions.

j 4.2.2.2 Determine if recommendations apply to 4 daughter instructions.

4.2.2.3 Review and revise.all current certification exams to reflect current requirements.

4.2.2.4 Personnel ! P. E. Halstead, Manager of Quality Control i 4.2.3 QA/QC Review Team I 4.2.3.1 Euview SET recommendations and document i agreement. } I t

R: vision: 2 Pcg2 . 6 of 7 ISAP 1.d.2

  / 'N                                           (Cont'd)
  \~s 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2     Review TUEC instruction revisions and document agreement.

4.2.3.3 Overview TUEC's consideration of daughter instructions. ,2 4.2.3.4 Personnel i Mr. J. L. Hansel QA/QC Review Team Leader Mr. J. E. Young, Issue Coordinator 4.3 Oualifications of Personnel SET and ERC personnel will have, as a minimum, five (5) years of management / supervisory level experience in QA/QC. Each person will have experience in some aspect of training, j either inspection of training programs or actual experience in j the conduct of training and will meet the qualification l requirements specified in the CPRT of Program Plan and ! appropriate Issue-Specific Action Plans. (} 4.4 Procedures This action plan will be conducted in accordance with the CPRT Program Plan and Issue-Specific Action Plans. 4.5 Standards / Acceptance Criteria The principal criteria and basis for this review will be the TUEC commitment in the FSAR to comply with the ANSI Standard N45.2.6-1978~as endorsed by Regulatory Guide 1.58. Revision 1. 4.6 Decision Criteria , There are three primary decision points in the action plan. Criteria are established to assure that action will be taken on questionable items until an adequate basis exists for disposition. 4.6.1 Initial Review Conducted l Unless the procedures CP-QP-2.1 and CP-QP-2.3, clearly meet the requirements, recommendations will be forwarded to TUEC for reconciliation. O

R vision: 2 Pcgs 7 of 7 l l ISAP I.d.2 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) i i 4.6.2 Review and Reconciliation by TUEC l 4 3 Recommendations will~be evaluated and procedures ' revised as necessary with concurrence from the QA/QC , Review Team Leader that FSAR commitments have been i satisfied, i j 4.6.3 Evaluation of Results- l Evaluate implementation of revised procedures during - the conduct of ISAP's I,d.1 and'VII.c to determine if i J the revisions are adequate and prove to be effective, i If found to be inadequate, additional recommendations will be provided to TUGCO. 1 j  ! I i i i .j . 1 1 i

)

i ll. i I i. f i l l I

f, COMANCHE PEAK RESPONSE TEAM ACTION PLAN i ISAP I.d.3 i. j

Title:

Craft Personnel Training i i 1 i Y Revision No. 0 3 Description Original Issue , Prepared and j Recommended by: Review Team [ Nh&' [ i Leader I j ~Date /!2 yid 1 Approved by: Senior l Review Team h_id), k1_ j nate /h+/n, O I 4 ,

R;vicion: O Para 1<f6 ISAP I.d.3 () Craft Personnel Training

1.0 DESCRIPTION

OF ISSUES IDENTIFIED BY NRC (NUREG-0797, supplement No. 7, Page J-34 and Supplement Number 8, Page K-147) It was alleged that, in general, there were problems with the adequacy of training of personnel installing conduit supports.

             "The TRT interviewed personnel, craft supervisors, and training.

personnel to determine the availability and effectiveness of the training program, and found that there was a training program for newly hired personnel or transfers into the installation. This' training program included periodic briefings on procedure changes. The interviews revealed that the training program was not effective because 7 of the 11 crew members interviewed were not cogaizant of Manual 2323-S-0910. " Conduit and Junction Box Supports", which is the primary reference manual for installation of supports. Although these seven crew members indicated that they had no need to use this manual in their job assignments, the TRT could not substantiate this assertion. Hence, the lack of awareness of this procedure by craft personnel may be indicative of poor training in the area of procedural requirements."

             "An NRC Region IV Resident Inspector identified a violation as a g             result of a discussion with a craft person who stated that he had not received instructions about how to rig and handle a large motor-operated valve."
             "The NRC Technical Review Team (TRT) found no need to contact the alleger to further clarify the allegation. The TRT~ reviewed NRC Inspection Report 50-445/79-27, 50-446/79-26 and its correspor. ding Notice of Violation (NOV). The TRT also reviewed the Texas Utilities Electric Company (TUEC) response to these documents (TXX-3080, dated December 18, 1979), which stated that the subject valve was not mishandled, nor was it damaged. The engineering organization had not, however, reviewed specific vendor rigging or handling recommendations or noted the procedures for loads exceeding 2000 pounds. An NRC follow up inspection verified that Brown & Root (B&R) Procedures CP-CPM-6.3, 35-1195-CCP-24, 35-1195-ACP-3, and QI-QAP-13.1-1 were reviewed by TUEC and revised appropriately.      NRC Inspection Report 50-445/80-18, 50-446/80-18 (dated September 19, 1980) documented corrective action during the follow up inspection."

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7 Page J-35 and Supplement Number 8, Page K-147)

 -s          " Prior'to fuel load TUEC shall accomplish the following action:
      )      Evaluate the adequacy of craft personnel training in the use of
            installation manuals to establish root causes and appropriate

R:vicient 0 < Pcg2 2 of 6 ISAP I.d.3 (} (Cont'd) N.) 2.0 ACTION IDENTIFIED BY NRC (Cont'd) corrective actions. This action shall be integrated with other actions concerning craft personnel training addressed under QA/QC Category 8, 'As-Built'." The TRT determined that Region'IV (RIV) confirmed that the craft person's stated need for better instructions was correct and confirmed follow up inspection by the RIV inspector to verify that corrective action was accomplished in accordance with TUEC letter TKX-3080 (December 18, 1979). Thu TRT concludes that the failure to provide proper instructions for rigging and handling heavy loads is safety-significant and has generic implications;'however, corrective action was taken. No evidence of further inadequacies in this area ".as found; consequently the allegation requires no further action.

3.0 BACKGROUND

3.1 Information Supplementing NRC Description of Issue (q

       ,/

A preliminary investigation from the CPRT revealed that Manual 2323-S-0910, " Conduit and Junction Box Supports", is an engineering document. As such, it was required that only structural engineers and craf t supervisors be familiar with the use of the document. When craft personnel began installing junction box or conduit supports they were given specific directions by their supervicor concerning the type of support which was required to be installed. Thus there was no need for the craft to be awar. of this document.

                      "The TRT interviewed TUEC's Rigging Craft Superintendent, Assistant Mechanical Superintendent, and Senior Staff Engineer. They stated that the revised procedures          ~

(specifically, CCP-2A, Revision 4, " Rigging"; CP-CPM-6.3, i Revision 10. " Preparation, Approval, and Control of Operation

!                     Travelers"; and, CP-CPM-6.9, Revision 2, " General Piping Procedure") adequately controlled heavy lifts of equipment.and components. Non-conformance Report (NCR) M-2128 documented une problem which was identified as a violation, and the appropriate site personnel reviewed the NRC Inspection Report and concurred with the corrective action. In addition, the TRT independently reviewed the revised procedures for the control of heavy lifts of equipment and found the control of rigging and handling to be acceptable for loads less than or l'                     exceeding 2000 pounds."    (NUREG-0797, Supplement No. 8, Page
      ~~g             K-147) l (d

I

                                                                                                                  -R visions.               O Pago      3 of 6 i

ISAP I.d.3 (Cont'd) i ,

' j i

I i l , l 4.0 CPRT ACTION PLAN i 4.1 Scope and Methodology l The objective of this action is to evaluate the Craft Training i Program to determine if it was adequate in the past, and also i evaluate the current program. f To achieve this objective, the following tasks will be implemented: I - Resolve specific NRC concerns. l - Review procedures and interview personnel. j 4.1.1 Specific NRC Concerns j To address the specific concerns regarding Manual j 2323-S-0910, (NUREG-0737, Supplement Number 7. Page J-34), the installation procedure for conduit and junction box supports, ECP-19 " Exposed Conduit / Junction Box and Hanger Fabrication and Installations" ! will be fu'ther r investigated to determine if craft i j personnel should have been cognizant of the manual. If , i required, the existing procedures will be reviewed and ! recommendations for improvement made to TUGC0 as

' required. ,

To address th'e NRC concern involving instructions for i rigging and handling heavy loads (NUREG-0737,

l. Supplement Number 8, Page K-147), the procedure or

method used to retrain craft to revised procedures will i be reviewed.

iO 4 i i

R:visicn 0

                                                                      -P2g2   4 of 6 1

ISAP I.d.3 g (Cont'd) L) 4.0 CPRT ACTION PLAN (Cont'd)

                 -4.1.2 Special Evaluation Team A Special Evaluation Team (SET) comprised of individuals with no direct responsibility to CPSES will perform the evaluation of-the Craft Training Program including the craft personnel selection _ training, assignment and retraining. The following, items will be considered during the SET review:

How requirements for craft skill levels are established.

                            -       How craft personnel (when selected and while on assignment) are determined to meet the skill and performance requirements.

How craft personnel classifications are established for crew loading. How craft personnel become aware of changes in design and construction requirements and how retraining occurs. How craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and char.ges to those requirements / criteria. How management is assured that the craft personnel selection, training, assignment and retraining program complies with project

requirements.

How supervisory personnel are selected and trained. How background of education and experience of i craft personnel is verified and' documented. The SET evaluation will be accomplished through reviewing those craft procedures that were in existence, interviewing craft personnel, and observing training and field activities. i 4.1.2.1 Review Procedures The Craft Training Procedure (CP-CPM-2.2) (\ ~ will be reviewed to determine if it supports l the activities as described during interviews and field observations. I I l _~

I

                                                                       .Rsvicient   0-  l P:ga   5 of 6 ISAP I.d.3 (Cont'd) 7 v/}

4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.2 Interview Personnel i Craft personnel will be interviewed, from the general superintendent / building manager level to the craft level including the following disciplines: mechanical, civil coatings, electrical and paper flow group to determine how craft personnel were selected and trained. 4.1.2.3 Observe Training and Field Activities Training and field activities will be observed to determine if adequate training is

 !                                   provided and to evaluate how well the craft
 !                                   performed in the field after training has l                                   taken place.

4.1.3 Use of Results 1 Based on this review, conclusions will be drawn by the

    ,)                     QA/QC Review Team Leader as to the adequacy of.both past and current practices used for craft selection and

] training. If current procedures are determined to be inadequate, recommendations for improvement will be provided to TUCCO prior to the closure of this action plan. 4.2 Participants Roles and Responsibilities l 4.2.1 Special Evaluation Team (SET) 1 4.2.1.1 SET will be responsible for conducting the , reviews of the procedures, the interviews of I the personnel and for observing the training and field activities. { 4.2.1.2 SET consists of a minimum of two members who l are external consultants with appropriate qualifications. 4.2.1.3 Personnel: Mr. M. L. Curland, Consultant Mr. J. W. Sutton, Consultant O

R2 vision: 0-Pegs 6 of 6 _cs ISAP' I.d.3 ( ) (Cont'd)

    %/

4.0 CPRT ACTION PLAN (Cont'd) 4.2.2 Evaluation Research Corporation (ERC) 4.2.2.1 ERC will-be responsible for evaluating

recommendations and reconciliation of comments with-TUEC.

4.2.2.2 Personnel: Mr. J. L. Hansel, QA/QC Review Team Leader Mr. J. E. Young, Issue Coordinator 4.3 Qualifications of Personnel SET and ERC personnel will have, as a minimum, 5 years of management / supervisory level experience in QA/QC, Each person will have experience in some aspect of training, either review of training programs or actual experience in the conduct of training and will meet the qualification requirements specified in the CPRT Program Plan. O 4.4 Procedures This action plan will be conducted in accordance with the CPRT' Program Plan. 4.5 Standards / Acceptance Criteria The requirements of ANSI N45.2-1971, set forth in part that personnel performing activities affecting quality are trained and indoctrinated to assure the suitable proficiency is

achieved and maintained, will be met.

4.6 Decision Criteria i The results of inspections conducted during ISAP VII.c will i provide an indication of the adequacy of hardware construction. This information will be categorized by major discipline i.e., civil, mechanical, electrical, and structural. This information can then be compared to the results of this ISAP during the collective evaluation phase. If craft training was determined to be a root cause, l recommendation will be provided to TUCCO. b O I l l

jO. COMANCHE PEAK RESPONSE TEAM i ACTION PLAN l ISAP VII.a.1 1

Title:

Material Traceability  ! Revision No. 0 1 I Reflects Coments Description Original Issue On Plan O Prepared and u.4.c[ Recommended by: Review Team Leader Date ' 'Vf l 2 '/ [ G i n av v Team _M d. M, h_,f_ _ Date b/2./ f $f /l24fff

'(
  - . ,        ,-                              n             ~             , , . - . . . . - . , , . . . , ,
                                                                                                             ,- - .,m--

R1 vision: 1 Paga 1 of 6 ISAP VII.a.1 O Material Traceability

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (USNRC Letter January 8, 1985, Issue ll, Materials)

             "The as-built review effort by the TRT included a material traceability check on 33 of the same pipe supports that the TRT had field inspected. The material traceability was adequate for those 33 pipe supports, with.the exception of four material identification discrepancies, as noted in Section 4 on as-built inspections.

In another case, TUEC failed to maintain material traceability for safety related material and numerous hardware' components. This QA , breakdown was identified in an ASME Code survey in October,1981 yet was not reported to the NRC in accordance with.the requirements of 10CFR50.55(e)." With the issue of NCR (NUREG-0797, Supplement Nos. 10 and 11) the TRT identified the following additional areas of concern: Material traceability for a hanger piece was lost due to several heat numbers listed for different pieces on a receipt O inspection report. Fif teen (15) to twenty (20) . hangers lacked material traceability. Traceability of heat exchange bolting is missing.

                   ~TUEC failed to maintain material traceability prior to October, 1981.

Heat number for material used in safety related' applications were assigned improperly in the field. Safety related bulk pipe joints were sandblasted, which removed all heat markings used for traceability. l 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications sof these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT.

                   " Address the root cause of each finding and its generic

() implications...

                   " Address the collective significance of these deficiencies...                    l l

I i I

Rsvision 1

                                                                       .Page   2 of 6 i                                          ISAP VII.a.1 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC
                    " Propose an action plan...that will ensure that such problems do not occur in_the future."

3.0 BACKGROUND

The question of material ~ identification discrepancies on pipe supports is to be addressed by Issue-Specific Action Plan (ISAP) VII.b.3, " Pipe Support Inspections." The question of TUGC0 failure to report "a significant breakdown in any portion of the quality assurance program...", under the provisions of 10CFR50.55(e) is to be addressed by Issue-Specific Action Plan VII.a.2, "Non-conformance and Corrective Action Systems." Input from ISAP VII.c, " Construction Reinspection / Documentation , gs Review Plan" associated with material traceability concerns will be included in the evaluations performed during the implementation of this action plan. Input from ISAP VII.b.1, "Onsite Fabrication" will also be included. Additional background information.has been. included in the Safety Evaluation Report Supplement on QA/QC issues (SSER fil, May 1985). l 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 This Issue-Specific Action Plan assesses the adequacy of the material traceability and control systems j implemented during construction at CPSES. l l d

    - p                -                                        _-       w  =           w

Rsvision: 1 Pago 3 of 6 g-w ISAP VII.a.1 (,,j (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd). The following tasks will be implemented to-achieve this obj ective: Assure that the reinspection ISAP VII.c provides requirements for verification of material traceability. Evaluate the 1981 ASME B- & PV Code Survey results and Brown & Root corrective action. Review Brown & Root and TUCCO procedures for establishment of material control measures. Review results of'ISAPs VII.b.1, VII.b.3, and

                                 .VII.c for-adverse trends related to material' control.

Review' external source findings, such as  ; SSERs, NRC RIV Inspection Reports, and other l management evaluations, related.to material control to assure resolution of findings and. for adversa trend or programmatic deviations. l 4.1.2 The specific methodology is as follows: 'r 4.1.2.1- Interface with the Issue Coordinator of Action Plan VII.c. to' ensure the Construction Reinspection / Documentation Review Plan includes verification of material

                                 ' traceability requirements during.the course of the reinspection process in order that a final determination of the overall adequacy of the control can be reached.

4.1.2.2 The procedural controls that are in effect' for material control will be evaluated against requirements.of 10CFR50 Appendix B, Criterion VIII and the FSAR. Material control procedures will be reviewed to determine if these requirements are included. 4.1.2.3 Evaluate the TRT finding regarding failure to maintain material traceability as identified in the October, 1981, ASME Code survey. This f-s evaluation shall be conducted.in sufficient (J depth to determine the root'cause and generic implications of the original ASME Code finding and whether TUGCO's corrective actions in response to-the ASME Code Survey. were appropriate. i l

l Rsvision: 1 l Page 4 of 6 (~' ISAP VII.a.1 (Cont'd) 4.0 CPRT' ACTION PLAN (Cont'd) 4.1.2.4 Review and identify all SSER findings relating to material traceability and verify action is being taken to resolve the findings. If areas are identified which are not being adequately addressed, notify applicable Review Team Leaders and/or develop action plans to address the areas of concern. 4.1.2.5 Review the results of Action' Plan VII.b 3 and verify that the concerns regarding mate ial traceability on pipe supports have beer adequately addressed. Also review the results of ISAP VII.b.1 and verify that the-concerns regarding material traceability involving onsite fabrication shop activities have been resolved. Review root cause and generic implication evaluations to identify items which might impact this material traceability evaluation.

 /n k )'                  4.1.2.6    Review the results of Action Plan VII.c-for deficiencies related to material traceability. Perform an evaluation of deviations identified for ISAP VII.c populations to determine if there are any adverse trends or any impact on the overall adequacy of material traceability. Also review the results of other action plans for         ,

similar. occurrences. If safety-significant  ! deficiencies or adverse trend programmatic deviations are identified, perform a root cause and generic implication analysis in accordance with the CPRT Program Plan. 4.1.2.7 A detailed analysis will be conducted on the data from the reviews in paragraphs 4.1.2.2 through 4.1.2.6. Data will be analyzed to determine if the material control systems have met the requirements of 10CFR50 Appendix B, Criterion VII and the FSAR. 4.2 Participants Roles and Responsibilities I

              '4.2.1 CPRT QA/QC Review Team

(_) This action plan will be developed and implemented by i the QA/QC Review Team. .l i

i R: vision: 1 Pag 2- 5 of 6 l ISAP VII.a.1 i () 7- s . (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.1 Scope The scope 'fo this evaluation is to assess the adequacy of material traceability and control to assure that.only correct and accepted' material, parts, and components are installed and used at CPSES. 4.2.1.2 Personnel Mr. S. L. Crawford - Issue Coordinator Mr. J. L. Hansel - QA/QC Review Team Leader 4.3 Qualifications of Personnel All personnel associated with analysis and evaluation'of-findings wi.ll be qualified in accordance with the requirements of the CPRT Program Plan. () Where inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. 4.4 Procedures Checklists, guidelines,-data sheets, and flowcharts will be developed as an integral part of the evaluation. These will be retained to support justification of the conclusions. 4.5 Standards / Acceptance Criteria Material traceability activities shall be in compliance with 10CFR50, Appendix B, Criterion VIII " Identification and Control of Materials, Parts and Components" and the associated commitments of CPSES/FSAR paragraph 17.1.8. Specifically, such activities are acceptable if: 4.5,1 Measures _have been established to identify.and control materials, parts and components through receipt, storage, fabrication, erection and installation. 4.5.2 Identification of such items is maintained by unique

                                                                              ~

identifier either on the item or on records traceable to the item. Nm-4.5.3 Where identification marking ~is employed, the marking is clear, unambiguous and indelible.-

                                                          - - , - - -+ ,                 ,

Ravision: 1 Pags. 6 of 6 ISAP VII.a.1 O (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5.4 k'here required, items can be traced to drawings, specifications, inspection, test or other records. 4.5.5 Such control measures are documented in procedures and are properly implemented. l 4.6 Decision Criteria If the compilation of information resulting from the-implementation of paragraphs 4.1.2.1 through 4.1.2.7 contains any. safety-significant deficiencies or adverse trends whose root causes are attributable to material control inadequacies, corrective action required for the remaining construction activities will be included in the ISAP Results Report and the ISAP closed. Otherwise, document the results of the evaluation in the ISAP Results Report and close the ISAP. l O l O

Rsvision: 1 Page 6 of 6

  /~                                        ISAP VII.a.1 (Cont'd) 4.0 CPRT ACTION PLAN.(Cont'd) 4.5.4  Where required, items can be traced to' drawings, specifications, inspection,. test or other records.

4.5.5 Such control measures are documented in procedures and are properly implemented. l 4.6 Decision Criteria If the compilation of information resulting from the implementation of paragraphs 4.1.2.1 through 4.1.2.7 contains any safety-significant deficiencies or adverse trends whose l root causes are attributable to material control inadequacies, i 4 corrective action required for the remaining construction phesG activities btpJ4fith will be included in the ISAP Results Report and the ISAP closed. Otherwise, document the results of the evaluation in the ISAP Results Report and close the ISAP. I, O l l l A( ,)~ I

COMANCHE PEAK RESPONSE TEAM ACTION PLAN' l ISAP VII.a.2 \

Title:

Non-conformance and Corrective Action Systems Revision No. 0 } Description Original Issue lan Prepared and (

                                                     "O Recommended by:

Review Team Leader Date 2( ff. llj sjlsff Approved by: Senior Review Team IM y, g{ oate 6/w / rr f/2,/,c - O

Rsvision 1 Page 1 of 18 { ("'} ISAP VII.a.2 V Non-conformance and Corrective Action Systems

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC 1.1 Non-conformance Issues Identified by the NRC (USNRC Letter January 8, 1985, Pg. 25) l "There were several weaknesses in the NCR and deficiency identification reporting systems. The TRT found that: The TUEC procedure for preparation and processing of NCRs did not contain explicit-instructions for handling voided NCRs. NCRs'were used as a tracking document to record removal of a part from equipment on a permanent equipment transfer rather than for reporting a non-conforming condition; such usage of the NCR was not defined in procedures. There was an inconsistency between paragraphs 2.1 and 3.2.1 in procedure CP-QP-16.0. Paragraph 2.1 required

     }                  all site employees to report non-conformances to their supervisor or to the site QA supervisor, while paragraph 3.2.1 required persons other than QA or QC personnel to submit a. draft NCR to the Paper Flow Group.

The NCR form had no form number or revision date to indicate that the form was being adequately controlled. There were two versions of the TUEC NCR form, one with and one without a space for the Authorized Nuclear Inspection (ANI)' review. The NCR form had no space to identify the cause of the non-conformance and the steps taken to prevent its recurrence. The NCR form had no provision for quality assurance review. 1 The TRT found approximately 40 different forms (other than NCRs) for recording deficiencies. Many of these forms and reports were not considered in trending non-conforming conditions. The TRT notes that TUEC did not initiate an-NCR q j identifying the widespread problem of missing locknuts; only a Request for Field Information was genere*e -

R2 vision: 1 Page 2 of 18

  /)                                                   ISAP VII.a.2

(_,/ (Cont'd)

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (Cont'd) Deficiency reporting procedure CP-EP-16.3 appeared to relate only to Craft and Engineering personnel and was not directed to noncraft and nonengineering personnel who may have had knowledge of reportable items. Procedure CP-EP-16.3 indicated that the applicable manager was responsible for documenting and reporting Deficiency and Disposition Reports (DDRs); but there were no checks or' balances to ensure that a manager or a designated substitute would process a DDR." Safety Evaluation Report Supplements (SSERs) elaborate on the weaknesses in the NCR and deficiency identification reporting systems as reported'by the NRC Technical Review Team in the NRC January 8, 1985 letter. Allegation numbers pertaining to weaknesses in the NCR and deficiency identification reporting systems are listed in paragraph 3.1. 1.2 Corrective Action Issues Identified by the NRC (Enclosure to USNRC Letter dated January 8, 1985) }

                                " Repetitive'NCRs were issued that identified the need to retrain construction personnel in the requirements and contents of QA procedures ~. One corrective action request (CAR) dealing with inadequate construction training and records remained open for one year. The identical problem was identified in a subsequent CAR, which still had not been closed at the time of the TRTs onsite review. (The subject of craft training is addressed in' Action Plan I.d.3.]

The Brown & Root corrective action system was generally ineffective and was bypassed by the Brown & Root QA Manager, as exemplified in the following instances: There were no definitive instructions to describe the types of problems that required corrective action. Minimal procedural instructions resulted in corrective action decisions frequently being left to the-judgment of the QA Manager. I Since June 1983, Brown & Root had issued no Corrective l Action Requests (CARS), and was. substituting memos and ' letters of concern for this function. This shortcut

                                                                  ~

had.become a regular method of operation and appeared to bypass the CAR system. p (,) The TUEC corrective action system was poorly. structured and i ineffective in that: I Controlling procedures were brief and general. l 1

l l Rsvision: 1 Pags 3 of 18 (" ' ISAP VII.a.2 ( (Cont'd) l r

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (Cont'd) There was no~ translation of FSAR requirements on trending and no details on how trend analyses were to be accomplished. Quarterly reports were not issued in a timely manner. The method of categorizing problems by building did not assure meaningful trend analysis. A 1984 CAR report identified three items requiring action; however, none had been taken. CAR 029 was used as a vehicle for a specific disposition rather than for generic action, as intended by the: CAR system." Safety Evaluation Report Supplements (SSERs) elaborate on the weaknesses in the 10CFR50.55(e) Reportability system as reported by the NRC Technical Review Team in the NRC January 8, 1985 letter. Allegation numbers pertaining to the 10CFR50.55(e) Reportability system are listed in paragraph 3.1. 1.3 10CFR50.55(e) Reportability Issues Identified by the NRC (Enclosure to USNRC Letter dated January 8, 1985) l "There were potential weaknesses in th'e TUEC 10CFR50.55(e) deficiency reporting system. Applicable procedures did not identify what types of deficiencies constituted significant breakdowns in the QA program, nor how they should be evaluated for reportability to the NRC. Evaluation guidelines for reporting hardware deficiencies lacked clarity and definitive instructions and the threshold for reporting deficiencies was too high. Specific past and present construction deficiencies that were not reported by TUEC are listed in Sections 4, 5 and 11 [NRC January 8 letter]. l The TRT found examples in Unit I where deficiencies existed so that TUEC was in potential violation ~of the codes, procedures, guidelines, and commitments concerning locking devices for threaded fasteners. In spite of the requirements pursuant to 10CFR50.55(e)(1), TUEC did not report to .the NRC the omission of thread-locking devices in the Unit I nuclear safety systems and did not attempt corrective action until May 1984, when l TUEC tested previously applied paint for thread-lock O s capability. That test was inconclusive, since it did not establish that the paint, an epoxy process, would reliably perform as an effective locking device under all service l

                                                                                                               \

Rsvision: 1 Page 4 of'18

    ~'
 '[                                       ISAP VII.a.2 (Cont'd)

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (Cont'd) conditions and throughout the expected lifetime of the plant. Further, TUEC could not identify.to the TRT which paint was the subject of testing. TUEC did not consider the.Cygna audit findings regarding the DCC as appropriate for formal reporting to the NRC-pursuant to 10CFR50.55(e), as required by procedure CP-EP-16.3, " Control - of Reportable Deficiencies." TUEC failed to maintain material traceability for safety-related material and numerous hardware components. This QA breakdown was identified in an ASME Code survey in October, 1981 yet was not reported to the NRC in accordance with the requirements of 10CFR50.55(e)." 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. ". . . examination of the potential (

  \

safety implications should include, but not be limited to the areas or activities selected by the TRT."

             " Address the root cause of each finding and its generic imp lica tions . . . "                                                     ,

t

             " Address the collective significance of these deficiencies..."
             " Propose an action plan...that will ensure that such problems do not occur in the future."
                      ~

Safety Evaluation Report Supplements (SSERs) elaborate on the weaknesses in the 10CFR50.55(e) Reportability system as reported by the NRC Technical Review Team in the NRC January 8, 1985 letter. Allegation numbers pertaining to the 10CFR50.55(e) Reportability system and listed in paragraph 3.1.

3.0 BACKGROUND

Because of the close interrelationship of TRT concerns involving the non-conformance systems, the corrective action systems, and the 10CFR50.55(e) reportability system, all TRT issues will be addressed under.this one Issue-Specific Action Plan. The TRT l concerns which must be addressed by this action plan are as follows: Did the large number of methods utilized to document and report non-conformances ensure appropriate processing and dispositioning of all non-conformances? i l

R3 vision: 1 Page 5 of 18 r l [- s ISAP VII.a.2 i

   ' \ -)%                                     (Cont'd)                                                l l

3.0 BACKGROUND

(Cont'd) Is there an adequate trending program in place as committed to in the FSAR? Are the TUEC and Brown & Root corrective action systems being properly implemented? Are the procedures and practices being utilized for the evaluation of the 10CFR50.55(e) reportable items adequate to ensure all conditions required to be reported are being. reported? This action plan is written to answer these questions. The evaluations conducted under this action plan using the methodology described herein, will also answer each of the TRT issues listed under 1.1, 1.2, and 1.3 above, as identified in the January 8, 1985 NRC-TRT letter and the additional issues listed in SSERs 7,~ 8, 9, 10 and 11. The following twenty six (26) items from the SSERs have been identified. SSER PAGE NO. ALLEGATION NUMBER NCR 50.55(e) CA 8 K-100 AM-3,AM-23b X 8 K-115 AM-12 X 10 N-37 AW-38,AQW-24 X 10 N-89 AP-10 X 10 N-113 AP-11 X 10 N-119 AP-15,16,17 X 10 N-183 AQW-3&4 X 10 N-217 AH-3 X 10 N-299 AQW-74 X. 11 0-65 AQ-102 X 11 0-65 AQ-102 X 11 0-161 AQ-34 X 11 0-161 AQ-36 X 11 0-161 AQ-124 X 11 0-161 AQ-97 X 11 0-161 AQ-114 X 11 0-175,176 AQ-5 X 11 0-195,197 AQ-38 X 11 0-223 AQ-113 X 11 0-248,256,260 AQ-50 X 11 0-254 AQ-50 X 11 0-250,251 AQ-50 X 11 0-264 AQ-50 X ! 11 0-258,259 AQ-50 X . 11 0-267 - 275 AQ-135 X l 11 0-268 AQ-135 I

~ Rsvision: 1 Pags 6 of 18 ISAP VII.a.2 ( (Cont'd)

3.0 BACKGROUND

, (Cont'd) The results of the evaluation responding to the questions above and each of the TRT SSER questions will be reported in the ISAP Results Report. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan are to assess the adequacy of the CPSES Non-conformance/ Corrective Action /Reportability systems and evaluate the effectiveness of implementation. The ' Trend Analysis Program will be evaluated for adequacy against FSAR commitments. This action plan will, evaluate individual NRC TRT and SSER t findings and provide a comprehensive evaluation of the CPSES construction site non-conformance, corrective action, and 10CFR50.55(e) reporting systems. The evaluation will provide I reasonable assurance that previous programmatic problems have been identified, t, hat potential hardware ~ problems have been identified and evaluated, that the current. Unit 2 7 10CFR50.55(e) system is satisfactory and that the Unit 2 and i Operations non-conformance and corrective action systems are satisfactory. Because of the differing complexity of the three systems being evaluated, the methodology for the evaluation of each will vary somewhat. For the non-conformance system, all the 1 various methods (populations) of documenting non-conformances will be identified. . Populations will be reviewed to determine l if non-conformances were properly processed and resolved. In addition, the procedures applicable to the selected non-conformance will be reviewed for compliance with 10CFR50 Appendix B and PSAR/FSAR requirements. 4 For corrective action systems, applicable site precedures will be reviewed for adequacy. This procedural review will be i followed by a review of the implementation of the site i corrective action systems. Also, a detailed review of the trending system, both procedures and implementation, will be conducted as part of this evaluation. The approach for evaluating the 10CFR50.55(e) reporting system is similar to that for. corrective action. Applicable procedures will be reviewed for adequacy _followed by a review of the implementation of the 10CFR50.55(e) reportability system. i

                                                                                     . _ , -l

Rsvision: 1 Pags' 7 of 18 ISAP VII.a.2 [l N/ (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) This ISAP will be conducted in three phases. The phases are:

                           -       Non-conformance System (Phase I)
                           -       Corrective Action System (Phase II) 1                           -       10CFR50.55(e) Reportability (Phase III)

The'results of Phase I will be considered in Phase II and-Phase III. The results of Phase II will be considered in Phase III. Later phases may be started prior to completion of earlier phases providing the information from the earlier phase is not required for the work that-is being done in the later phase. Specific tasks are listed under 4.1.1 (Non-conformance), 4.1.2 (Corrective Action), and 4.1.3.(10CFR50.55(e) Reportability) below. 4.1.1 Non-conformance System ( The following tasks will be implemented in the Non-conformance system evaluation to achieve the objectives- , listed in the first paragraph of 4.1 above: Identify methods for' processing non-conformances. Review processing of non-conformances.

                                       -      Evaluate TRT and SSER findings.

Notify RTLs of hardware concerns.

                                                                                                                    \

4.1.1.1 Methods of Processing Non-conformances l The NRC will be contacted to obtain the list

                                               ,f.the "approximately 40 different forms (other than NCRs) for recording deficiencies." In addition, an investigation                        -l l

including a procedural search, will be conducted to identify all methods for identifying and documenting non-conformances on site.

Ravision: 1 Page 8 of 18 p ISAP VII a.2

  \ /

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l 4.1.1.2 Review of Processing of Non-conformances l Non-conformance system populations will be sampled to determine that: 4.1.1.2.1 Proper dispositioning of non-conformances occurred. 4.1.1.2.2 Reporting systems in use conformed to FSAR and QA Program requirements. Non-conformances will first be grouped into appropriate populations. A list of non-conformances in each population will be generated and a Sampling Plan developed to i randomly select samples of non-conformances from each population. Sample sizes will be selected in accordance with Appendix D of the Comanche Peak Response Team (CPRT) Program Plan. Each randomly selected non-conformance will be reviewed utilizing a prepared checklist which includes as a minimum, the following attributes: The non-conforming item is properly-identified. The non-conforming condition is properly described. The disposition is identified as , use-as-is, rework, repair, or scrap. The Non-conformance Report contains. signature approval by appropriate level of personnel. Reworked, repaired, and replacement items are inspected and tested in

                                         -accordance with original requirements or acceptable alternates.

O

Rsvision: 1 Pags 9 of 18 jT ISAP VII.a.2 3s_,) (Cont'd) l 4.0 .CPRT ACTION PLAN (Cont'd)

                                        -    An independent review is conducted of the non-conformance, including disposition and closeout by appropriately qualified personnel..

The non-conformance is included in the trerd analysis process and reviewed for corrective action. The non-conformance is reviewed to determine necessity for conducting further evaluation for 10CFR50.55(e) reportability. In addition, the procedures specifically related'to the non-conformances and which specify the processing and dispositioning-of each non-conformance selected for evaluation will be reviewed'for adequacy using O essentially the same review criteria specified above. 4.1.1.3 Evaluate TRT and SSER Findings l Evaluate each of the TRT and SSER findings specifically related to non-conformance systems versus the results of paragraph 4.1.1.2 above to determine: l 1 Is the finding valid? Is the finding an isolated occurrence? Is the finding a result of an identified system deficiency? 4.1.1.4 Hardware Concerns l Applicable Review Team Leaders will be notified of .any potential hardware concerns which require further evaluation. The results will also be utilized in the evaluation of the corrective action and 10CFR50.55(e) reporting systems described.

    ,j                           below.
                                                                                 ,w

R2 vision: 1 Page 10 of 18 (} (m e ISAP VII.a.2 (Cont'd) l 1 4.0 CPRT ACTION PLAN (Cont'd) , 4.1.2 Corrective Action System The following tasks will be implemented in the Corrective Action system evaluation to achieve the

objectives listed in the first paragraph of paragraph

4.1 above

1 Identify discrepancies in procedures. Review implementation of the site Corrective Action system. Review Trend ~ Analysis system for programmatic

,                                   weakneises.

Evaluate TRT and SSER findings. 1 Notify Review Team Leaders of hardware concerns.

   \                    4.1.2.1    ' Identify Procedure Discrepancies Identify and review TUEC and Brown & Root site corrective action procedures. A detailed checklist will be developed and will address the following:

Conditions adverse to quality including non-conformances, failures, malfunctions, deficiencies, deviations, end defective material and equipment are evaluated by qualified personnel to prevent. recurrence. Follow-up action to verify proper implementation of corrective action occurs in a timely fashion. Significant conditions adverse to quality, including the cause and action to prevent recurrence, are documented and reported to appropriate levels of management for review and assessment. I l

I I Rsvisiont 1 ) Pags 11 of 18 l l (

  \

ISAP VII.a.2 (Cont'd) l 4 4.0 CPRT ACTION PLAN (Cont'd). If procedural discrepancies are identified action will be taken to correct the current systems in effect for Unit 2 and the Operations QA Program. 4.1.'2.2 Implementation of Site Corrective Action l System Review the site corrective action systems for implementation. The Corrective Action Requert (CAR) population will be identified (approximately 47 closed TUGC0 CARS and 57 closed Brown & Root CARS exist as of January 15, 1986). Each of the closed CAR's will be reviewed using information developed during the evaluation of the non-conformance system described in Section 4.1.1. Other criteria from 4.1.2.1- will be used during the review. This review will determine: Procedural changes required to l correct programmatic deficiencies relating to Unit 2 and the Operations QA Program. Potential specific or generic concerns relating to hardware. 4.1.2.3 Trend Analysis System Programmatic Weaknesses l Review the trend analysis program implemented on site versus~FSAR requirements. Identify any programmatic weaknesses which require correction on the work remaining on Unit 2 and the Operations QA Program. Information developed during the evaluation of the non-conformance system described in Section 4.1.1 above will'be utilized in this evaluation.- 4.1.2.4 Evaluate TRT and SSER Findings l Evaluate each'of the TRT and SSER findings specifically relating to the corrective p() action and trending systems versus the results of paragraphs 4.1.2.1, 4.1.2.2, and i 4.1.2.3 above to determine: l l

R2 vision: 1 Pags 12 of 18 [} y ISAP VII.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Is-the finding valid? Is the finding an isolated occurrence?

                                      -     Is the finding a result of an identified system deficiency?                    ;

4.1.2.5 Kardware Concerns l , Applicable Review Team Leaders will be notified of any potential hardware concerns which require further evaluation. The results will also be considered in the evaluation of the 10CFR50.55(e) reporting system' described below.

4.1.3 10CFR50.55(e) Reporting System The following tasks will be implemented in the O. 10CFR50.55(e) Reportability system evaluation to achieve the objectives listed in the first paragraph of I

paragraph 4.1. above: Evaluate Reportability procedures for compliance with requirements. Review implementation'of the Reportability system for compliance with requirements. Expand review as needed to identify extent of programmatic deficiencies. 4.1.3.1 Evaluate Reportability Procedure l , Identify and review the site procedures which specify the method of evaluating deficiencies for reportability per 10CFR50.55(e) requirements. Each procedure that forms a part of the reporting system will be reviewed to determine whether the threshold.of reportability is properly specified in the procedure. A prepared checklist which addresses, as a minimum, the following will be utilized during the procedure reviews. O , l

i R;vicion: 1 f Pcgo 13 of 18- i ( ISAP VII.a.2-O' (Cont'd)  ; 4 4.0 CPRT ACTION PLAN (Cont'd)

                                      -     Provision for evaluating each non-conforming condition for i                                            reportability.-
                                      -     Checklist used for determining reportability.-
                                     -      Reportability checklist addresses, as a minimum:
                                            --        Significant breakdown in the f                                                      QA Program.
                                            --        _Significant deficiency in design documents as released for construction.
                                            --        Design documents released for.

construction do not meet the requirements of the FSAR-or i

. ()                                        -

construction permit, Non-conformance is a ! deficiency in construction. t Non-conformance is a deviation from performance specifications. Provision for documenting the J evaluations. 4

                                      -     Provision for reporting each significant deficiency to the Nuclear Regulatory Commission (NRC)

Inspection and Enforcement Regional Office within 24 hours after determination of the significant l deficiency.

                                           . Provision for submitting a written report on the reportable deficiency within 30 days to the NRC Regional Office with copies sent to the

Director of Inspection and Enforcement, U.S. NRC. The report l

4 l 1 l i

Ravicion: 1 Paga 14 of.18 ISAP VII.a.2 (* 1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                                                        ~

shall include a description of the deficiency, an analysis of the safety implications and the corrective action taken, and sufficient information.to permit analysis and evaluation of the deficiency and of the corrective action. If sufficient information is not available for a definitive report to be submitted within 30 days, an interim report containing all available information shall be filed, together with a statement as to when a complete report will be filed. Provision for remedial action of the significant deficiency. 4.1.3.2 Review Implementation Review the 10CFR50.55(e) reporting system for implementation utilizing the review criteria developed in paragraph 4.1.3.1 above. Each formal reportability evaluation (Design - Construction, Significant Deficiency Analysis Report (SDAR)) will be reviewed. These formal reportability evaluations are the

                                                              ~

highest level evaluations for reportability and not to be confused with the initial' screening of non-conformances for potential

!                                reportability. Information developed during the evaluation of the non-conformance system l

described in Section 4.1.1 and the procedural

reviews described in paragraph 4.1.3.1 will be utilized in this evaluation.

r l In conjunction with the implementation review, the specific TRT findings along with any additional SSER findings which involve 50.55(e) reporting will also be evaluated. Verify that deficiencies which had undergone the TUGC0 evaluation process but which had not been reported were appropriately corrected and action had been taken to l prevent recurrence. i 1

R vision: L Paga 15 of 18 (

 \

ISAP VII.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3.3 Expand Review if Necessary l i If no procedural or implementation deviations are identified during the reviews and evaluations specified in paragraphs 4.1.3.1 and 4.1.3.2 above, the system will be deemed acceptable. If deviations are identified, additional reviews will be conducted as r'equired to identify the full extent of the programmatic deficiencies. In addition, areas or groups of deficiencies which require evaluation or reevaluation for 10CFR50.55(e) reportability shall be. identified and referred to TUGC0 for appropriate processing. Procedural changes required for Unit 2 to correct programmatic deficiencies will be identified and reported to TUGC0 for action. l l 4.2 Participants Roles and Responsibilities l s s 4.2.1 Evaluation Research Corporation (ERC) 4.2.1.1 Scope ERC is charged with the overall responsibility for'the conduct of the evaluation and preparation of the report. T 4.2.1.2 Personnel Mr. J. L. Hansel, Review Team Leader Mr. D. L. Boydston, ERC, Issue Coordinator 4.2.2 TUGC0 4.2.2.1 TUCCO will assist in identifying and locating applicable information and documentation to , support the Review Team Activities. 4.2.2.2 Personnel i As required. 4.2.3 TERA (DAP) O

                       --             - . _ - =                                           .      .-

u Ravision: 1 Pagi 16 of 18 i ISAP VII.a.2.

  /)

(,_, ~ (Cont'd) , 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.1 DAP is responsible for evaluating the . ! technical adequacy of the disposition of the NCRs contained in the ERC samples for the populations of NCRs. DAP is also responsible for transmitting the results of the evaluation to ERC for summarizing and inclusion in the VII.a.2 Results Reports. 4.2.3.2 Personnel . As required. 4.3 Qualifications of Personnel l All personnel associated with analysis and evaluation of the 4 systems and findings covered by this action plan shall be l qualified in accordance with the requirements of the CPRT Program Plan. 4.4 Procedures O ] k-- 4.4.1 CPRT Program Plan 4.4.2 Checklists, which address as a minimum, the items in i paragraphs 4.1.1.2, 4.1.2.1, and 4.1.3.1 will be developed as an integral part of this evaluation. These checklists will be retained to support the justification of conclusions. 4.5 Standards / Acceptance Criteria Applicable standards and acceptance criteria for this evaluation are contained in 10CFR50,' Appendix B, Criteria XV, IVI, 10CFR50.55(e), and the FSAR and paragraphs 4.1.1.2, 4.1.2.I. and 4.1.3.1. 4.6 Decision Criteria 4.6.1 Non-conformance System (Phase I) i If no-QA/QC Program deficiencies (departures from

,                                   10CFR50 Appendix B criteria XV, XVI,.or the CPSES FSAR)~

i are noted in the non-conformances or their associated procedures for the samples selected, the non-conformance system will be deemed acceptable. O 1 M.. _. . . . . . . - , .._ ._ . -. - .-, - _ _ _ _ c__,-- , - -

Rsvicion: 1 Pags 17 of 18 [}

 \s /

ISAP VII.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) If QA/QC Program deficiencies are noteduin the non-confornance system, root cause and generic implication analyses will be conducted of each deficiency. In  ; addition, the-sample-will be expanded to the extent i necessary so that the-results of the sample expansion coupled with the root cause and generic implication analyses will. provide reasonable assurance that no further unidentified programmatic deficiencies associated with the population of non-conformances remain. If negative hardware implications exist. TUGCO will be notified. 4.6.1.1 If a QA/QC Program deficiency is detected in one or more items in the. sample population, the sample will be expanded in accordance with Appendix D of the CPRT Program Plan. 4.6.1.2 If QA/QC Program deficiencies or adverse trends are detected in the original sample or the expanded sample the deficiencies will be subjected to root cause and generic O implication analysis, and corrective action will be recommended. 4.6.2 Corrective Action System (Phase II) If no QA/QC Program deficiencies (departures from 10CFR50 Appendix B or the CPSES FSAR) are found as a result of reviewing the Corrective Action Requests, the trending system, the corrective action procedures, and the data resulting from the non-conformance system review, the corrective action system will be deemed acceptable. If QA/QC Program deficiencies are identified in the corrective action system TUGC0 will be notified of the nature and extent of each of the QA/QC Program deficiencies. 4.6.3 10CFR10.55(e) Reportability (Phase III) l If ru) QA/QC Program deficiencies (departures from 10CFR50.55(e) or the CPSES FSAR) are found as a result of reviewing the reportability procedures, SDAR's, and the data resulting from the non-conformance and corrective action systems review, the reportability

 /~'N                  system will be deemed acceptable.

U

I Revision: 1

            -                                                              Paga 18 of 18 ISAP VII.a.2 C,_,'\
       /                                       (Cont'd) 4.0 CPRT ACTION PLAN-(Cont'd)-

l If QA/QC Program deficiencies are identified in the j reportability system the associated procedural changes required to correct the QA/QC Program deficiencies will l be reported to TUGC0 for corrective. action. l l 4.6.4 The action plan will be closed when it has been determined that: 4.6.4.1 No QA/QC Program deficiencies exist or, 4.6.4.2 When each of the QA/QC Program deficiencies that does exist and the recommended a corrective action has been reported to TUGCO. O h 1 ,I . > l 1 1 i

                                                                           , ,       . . _ _ . ~ . _ , , , , ,

, ,Q COMANCHE PEAK RESPONSE TEAM V ACTION PLAN ISAP VII.a.3

Title:

Document Cont'rol 1 i i b i Revision No. 0 1 Reflects Comentu

;      Description         Original Issue        On Plan Prepared and g

. Recommended by: h Review Team Leader V Date Lif!W / gyfff '

d I n e i w Team O. kg Date &f1 l {f f /fg.q ffg

O

Rivision: 1 Pcg2 1 of 7 (g ISAP VII.a.3 d Document Control

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The Comancha Peak SSER 11, Appendix P, Section 4.7. pages P-27 and P-28, describes the NRC concerns in the area of document. and record control. The concerns pertaining to document control have been extracted and are presented here: f "The TRT assessment of the document control function'for the period following July 1984 indicates that the preparation, issuance and changes to documents that specify quality requirements or prescribe activities affecting quality are adequately controlled. Documentation packages reviewed at the point of issue, and in the field where prescribed activities were being performed, were found to be complete and current. Further, a sample of safety-related quality records stored in the permanent plant records vault (PPRV) was reviewed and found to be acceptable. Included in the documentation packages were completed records for piping, piping supports (hangers), assembled and/or installed components, fabrication and inspection / testing data, including walkdown inspection l check lists and the applicable N-5 data reports. In-process and final inspection and acceptances for completed record , O packages appeared to have been performed to the latest revision of drawings and specifications. However, the history of recurring document control deficiencies prior to July 1984 raises concerns about certain aspects of the quality of construction....In procedural control, the TRT mechanical and piping group observed that uncontrolled and unauthorized procedures were used to perform cold-springing (realign piping) during its installation. With respect to drawing control prior _ to 1984, the TRT found deficiencies that included: distribution of incomplete or obsolete drawing packages to the _ craf t and QC personnel; inadequate drawing control; high DCC satellite error rates; and procedural non-compliance. The~TRT QA/QC Group concludes that although many of the document control inadequacies have been corrected, the implications of past inadequacieu on construction and inspection have potential generic i significance which has not yet been fully analyzed by TUEC. The TRT found~that the DCC issued'a controlled copy stamp to the QC department to expedite the flow of hanger packages to the' Authorized Nuclear Inspector. Methods for this kind of issuance and control of such stamps were not described in TUECs procedures." ("')N

 \~.

J f

Rsvision: 1 Page 2 of 7 ISAP VII.a.3 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC

             -    Evaluate the TRT findings and consider the. implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."
             -    " Address the root cause of each finding and its generic implications..."
             -    " Address the collective significance of these deficiencies..."
                  " Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

I Deficiencies in the Document Control Program may result in an incorrect revision being utilized for fabrication, erection, installation, inspection, or testing. Basic problems in the Document Control Program were identified and documented by TUCCO. As a result, appropriate changes were  ;. introduced into the program, and an acceptable level of I implementation was achieved by July 1984. f i TUGC0 has performed activities to ensure that the features of the l physical plant affected by the CPSES QA/QC program conform to.the I latest design information. These activities include the following: { Design change verification program. (Begun Summer 1984 and f i ongoing) Preparation of ASME Code Data Sheets (N5) (Unit 1, 1983 to 1984; Unit 2,.in process) Class V hanger / support as-built program. (Included in 79-14 , program Summer 1981 to Winter 1983)

                                                                        ~

The CPRT is performing activities that will verify that the latest design information has been incorporated into the plant features that are of interest. These activities include the following:

Rsvisien: 1 Page 3 of 7 ISAP VII.a.3

 \                                       (Cont'd)

3.0 BACKGROUND

(Cont'd)

          -~    ISAP III.d, "Preoperational Testing"
          -     ISAP VII.c, " Construction Reinspection / Documentation Review Plan" This action plan, is designed to provide reasonable assurance that the physical plant conforms to the design requirements and that the specific TRT and SSER items pertaining to document control have-been addressed.

TUGC0 has previously responded to the NRC concerning the issue of the " Controlled Copy" Stamp to the QC Department. The response and subsequent correspondence with the NRC will be reviewed to determine the status and possible additional actions. l 4.0 CPRT ACTION PLAN

   )      4.1   Scope and Methodology 4.1.1  The scope of this action plan is to provide confidence lthat, although problems were identified over a period of time in the implementation of the Document Control program during the construction phase of CPSES, the hardware has been installed and tested in accordance with the current design requirements.

4.1.2 The specific methodology is described below. 4.1.2.1 The Issue Coordinator will review the CPRT. Issue-Specific Action Plans (ISAP) and associated instructions to determine the populations for which verification of l incorporation of the latest design information (e.g. , drawings, Design Change Authorizations, Component Modification Cards) l l l l l l l i

R: vision: 1

                                                                         'Page    4 of 7-ISAP VII.a.3
     ' ')                                    (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) will be performed during the implementation of the action plan. The Issue Coordinator
                                                                     ~

will assure-that the action plans and instructions provide confidence'that applicable design changes have been incorporated into the physical plant and/or have been appropriately considered for other applicable activities, e.g.. Prerequisite and Preoperational Testing. Review of the current revisions of Issue-Specific Action Plans III.d " Pre-operational Testing", and VII.c, " Construction Reinspection / Documentation Review Program" indicate that the prescribed actions will provide the necessary verifications. l. 4.1.2.2 ISAPs VII.c and III.d specify actions to be performed as follows: ISAP VII.c. " Construction 1 Reinspection / Documentation Review Plan" includes a Reinspection ~/ Documentation Review of QC ac'cejted safety-related construction wor k activities performed at CPSES. The implementation of this action plan requires that the latest design information be utilized in preparing reinspection / documentation review checklists, and that the latest applicable design information, including design change , authorizations (DCA) and component i modification cards (CMC) are included in-the reinspection / review package. If equipment differs from checklist requirements or if the associated documentation does not j exist or is improperly completed, a deviation report will be initiated. In accordance with the requirements of the ISAP, valid deviations will be evaluated for safety significance, root cause, and generic implications, and l g appropriate corrective action will l C.,/ be taken. All deviations for each l population will also be evaluated for adverse trends.

Rxvision: 1 Page 5 of 7 [\

   \'"!

ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) These root cause and generic implication analyses for safety significant deficiencies and adverse trends will be reviewed to compile information regarding root cause and generic implication analyses which may be relatable to document control concerns. ISAP III.d. "Preoperational Testing" actions include an investigation to determine if the problems associated with document control had an adverse effect on either prerequisite or preoperational' testing. In accordance with the requirements of the ISAP, identified deficiencies will be evaluated for root cause and generic implications, and

  -O                                                appropriate corrective action will be taken. These root cause and generic implication analyses will also be reviewed to compile information which may be relatable to document control problems.

4.1.2.3 The Issue Coordinator will compile and review the results of ISAPs VII.c and III.d. From this evaluation, a determination will be made' for any corrective actions and/or program changes required for the remaining construction phase of Unit 2 and the operations phase. 4.2 Participants Roles and Responsibilities 4.2.1 TUGC0 4.2.1.1 Scope TUGC0 will assist in identifying and locating applicable information and documentation to support the Review Team activities. 4.2.1.2 Personnel Mr. D. Snow will be the principal contact between the Issue Coordinator and TUCCO.

R vision: 1 Page 6 of 7 () ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2 Evaluation Research Corporation 4.2.2.1 Scope Provide Issue Coordinator Review ISAPs VII.c and III.d results and compile data related to document control problems.

                                               -      Analyze / evaluate data for generic
                                                      . implications I

Determine corrective actions and recommend program changes 4.2.2.2 Personnel i Mr. J. Hansel QA/QC Review Team Leader i Mr..J. Gelzer Issue Coordinator 4.3 Qualifications of Personnel Participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. 4.4 Procedures Program Plan and Issue-Specific Action Plans. 4.5 Standards / Acceptance Criteria Programs and procedures will be evaluated for adequacy against applicable portions of the CPSES FSAR and 10CFR50, Appendix B. Criterion VI, including the following: 4.5.1 That procedures are established to assure that documents are available at the location where the activity will be performed prior to commencing the work. 4.5.2 That procedures are established to assure that obsolete or superseded documents are removed and replaced by (} V applicable revisions in work areas in a timely manner. 4.5.3 A document control system is established to identify the current revision of controlled documents. i

Rivioion: 1 Page 7 of 7 . [~'T ISAP VII.a.3 l

 \_s/                                             (Cont'd)                                     l l

4.0 CPRT ACTION PLAN (Cont'd) l 4.5.4 That the Results Report of Action Plans III.d -

                               "Preoperational Testing" and VII.c-      " Construction Reinspection / Documentation Review" provide reasonable assurance that items of concerns related to document.

control prior to July 1984 had no adverse impact on either testing conducted or the quality of irstalled hardware or if, in fact, anomalies are identified, appropriate corrective measures are indicated in the report. 4.6 Decision Criteria If the compilation of information resulting from the implementation of paragraphs 4.1.2.1 through 4.1.2.3 does not contain any safety-significant deficiencies or adverse trends-whose root causes are attributable to document control inadequacies, no further actions are required for this ISAP. Should adverse trends or safety-significant deficiencies whose root causes are attributable to document control inadequacies-

 ,-,g                   be identified, the following will be required:

4.6.1 If identified by VII.c implementation, this action plan shall verify that adequate recommendations for remedial actions to effected hardware and/or program elements as applicable to Unit I completed construction, future construction associated with Unit 2 and Operations Phase activities as required have been included in the results report. 4.6.2 If identified by III.d implementation, this action plan shall verify that adequate recommendations for remedial actions to affected hardware, program and/or test elements as applicable to Unit I completed construction, Unit 2 future construction and Operations Phase activities as required have'been included in the results report. 4.6.3 If identified thru implementation of ' paragraph 4.1.2.3 recommendations for remedial actions to affected hardware / program as applicable to Unit 1 completed construction, Unit 2 future construction and Operations Phase activities shall be included in the Results Report. O

l COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.a.4

Title:

Audit Program and Auditor Qualification Revision No. o 1 Description Original Issue 0$ Plak V Reco ended by: Review Team Leader - ) o te

                              %Ar              fy/w, Approved by:

Senior Review Team Q, hj g[

                             ~

Date Qfylgf Q

O

Rsvision: 1 Page 'l of 9 ISAP VII.a.4 Audit Program and Auditor Qualification i

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The Comanche Peak SSER 11, Appendix P, Section 4.7 pages P-31 through P-34, describes the NRC concerns in the areas of audit and reporting. The concerns pertaining to the audit program and audit personnel qualification have been extracted and are presented here:

                 " Region IV found that TUEC's audit procedures did not comply with NRC requirements, and that the program was not implemented in accordance with procedures. The lack of an established audit program was also substantiated by Region IV.

For example, Region IV Report No. 50-445/84-32 cited TUEC for i failure to establish and implement a comprehensive system of planned and periodic audits. Non-compliances identified were: I annual Jits were not adequately addressed by audit implementation procedures; planning and staffing to perform 1983 audits were inadequate; The Westinghouse site organization performing Nuclear Steam Supply System (NSSS) engineering services was not audited by TUEC from 1977 through 1981; and audits of vendors that manufacture or fabricate

                                                                                        },

Q parts, components, and equipment for safety related systems

    )            were not conducted in~ compliance with annual or other applicable requirements dating back to August 1978.

Assessments by the Miscellaneous and Mechanical and Piping j Groups concurred with the QA/QC Group that the audit frequency of vendors did not comply with ANSI N45.2.12 requirements. Review of past administration of the audit program disclosed that during 1981 and 1982, the height of construction, the i audit staff consisted of four auditors. From 1982 to 1984, the audit staff has increased from 4 to 12. Also, on occasions, individuals participating on the audit teams were not QA auditors. As such, a potential existed to compromise [ their independence. The TRT reviewed the technical l background, experience, and training of auditors, as well as [ the quality of audit reports. The TRT determined auditor staffing and qualifications to be questionable, which rendered the audit results for 19,81 through 1983 potentially ineffective. The TRT and Region IV reviewed the scope of the QA Program audited during 1983. Of approximately 650~ safety related procedures, 165 (25% overall) were audited. In looking at quality procedures, TUEC audited 24% of TUCCO's implementing procedures and 39% of Brown & Root procedures for a composite 32% audit rate. Although audits on a' sampling basis are acceptable, there was no evidence that all safety related s ) areas were audited. The audits did not encompass all aspects of the QA Program in order to determine effectiveness.

Rsvisiont . 1' Page 2 of 9 , 1 1 () ISAP VII.a.4 (Cont'd) l ! l

1.0 DESCRIPTION

OF ISSUE (Cont'd)

.With respect to audit corrective action follow up, it was learned that TUEC QA had not been verifying that corrective

'                 action on previous audit findings was accomplished. For example, audit TCP-111, initiated to verify corrective actions on previous audit findings, was started prior to. the furr's

, review. TUEC emphasized that TCP-111 be considered a " Punch List of Completion Tasks" to verify that corrective action had been implemented and not an attempt to rewrite or change

                 . previous audit findings. Another specific example of 4

ineffective follow up action was found that pertained to a deficiency identified in audit TCP-23, performed in September, 1981. Audit TCP-68, conducted in March, 1983, attempted to verify corrective action of TCP-23's audit finding, but logs

;                 that would document the corrective action had been destroyed.

A new deficiency was written at that time and the response was

] accepted, but the corrective action implementation is still unverified. Following the Lobbin Report, the NRC performed a CAT inspection (IR 445/83-18;446/83-12, dated April 11, 1983) - and l included a review of the TUCCO audit program at the corporate , offices. The inspection included a review of 18 audits- 1

(conducted between 1978 and early 1983), auditor i qualifications, audit planning and scheduling, audit reporting

, and follow up, and audit program effectiveness. The report concluded that weaknesses existed in the established QA audit program which included the scheduling and frequency of audits,

the lack of effective monitoring of the construction program, and the lack of effective resolution of certain audit findings. The inspection also indicated that the QA Program should have been more effective.

l During the TRT's evaluation of allegations and concerns,'it was observed that the audit function did not always identify QA Program breakdowns, or if reported, effective corrective

action was not instituted to prevent recurrence . . .

Based on its. findings and observations, the TRT concludes that the QA audit . . . program has had and continues to exhibit i deficiencies. Over a significant period of time, recurring deficiencies include: inadequate staffing during peak periods; ! . . . procedural and implementation inadequacies; questionable. qualifications and capabilities; incomplete assessment of the QA program on an annual basis . . . In summation, the QA/QC Group finds the past audit . . . system less than adequate, and the audit . . . program at the time of'the TRT review was O questionable."

   .n,-       --        -,,w   . . , - -                                         .nn,

R. vision: 1 Page 3 of 9 ( t ISAP VII.a.4 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC l

                       -      Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the
                                                                                                      )

l potential safety implications should include, but not be l limited to the areas or activities selected by the TRT."  ! j - " Address the root cause of each finding and its generic implications..."

                       -      " Address the collective significance of these deficiencies..."
                             '" Propose an action plan... that will ensure that such problems do not occur in the future."

l i i

3.0 BACKGROUND

l l i i In addition to the TRT issue and SSER 11, the NRC issued a notice f of violation (445/8432-03; 446/8411-03): l Contrary to requirements, the following examples were identified which demonstrate the failure to establish and implement a comprehensive system of planned and periodic audits of safety related activities as required, as noted below: Annual audits were not adequately addressed by the audit i implementation procedures. TUGC0 Procedure DQP-CS-4, Revision 0, dated August 9,

                                                   ~

1978, only required two audits of vendors fabricating reactor coolant pressure boundary components, parts, and equipment; one audit of vendors fabricating engineered safeguards components, parts, and equipment; I and audits of balance of plant (safety related) as  ! required by the quality assurance manager.  ;

                                 '                                                                    1 TUGC0 Procedure DQP-CS-4, Revision 2, dated April 16,            l 1981, required only that organizations will be audited on a regularly scheduled basis.

TUCCO Procedure DQP-CS-4, Revisions 2 and 10, did not i specify auditing frequencies for design, procurement, construction, and operations activities. O _ . _ - -. .. - .- -. - 1

Rsvision: 1 Pcgs 4 of 9 Ih ISAP VII.a.4

   \~ I                                      (Cont'd)

3.0 BACKGROUND

(Cont'd)

                       --    TUGC0 Procedure DQP-CS-4, Revision 10, based audit requirements on Regulatory Guide 1.33, Revision 2,

. February, 1978. This commitment did not fully address the requirements of the Construction Quality Assurance l Program.

The above procedure and subsequent revisions failed to describe and require annual audits in accordance with commitments and requirements. Earlier audit procedures were not available to determine if they met requirements. Planning and staffing to perform 1983 audits was inadequate to assure that a comprehensive system of audits was established and implemented to verify compliance with all aspects of the Quality Assurance Program, in that, of 656. safety related procedures (which control safety related activities) the NRC review revealed that the applicant sampled only 165, or 25-percent, during the 1983 audit program. Consequently, significant aspects of'the safety related activities were not adequately audited. The Westinghouse site organization, established in 1977 to perform Nuclear Steam System Supply (NSSS) engineering services, was not audited by TUGC0 during the years of 1977, 1978, 1979, 1980, and 1981. Audits of vendors that manufacture or fabricate parts, components, and equipment for reactor coolant pressure boundary and engineered safeguards systems have not been

!                   conducted annually dating back to August 9,1978.

l l l l v

R& vision: 1 Page 5 of 9 l f l ISAP VII.a.4 (' ' (Cont'd) l 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 The scope of this action plan is to evaluate the adequacy of the TUCCO QA-Audit Program from its inception to the present, determine the effect of any identified inadequacies on the. Quality Assurance Program and/or.the 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, follow up and closeout, and audit personnel qualification. 4.1.2 The specific methodology is described below. 4.1.2.1 All revisions of the program and procedures pertaining to the QA Audit Program that have been in effect at CPSES will be evaluated to identify commitments and the degree to which the written program conformed to these commitments. Included in this evaluation-will be the CPSES PSAR/FSAR (Appendices 1A(N) and 1A(B), Chapter 17.1, and QA branch i questions and answers); TUCCO Corporate Quality Assurance Program; CPSES Project Quality Assurance Plan (Design and Construction); Dallas Quality Procedures / Instructions mannal. 4.1.2.2 Reports, documentation, and data generated l j during the implementation of the program will be reviewed on a selective basis to evaluate l the effectiveness of implementation. The selection of specific items to be reviewed will be based on concerns identified ~by the NRC; significant revisions to commitments,

       ,                              program description, and/or organization; and to pursue questionable areas identified during the review. Specific topics to be addressed include the following:

Audit Planning Criteria Published and As-run Schedules l v I

R; vision: 1 Page 6 of 9 () ISAP VII.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Audit Plans and Checklists Audit Report's Audit Deficiency Follow up t Audit Team Members, Including Qualifications and Staffing Levels Organizations Performing Audit Activities Application of Audit Activities to Hardware vs Program / Procedures The object of this evaluation is to develop a conclusion concerning the adequacy of program assessment prorided by the Audit Program. This information will be used as an input for recommendations for revision of the current program, as appropriate. '! b(-g 4.1.2.3 Should ardit program deficiencies or weaknesses elated to construction activities be identified, they will be evaluated to determine whether action beyond that specified in ISAP VII.c is required to identify potential areas of concern regarding construction quality. Should such actions be required, a detailed plan will be developed and this ISAP revised to describe the methodology. In addition, should any identified audit program deficiencies apply also to off-site TUGC0 suppliers, a program

                                                                         ~

will be developed to determine the acceptability of the suppliers' quality assurance programs for the applicable equipment and services during the period in question. This program, if required, will utilize external sources of information such as other utility or architect-engineer audits, the Coordinated Agency for Supplier Evaluation, and the NRC " White Book". If suppliers are identified for which the O

R:vicicn: 1 Page 7 of 9 -l ISAP VII.a.4 ['d~) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) adequacy of the QA program cannot be determined, a detailed plan will be developed to resolve the concern and this ISAP revised to describe the methodology. 4.1.2.4 The current audit program, including auditor i qualification requirements, will be evaluated against licensing commitments contained in a the FSAR. i A determination will be made concerning the l adequacy of the TUGC0 written program and the qualifications of the audit staff and staffing levels for the remaining construction phase of Unit 2 and for the operations phase. 4.1.2.5 The Results Report will provide recommendations for corrective action and/or program improvements as appropriate. 4.1.2.6 Copies of the Results Report for this ISAP will be provided to TUCCO for their consideration in responding to the NRC Notice of Violation (445/8432-03; 446/8411-03). 4.2 Participant's Roles and Responsibilities 4.2.1 TUCCO

                                     ~4.2.1.1    Scope TUGC0 will assist in identifying and locating applicable information and documentation to support the Review Team activities.

l 4.2.1.2 Personnel 4 l Mr. D. McAfee, Dallas QA Manager, will ensure effective coordination between the Review Team and TUGCO. l l

Revisicn: 1  ! Page 8 of~9 [m\ ISAP VII.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2 ERC 4'2.2.1

                                       .         Scope ERC will be responsible for reviewing
!                                                applicable TUCCO documentation to determine the adequacy of the program.

4.2.2.2 Personnel Mr. J. Hansel Review Team Leader Mr. J. Celzer Issue Coordinator l 4.3 Qualifications of Personnel 4.3.1 Participants will be qualified to the requirements of

  .                                  the CPSES Quality Assurance Program or to the specific l                                   requirements of the CPRT Program Plan.

4.4 gocedures Program Plan and Issue-Specific Action Plans. 4.5 Standards / Acceptance Criteria Audit activities shall be in compliance with 10CFR50, Appendix B, Criterion XVIII and the applicable codes and standards relating to CPSES FSAR paragraph 17.1.18. Specifically such activities are acceptable if: 4.5.1 Audits to assure that procedures and activities comply with the overall QA program are performed by: 1 4.5.1.1 The QA organization to provide a comprehensive independent verification and evaluation of quality-related procedures and activities. 4.5.1.2 The applicant to verify and evaluate the QA progrsas, procedures, and activities of suppliers. i j 4.5.2 An audit plan is prepared identifying audits to be ! performed, their frequencies, and schedules. Audits j should be regularly scheduled based upon the status and

R:vicion: 1 Page 9 of 9 O f ) ISAP VII.a.4

  \d                                                         (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) safety importance of the activities being performed.and   .

are initiated early enough to assure effective QA during design, procurement, manufacturing, construction, installation, inspection, and testing. 4.5.3 Audits include an objective evaluation of quality-related practices, procedures, instructions; activities and items; and review of documents and records to ensure that the QA program is effective and properly implemented. 4.5.4 Provisions are established requiring that audits be performed in all areas where the requirements of Appendix B to 10CFR Part 50 are applicable. Areas i which are often neglected but should be included are activities associated with: 4.5.4.1 Indoctrination and training programs. f- - 4.5.4.2 Interface control among the applicant and.the principal contractors. 4.5.4.3 Corrective rction, calibration, and non-conformance control systems. 4.5.4.4 SAR commitments. 4.5.5 Audit data are analyzed and the resulting reports indicating any quality problems and the effectiveness of the QA program, including the need for reaudit of deficient areas, are reported to management for review and assessment. 4.5.6 Audits are performed in accordance with pre-established written procedures or checklists and conducted by trained personnel having no direct responsibilities in the areas being audited. 4.6 Decision Criteria Decisions concerning the number of individual reports, records, files, etc., to be reviewed, and the level of detail to which they will be reviewed, will be determined by the quantity and quality of data obtained as implementation of the ISAP proceeds. (Oj This item will be considered closed when sufficient data has been evaluated to support a firm conclusion as to the l acceptability of the program against the acceptance criteria contained in Paragraph 4.5. l l ....- -- - - . - . _ _ _, _ _

COMANCHE PEAK RESPONSE TEAM

  ,                                                                            ACTION PLAN ISAP VII.a.5

Title:

Periodic Review of QA Program i i

!         Revision No.                        0                                                        1 Reflects Coments

! Description Original Issue On Plan Prepared and Recommended by:

                                             ,                                                             M
                                     /)

Review Team Leader // Date EI 'S V l l 'V(, i 6 i, i i i Approved by: M Senior Review Team M / _{ Os .a 1, 7. _ _ / y - . I Date (pfbll C( ,/Z+l8L

                                                                                 /

1 l

O o

1 Rsvioicut 1 Page 1 of 5 ISAP VII.a.5 ! Periodic Review of QA Program l i l

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC j I The Comanche Peak SSER 11, Appendix P. Section 4.7, pages P-31 i ~through P-34, describes the NRC concerns in the arean of audit and l reporting. The concerns pertaining to the Periodic. Review of QA program have been extracted and are presented here: i "The TRT found that TUEC management had failed to periodically ! review the status and adequacy of their QA program. This was j confirmed by Region IV (IR 50-445/84-32). TUEC j representatives stated that there had been no regular j assessments or reviews of the adequacy of the total QA prograa ! by upper management, as required in Criterion II of 10CFR50,  ; Appendix B, and as couaitted in the FSAR. I With respect to follow-up corrective action for previous findings cited against the audit program by NRC and TUEC

consultant audit / inspection teams, the TRT found TUEC's j corrective action follow-up to be not fully effective. The i

Fred Lobbin Report (a TUEC consultant), dated February,1982, identified four major findings (1) level of experience within j the TUGC0 QA organization is low; i.e., commercial nuclear ! plant design and construction QA experience; (2) staffing for ! the audit and surveillance functions is inadequate; (3) the l number and scope of design and construction audits conducted l by TUGC0 QA to date has been limited; and (4) QA management ! has not defined clearly the objectives for the surveillance l program resulting in a program which, in the author's opinion j "is presently ineffective." To date, findings (2) . (3) and 4 (4) have not been adequately addressed by TUIC. (Region IV { Report No. 50-445/84-32.) )' Based on its findings and observations, the TRT concludes that the QA audit and reporting program has had and continues to exhibit deficiencies. Over a significant period of time, i recurring deficiencies includet.... failure by management to review the QA program for effectiveness; procedural and implementation inadequaeies;....and insufficient aanagenent ! direction and understanding. In summation, the QA/QC group l finds the past audit and reporting system less than adequate, I and the audit and reporting program at the time of the TRT j review was questionable." I 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these l O findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the ~ areas ! or activities selected by the TRT." i i I

Rsvicient 1 Page 2 of 5 r O ISAP VII.a.S (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)

          " Address the root cause of each finding and its generic implications..."
          " Address the collective significance of these deficiencies..."
          " Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

The intent of this Issue-Specific Action Plan (ISAP) is to ensure that, for the remaining construction phase for Unit 2 and for operations, a Periodic Review of QA Program is developed which will provide corporate management with data concerning the adequacy and effectiveness of the overall QA Program and which provides for the evaluation, by management, of adverse findings and subsequent corrective action follow up. This ISAP is not intended to perform evaluations which would result

! O       in conclusions regarding the installed hardware. The quality of hardware and any potential safety implications will be assessed

^ from other hardware and programmatic ISAPs and the self-initiated Reverification Program, ISAP VII.c. In addition to the TRT issue, the NRC issued a notice of violation (445/8432-02; 446/8411-02): Contrary to the requirements, the applicant did not establish quality assurance procedures to regularly review the status and

;         adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the I          construction quality assurance program.

4.0 CPRT ACTION PLAN 1 4.1 Scope and Methodology 1 i 4.1.1 The purpose of this action plan is to assess the adequacy of the current CPSES Periodic Review of QA Program against criteria to be developed as part of j this plan. The Review Team will review in-place Periodic Review of QA Programs in other organizations i and will consult with INPO to define criteria for an adequate and effective Periodic Review of QA Program. l 1

                  - . -      +-.i.----          ,e    - p   w            e-_-        - .-,

Revioi n '1'

! Page 3 of 5 ISAP VII.a.5

                               .                                                  (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

The Review Team will then evaluate the current CPSES Periodic Review of QA Program against the criteria l developed above and recommend appropriate revisions to

the CPSES Program.

4.1.2 The specific methodology is described below.  ! l 4 .1 '. 2.1 The Review Team will obtain from other j utilities, and INPO, information and procedures governing in-place Periodic Review l of QA Programa for.both construction and operations phases. 4.1.2.2 The Review Team will review the current TUGC0 written program and practices implementing the Periodic Review of QA Program. l l l 4.1.2.3 Utilizing the information gathered, a set of 1 criteria will be developed to define an O effective Periodic Review of QA Program for CPSES which addresses, among others, the following: i

                                                                                -       Scheduling and performance of reviews at least annually j
                                                                                -       Reports directed to, and responses received from, a sufficiently high

level of management to ensure effective correction action i

- Ongoing contact by management with 4

program status I - Identification of corrective action

                                                                                -       Tracking and follow up 4.1.2.4                       The current TUCCO program will be evaluated against the criteria developed above and.if appropriate, revisions to the TUCCO written

, program will be proposed to assure that an i effective Periodic Review of QA Program is in [ effect for the remaining construction phase

,                                                                          of Unit 2 and for the operations phase.

4 O i

R;vicient 1 Page 4 of 5 [ ISAP VII.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.5 Copies of the Results Report for this ISAP will be provided to TUGC0 for their consideration in responding to the NRC Notice , of Violation (445/8432-02; 446/8411-02).

4.2 Participants Roles and Responsibilities 4.2.1 TUCCO 4.2.1.1 Scope .

l TUCCO will assist in identifying and locating applicable information and documentation to support the Review Team activities, and will provide contact with other utilities and INFO. , 4.2.1.2 Personnel Mr. David McAfee, Dallas QA Manager, will iO ensure effective coordination between the Review Team and TUGCO. 4.2.2 ERC l 4.2.2.1 Scope

ERC will be responsible to communicate with

} outside organizations and TUCCO Management; j provide review of data and make recommendations. ! 4.2.2.2 Personnel Mr. J. Hansel Resiew Team Leader Mr. J. Celzer Issue Coordinator Quality Engineers as required. 4.3 Qualifications of Personnel Participants will be qualified to the requirements of the j CPSES quality assurance program or to the specific i i requirements of the CPRT Program. Plan. 1 iU i i

           -c- - --.       -.       .-_a  -g.      g                   -s--,et

R:vicion: 1

          .                                                                    Page    5 of 5

[' ISAP VII.a.5 (Cont'd) 4 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures

,.                  4.4.1          Program Plan and Issue-Specific Action Plans.

4.5 Standards / Acceptance Criteria Periodic Review of QA activities shall be in compliance with 10CTR50, Appendix B, Criterion II and ANSI N45.2-1971, Section 2. Specifically, such activities are acceptable if a j description is provided of how management (above or outside the QA organization) regularly assesses the scope, status, j adequacy, and compliance of the QA Program to 10CFR50, Appendix B. These measures should include: 4.5.1 Frequent contact with program status through reports, meetings, and/or audits. 4.5.2 Performance of an annual review preplanned and documented. Corrective action is' identified and tracked. l l 4.6 Decision Criteria This item will be considered complete when the following have been accomplished: 4.6.1 A set of criteria for an effective Periodic Review of

QA Program has been developed.

I 4.6.2 The TUCCO Program has been evaluated against the criteria. 4.6.3 The results of the evaluation have been transmitted to TUCCO for consideration in their program. i !O 1

i COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.a.6

Title:

Exit Interviews Revision No. 0 1 Reflects Connents ) Description Original Issue On Plan iO Prepared and L i Recommended by: Review Team Leader 1

! Date                    El W
                                               / A 1 '$l     ,
)

'l i i a I Approved by: Senior Review Team b d ,/k l_ h . j, _1 i V V I Date &l1./lf( /f3.f ffL

R.vicion: 1 Page 1 of 6

                                     .ISAP VII.a.6 Exit Interviews

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC "The TUEC exit interview system for departing employees' appeared to be neither well structured nor effective, as evidenced by the lack ot employee confidence, limited implementation, failure to document explanations and rationale, and failure to compiere corrective I actions and to determine root causes." (NRC letter, January 8, 1985)

With the issue of NRC (NUREG-0797, Supplement No.11) 'the TRT elaborated upon their findings as part of their investigation of

        . Allegation No. AQ-133, which alleged the " Personnel Exit Interview Program is inadequcte and ....not effective." Upon completion of its investigation the TRT substantiated the concern regarding the 1         program's adequacy and effectiveness, additionally stating that its implementation by exit interview and follow up did not appear to j         meet the objective of the program.

l 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. ". . . examination of the potential safety implications should include, but not be limited to the areas or activities selected by.the TRT." ) " Address the root cause of each finding and its generic implications..."

         " Address the collective significance of these deficiencies..."
         " Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

I In response to the NRC Enforcement Action, EA 83-64, TUGC0 procedurally defined programs which required all personnel departing from QA/QC to complete a questionnaire and all Brown & Root construction employees terminating employment to be interviewed. One of the purposes of the questionnaires and interviews was to identify " quality concerns". TUEC in turn was committed to evaluate and disposition these concerns. In April of 1984 TUEC initiated a " Quality Awareness Program" which included a " Hotline" for employees to call in quality c'oncerns.

R: vision 1 Page 2 of 6 ISAP VII.a.6 (Cont'd)

3.0 BACKGROUND

(Cont'd) 4 An Ombudsman from an outside organization (Gilbert / Commonwealth) was assigned to the site in November 1983, and personnel released from QA/QC since October 3, 1983 who had not filled out a questionnaire were located, if possible, and given the opportunity to fill out the questionnaire. On January 14, 1985, TUEC established an independent group called SAFETEAM utilizing personnel from Utility Technical Services, Inc. This group has assumed the responsibility for interviewing personnel and investigating concerns. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 The purpose of this action plan is to determine if TUGC0 management has now' established an effective program which encourages employees to voice concerns regarding safety and seriously evaluates these O concerns. This determination will be made by evaluation of the adequacy of the policies, procedures l and activities of the CPSES Ombudsman and the CPSES SAFETEAM in identifying and resolving site personnel  ! concerns which have potential safety implications. The  ; scope includes the evaluation of the Ombudsman's activities associated with employee concerns brought before him, including those uncompleted actions transferred by him to TUGCO. However, due to the time frame within which this plan will be conducted related to the time of transfer of responsibilities from Ombudsman, the majority of review and evaluation will , center upon the activities and program of the SAFETEAM as implemented through December 1985. l The following general activities will be implemented  ! during the process of evaluating the Ombudsman and SAFETEAM activities. j 4.1.1.1 Develop evaluation attributes from TUGC0 commitments and industry guidelines. 4'.1.1. 2 Evaluate procedural compliance to commitments made. t 0 V i

l l R:vicion: I l Page 3 of 6 ISAP VII.a.6' (Cont'd) l i l -4.0 CPRT ACTION PLAN (Cont'd) i 4.1.1.3 Evaluate procedural impic.nentation. j 4.1.1.4 Determine adequacy of existing program. , i 4.1.2 Implementation Methodology 4.1.2.1 A set of attributes shall be developed to be employed during the review of procedures as well as procedure implementation. Attributes development will consider: Commitments made by TUCCO in response to NRC enforcement action EA-83-64. i Appropriate requirements of 10CFR50, l Appendix B, Criterion I. Applicable industry criteria as i available. O During attribute development stage the l following areas are.to be conside' red: Identification, investigation and ' { evaluation of concerns. j Resolution of concern with employee. Notification given to TUGC0 ' management of those concerns of potential safety implications. Employee anonymity and protection from harassment and/or intimidation. Ombudsman /SAFETEAM/TUGC0 e.oordination. Interviewer / Investigator independence. O . .

                               'l

~ Rsvision: 1 Page 3 of 6 ! ISAP VII.a.6 s_ / (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) , 4.1.1.3 Evaluate procedural implementation. j 4.1.1.4 Determine adequacy of existing program, i 4.1.2 Implementation Methodology 4.1.2.1 A set of attributes shall be developed to be employed during the review of procedures as well as procedure implementation. Attributes I development will consider: l

                                            -      Commit'ments made by TUGC0 in response to NRC enforcement action EA-83-64.                                    ,

i j - Appropriate requirements of 10CFR50, [

Appendix B, Criterion.I.

Applicable industry criteria as available. . During attribute development stage the following areas are to be conside' red: Identification, investigation and i evaluation of concerns. Resolution of concern with employee. Notification given to TUGC0

management of those concerns of-

{ potential safety implications. Employee anonymity and protection j from harassment and/cr intimidation. l Ombudsman /SAFETEAM/TUCCG ! coordination. t Interviewer / Investigator independence. a

  %w l
                           ..~    . __          _.     - . _ .   . _ .

R vision 1 Page 4 of 6 O ISAP VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.2 Develop checklist (s) with attributes from the above. Attributes may be separated into two sections as regards mandatory and non-mandatory based upon the source of the criteria being either TUGC0 commitment or industry example. These checklists will be-used during both the policy / procedure review and the implementation review. 4.1.2.3 Review established policies / procedures in place governing the activities of the Ombudsman /SAFETEAM interviews to the checklist attributes. 4.1.2.4 Using checklist (s) developed, evaluate the implementation of the policies / procedures being utilized by the Ombudsman and SAFETEAM to determine compliance with same and the effectiveness of their implementation. Implementation will, in the case of SAFETEAM, be limited to examination of records which, in the judgment of SAFETEAM, will not  ; compromise the independence and effectiveness ' of their operation, but more importantly will not cause adverse effect upon the protection i of the anonymity of past or future employee l participants of the program. The Issue $ Coordinator will abide by.the SAFETEAM's advisement in these instances. 4.1.2.5 Reviews and evaluations shall be conducted of and limited to past items of concern brought before the Ombudsman or identified through l employee interviews with the SAFETEAM. Evaluations will then be made as to the , effectiveness of the Ombudsman /SAFETEAM's j handling of the concerns including the evaluation for; potential safety implications. Any specific technical issues or concerns found during this review shall be coordinated with QA/QC RTL and other cognizant RTLs to determine additional evaluation as required. O - - - .L.. - , -

Rsvision 1 Page 5 of 6 () ISAP VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.6 The results of reviews and evaluations conducted in paragraphs 4.1.2.3, 4.1.2.4'and 4.1.2.5 will provide a basis for determining whether the Ombudsmans interview progran and implementation was adequate and effective in identified employee concerns, as well as determining whether the existing SAFETEAM program as implemented is effective in identifying and evaluating employee concerns regarding potential safety implications. The results of this action plan will provide input for the overall evaluation.of the adequacy of the QA program being conducted by the QA/QC Review Team as well as providing recommendations for improvement for future program implementation as required. 4.2 Participants Roles and Responsibilities 4.2.1 Evaluation Research Corporation

    )                         This action plan will be developed and implemented by Evaluation Research Corporation (ERC).

4.2.1.1 Scope The entire scope of this action plan will be implemented by ERC. 4.2.1.2 Personnel Mr. J. L. Hansel QA/QC Review Team

!                                                                    Leader Mr. P. E. Ortstadt         Issue Coordinator a

4.3 Qualifications of Personnel Personnel participating in the implementation of this ac . plan shall be qualified in accordance with the requirements of the TUGCOs " Program Plan and Issue-Specific Action Plans". ! 4.4 Procedures Development and implementation of this action plan shall be in accordance with TUGCOs Program Plan and Issue-Specific Action Plans. Checklists will be developed by the Issue Coordinator for use in conducting reviews of policies and procedures and I

I R2vicion: 1 Page 6 of 6 f I"AP VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) program implementation. Procedures to implement this action j i plan will be developed only as required by Issue Coordinator / Review Team Leader decision. 4.5 Standards / Acceptance Criterin There are no published industry standards addressing exit interviews nor criteria for acceptable programs. For this. action plan, acceptance criteria vill be developed from TUGC0 commitments made in response to the NRC Enforcement Actions and available industry " Guidelines". The criteria to be developed at the beginning of this plan will consider the following areas: 4.5.1 Concern identification 4.5.2 Concern investigation 4.5.3 Concern identification as to potential safety implications 4.5.4 Concern notification to responsible TUGC0 management 4.5.5 Concern resolution 4.5.6 Feedback to employee 4.5.7 Employee anonymity-4.5.8 Interviewer independence 4.6 Decision Criteria This plan will be closed when: i 4.6.1 Evaluation of the current program against the developed criteria has been completed and recommendations for program improvement concerning any areas of weakne'sses which may be identified have been transmitted to TUCCO. 4.6.2 Any specific technical issues or concerns identified are. assigned to cognizant RTL(s) for resolution. I D a l l i

     }                              COMANCHE PEAK RESPONSE TEAM
 %./

ACTION PLAN ISAP VII.a.7

Title:

Housekeeping and System Cleanliness Revision No. 0 1 Reflects Coments Description Original Issue On Plan Prepared and ( ,[ Recommended by: Review Team Leader

                          //
                          /

Date l llC l Y ISC l Approved by: Senior Review Team bki .W, kg b oJ, k Date (sl%llf( ll24 fL l l

b3 l 1

1

R3 vision: 1 Page 1 of 7 /~'T (j ISAP VII.a.7 Housekeeping and System Cleanliness

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (USNRC Letter January 8, 1985, Issue 9. Housekeeping and System Cleanliness)

         "The TRT inspections at CPSES identified two issues that indicate housekeeping and system cleanliness deficiencies.

A. The TRT reviewed the August 6, 1984, draft of flush procedure FP-55-08. The purpose of this procedure was to verify the cleanliness of Unit I reactor coolant loops, including the reactor vessel, by means of handwiping, visual inspection, and swipe testing. Tests to determine surface chloride and fluoride contamination were performed by TUEC systems test engineers and Westinghouse representatives. The TRT notes, however, that FP-55-08 required only two swipe tests of the reactor vessel--one on the side and one on the bottom. This limited number of swipe tests may not provide adequate assurance that the vessel had been properly cleaned. B. In rooms 67, 72, and 74 of the Unit 2 Safeguards Building, the TRT observed that not all snubbers were wrapped with ,' protective covering when welding was being done in close proximity to them. This practice was a violation of Brown & Root procedure CP-CPM-14.1, which required protection of installed equipment during velding. This condition was immediately corrected when the TRT reported it to TUEC QA management, and an inspection was performed by TUEC to correct similar conditions in other areas as well." 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT.

              " Address the root cause of each finding and its generic implications...
              " Address the collective significance of these deficiencies...
              " Propose an action plan...that wil' ansure that such problems do not occur in the future."

f) V

Rsvicion: 1 Page 2 of 7 O g ISAP VII.a.7 (Cont'd) ,

                                                                                     )

3.0 BACKGROUND

J < Previous NRC-TRT reports-have requested specific actions to be l taken for deficiencies related to housekeeping and system i cleanliness. Specifically, NRC-TRT letter, September 18, 1984, l addressed NCR closeout for construction debris'in the air gap of I seismic Category I structures. Action Plan II.c was prepared to resolve that item. NRC-TRT letter, November 29, 1984 addressed the possibility of construction debris in the RV shield wall annulus. Action Plan VI.a was prepared to resolve that item. As a result of the NRC-TRT items, a " critical spaces program" was incorporated'in ISAP VI.a to asses.s the impact of construction debris. A preliminary review of the circumstances related to Reactor Coolant System (RCS) flush and cleanliness verification was performed to identify background data related to NRC-TRT letter, January 8, 1985, Item 9A. I Visual-inspection of all four (4) loops, steam generators, reactor coolant pumps, and the reactor vessel and internals was conducted by Startup personnel prior to turnover to Startup on February 18, 1982. RCS loops were handwiped on several occasions between January, 1982 and July,1982 following ECCS flushes. The RCS was cleaned, visually inspected, and tested.for chloride residue preparatory to cold hydrostatic test. During l cold hydro, water samples were taken and analyzed to assure water chemistry specifications were maintained. The RCS was cleaned and visually inspected again, preparatory to Hot Functional Test (HFT). During HFT, water samples were taken and analyzed to assure water chemistry specifications were maintained. The RCS was periodically filled and drained during testing of other fluid systems. Cleaning was performed in accordance with Flush Plan FP 55-08 l prior to turnover to Operations. Although the flush plan only required chloride residue swipes at two (2) locations, eight (8) swipes were actually taken by test lab technicians. The RCS was turned over to Operations in October, 1984 following i final QA acceptance of system cleanliness. O L V

l l l Rsvision: 1 l Page 3 of 7 ISAP VII.a.7 l (f-~}s (Cont'd)

3.0 BACKGROUND

(Cont'd) A preliminary review of protection of components from adjacent welding activities (NRC-TRT letter, January 8, 1985,' Item 9B) was not performed since the NRC-TRT evaluation, as documented in SSER 11, Allegation AQ-54, page 0-158, concluded that the observation . was an isolated occurrence and was immediately corrected. I 1 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 This Issue-Specific Action Plan assesses the adequacy of the housekeeping and systen cleanliness program at CPSES. The following tasks will be implemented to achieve this objective: Review the results of ISAPs II.c and VI.a for N adverse trends related to housekeeping and system cleanliness. Review TUGC0 and Brown & Root procedures for establishment of housekeeping and cleanliness measures (including surveillance requirements). Evaluate implementation of FP 55-08 for Reactor Vessel cleanliness. Review and evaluate implementation of TUGC0 and Brown & Root Surveillance program. 4.1.2 The specific methodology is described below. 4.1.2.1 The results of the following action plans will be rev!ewed for housekeeping and system cleanliness deviations: l l

                                             -     Action Plan II.c, Maintenance of Air Gap Between Concrete Structures, relates to construction debris in the air gap.

O

Rsvision: 1 Page 4 of 7 ISAP VII.a.7 (Cont'd) l l l 4.0 CPRT ACTION PLAN (Cont'd) Action Plan V.b - (deleted). l

                                     -    Action Plan VI.a. Gap Between Reactor Pressure Vessel Reflective             l Insulation and the Biological Shield Wall, relates to construction debris in the gap between the RPVRI and the
                                                              ~

shield wall. Action Plan VI.a incorporates requirements for a

                                          " critical spaces program".

4.1.2.2 The procedural controls that are in effect for housekeeping and system cleanliness shall' include the requirements of 10CFR50 Appendix B, Criterion XIII and the FSAR. Housekeeping and system cleanliness procedures will be reviewed to determine if these requirements are included. Procedural

;                              controls for site and plant surveillance will i i

(~N also be reviewed. 4.1.2.3 The TUGC0 flush procedures for verifying cleanliness of the Reactor Coolant Loops, including FP 55-08, as referenced in Item 9A. , of the NRC-TRT letter dated January 8, 1985, l will be reviewed to determine the adequacy of swipe testing performed in accordance with the Westinghouse guidelines. Also verify the adequacy of the flushing and associated swipe testing performed on the reactor coolant system. Input from other Review Team Leaders will be used as required in the determination of the adequacy of the swipe testing performed on the Reactor Coolant System, as well as the procedural requirement for two (2) swipe tests of the Reactor Vessel. 4.1.2.4 In conjunction with TUGC0 surveillances, review plant areas (warehouses, laydown areas, and in place storage areas), both Unit 1-and Unit.2, for evidence of Housekeepin's l and System Cleanliness problems. The results l of these reviews will be used to determine l the effectiveness of the housekeeping and system cleanliness program. The reviews l shall check the following: U l \

Rsvision: 1 Page 5'of 7 C , Q) ISAP VII.a.7 (Cont'd)

                                                                                    )

4.0 CPRT ACTION PLAN (Cent'd)

                                       -    Access control to plant areas Any evidence of damage or deterioration to materials and equipment
                                       -    Equipment protected from environmental and work induced conditions Noted discrepancies will be documented and corrective action (s) recommended.

4.1.2.5 A review of TUGC0 documentation will be l conducted to establish the effectiveness of-the current TUCCO housekeeping and system cleanliness program. The following documents l will be reviewed for related housekeeping and system cleanliness concerns: TUGC0 and Brown & Root audit reports, surveillance reports, i inspection reports NCRs, CARS, NRC reports and system cleanliness packages. This review will include information relating to Unit I and Unit 2, operations program and on-going in process inspections. 4.1.2.6 A detailed analysis will be conducted on the data from the reviews in paragraphs 4.1.2.1, through 4.1.2.5. Data vill be analyzed to determine if the housekeeping and system cleanliness program has met the requirements of 10CFR50 Appendix B, Criterion XIII and the FSAR. 4.2 Participants Roles and Responsibilities 4.2.1 TUGC0 4.2.1.1 TUGC0 will assist in identifying and. locating applicable information and documentation to support the Review Team' activities.

  >O
 . y/

1 l

R: visions 1 Page 6 of 7 -[') '\s_/ ISAP VII.a.7 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 -Personnel  ; Mr. D. Snow - TUGC0 QA/QC Coordinator 4.2.2 CPRT QA/QC Review Team  ! 4.2.2.1 Scope , l All activities not identified in 4.2.1 above or 4.2.3 below will be the responsibility of~ the QA/QC Review Team. l l 4.2.2.2 Personnel l

                                                                               ~

Mr. J. L. Hansel - QA/QC Review Team Leader l i Mr. S. L. Crawford - Issue Coordinator 4.2.3 CPRT-Other Review Team Leaders () 4.2.3.1 Review valid deviations to determine the safety significance of each deviation. 4.2.3.2 Personnel CPRT- Review Team Leaders as applicable. l 4.3 Personnel Qualification Requirements i All personnel associated with analysis and evaluation of  ! findit.gs will be qualified in accordance with the requirements  ! of CPRT. Program Plan. Where inspections require the use of certified. inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. l 4.4 Procedures Checklists, guidelines, data sheets, and flowcharts'may be developed as an integral part of the evaluation. These will be retained to support justification of the conclusions. l l 1 l l l 1

Rsvision 1 l Page 7 of 7 ISAP VII.a.7

 ~                                       (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Standards / Acceptance Criteria Housekeeping and System Cleanliness acti/ities shall be in compliance with 10CFR50, Appendix B, Criterion XIII -
                 " Handling, Storage and Shipping" and the associated commitments of CPSES/FSAR paragraph 17.1.13.      Specifically such activities are acceptable if they include as a minimumi 4.5.1   Materials and equipment are. protected from damage or             i deterioration during storage.

4.5.2 Implementation of procedure requirements are verified through surveillances'or audits. 4.5.3 Special environmental protection such as inert gas, humidity controlled, or temperature controlled reorage areas are provided for materials and equipment, when i required. 3 4.5.4 Access control to plant and storage-areas are maintained. 4.6 Decision. Criteria If the compilation of information resulting from the implementation of paragraphs 4.1.2.1 through 4.1.2.6 contains any safety-significant deficiencies or adverse trends whose root causes are attributable to housekeeping, cleanliness, or surveillance inadequacies, corrective action required for the remaining construction phase activities on Unit 2 and operations phase activities will be included in the ISAP Results Report and the ISAP closed. 0therwise, document the results of the evaluation in the ISAP Results Report and close the ISAP. I O

(~ im)I COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.a.8

Title:

Fuel Pool Liner Documentation Revision No. 0 1 Reflects Coments Description Original Issue On Plan %J Prepared and //,,,,,f Recommended by: " -- ' Review Team Leader Date UW f Z $$ n r ev v Team v d./ h(), /b

                                         /

Date (o f%l fia /f34l8L O (

Rsvision 1 Page 1 of 6 ISAP VII.a.8 ( Fuel Pool Liner Documentation

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (USNRC Letter of January 8, 1985, Pg. 3)

                     " Based on the TRT review of about 200 fuel pool travelers, TUEC was unable to maintain an effective and controlled QC program _for fuel                    '

pool liner fabrication, installation,-and inspection. Typical fuel pool traveler irregularities were: There was apparently a routine practice during construction of the fuel pool that allowed Craft personnel to complete a portion of the inspection report forms prior to the actual inspection. Craft personnel entered the word " SAT," dated the entry, and lef t blank only the space for the QC inspector's signature. It appeared that the Craf t personnel were judging the inspection results prior to inspections. The date accompanying the signature for visual examination of an inside weld was changed to a date that-appeared to precede the examination. Entries by the same inspector for two different inspections Os did not appear to match in that one entry appeared to be written by another person. The procedure number for a dye penetrant inspection was changed by an inspector different from the one who conducted the inspection. The date'for a dye penetrant inspection was changed by an inspector other than the one who performed the inspection. Fuel pool travelers were found with missing QC sign offs for fitup and cleanliness. No proof could be found that some of the required weld ficup and cleanliness inspections were ever performed. The TRT review disclosed the following irregularities with traveler entries in addition to those listed above: Date changes after the fact Sign offs for functions out of-sequence Corrections after the fact I - Changes to first party inspector date sign offs () - Missing signatures" l- ___-- - . _ - . . . _ . . . - . - _ , , y

Rivision: 'l , Page 2 of 6 ( ISAP VII.a.8 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."

         -     " Address-the root cause of each finding and its generic implications..."
         -     " Address the collective significance of these deficiencies..."
               " Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

l CPSES Safety Evaluation Report, Supplement 10 (SSER #10), April 1985, provides additional information related to the technical adequacy of fuel pool liver (and transfer canal and reactor refueling cavity liner) welds. The following observations were O made by SSER #10: The fuel pool liners are not required by FSAR to meet 10CFR50 or ASME B&PV Code requirements (although G&H Specification 2323-SS-18 does impose 10CFR50 Appendix B QA Program , requirements). The fuel pool liners also are not required to be designed and erected to meet Seismic Category I criteria. The Brown & Root construction and inspection procedures used for fuel pool liner erection and welding are consistent with G&H Specification 2323-SS-18. The TRT observed approximately 20% of the seam welds in the spent fuel pools. The leak chase system and' imbeds are inaccessible and were not checked. Five (5) allegations were reviewed by the TRT related to fuel pool liner fitup and welding; none of the allegations'were

found to have safety significance.

The observations of SSER #10 notwithstanding, Gibbs & Hill Specification 2323-SS-18 Revision April 15, 1985, Paragraph 1.1 does identify the stainless steel liner systems (except the Unit I and Unit 2 Reactor Building Refueling Cavities) as Nuclear Safety

                                                                ~

Related. This includes the spent fuel storage pools, transfer canals, and cask loading pits. 1 i l

R: vision: 1 Page 3 of 6 [

  \-

ISAP VII.a.8 (Cont'd)

3.0 BACKGROUND

(Cont'd) QA/QC aspects of the fuel pool liner erection and welding are not included in SSER #10, but have been published in'SSER #11. May 1985. The reinspection of fuel pool liner welds will be performed under ISAP VII.c, " Construction Reinspection / Documentation Review Plan", population FPLR.

                     .                                                               I 4.0 CPRT ACTION PLAN 4.1. Scope and Methodology 4.1.1  The objective of this action plan is to evaluate irregularities in the fuel pool liner travelers and related documentation.

To achieve this objective the following tasks will be implemented: () - Review of liner specification, drawings ~and procedures to determine requirements. Review of liner travelers for irregularities. 4.1.2 The specific methodology is described below: 4.1.2.1 Review the fuel pool liner specification, drawings, and fabrication and inspection procedures. Identify the erection, inspection and testing requirements. 4.1.2.2 Select a sample of the' liner welds for traveler review. The sample will be randomly selected from a list of all the spent fuel pool, transfer canal,.and cask loading pit travelers used during erection of the liner and associated components. The sample will be selected to provide at least 95/5 screen. A minimum random sample size of 60 is required to meet this condition-in accordance with CPRT Program Plan Appendix'D. Table 1. A sample review is considered a reasonable i approach for the following reasons: O , l

Rsvision: 1 Page 4 of 6 ( - ISAP VII.a.8 (Cont'd)- 4.0 CPRT ACTION PLAN-(Cont'd)

                                                -    No programmatic deficiencies have been identified in this population to date.

The population of travelers is homogeneous in that all the work was accomplished by the same crafts and used the same procedures. 4.1.2.3 Obtain fuel pool travelers associated with the liner weld sample selected. Review these travelers to' determine if all the required inspections were performed to the applicable design and procedure requirements and that the. travelers were properly completed. The review will be. conducted using a documentation data sheet and will include, but is not limited to, verification of date entries and authorized inspection sign offs. 4.2 Participant's Roles and Responsibilities The organizations and personnal that will participate in this effort are described below with their respective scopes of work. 4.2.1 TUCCO 4.2.1.1 Scope Assist the QA/QC Review Team in the identification and provision of all necessary specifications, drawings, procedures and other documentation necessary for the execution of this 2 action plan. Process NCRs that may be generated due to this action plan. ( 4.2.1.2 Personnel l i Mr. C. R. Hooton - Project Coordinator (CPPE)

Rivision: 1 Page 5 of 6

 /(G)                                ISAP VII.a.8 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Mr. D. Snow - TUGC0 QA/QC Coordinator 4.2.2 CPRT QA/QC Review Team l 4.2.2.1 Scope The QA/QC Review Team will be responsible to l evaluate the adequacy of completed inspection records (travelers) for fuel pool liner 1 . fabrication. 4.2.2.2 Personnel Mr. J. L. Hansel - QA/QC Review Team Leader Mr. M. P. Obert - Issue Coordinator l 4.3 Qualifications of Personnel Where tests or inspections require the use of certified

 \             inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the quality procedures developed under this action plan.

Other participants will be qualified to the requirements of the CPSES. Quality Assurance Program, or to the specific requirements of the CPRT Program Plan. 4.4 Procedures Matrices, checklists, and data sheats may be developed as an integral part of the evaluation. These will be retained to support justification of conclusions. 4.5 Standards / Acceptance Criteria Fuel pool liner inspection records shall be in compliance with the inspection record requirements of 10CFR50 Appendix B, Criterion X . " Inspection", and Criterion XVII " Quality Assurance Records" and the associated commitments of CPSES/FSAR paragraphs 17.1.10 and 17.1.17 respectively. Specifically, such records are acceptable if they provide, as a minimum.

l R3 vision: 1 l Page 6 of 6 ISAP VII.a.8 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                                                                       ~

4.5.1 Sufficient detail to permit adequate confirmation of inspection activities. 4.5.2 Identification of the person (s) recording the data a'nd approving the Inspection Results. 4.5.3 Acceptance of the item or activity documented and approved by authorized personnel. 4.5.4 Type of observation and results. 4.5.5 Action taken in connection with any deficiencies noted. 4.5.6 Legible, accurate record of work accomplished. 4.6 Decision Criteria l If the compilation of information resulting from the implementation of paragraphs 4.1.2.1 through 4.1.2.4 contains any safety-significant deficiencies or adverse trends whose root causes are attributable to inspection inadequacies, corrective action will be included in the ISAP Results Report and the ISAP closed. Otherwise, document the results of the evaluation in the ISAP Results Report and close the ISAP. I

                                                                                                -i l

l l i I (_/

 /O                                COMANCHE PEAK RESPONSE TEAM
 \Q ACTION PLAN          !
                                         .ISAP -VII.b.1

Title:

On-Site Fabrication Revision No. 0 1 Reflects Coments

 /    Description         Original Issue       On Plan Prepared and         (

Recommended by: Review Team Leader g a Date S 'A(~ / p off Approved by: Senior Review Team d f,,1__($ g j{j Date lylf'( )fg.4 fyg l

I i Rsvision: 1 Page 1 of 8 ( ISAP VII.b.1 Onsite Fabrication i

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (USNRC Letter January 8, 1985, Issue 8, Onsite Fabrication) l "The TRT findings regarding onsite fabrication shop activities indicated that: A. The scrap and salvage pile in the fabrication (fab) shop laydown yard was not identified and did not have restricted access. B. ~ Material requisitions prepared in the fab shop did not comply with the applicable procedure. 4 C. The fab shop foremen were not familiar with procedures that controlled the work under their responsibility. D. Fabrication and installation procedures did not include information to ensure that Brown & Root fabricated threads conformed to design specifications or to an applicable standard. i E. Indeterminate bulk materials that accumulated as a result of site cleanup operations were mingled with controlled safety and nonsafety material in the fab shop laydown yard. F. Site surveillance of material storage was not documented. 1 G. Work in the fab shop was performed in response to memos and sketches instead of hanger packages, travelers, and controlled drawings."

       '2.0  ACTION IDENTIFIED BY NRC Evaluate.the TRT findings and consider the implications of these findings on construction quality. "... examination of i                     the potential safety implications should include, but not be limited to the areas or activities selected by the TRT.
                     " Address the root cause of each finding and its. generic implications...
                     " Address the collective significance of these deficiencies...

l

                     " Propose an action plan...that will ensure that such problems          ,

l do not occur in the future."  ! l

                                                                                             \

l l l Rivision: 1 I I' age 2 of 8

 )                                   ISAP VII.b.1 (Cont'd)                                   l i

3.0 BACKGROUND

This action plan involves the fabrication shop identified as a part of the NRC item on material traceability, and addressed by Issue-Specific Action Plan VII.a.1, " Material Traceability". CPSES Safety Evaluation Report Supplement No.11 (SSER 11), May 1985, Appendix 0, Allegation AQ-138 (pages 0-145 to 0-153) discussed fabrication shop activities under QA/QC Category 5B, Onsite Fabrication. Specifically, Allegation AQ-138 consists of 12 elements:

1. , Personnel asked to perform work without knowledge of paperwork.

2. Paperwork illegal due to post dating.

3. Non safety material mixed with safety related material.

4. Personnel directed not to mark indeterminate material as scrap.

5. Electrical and iron fab shop material consolidated and

mixed.

6. Electrical personnel used undocumented material.

7. ASME QC personnel in iron fab shop did not check Brown

                       & Root threads.

8. Undocumented weld repairs made on base metal.

9. Threaded rod cut without QC verification of heat numbers.

10. Arc cut done too close to cut line.

11. Beam clips may have been cracked during bending.

12. Chain and triple hook fabricated without regard to procedures.

The NRC conclusions to Allegation AQ-138 (page 0-152) are:

                 --    Substantiated:     Item 1.                                   I 1
                 -     Not substantiated: Items 3, 4, 5, 7, 9, 11.

9 4

                                                                         .        -       1
                                                                                          )

Rsvision: 1 Page 3 of 8 l ISAP VII.b.1 (Cont'd)

3.0 BACKGROUND

(Cont'd) Unable to substantiate: Items 2, 6, 8, 10, 12. However, SSER 11, . Appendix P lists seven (7) Allegation AQ-138 concerns or deficiencies under QA/QC program area 4, Construction and Testing (page F-14) . (Note that the QA/QC program areas of Appendix P are not the QA/QC categories of Appendix 0.) The seven (7) AQ-138 concerns. or deficiencies, referenced to SSER 11, Appendix P, are:

1. Parts fabricated without hanger package, traveler, or drawings.

2. Scrap and salvage material not marked or restricted

                       'CCess.

a

3. Indeterminate material mingled with safety related material.

4. Fabrication procedures did not identify design standards for threads.

5. Material requisitions did not comply with procedures.

6. Random QC surveillance of storage areas not performed.

7. Unused material not returned to warehouse.

Concerns I through 6 were included in. the NRC-TRT January 8, 1985 letter as Items 8G. 8A, 8E, 8D, 8B and 8F respectively (see paragraph 1.0 above also). _ NRC-TRT January 8,1985 Item 8C (Shop Foreman familiarity with procedures) was identified only in SSER 11, Appendix 0 (page 0-146), but was not included in Appendix P.- Adequacy of craft training is addressed in ISAP I.d.3. Concern 7 (above) was first identified in Appendix P, and will be addressed in ISAP VII.a.i. Background and historical information will be obtained and evaluated as a part of the implementation of this action plan. l 4.1 Scope and Methodology i 4.1.1 This Issue-Specific Action Plan assesses the adequacy l of the procedural and management control' of fabrication shop work activities at CPSES. This action plan consists of two separate areas of evaluation: I _. _ - . _ .

l Rsvision: 1

                                                                   .Page   4 of 8 l l

T ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN

   .                  4.1.1.1   Concerns which may be evaluated by review of safety related fabrication document packages:

1 Material requisitions not properly completed. Fabricated thread conformance. Fabrication to memos and sketches. 4.1.1.2 Concerns which may be evaluated.by review of procedures, survey, surveillance, and audit records to identify trends-and corrective action effectiveness: Scrap and salvage area control Safety, non-safety and bulk material segregation () - Site surveillanc of material storage 4.1.2 The specific methodology is described below. 4.1.2.1 Identify, obtain, and review applicable materia 1' storage, fabrication, and inspection procedures in effect for toch ASME and non-ASME safety related work in onsite fabrication shops. Evaluate procedural adequacy with respect to controls for material traceability, fabrication processes and item acceptability. 4.1.2.2 Identify populations of ASME and non-ASME safety related fabricated pieces. 4.1.2.3 Select a random sample of at least 60 fabricated pieces each for both ASME and non-ASME safety related fabricated items in accordance with the CPRT Program Plan, Appendix D. . Review the completed fabrication ] packages for the sampled pieces for adequacy of material identification, applicable drawings and procedures used, and fabrication and inspection sign offs. If no s discrepancies are identified, document the results and close the action item.

l Rsvision: 1 i Page 5 of 8

                                                                                 )

p \ ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.4 If documentation discrepancies are identified, perform a visual reinspection of the selected items in situ for velds, dimensions, fasteners, material identification, component identification, etc. Based upon the review in Section 4.1.2.1, and l hardware reinspection checklists developed under ISAP VII.c appropriate inspection attributes and accept / reject criteria will be developed. 4.1.2.5 Review storage and surveillance procedures and records for adequacy of requirements, ' identification of trends, and effectiveness of corrective action. 4.1.2.6 Review any fabrication shop deviations l identified by Item VII.a.1 Issue Coordinator {s for needed additional sampling per paragraph 4.1.2.3 or for~ hardware and programmatic correction per paragraph 4.1.2.10. 4.1.2.7 A detailed analysis will be conducted on the data from the reviews in paragraphs 4.1.2,1 through 4.1.2.6. Dcta vill be analyzed to determine if the shop fabrication activities have met the requiremsnes of 10CFR50 Appendix B, Criteria V, II, and X and the FSAR. 4.1.2.8 Provide any discrepancies related to material traceability to Item VII.a.1 Issue Coordinator for integration into that action p *_an . 4.1.2.9 Advise TUCCQ of specific hardware deviations to be documented within the CPSES NCR program for resolution and disposition. 4.1.2.10 Programmat*c implications, if any, will be  ! reported to the CPRT Manager--QA/QC Programmatic Issues, and those with potential impact on other action plans will be  ; O identified and addressed to the affected Issue Coordinator. J 1 i l

Rsvision: 1 Page 6 of 8 (

  \,

ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participant's Roles and Responsibilities The organizations and personnel that will participate in this.

                                                                               ~

l effort are described below with their respective scopes of l work.

4. 2.1 ~ TUGC0 l

4.2.1.1 Scope Assist the QA/QC Review Team in obtaining information regarding the identity and location of all Fabrication shops used during the I life of CPSES Unit 1 & 2 l Construction. Assist in the identification and provision of all necessary , specifications, drawings, procedures ! s and other documentation necessary i for the execution'of this action plan. Assist in determining the type of items fabricated onsite in the respective fabrication shops. Process NCRs that may be generated due to this action plan. 4.2.1.2 Personnel Mr. D. Snow TUGC0 QA/QC Coordinator Mr. C. R. Hooten Project Coordina!pr (CPPE) l 4.2.2 CPRT Safety Evaluation Group 4.2.2.1 . Perform evaluations for safety significance.

                                                                                            ~

4.2.2.2 Personnel Mr. J. A. Adam SSEG - Supervisor i O i

1 R; vision: 1  ; Page 7 of 8 [D N-- ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 CPRT QA/QC Review Team , 4.2.3.1 Scope All activities not identified in 4.2.1 and 4.2.2 above will be the responsibility of the QA/QC Review Team. 4.2.3.2 Personnel Mr. S. L. Crawford Issue Coordinator Mr. J. L.' Hansel QA/QC Review Team Leader 4.3 Qualifications of Personnel All personnel associated with analysis and evaluation of findings will be qualified in accordance with the requirements of the Program Plan.

     )                   Where inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2 i at the appropriate. level.

4.4 Procedures Checklists, guidelines, data sheets, and flowcharts may be -l developed as an integral part of the evaluation. These will be retained to support justification of the conclusions. 4.5 Sampling Plan A sample of items randomly distributed throughout each population will be selected in accordance with the provisions of the CPRT Program Plan, Appendix D. If reinspection is required per paragraph 4.1.2.4, items will l be checked for accessibility and if inaccessible, replaced with other randomly selected items. 4'. 6 Standards / Acceptance Criteria Acceptance-criteria vill be based on a review of shop fabrication procedures, QC inspection procedures, codes and standards, drawings and sketches. O U 1 ce - - - y

Rsvision: 1 Page 8 of 8 1,- ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION. PLAN (Cont'd) Fabrication shop work activities will be accepted if all required documents are present and correctly identify drawings and process procedures used, inspection criteria satisfied,  ; material identification and type, and authorized sign offs l attesting to the adequacy of the items and documentation. ' 4.7 Decision Criteria If the compilation of information resulting from the implementation of paragraphs 4.1.2.1 through 4.1.2.7 contains any safety-significant deficiencies or adverse trends.whose root causes are attributable to procedural and management' control inadequacies related to fabrication shop work activities, corrective action required for the remaining i construction phase activities on Unit 2 will be included in the ISAP Results Report and the ISAP closed. Otherwise, document the results of the evaluation in the ISAP Results Report and close the ISAP.

COMANCliE PEAK RESPONSE TEAM () ACTION PLAN ISAP VII.b.2

Title:

Valve Disassembly Revision No. 0 1 Reflects Comments On Plan Description Original Issue Prepared and Recommended by: [ Review Team Leader

     *'*            .                      .      l 24/ '[$

! Approved by: Senior Review Team _d,/ Q g j] V Date 4 l2.p lg f r l24lgg l o N

Rsvision 1 Page 1 of 7 O

  \s /                                    ISAP VII.b.2 Valve Disassembly

1.0 DESCRIPTION

OF ISSUE IDENTIFIED SY NRC (USNRC letter of January 8,1985, Pg. 23)

               "The TRT found that installation of certain butt-welded valves in three systems required removal of the valve bonnets and internals prior to welding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system. This installation process was poorly controlled in that disassembled parts were piled in uncontrolled areas, resulting in lost, damaged, or interchanged parts. This practice created.the potential for interchanging valve bonnets and internal parts having different pressure and temperature ratings."

2.0 ACTION IDENTIFIED BY NRC Evaluate the fDRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT." (% O " Address the root cause of each finding and its generic implications..."

               " Address the collective significance of these deficiencies..."
               " Propose an action plan...th't a will enenre that such problems do not occur in the future."

3.0 BACKGROUND

Other possible reasons for valve disassembly include hydrotest, flushing, purging and repair, and therefore many different valve types are potentially affected. Additional background information such as valve manufacturers, types, sizes, ratings, installation dates, etc. will.be obtained as a part of the implementation of this Issue-Specific Action Plan. 'y

 . _.                                                                                1 Rsvicion:  1 Page 2 of 7

[\ ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN 4.~ 1 Scope and Methodology The objective of this action plan is two fold. Firstly, to evaluate if procedures are adequate to control.the valve disassembly / reassembly process. Secondly, to evaluate if valves that required disassembly were properly reassembled; and,-if not, whether an improperly reassembled valve could result in a code violation or have a safety- consequence. The following tasks will be implemented to achieve these objectives: Identify all valves which have been disassembled and

reassembled.

A procedure review to determine adequacy of cont'rol of

                       ~

valve components during disassembly and reassembly. A safety consequence analysis to determine if valve

   *s                        component parts from.one valve are physically capable of fitting up to another valve of the same type but having a lower pressure / temperature rating or code
    ~

class and identify potential. risks if such reassembly occurred. A reinspection of valves which have been disassembled and reassembled to establish confidence that valveg were properly reassembled. The first three of the above tasks'shall be considered Phase I of this action plan. Phase II of this plan will be the fourth J_ task. The specific mgchodology is described below: 4.1.1 The first step in this investigation will be to identify the population of valves which have been disassembled. All valve' disassembly and reassembly was accomplished under operation travelers. A log of all operation travelers will be reviewed and those pertinent to valve disassembly will be utilized to , develop a list of all valves which have been 1 disassembled. O

Ravision: 1 Page 3 of 7 l ISAP VII.b.2 (Cont'd) I 1 4.0 CPRT ACTION PLAN (Cont'd) From this_ list another list will be developed of those valves in the population identified in the TRT issue (diaphragm valves in the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system). 4.1.2 Review applicable procedures, for both construction and QC, to determine- if they provided adequate controls of materials during valve disassembly and reassembly. In

                   ' addition to proper matching of components, the procedures will_be reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process.
                    .If procedures have changed during the course of construction the historical file of procedures will be reviewed to determine if improper reassembly were more likely to occur during a particular time frame. If the procedures for Units 1, 2 and Common are different, they will each be evaluated.

V In terms of valve installation processes present procedures will be viewed as adequate or not based on their. clarity, completeness and on the practicality of their use.

4. '1. 3 In parallel with the procedure review, an analysis will be made to determine the safety consequences of improperly assembled valves. The analysis will include potential failure modes resulting from improper reassembly of the generic valves in question. Generic valves are those which required disassembly of all valves of that type. This analysis will be performed on a case basis for non generic valve types pending the results of reinspections.

In addition, an evaluation will be made to define potentia' code violations which could result from improperly assembled valves. , 4.1.4 A reinspection of valves which have been disassembled will be performed to provide assurance that the valves  ; were reassembled using the correct components. A sample of valves from the population of all valves which have been disassembled will be reinspected and an /7 additional sample of valves from the. population Q comprised of the valves identified in the TRT issue l l

Ravision: 1 Page 4 of 7

  ' ()                                  ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) will be reinspected.- Both samples will be' in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection is considered to be reasonable approach for the following reasons:

No programmatic deficiencies have been identified in this population to date.

                              -     The population of valves which have been disassembled is homogeneous. Specifically, all the valves were disassembled by the same craft under the same procedures. Therefore, sampling in accordance with Appendix D will detect, with a high level of accuracy, programmatic errcrs associated with the process of disassembling and reassembling valves.

4.1.5 Manufacturers drawings and disassembly procedures will p) ( be reviewed and documentation packages will be assembled for those valves selected in the random sample. Inspection procedure will be predicated on the-results of this review. If review of the documentation for a specific valve indicates probable improper

,                        reassembly, reinspection will include's verification of internal parts.' Probable improper reassembly will be indicated by an inconsistency in internal component serial nos from one Operation Traveler to another for a particular valve.

I 4.2 Procedures Operations, construction and/or QC procedures now in effect will be reviewed and if found satisfactory, will be used for disassembly, inspection, reassembly and test as required. 4'. 3 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of work. I l O I

R vision:- 1 Page 5 of 7

 .                                       ISAP VII.b.2 U                                        (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1 TUGC0 Comanche Peak Project Engineering CPPE 4.3.1.1     Scope Assist the QA/QC Review Team in the identification and provision of all necessary specifications, drawings, procedures and other documentation necessary for the execution of this action plan.
                                          -    Assist in determining the physical location of the valves selected for inspection.
                                          -    Process.NCRs that may be generated due to this action plan.

4.3.1.2 Personnel Mr. C. Moehlman TUCCO Coordinator 4.3.2 Brown & Root Millwright Shop 4.3.2.1 Scope Disassemble and reassemble valves, as , required, for inspection.

                                                                                                        ]

4.3.2.2 Personnel Mr. C. Moehlman TUGC0 Coordinator 4.3.3 CPRT-QA/QC Review Team 4.3.3.I' Personnel All activities not identified in 4.3.1, and

                                    -4.3.2 above will be the responsibility of the.

QA/QC Review Team. 4.3.3.2 Personnel i Mr. M. Obert Issue Coordinator. Mr. C. Spinks- Inspection Supervisor 1 _ _ , . _ - . . _ . _ . . . _ . . _ ...___.l

Revision: 1 Page 6 of 7 t ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'.d) 1 Mr. 'J. Adam Safety Significance Evaluation Supervisor Mr. J. L. Hansel QA/QC Review Team Leader 4.4 Qualifications of Personnel Where inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. CPSES personnel will be qualified in accordance with applicable project requirements. Third-party inspectors will be certified to the requirements of the

           . third-party employer's Quality Assurance Program and specifically trained to the requirements of the CPSES quality procedures.

Other participants will be qualified to the requirements of the CPSES Quality' Assurance Program or to the specific requirements of the Program Plan. 4.5 Sampling Plan The sampling plan will be designed in accordance with the guidelines of Appendix D, and will result in reasonable assurance that programmatic deficiencies do not exist in the population. The minimum sample size according to Appendix D is 60, with a detection number-of zero (i.e., the-critical region is one'or more deficiencies found in the sample). If one (1) deficiency is found, the sample will be expanded to 95, and the root cause of the deficiency will be evaluated. If no further deficiencies are found, and the deficiency from the first sample is determined to be non-programmatic, it will be concluded that the population passes the requirements of Appendix D. If the number of deficiencies discovered is large (i.e., two or more), or a potential root cause is identified as programmatic, a 100% reinspection and record review of the population will be performed. 4.6 Acceptance Criteria A valve will be accepted if the body markings and bonnet markings'found in the field are traceable to the Manufacturer's Data Report (Form NPV-1) in the Receipt /" Inspection Report for that valve. Valves which have Permanent Equipment Transfers documenting replacement of valve

Rsvision: 1-Page- 7 of.7 D) (, ISAP VII.b.2 (Cont'd)- 4.0 CPRT ACTION PLAN (Cont'd) components and for which the new component is traceable to a l form NPV-1 of a valve of identical make, pressure rating, l

             , temperature rating, metallurgical type and code class are                           l acceptable.

4.7 Decision Criteria 4.7.1. The action plan will be closed if the valves which have been disassembled and reassembled can perform their intended safety function. Otherwise necessary , corrective action will be recommended to meet the design requirements. 4.7.2 If a safety-significant deficiency is found the sample will be expanded' and a root cause and generic implication analysis will be done. If deviations are found, trend analysis will be done and for any adverse trend identified a root cause and generic implication analysis will be performed. Any QA/QC Program deficiencies found will be identified to the QA/QC O Programmatic Isnue Supervisor for analysis. { _ . - - - . .

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.b.3 i

Title:

Pipe Support Inspections Revision No. 0 1 Reflects Comments Description Original Issue On Plan . Prepared and Recommended by: dj Review Team Leader v Date LifW /2 q(, Approved by: Senior Review Team kd, , h d, /h_/ Date & f2./ lf5 //Z+lEL

1 1 Rsvision: 1 1 Page 1 of 12 ISAP VII.b.3

                                     . Pipe Support Inspections

1.0 DESCRIPTION

OF ISSUE IDENTIFIED.BY NRC (USNRC letter of January 8, 1985, Pg's. 4 through 17)

                 "The TRT conducted a series of inspections encompassing as-built safety related pipe support... installations. These inspections were of completed systems or components that had been-previously-inspected and accepted by TUEC QC as meeting the rc oective construction and installation requirements."
                -      Pipe Support Inspections "Of the.42 pipe supports inspected, 37 were randomly selected, while 5 originated from an alleger's list. Forty-six deficiencies were identified in the supports inspected."

Tables 1 and 2 summarize the results of this -TRT inspection effort.

               -       Deficiencias With High Rate of Occurrence The TRT identified six specific deficient items which need further evaluation to assess their generic implications. The Os                   TRT concern is that the items may have a high rate of occurrence throughout plant safety related systems. These inspections were in addition to those in Item 1.1 above and are summarized in Table 3.

2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of i the potential safety implications should include, but not be i limited to the areas or activities selected by the TRT."

                       " Address the root cause of each finding and its generic implications..."

Address the collective significance of these deficiencies..."

                       " Propose an action plan... that will ensure that such problems do.not occur in the future."

l I i

Rsvision: 1 Page 2 of 12 ISAP VII.b.3 (Cont'd)

3.0 BACKGROUND

Previous NRC reports have proposed specific corrective action for specific discrepancies. The NRC has in this case requested that TUEC evaluate the TRT findings and consider the implications of these findings on construction quality. The sample reinspected by TRT was not constructed to provide statistically valid conclusions, therefore,.an additional random sample must be inspected independent of TRT sample verification. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to assure the construction quality of pipe supports, by validating the TRT findings and by reinspecting randomly selected samples. The following tasks are required to accomplish the stated objective: NJ - Reinspect the TRT sample to validate the TRT identified discrepancies. Reinspect randomly selected samples of pipe supports-(Note: this reinspection is performed under the ISAP VII.c program). Evaluate valid discrepancies for safety significance and perform trend analysis. Determine the root cause, generic implications and programmatic concerns for any construction deficiencies and adverse. trends. Identify / develop procedures required to accomplish the 2 tasks outlined.above. This action plan covers safety related Class 1, 2, and 3 pipe supports in Units 1, 2 and common areas. O ) d i

                                                                                      )

l R2 vision: 1 Page 3.of 12 ) I ISAP VII.b.3 I (Cont'd) i 1 1 l 4.0 CPRT ACTION PLAN (Cont'd) l Remedial action programs based on QA/QC Review Team recommendations will be developed by TUGC0 to correct any identified safety-significant hardware problems as well as to remedy any programmatic concerns resulting from the root cause analysis. 4.1.1 Verify the TRT Identified Discrepancies 4.1.1.1 Obtain and review the specifications, procedures, drawings, reference codes and standards, checklists and instructions used covering the pipe supports inspected by the TRT to develop reinspection checklists of TRT identified discrepancies. I 4.1.1.2 Prepare reinspection packages including checklists, instructions and all documents and drawings necessary to perform and document the required reinspections.

,                    4.1.1.3    Perform reinspection of identifiable hardware inspected by TRT.

4.1.1.4 Compare the inspection results with the TRT' findings and identify differences or resu,lts that cannot be reconciled. 4.1.2 Inspection of Random Samples (performed in accordance l with ISAP VII.c)

!                    4.1.2.1    Identify the VII.c pipe support populations for Units 1, 2, and common areas which are j                                representative of the TRT samples.

4.1.2.2 Include.the attributes and instructions required to verify the TRT identified discrepancies in the Action Plan VII.c reinspection checklists and quality instructions for each population identified in 4.1.2.1. (Note: The required inspections will be performed under Action Plan VII.c) 4.1.2.3 Review VII.c inspection results for pipe support populations and identify valid discrepancies. . O

Rsvision: 1 Page 4 of 12 ISAP VII,b.3

                                                                                               )

U (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Evaluate Valid Discrepancies 4.1.3.1 Evaluate all valid discrepancies for safety significance in~accordance with the  ; requirements of Appendix E of the CPRT Program Plan., 4.1.3.2 Perform trend analysis for all valid deviations in accordance with the requirements of Appendix E of the CPRT Program Plan. I l 4.1.4 Identify / Develop Procedures This action plan will be conducted in accordance with existing CPSES and CPRT procedures as applicable to specific action plan activities. Inspectors will be-qualified to ERC Procedures and ANSI N45.2.6. Procedures identified as applicable to this action plan ! are as follows: 4.1.4.1 CP-QAP-10.2: Nondestructive Examination Procedures Qualification and Control. 4.1.4.2 QI-QAP-11.1-28: Fabrication, Installation Inspections of ASME Component Supports, Class 1, 2 and 3. 4.1.4.3 QI-QAP-11.1-28A: Installation Inspections of ASME Class 1, 2, and 3 Snubbers. 4.1.4.4 Additional procedures will be developed as required to' support specific activities required by this action plan. 4.2 Participant's Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of work. a l l

Rsvision 1 Page 5 of 12 b ISAP VII.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                                                                                                                 .                     i 4.2.1 TUCCO - Comanche. Peak Project Engineering CPPE 4.2.1.1  Scope Assist the QA/QC Review Team in obtaining the TRT inspection i

checklists and instructions used in the TRT inspection of pipe supports.

                                                     -        Assist in the identification and provision of all necessary l                                                            'specificationts, drawings, procedures and other documentation necessary for the execution of this action plan.
                                                    -         Assist in determining the number of items in each pipe support population.

Assist in establishing a list of all items in each pipe support population.

                                                     -        Process NCRs that may be generated due to this action plan.

! 4.2.1.2 Personnel Mr. D. Snow TUCCO QA/QC Mr. J. Finneran TUGC0 Engineering l 4.2.2 CPRT-Safety Significance Evaluation Group 4.~2.2.1 Scope Participate in the evaluation for i safety significance. Concur in identification of safety-significant attributes and i acceptance criteria. l

4.2.2.2 Personnel

.i y Mr. J. Adam Supervisor - SSEG l i

R; vision: 1 Page 6 of 12 ISAP VII.b.3 (Cont'd)  ;

                                                                                                 -)

4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 CPRT-QA/QC Review Team 4.2.3.1 Scope All activities not identified in 4.2.1 and 4.2.2 above will be the responsibility of the QA/QC Review Team. 4.2.3.2 Personnel Mr. J. Hansel Review Team Leader - ERC Mr. L. F. Fendo Issue Coordinator - ERC l 4.3 Qualifications of Personnel Where tests or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI I N45.2.6 at the appropriate level. Third-party inspectors will

s. be certified to the requirements of the third-party employer's j Quality Assurance Program and specifically trained to the requirements of the quality procedures developed under this action plan.

Other participants will be qualified to the requirements of the CPSES Quality Assurance Program, or to the specific requirements of the CPRT Program Plan, j 4.4 Random Sampling Plan In addition to a reinspection of all identifiable pipe supports inspected by the TRT, random samples of pipe supports will also be reinspected. This reinspection of random samples is performed under ISAP VII.c. 4.5 Acceptance Criteria Acceptance criteria will be based upon a review of the following: 4.5.1 Site Q.C. inspection acceptance criteria for pipe support installations. 4.5.2 A detailed review of specifications, drawings, l referenced codes and standards in order to identify and

   ,G                     verify safety-significant attributes and minimum
                                                                                                  )

i V acceptance criteria necessary to meet design requirements. l

Rsvision: 1 Page 7 of_12 1 4 ISAP VII.b.3 (Cont'd)' 4.0 CPRT ACTION PLAN (Cont'd) Inspection checklists and instructions will be developed based on the results of this review. These acceptance criteria will-4 be made available to other RTLs and to the third-party Safety Significance Evaluation Group for information. i 4.6 Decision Criteria j 4.6.1 The action plan will be closed if all the design requirements are met', otherwise necessary corrective , action will be recommended to meet the design i requirements.

4.6.2 Programmatic and generic implications, if any, will be i identified and additional activities recommended as required. The reinspection results, including I programmatic and generic implications, will be

!                                                 documented in a final report.

1 i i r t l i l ,l i

R:vicion: 1

Page 8 of 12 l

It\--) ISAP VII.b.3 (Cont'd) l Table 1 Pipe Supports in Unit 1 Supports Inspected by TRT As-Built Group *42 Class 1 Supports Inspected 4 Class 2 Supports Inspected 14 Class 3 Supports Inspected 24 Hangers With Problems 26 Total Problems Identified 46 Procedure Adequacy Problems 5 Hardware-Related Problems 16 As-Built Drawing Related Problems 8 Component Identification Problems 2 Weld-Related Problems 10 QC Record Problems 1 Material Identification Problems 4 Welds Inspected Without Paint by TRT 305 Welds Inspected With Paint by TRT 89 Total Welds Inspected by TRT 394 f' Welds Needing Weld Repair 10

                 % of Welds Inspected                                            2.5%

Supports Needing Welding Repair 6

                 % of Supports Inspected                                        14%

i NO. OF SUPPORTS BUILDING SYSTEM INSPECTED Containment Safety Injection (SI) 1 Containment Reactor Coolant (RC) 6 Containment Residual Heat Removal (RHR) 2 l Fuel Handling Component Cooling (CC) 11

Safeguards Residual Heat Removal (RHR) ' 1 Safeguards Containment Spray (CT) 8 Safeguards Demineralized Water (DD) 1 Safeguards Auxiliary Feedwater (AR) 8 j Auxiliary Chemical Volume & Control (CS) 1 i Safeguards Main Steam (MS) 2 Safeguards Chilled Water (CH) 1 i

• All 42 pipe supports inspected by the TRT had been previously accepted by site QC.

l l

        -   ,. -        ---   , .    ~    . - . ,   -   -    --      - -           .          - - . - - - , , , .

R;vicion: 1 - P:g2 9 of 12 ISAP VII.b.3 (Cont'd) Table 2 Pipe Supports in Unit 1* HANGER NO. NO. OF PROBLEMS TYPE PROBLEM CATEGORY

1. No locking device for threaded fasteners RC-1-901-702-CB25 2 Hardware problem CS-1-085-003- A42K

2. Min edge distance (on base plate) violated CC-X-039-006-F43R 1 Hardware problem Base plate hole-location dimensions out of tolerance CC-X-039-007-F43R 4 As-Built problem 3.

CC-1-126-010-F33R CC-1-126-011-F33R CC-1-126-012-F33R

4. Spherical bearing / washer gap excessive CC-1-126-015-F43R 4 Hardware problem RC-1-052-016-C41K RC-1-052-020-C41K MS-1-416---l-S33R

5. Spherical bearing contamination SI-1-090-006-C41K 2 Hardware problem MS-1-416-002-S33R

6. Snubber adapter plate-insufficient-thread engagement MS-1-416-002-S33R 3 Procedure problem SI-1-090-006-C41K CT-1-013-012-S32K

7. Insufficient threaded eng'mt, threaded rod RC-1-901-702-C82S 1 Hardware problem (sight holes)

8. Snubber / Strut load pin locking device broken or AF-1-001-014-S33R 1 Hardware problem missing

9. Load aide of pipe clamp halves not parallel AF-1-001-001-S33R 2 Procedure problem AF-1-001-014-S33R

10. Pipe clearances with support out of tolerance CC-1-126-013-F33R 2 Hardware problem AF-1-001-702-S33R w All 42 pipe supports inspected by TRT had been previously accepted by site QC.

O O O

R; vision: 1 P;g2 10 of 12 ISAP VII.b.3 (Cont'd)

                                         ' Table 2 (Cont'd) Pipe Supports in Unit 1*

HANGER NO. NO. OF PROBLEMS TYPE PROBLEM CATECORY

11. Pipe clamp locknut loose AF-1-035-011-S33R 1 Hardware problem

12. Snubber / Sway strut misalignment CC-1-126-014-F43R 2 Hardware problem RC-1-052-020-C41K

13. Snubber cold set dimension does not match drawing CS-1-085-003-A42K 1 As-Built problem

14. Snubber orientation does not match drawing CT-1-005-004-S22K 2 As-Built problem CT-1-013-010-S22K

15. Component type /model no. installed does not match SI-1-090-006-C41K 2 Compon. ID problem drawing RC-1-052-020-C41K

16. No identification for support materials, parts, and CT-1-013-015-S32R 4 Material identific.

components CC-1-126-012-F33R problem CC-X-039-005-F43R AF-1-035-011-S33R

17. BRP column line dimension does not match BRHL Support not affected 1 As-Built problem dimension

18. Weld porosity excessive- AF-1-001-001-S33R 1 Weld-related problem

19. Weld undercut excessive AF-1-001-702-S33R 1 Weld-related problem

20. Weld length undersized AF-1-001-001-S33R 1 Weld-related problem

21. Weld leg or effective throat undersized AF-1-001-001-S33R 3 Weld-related problem RH-1-006-012-C42R CC-X-039-007-F43R

22. Weld called out on drawing does not exist in field CC-1-126-013-F33R 1 Weld-related problem u All 42 pipe supports inspected by TRT had been previously accepted by site QC.

O O O -

R;vicion: 1 Pcg:a 'll of 12 ISAP VII,b.3 (Cont'd) Table 2 (Cont'd) Pipe Supports in Unit 1* PROBLEM CATEGORY HANGER NO. NO. OF PROBLEMS TYPE

23. Welds added in field are not reflected on drawing AF-1-001-702-S33R 1 Weld-related problem numerous welds

24. Excessive grinding resulting in min. thickness AF-1-037-002-S33R 2 Weld-related problem violations (weld clean-up) CT-1-013-014-S32R

25. No QC Buy-off on weld data card CC-1-126-013-F33R 1 QC record problem 46 Total problems identified by TRT u All 42 pipe supports inspected by TRT had been previously accepted by site QC.

O O O

Revision 1 Page 12 of 12

   'I x/
        )                                                                  ISAP VII.b.3 (Cont'd)

Table 3 Summary of Additional TRT Inspections AREA: Room 77N, El 810'-6" Unit 1 Safeguards Bldg. NO. OF SUPPORTS NO. OF SUPPORTS DEFICIENCY INSPECTED DEFICIENT  % DEFICIENT I Item 1. Excessive Spherical 92 5 5.4% Bearing Clearance i Item 2. Load Pin Locking 92 14 15.2% Device Missing Item 3. Pipe Clamp Halves 40 9 22.5% Not Parallel Item 4. ' Snubber Adapter Plate 19 *13 to be Bolts With Less Than determined Full Thread Engagement t AREA: Cable Spread Room 133, El 807'-0" Unit.1, Auxiliary Bldg. I NO. OF BOLTS NO. OF BOLTS I DEFICIENCY INSPECTED DEFICIENT  % DEFICIENT

,                                     Item 5.** Hilti Kwik Bolt             24                                  3                                12.5%

Does Not Meet Minimum Embedment*** l Area: Unit 1 Item 6. Locking Devices for Threaded Fasteners

• Bolts had less than full thread engagement.

'                                     **   Found by the TRT during inspections of electrical support baseplates.

, *** Taking into account the " allowed" slippage of the bolt for a distance of { one nut thickness due to torquing (Ref. " Installation of Hilti Drilled-In (-~ , Bolts" 35-1195-CEI-20, Revision 3. Paragraph. 3.1.4.1) and the minimum i ( , specified embedment, the above Hilti bolts violated the " effective" embedment requirements. l

          , _ _ . . . _ _ _ _ _ . - -       ,                 - ,   ,   .         _     , _ , . . ,                 _ _ . . _ _ . , n._,.

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.b.4

Title:

Hilti Anchor Bolt Installation i 4 Revision No. 0 1 i Reflects Coments Description Original Issue On Plan

                                                                                    ~

O Prepared and (

Recommended by:

Review Team Leader l , Date ZA S[ I A9 l$$

                                                                        /       I I

i t n r av w Team d./k Oar D, _I. / Date & f1/ )f( lf3 4fff, O i

R vicion: 1 i Pcgs 1 of 6

   ~'h                                   ISAP VII.b.4

[O Hilti Anchor Bolt Installation

1.0 DESCRIPTION

OF ISSUE IDEFIIFIED BY NRC (USNRC istter, dated January 8, 1985, Pg'.s. 15 and 20) The TRT inspected Hilti anchor bolt installation on pipe supports

and electrical raceway supports to the requirements of QI-QP-11.2-1, Installation of Hilti Drilled-In Bolts.

The TRT found the following deficiencies during its inspection: 1.1 Cable Spread Room 133 Inspections

                  -       "Hilti Kwik bolts (concrete expansion anchors) as installed did not meet minimum effective' embedmont criteria (Ref. QI-QP-11.2-1, Sec. 3.5.1, Rev. 16."

j Three of the twenty-four bolts inspected did not meet the minimum embedment requirements. l 1.2 Electrical Raceway Support Inspections i 1 -

                          "CTH-6742 (Auxiliary Building)~ anchor bolt torque was not verified (paragraph 3.5 of the procedure). Hilti i

O bolts were not marked in accordance with Attachment 1 of the procedure, nor was the length of these bolts verifiable (paragraph 3.2)." 4 l l "CTH-5824 (Containment Building) base plate bolt holes i had violated minimum edge distance--edge distance , cannot be less than -1 7/8" (Attachment 2 of the procedure). Actual distance was 1 5/8" to 1 3/8" from the nearest plate edge. This condition affected five of the eight Hilti anchor bolt holes in the base plates for this hanger."

                          "One Hilti bolt was skewed to more than 15 degrees.

Maximum allowable skew was 6 degrees without corrective bevel washers (paragraph 3.1.2)."

                  -       "The Hilti bolt torque on this hanger CTH 6741 (Auxiliary Building) was not documented as being i

verified by QC (paragraph 3.5)." 2.0 ACTION IDENTIFIED BY NRC 2.1 Evaluate the TRT findings and consider the implications of

;                  these findings on construction quality. "... examination of
!                 the potential safety implications should include, but not be                i 1                  limited to the areas or activities selected by the TRT."

l 2.2 " Address the root cause of each finding and its generic implications..."

R;vioien: 1 Page 2 of 6 A ISAP VII.b.4 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd) l l i 2.3 " Address the collective eignificance of these deficiencies..." 2.4 " Propose an action plan... that will ensure that such problems do at occur in the future."

3.0 BACKGROUND

The inspections performed under Action Plan VII.c includes: a) sample reinspection-of Hilti bolt installations as a reinspection attribute and b) Jocumentation reviews to conclude that appropriate surveillance attributes had been properly noted. This action plan for Hilti belt installations wf.11 utilize the results of the above inspectiore as well as additions 1 inspections to resolve the Hilti bolt con.: erns. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 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. The following tasks will be implemented to achieve these objectives: Review for safety-significant attributes. Insure inclusion of safety-significant attributes in Action Plan VII.c. Review for commonality in requirements amon5 various , project (discipline) documents. Evaluate sample size. I Initiate a Hilti torque verification program that correlates the documentation being reviewed for setting of Hilti's with actual field results. Report programmatic implications with specific action i plan tasks to react to these implications.

R;vicicnt 1 P:g2 3 cf 6 l

     /"'                                     ISAP VII.b.4

( ,j} (Cont'd) l i 4.0 CPRT ACTION PLAN.(Cont'd) 4.1.1 Re' view specification and/or procedure requirements for Hilti bolts and identify safety-significant attributes. Safety-significant attributes are in accordance with Action Plan VII.c. 4.1.2 Review the inspection plans for the Action Plan VII.c, to assure they cover all necessary safety-significant attributes required for Hilti bolt installation. If additional attributes are required, supplement checklist and instructions for the reinspection to cover the. additional attributes. 4.1.3 The specification, procedures, QC inspections, and training procedures and records for Craft installing Hilti bolts for various items i.e. electrical raceway supports, pipe-supports, HVAC supports, conduit supports, equipment supports etc. on Units 1, 2 and common will be reviewed to determine whether they are the same. If so, then the results of inspection of these itees will be considered applicable to all Hilti p\_,/g bolt installations. 'If not, samples from other populations of Hilti bolts in Units 1, 2 and common will be inspected. 4.1.4 The results of inspections for Hilti bolt attributes from Action Plan VII.c. " Construction Reinspection / l Documentation Review Plan" will be used for those t populations that contain Hilti bolts as part of their inspection scope. 4.1.5 Evaluate the samples chosen from Action Plan VII.c to g

 ,                             assure that the sample size is adequate. Additional items may be added to the sample as per Sampling Plan i                            Section 4.5 to increase the sample to an acceptable 1                             size.

4.1.6 Reinspections shall be performed in accordance with Action Plan VII.c. l

)

4.1.7 To provide additional assurance in the results from the document review for the non-recreatable attribute of

                               " setting" of Hilti bolts, the physical condition of these bolts will be checked by a torque verification progran. This program will consist of torque checking a number of Hilti bolts from Electrical Raceway Supports, pipe supports, and HVAC duct supports. This O                          check will be accomplished by reinspecting for nut I

l

R vision: 1 Pcg3 4 of 6 ISAP VII.b.4 ( (Cont'd) 4.0 CPRT ACTION Pl.AN (Cont'd) rotation resistance to a-percentage of the original torque setting value. This percentage will be defined

                         ~ by engineerinig evaluation. Based on engineering evaluation of this program, further pull-tests of questionable samples will be considered. Pull-tests, if required, will be based on detkraining the Hilti bolts resistance to the service load required of the bolt.

One quarter inch diameter Hilti bolts will not be included in the above correlation, on the basis of their lower loading requirements. 1

4. f ; 8 Programmatic implications will be reported to the N osg.er - QA/QC - Programmatic Issues, and those with 4 K N t W. impact on other actios: plans will be provided N Q.' 4fr.ected Issue Plan Coordinator for any ettusar; accion.

4.2 Procedures to A gised 4.2.1 This actfor A an will be conducted in accordance with procedures deve. loped for Action Plan VII.c, CPSES procedure QI-QP-11.2-1 Installation of Hilti Drilled-In Bolts, and a procedure developed for the torque verification program identified in 4.1.6. 4.3 Partiepants Roles and Responsibilities

             'he orgati: cations and personnel that will participate in this a U ort atw b scribed below with their respective scopes of wL 4.3.1        TuGC0 Comanche Peak Project Engineering CPPE 4.3.1.1    Astist in determining the number of items with Hilti bolts to be covered in the pipe support and electrical raceway support action plans.

4.3.1.2 Process NCRs that may be generated due to this action plan. 4.3.1.3 Personnel i Mr. C. R. Hooton TUCCO Coordinator .l O l l

R vicient 1 I l Pcg2 5 of 6 j 1 1

p. ISAP VII.b.4 (Cont'd)

Q 1 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 CPRT-Safety Significant Evaluation Group 4.3.2.1 Assist in determining safety 91gnificance of l identified deficiencies. 4.3.2.2 Personnel Mr. J. Adam Supervisor, SSEG l 4.3.3 CPRT-QA/QC Review Team 4.3.3.1 All activities not identified in 4.3.1 and 4.3.2 above will be responsibility of the QA/QC Review Team. l 4.3.3.2 Personnel Mr. J. Hansel QA/QC Review Team Leader l Mr. S. H. Popper Issue Coordinator l 4.4 Qualifications of Personnel Where tests or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third-party inspectors will

!              _ be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the CPSES quality procedures and other procedures generated to implement this action plan.

4.5 Sampling Plan The sampling plan shall be performed in accordance with Action Plan VII.c. 4.6 Acceptance Criteria Acceptance criteria will be based upon a review of the following: 4.6.1 Site Q.C. inspection acceptance criteria for Hilti bolt installatirns will be used for verification based on i , specification and code review.

'O I

             .                         .       =                                                . _                   .-.                   _   _

R vicion: 1 Pcg2 6 of 6 i ISAP VII.b.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6.2 A detailed review of specifications, drawings, referenced codes and standards in order to identify and verify safety-significant attributes and minimum acceptance criteria (constructicn adequacy) necessary to meet design requirements. These acceptance criteria vill be made available to other RTLs and to the third-party Safety Significance Evaluation Group for information. 4.7 Decision Criteria 4.7.1 This action plan will be closed when successful completion of the steps identified by Sections 4.1.4

 ;                                            through 4.1.7 can be demonstrated. If not, appropriate corrective action will be recoemended to TUGCO.

4.7.2 Programmatic and generic implications, if any, will be j identified and additional activities recommended as required. 1 I I i . t' i l l O .i l _.. . , _ _ . . _ - _ _..._m . _. .- __

p COMANCHE PEAK RESPONSE TEAM v ACTION PLAN ISAP VII.c

Title:

Construction Reinspection / Documentation Review Plan 1 i Revision No. 0 1 Reflects Comments Description Original Issue On Plan O i Ree nd by: 6lzjlljp

                                                                                          /    lhfg
                                                                                          /

l i Approved by: Senior Review Team d.{k Os d kj Date b fbl f V( /f2-+f14 O l

R vicient 1 l Pcgs 1 of 14 i ISAP VII.c Construction Reinspection / Documentation Review Plan

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC This action plan does not result from e specific issue raised by l the NRC. Therefore this section is not applicable.  ; 1 2.0 ACTION IDENTIFIED BY NRC Not Applicable

3.0 BACKGROUND

i

This ISAP is self-initiated and includes a reinspection /

documentation review of QC accepted safety-related construction work activities performed at CPSES. This inspection effort provides i data useful for the evaluations performed.under other action plans and extends into those areas that have been specifically identified i by external sources. j The primary reason that this self-initiated action plan has been developed is that it represents the most direct, reliable, and 3 achievable method of providing additional confidence that currently unidentified concerns related to the quality of construction of the hardware at CPSES will be identified, evaluated, and resolved. It

         ,                         also provides additional confidence that any adverse. impacts on the installed hardware that may have occurred as a result of potentially inadequate qualifications of historical QC inspectors will be identified and addressed.

I j This plan consists of a sample reinspection of QC accepted i safety-related construction work supplemented by a review of

!                                  related quality documentation for non-recreatable ard/or 1                                   inaccessible inspections. It includes areas of Unit a 1, 2, and those common areas that are not specifically coverec by existing CPRT ISAPs.

4.0 CPRT ACTION PI.AN 4.1 Objective The objectives of this action plan are as follows:

                                        -       To investigate on a proactive basis additional areas to which the CPRT may ultimately be led in the course of-its root cause/ generic implications assessments for External Source issues

(

      .- --. _.- - ._--,..                                         _     -          ~ _ , . . - -. , - - , - -

Revisient 1 Pcg2 2 of 14 i ! ISAP VII.c (Cont ',d) 4.0 CPRT ACTION PLAN (Cont'd)

                                                      -       To ensure that the investigative efforts of the CPRT program are of sufficient depth and breadth to permit the conclusions reached for the External Source issues to be extended to the remaining safety-significant areas of construction
                                                      -       To provide data useful to resolve the issue of potentially inadequate historical inspector qualifications
                                                      -       To provide. data useful to address the assertion of existence of a pervasive pattern of intimidation and harassment of inspectors that may have resulted in hardware deficiencies.

In order to accomplish these objectives, the following tasks are required: Establish populations Select samples Develop checklists and inspection procedures Prepare verification packages Perform reinspections and documentation reviews Identify deviations.and review for safety significance and adverse trends Evaluate sample results 4.2 Scope The scope of this action plan includes all safety-related , construction work which has been inspected and accepted by CPSES QC. (With the exception of cable tray hangers which are being addressed in the Corrective Action Program described in DSAP VIII.)  ! l 4.3 Methodology The following sections describe key activities of the plan: O l f rn-, - -- - g , , , , , ,, - , , - , - -

                                                                       . - , . - . - - . - - - . -        -    , _ . , . , , ,-         .-w-, ,        - - , - - - ,   .--,,--,n-----

R vision: 1 Pcg2 3 of 14 O ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1 Establish Populations Installed safety-related hardware is categorized into 4 populations within reasonably homogenous work activities (HWA) and associated quality characteristics (attributes) from which random samples can be drawn for evaluation. This process is performed in accordance with Appendix B of the CPRT Program Plan, and as detailed in the QA/QC Review Team procedures and i instructions. Illustrative examples of populations are l provided in Attachment A. The final list of

populations will be established after each population has been identified, its components, boundaries, and

 !                                 specific interfaces described and the attendant' work activities evaluated to ensure reasonable homogeneity' within each work activity. (See Appendix B. Section II.A.2)
.                                  A description will be prepared for each population. A supporting document for each population will be O                     prepared which documents the reasonable homogeneity of each associated work activity.

For each population, a list of all safety-related items that have been completed and accepted by Quality i Control Inspectors will be prepared. These lists of population items and a description of how the list of items within each population was established will be retained on file.

To'the extent that the reinspections made under other action plans satisfy the objectives of this plan and  ! the population criteria, these reinspections may be 1 used herein. Such decisions will be documented and retained as a record in the ISAP file. 4.3.2 Selection of Samples 4.3.2.1 General Approach i For each population two samples will be randomly selected. The first sample will .) provide information about the total i population. The second sample will provide l additional information about a portion of the total population that.is required to safely O shutdown the plant. All samples will be selected in accordance with Appendix D.of the CPRT Program Plan.

R:visien: 1 Pcg2 4 of 14 O ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) If the safety-significant attributes on a particular item are reinspectable, the sample will be reinspected and no. documentation reviews need be conducted. Items selected during this process which are inaccessible will be discarded and a new sample randomly selected until the desired sample size of reinspectable items is achieved. In some.HWAs, some of the safety-significant attributes may be inaccessible or not recreatable. " Inaccessible" is defined to mean a condition where extensive dismantling would be required to gain access for direct reinspection, such as in the case of piping, reinforcing steel or conduit that is embedded in concrete. "Not recreatable" is defined to mean a condition where a process or event cannot be recreated, such as pull force durir.g cable pulling interpass weld O temperature or receiving inspection. In these cases, records relating to these attributes for the items randomly selected will be reviewed for adequacy while the remaining attributes will be reinspected. There will also be a limited number of-hardware categories in which all of the safety-significant attributes are either inaccessible or not recreatable. In these cases, records review will be used to evaluate randomly selected items. . The bases for decisions on inaccessibility will be documented for'each population and records maintained which identify the hardware items and attributes determined to j be inaccessible. 4.3.2.2 First Random Sample A sample of items randomly distributed throughout each population will be selected in accordance with Appendix D to the CPRT l Program Plan. I Items will be checked for accessibility and, l 3 if inaccessible, replaced with.other randomly selected items. If selected items are later i discovered to have inaccessible attributes, l

1 Revicion: 1 Pcg2 5 of 14 ISAP VII.c Os (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l 1 or attribute coverage is incomplete, additional items will be randomly selected and reinspected for the' applicable attributes. If no portion of the population ) is accessible, a documentation review will be performed on items wbf ch have been randomly selected as specified above. 4.3.2.3 Second Random Sample The second randos sample is made up of items selected from the safe shutdown systems within the.HWA, or, for populations such as j concrete which do not-directly contain items in the safe shutdown systems, is made up of items which support those systems or are in locations where failures could adversely impact these systems. This identification is conducted by the [ 'T Construction Reinspection / Documentation (m I Review Engineering. Group n accordance with a QA/QC-Review Team instruction. Members of the first random sample which fall within the safe shutdown systems shall be included in the second random sample. In order to attain a minimum sample size of sixty (60) for populations of one-hundred one ' (101) or more, additional samples will be selected randomly from the entire population, and then reviewed to identify those falling within the safe shutdown category. These samples will b'e checked'for accessibility and, if inaccessible, replaced l with other randomly selected samples falling within the critical categories. If items are later discovered to have inaccessible attributes, or attribute coverage is incomplete, additional items randomly

                                    . selected which fall within the safe shutdown category be reinspected for the applicable attributes. If no portion of the population is accessible, a complete documentation review.will be performed on randomly selected samples falling within the safe shutdown

(} category.

R:vicion: 1  ; Page 6 of 14 O ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.3 Develop Checklists and Inspection Procedures For each population, attributes which have safety significance will be determined. A safety-significant attribute is a characteristic of a component or construction activity which, if not in accordance with applicable design documents, codes and standards, could impair the ability of the component to perform its safety-related funccion under design loading conditions. This determination will be made.by the QA/QC Review Team, and distributed to'the other'RTLs and the third-party Sefety Significance Evaluation Group for their information. Relevant design information will be reviewed to determine attributes that have safety significance. Design'information will include the latest specifications, design drawings, codes, and standards. From these design requirements, attributes will be 4 selected which are required by applicable. codes and-  ?

         .                standards, and have a potential impact on the item's ability to perform its safety-related function.

i Justification for not including attributes in the reinspection or documentation review checklists which have been identified as non safety-significant will be documented and retained as records in the ISAP file. For each safety-significant attribute identified, detailed instructions for the verification of the attribute, including definitive accept / reject criteria, . I will be established. This information will be incorporated into a detailed inspection procedure for that population. The inspection procedure will provide detailed instructions to the inspectors and/or documentation reviewers for performing the reinspections and/or documentation reviews. For each inspection procedure, a corresponding inspection I checklist will be created. Inspectors are required to document the results of inspection of each attribute on l the inspection checklist. 4.3.4 . Prepare Verification Packages Verification packages will be assembled for each sample. )' item to facilitate the performance and documentation of l (- field reinspections and documentation reviews. Separate verification packages.will be generated for ! each field reinspection and documentation review performed. l l

i Rsvision: 1 Pcg2 7 of 14 ISAP VII.c C's) s (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) The field reinspection verification package will contain as a minimum the applicable population checklist, and current design documents pertaining to the item including Design Change Authorizations (DCAs) or Component Modification Cards (CMCs). The documentation review verification packages will contain the applicable population checklist and an index of all the documentation to be reviewed. Each verification package will contain an inder listing the contents of the package and the location of applicable documents not included in the package. 4.3.5 Perform Reinspections and Documentation Reviews Certified third-party inspection personnel will use the verification packages to perform reinspections and documentation reviews, and to dccument the results. Inspectors and documentation reviewers will be certified to a minimum of Level II in accordance with O- Regulatory Guide 1.58 (Revision 1) , and ANSI N45.2.6(1978). The inspector will inspec't the condition of the equipment for each attribute on the checklist. Documentation reviewers will assure that the required documentation exists, and that it is' complete and accurate. If equipment differs from checklist requirements or if the associated documentation does not exist or is improperly completed, a Deviation Report (DR) vill be initiated and processed in accordance with a written instruction. The DR will.be filled out by the inspector. It will identify the item reinspected or the documents reviewed, the condition which differs from requirements, and describe the condition in sufficient detail (sketches or other pertinent information may be attached) to provide subsequent reviewers with a clear l understanding of the condition. l 4.3.6 Deviation Reports 4.3.6.1 Each DR will be reviewed by the appropriate Level III inspector and the Construction f'/)

 's-Sample Reinspection Group to establish its validity.

Rivicion: 1 Pags 8 of.14 ISAP VII.c O (Cott'd) 4.0 CPRT ACTION PLAN (Cont'd) l A DR may be deemed to be invalid by any of I four methods:

                                       -     The DR may describe a condition which, in fact .is acceptable'in accordance with the approved. design or other appropriate data. Each DR will be reviewed to ensure that all notes, specification' details, approved DCAs, or CMCs were appropriately applied.
                                       -     Reviews will be performed to ensure that the DR was not previously documented on a controlled deficiency document, such as an existing NCR. In these cases an-engineering review of the actual condition will be conducted to assure that the condition is acceptable.

Determine whether the DR is valid in light of the requirements.which applied at the time of the original inspection. There may exist instances where items were constructed in accordance with the design applicable at the time of construction, but where subsequent design changes have caused the existing construction to deviate from the current design. A DR, which is a result of such a design change, may be acceptable if documentation exists exempting the specific hardware item from current design requirements. Perform a review to determine if the l DR documents a reinspection which is 1 highly subjective in nature, such as visual weld inspection. The reviewer may then request a Level III Inspector to determine the acceptability of the item.

Rsvision 1 Pag 2 8 of 14 ISAP VII.c O, (Cont'd) l l 4.0 CPRT ACTION PLAN (Cont'd) A DR may be deemed to be invalid by any of four methods:

                                -     The DR may describe a condition which, in fact, is acceptable in accordance with the approved design or other appropriate data. Each DR will be reviewed to ensure that all notes, specification details, approved DCAs, or CMCs were appropriately applied.
                                -     Reviews will be' performed to ensure that the DR was not previously documented on a controlled deficiency document, such as an existing NCR. In these cases an engineering review of the actual condition will be conducted to assure that the condition is acceptable.

Determine whether the DR is valid in

                                     . light of the requirements which applied at the time of the original inspection. There may exist instances where. items were constructed in accordance with the design applicable at the time of construction, but where subsequent design changes have caused the existing construction to deviate from.the current design. A DR, which is a result of such a design change, may be acceptable if documentation exists exemp*ing the specific hardware item from current design requirements.

Perform a review to determine if the DR documents a reinspection which is highly subjective in nature, such as visual weld inspection. The reviewer may then request a Level III Inspector to determine the acceptability of the item. O

1 l l RLvioicut 1-Pcra 9 of 14

                                     -ISAP VII.c                                                       1 (Cont'd)                                                       {

l 4.0 CPRT ACTION PLAN (Cont'd) If any of the above reviews determine the DR to be invalid, then the detailed reason.for this' determination will be documented on the DR and' retained as a record in the Action  ! Plan Files. 4.3.6.2 If a DR is deemed to be valid, it will be given to TUGC0 and processed as a NCR in accordance with site procedures. The DR and i NCR will be cross referenced for record purposes. Each valid DR will be forwarded to the Safety Significance Evaluation Group for processing of the identified deviations. 4.3.6.3 Valid DRs will normally be evaluated by the third-party Safety Significance Evaluation Group. In certain cases, responsibility for evaluations of deviations for safety. l significance may be assigned. to other CPRT

Review Teams, particularly where deviations-are in areas which are also under evaluation-by the other Review Team.

4.3.6.4 Evaluations of valid DRs for safety significance will be conducted.in accordance with the overall guidance contained in Appendix E of the CPRT Program Plan and in accordance with instructions which augment the requirements of this ISAP. The results of the evaluations fc safety significance, including references to engineering data or other information used to make the determination will be documented. 4.3.7. Evaluation of Deviations Determined to be Safety Significant-All valid DRs will be assessed to determine,'on a . case-by-case basis, if they are safety-significant. For those deviations determined to be safety-significant, a detailed review will be conducted to

       ,              determine the root cause and generic implications. This analysis will be documented.                                 l

4. 3. 8 ~ Evaluation of Deviations for Adverse Trends The totality of information collected on each population will also be reviewed to determine if there are any adverse trends with potential safety

l Revision: 1 Pcg2 10 of 14 O ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) significance that may warrant additional inspections in the specific population, or if there are generic , implications that may require additional evaluation in other populations. A statement of the results of this analysis will be prepared for each population. 4.3.9 Evaluation of Sample Results The acceptability of each HWA is established based on l the results of the reinspections a'nd documentation reviews conducted on the two samples from the population. If the items from the samples contain no safety-significant deficiencies, and there are no adverse trends, no further reinspections or documentation reviews will be required. If a sample is found to contain one or more safety-significant deficiencies, or there is evidence of an adverse trend, the sample will be expanded and additional reinspections/ documentation reviews tO conducted in accordance with Appendix D to the Program V Jlan. The methodology for sample expansion shall be established in an implementing procedure which supports this action plan. Safety-significant deficiencies will be analyzed for root cause and generic implications in conjunction with the 3xpanded reinspections/ documentation reviews as specified above. 4.4 Procedures l Detailed instructions will be prepared for implementation of each major step of this plan. 4.5 Participant's Roles and Responsibilities 4.5.1 CPRT - QA/QC Review Team 4.5.1.1 Scope Provide overall direction of this activity and provide third-party engineering and inspection personnel as required. O

R;vicicn 1 Pago 11 of 14 ISAP VII.c .O (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5.1.2 Personnel Mr. J. L. Hansel - QA/QC Review Team Leader Mr. A. A. Patterson - Issue Coordinator 4.5.2 CPRT - Other Review Team Leaders 4.5.2.1 Review valid deviations referred to them by. the third-party Safety Significance Evaluation Group to determine the safety significance of each deviation. 4.5.2.2 All CPRT Review Team Leaders 4.5.3 TUGC0 4.5.3.1 Scope Assist in population definition and description. Assist the QA/QC Review Team in the identificatfea of all necessary specifications, drawings, procedures and other documentation necessary for execution of this action plan. Provide copies as required.'

                                          -     Assist in determining the number of items in each population.

Assist in reviews to determine accessibility of hardware. Provide scaffolding, lighting, etc. as required to support inspection:. Process NCRs that may be generated due to this action plan. 4.5.3.2 Personnel General Liaison - Mr. R. Camp Electrical - Mr. I. Vogelsang (/) s, Mechanical - Mr. C. Moehlman

J Revisien: 1 Pcgs 12 of 14 O ISAP VII.c (Cont'd) 4.0 CPRT ACTIO4 PLAN (cont'd) Civil'/ Structural - Mr. R. Hootos l Piping / Supports - Mr. J. Finneran QA - Mr. D. Snow 4.5.4 Safety Significance Evaluation Group 4.5.4.1 Scope Coordinate and conduct evaluations of valid DRs for safety significance. Also responsible for determining whether evaluations will be conducted by themselves or CPRT Review Team Leaders. 4.5.4.2 Personnel i Stone and Webster and ERC will provida personnel to staff the third-party Safety Significance Evaluation Group. 4.6 Qualifications of Personnel All personnel associated with analysis and evaluation of findings will be qualified in accordance with the requirements of the CPRT Program Plan. Where inspections require the use of certified third-party inspection, their qualifications will be evaluated to the requirements on ' ANSI N45.2.6 (1978) and Regulatory Guide 1.58 (Revision 2). 4.7 Sampling Plan . See Section 4.3.2. l 4.8 Standards / Acceptance Criteria Acceptance criteria for the reinspections will be based _npon a detailed review of specifications, drawings, referenced codes and standards in order to identify and verify safety-

significant attributes. *hese acceptance criteria will be contained in the inspection procedures which will be issued prior to the start of inspection for each population.

, O e _ _. , , . , , . _ . , , , , , , , , , . _ .-. ,4

R:vicion: 1 Pcg2 13 of 14 l i 1 ISAP VII.c O (Cont'd) 4.0 CPRT ACTION PLAN (cont'd)- 4.9 Decision Criteria 4.9.1 Sample Evaluation and Expansion D> cision criteria regarding sample evaluation and expansion are described in paragraph 4.3.9. 4.9.2 Adequacy of QC. Inspection It should be noted that there is no attempt to directly identify cases of harassment and intimidation through implementation.of this ISAP. However, a determination of whether there is evidence of a generic QC inspection problem which might relate to the issues of inadequate inspector qualification or harassment will be made during the preparation of the Action Plan Results Report. This determination will be utilized as input to the collective evaluation process (described in Appendix B of the CPRT Program Plan) which will further address the adequacy of QC inspection.

  )                   4.9.3 Criteria for Action Plan Closure This action plan will be closed when the required reinspections and documentation reviews have been performed, results analyzed, and report issued.

O

Rivisien: 1 Page 14 of 14 O) ISAP VII.c (Cont'd) J i ATTACHMENT A MASTER POPULATION LIST ELECTRICAL (E). Conduit (CDUT) ' Cable (CABL) Cable Tray (CATY) Electrical Equipment (EEIN) Instrumentation Equipment (ININ) Lighting (LITG) NIS Cable Terminations (NIST) MECHANICAL (M) HVAC Ducts and Plenums (DUPL) HVAC Equipment Installation (EVIN) Field Fabricated Tanks (FFTA) Mechanical Equipment Installation (MEIN) Large Bore Piping Configuration (LBCO) Small Bore Piping Configuration (SBCO) g - Pipe - Welds and Material (PIWM) i - Piping System Bolted Joints / Material- (PBOM) Tubing Welds / Material (TUWM) STRUCTURAL (S) Concrete Placement (CONC) Structural Steel (STEL) Liners (LINR) Fuel Pool Liner (FPLR). Fill and Backfill Placement (Fill) - Document Review Only Cement Grout (GRTC) Epoxy Grout (GRTE) Large Bore Pipe Supports - Rigid (LBSR) Large Bore Pipe Supports - Non Rigid (LFR) '

          .Small Bore Pipe Supports (SBPS)

Large Bore Pipe Whip Restraints (PWRE) Instrument Pipe / Tube Supports (INSP) CAT 1 Conduit Supports (COSP) HVAC Duct Supports (HVDS) Equipment Supports (EQSP) l 1 O l i l x.____..._

                                   . _.. -                              _ . . - -                      . - _ _ . -                            . _ . -          .                 . . _ . . .              -. __ ~-. . .-.

1 i-i + i , DSAPs i VIII Civil / Structural Discipline Specific Action

• Plan IX Piping and Supports Discipline Specific Action Plan X Mechanical Systems and Components Discipline i

Specific Action Plan ! XI Electrical /I&C Systems and Components Discipline Specific Action Plan i 3 1 5 1 a i l 4 l I r i i i  !

j. .

I l~ I l  : i

      . _ _ _ .           , _ _ .          . . _ _ _ _ _ _ ~ _ . - . . _ _ _ . _ , _ . , _ _ . , _ - _ _ . . _ . _ . _ . . _ _ . _ , . . . . - . . . - . . - _ . _ . _ , - - , , . _ _ _ _ - , . . . ._                   ,.._

COMANCHE PEAK RESPONSE TEAM ACTION PLAN DSAP VIII

Title:

Civil / Structural Discipline Specific Action Plan Revision No. 0 1 Description Reflects Coments Original Issue On Plan O Prepared and Recomended by:  ; Review Team , Leader [ M c' .-wd Date & Z4fS( u of*LfVG Approved by: Senior Review l Team , _ 2/ .M,d, ( 4  ! Date l2,(,fff /f2.+/ Tc4, 1 O i e

R vision: 1 Page 1 of 62 DSAP VIII Civil / Structural Discipline Specific Action Plan 1.0 ' PURPOSE The purpose of the Civil / Structural Discipline Specific Action Plan (DSAP) is two fold: 1) to take the appropriate steps to investigate, evaluate and resolve issues identified by External Sources and 2) to expand the scope of review through self-initiated actions to provide reasonable assurance that all safety-significant' design deficiencies have been identified and resolved. The - fundamental acceptance criterion for all areas of review is compliance with CPSES licensing commitments including applicable codes and standards. This effort will permit a complete evaluation of the quality of civil / structural design end products. 2.0 SCOPE The scope of the civil / structural DSAP encompasses three categories of review as follows: Verification of cable tray and conduit support designs in response to a number of external source identified issues. Review of specific design areas directly related to issues identified by the NRC Technical Review Team'(TRT). Self-initiated review of the remaining civil / structural design areas that are not covered by the above-items to provide reasonable assurance of overall design adequacy. The scope of the civil /s'tructural DSAP for each of these categories is presented in the following subsections. 2.1 Cable Tray and Canduit Supports The scope of the cable tray supports review includes a 100%

verification of all cable tray support designs for both Units 1 and 2.

The scope of the conduit supports review currently includes assessment of Unic 1 and. common conduit supports on.a sampling. basis. Unit 2 conduit supports are being designed on a fully-engineered basis.

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Ravision: 1 Page 2 of 62 ( ). DSAP VIII (Cont'd) 2.0 SCOPE (Cont'd) 2.2 TRT-Related Issues There are a number of civil / structural design issues identified by the NRC-TRT that are being addressed by previously established Issue-Specific Action Plans (ISAPs). These ISAPs will fully address the specific'IRT issues raised and document their resolution. Design-related technical and programmatic conclusions from these' evaluations will be included within the civil / structural discipline root cause and generic implications evaluations. For one issue, Item V.b, "Shor*'ning of Anchor ~ Bolts in Steam Generator Upper Lateral Suppor , implementation of ISAP V,b has identified additional design concerns. Responsibility for investigation of these concerns has been transferred to the scope of the Civil / Structural DSAP and will include a review of the design of both the upper and lower steam generator lateral restraint beams, embedments, connections and the

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concrete walls.

  /~       2.3 Self-Initiated Review The scope of the self-initiated review is intended to encompass all safety-related civil / structural discipline design processes that are not covered by the cable tray support, conduit support or TRT-related reviews noted above.

This scope will include the following review areas: Load Determination Concrete Design f _ Structural Steel Design Foundation Design Supports / Anchorage Design Other Structures Design

                          - Heavy Load Drop Development of Specifications Testing Special Studies b                                                                    ..

r i l Rsvision: 1 l Page 3 of 62 , DSAP VII'I (Cont'd) 2.0 SCOPE (Cont'd) These review' areas are summarized in Attachment 1 through the

identification of associated homogeneous design activities

! .(HDA) from which designs will be selected, thus establishing the breadth of the review to be perf.ormed. The HDA-

methodology is discussed in Attachment 5 of Appendix A to the l CPRT Program-Plan.

I more specific description of the scope for' each of these. .

review areas is presented in Section 4.0 of this action plan.

Section'5.0 details the organizational responsibilities for i performing this scope.

3.0 BACKGROUND

i A discussion of. background information pertinent to each-of the three major elements of the Civil /3tructural DSAP is provided in the following subsections. I 3.1 Cable Tray and Conduit Supports i A number of potential design concerns related to. cable tray and conduit. support design have been identified through the ' , conduct of external design reviews. The most significant review was the Independent Assessment Program (IAP): conducted by Cygna. A few additional issues have been-identified based

                           .on NRC review and ASLB hearings. A summary of the most                                                     +
                           . pertinent issues and their applicability to~ cable tray or

conduit supports is presented in Table VIII.1. Tables VIII.2 and VIII.3 provide a short description of cable tray and conduit support issues identified by.Cygna and documented in their November 26, 1985 letter.

i Based on the number'of individual issues raised and concerns

)                             regarding their cumulative effects, TUGC0 has decided to-                                                '

i perform additional reviews of the cable tray and conduit

j. support design areas.

1 For Unit 1 and common cable tray supports TUGC0 has retained ! two outside~ contractors (Ebasco and Impell) to perform a 100%

verification of the designs.

i- . . For Unit 2 cable tray supports, TUCCO has retained Ebasco to. perform a similar review. 4 ] For Unit I and ccomon conduit' supports, TUGCJ Nuclear Engineering -(TNE) will sample the design of the existing J supports to evaluate. design adequacy. The results of this evaluation may establish the need for additional evaluation to-

                           -ensure coverage of the entire population or to address issues i                              pertinent to specific hardware.

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Rsvision: 1 Page 4 of 62 ( ) DSAP VIII t (Cont'd)

3.0 BACKGROUND

(Cont'd) + For Unit' 2 conduit supports, TUGC0 has retained Ebasco to fully engineer all support' designs in accordance with procedures established to address all external source issues. These planned design verification activities performed by TNE and' outside contractors will be subjected to third-party overview for additional assurance of resolution of external source issues and compliance to CPSES licensing commitments. 3.2 TRT-Related Issues The NRC-TRT findings primarily focus on construction-related concerns. Investigation of these findings through the implementation of CPRT ISAPs has, however, raised some potential civil / structural design-related concern:. In most instances, these design-related concerns have been addressed-

as part of the scope of the applicable ISAP.

In the case of TRT Issue V.b " Improper Shortening of . Anchor i Bolts in the' Steam Generator Upper Lateral Supports", O investigation of the design of these restraints has been transferred to the Civil / Structural DSAP.to be handled in a manner equivalent to the self-initiated review. This review , will be performed by CPRT third-party personnel.- 3.3 Self-Initiated Review 4 Outside of-the cable tray support, conduit support and TRT-related design concerns, few external source issues have been identified for the civil / structural design. However, as an additional level of design adequacy assurance, the CPRT has'

committed to perform-self-initiated reviews of additional 1

civil / structural safety-related designs. The purpose of these self-initiated reviews is to supplement the review coverage of the civil / structural design discipline to include all principal design processes, activities and j organizations involved lin CPSES. This additional effort will ! provide reasonable assurance that all civil / structural designs are in conformance to.CPSES licensing-commitments and address potential generic implications of issues noted in other civil / structural design areas. i 1

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R1 vision: 1 Page 5 of 62 O) (_, DSAP VIII (Cont'd)

3.0 BACKGROUND

(Cont'd) The focus of the self-initiated reviews will be on those civil / structural design processes which are not covered by the activities associated with cable tray supports, conduit supports and TRT-related issues. This will include concreto and structural steel design, HVAC supports and other component supports and structures. The self-initiated reviews w'ill be performed by CPRT third-party personnel. 4.0 CPRT ACTION PLAN This section and associated attachments describe the activities that will be implemented in each of the major elements of the Civil / Structural DSAP. The main body of this document describes the activities of the CPRT third-party personnel. The actions of TNE and contractor organizations are detailed in attachments to this DSAP. T 4.1 Cable Tray and Conduit Supports [O 4.1.1 CPSES Project Actions The objective of the Project activities is to conduct design verification of CPSES cable tray and conduit support systems by addressing issues and concerns from external sources and by demonstrating compliance with CPSES licensing commitments. The Project (including contractors) activities for cable tray supports are described in Attachment 2. The Project activities for conduit supports are described in Attachment 3. Project testing activities to support the work for cable tray and conduit supports are described in Attachment 4. 4.1.2 Third-Party-Review Actions The ~ objective of the third-party review of' the Project actions for cable tray and cor.duit supports is to verify the technical adequacy of the design verification criteria, methodology, methodology ps () implementation and corrective actions. Additionally, the thir'd-party will verify that external source

Revlsion: 1 Page 6 of 62

 \__/                                       DSAP VIII (Cont'd) 4.0_ CPRT ACTION PLAN (Cont'd) issues have been identified and adequately addressed, including an assessment of root cause and generic implications. This verification effort will provide reasonable assurance that all identified issues are resolved and currently unidentified issues are detected and resolved. It will also confirm that CPSES cable
                         -tray and conduit' supports are designed in conformance to CPSES licensing commitments.

4.1.2.1 Review of Issues This action consists of third-party identification, review and tracking of ' external-source-identified issues which have been raised regarding cable tray and conduit support analysis and design. The tasks included are as follows: Issue Identification - This task involves the identification of all O. applicable. issues through the review of related documents such as Cygna Independent Assessment Program Reports, NRC Review Reports (SIT, SRT, TRT, SSER,' Meeting Transcripts), ASLB proceeding documents, etc.- Issue Review and Evaluation - This task involves reviews of each issue, determination of the significance with respect to the design adequacy program, evaluation and review of resolutions and investigation of root cause an'd generic implications.

                                               -Issue Tracking - This task-involves tracking the status of.each issue to the point of satisfactory resolution and identifying the Project's
                                               . activities which address the resolution.

4.1.2.2 Criteria and Standards The CPSES-design criteria and commitments (} D govern the activities'of this DSAP.

i i 1 Rivision: 1 Page- 7 of-62 .,,jf DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) I This action involves the verification that commitments establishing cable tray and conduit design criteria and standards are identified, consistent, and complete. The-commitment sources include the FSAR, design. specifications, and relevant codes. The criteria will be used in the development of checklists for the review of specific program areas. 4.1.2.3- Review of Project Activities and Corrective Actions T This action consists of third-party review of Project activities and corrective actions which are separated into the following areas:

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Review of design procedures and supporting analytical studies. [' Testing program review and

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evaluation. Analysis / calculation verification. Review of resolutions and modifications. Evaluation of root causes and generic implications.- JAs-built verification. Review of Design Procedures and Supporting Analytical Studies

                             'This activity. involves the review of procedures developed and used by the Project for all reanalysis and qualification activities described in Attachments 2 and 3 and the verification that they.are adequate to achieve their intended purpose.                      ;

I For conduit supports, the third-party will { review the S2-910 package initially prepared  ! by Gibbs & Hill and subsequently revised by

 'N                           Ebasco. This package provides the design criteria and methods used for' Unit 2 conduit
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i R* vision! -1 Page 8 of 62 DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAM (Cont'd) 4

                                  . supports. The design and analy6is methods used by TNE to verify the design adequacy of Unit 1 and common conduit. supports will also be evaluated by the third-party.

For cable tray supports, the procedures

developed _and used by Ebasco and Impell vill be reviewed. The techniques to be proposed by Ebasco and Impell to investigate the system behavior of cable tray runs and selected implementation of these techniques will also be reviewed by the third-party.

For both areas, analytical _ studies that are essential to support criteria specified in the procedures will be reviewed. fhe third-party will prepare an engineering evaluation report which will cover all relevant design and_ analysis procedures and supporting analytical studies. { } Testing Program Review and Evaluation

,                                  This activity involves the review of testing 4

programs and associated analytical programs that support the cable tray and conduit ' support design verification activities. The objectives and scope-of Project activities in this area are detailed in Attachment 4. The third-party will review the test scope, the test specifications and the test procedures to ensure that th.sy are sufficient to achieve the stated objectives. These reviews -tur the third-party will ensure that the hardware assemblies tested represent, as closely as possible, actual in-plant hardware and the tests follow standard testing procedures. The third-party will also review post-test data reduction performed by the Project and its contractors.

                                  'An engineering evaluation report will be prepared to document third-party review                I activities in this area.                                l
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      '6 R1 vision:       1 Page    9 of'62 DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
                                 -Analysis /Caleclation Verification This activity involves the review of selected cable tray and conduit support designs using checklists. For Unit I and and for Unit 2 cable. tray supports, the third party will review selected calculation packages from each of the Ebasco and Impell studies. These calculation packages will be selected to include:' 1) packages for supports which are qualified without modifications, 2) packages for supports which are qualified through-modifications, and 3) packages from the system analyses.
,                                 For conduit supports of Unit I and Unit 2, selected conduit run/ support calculation packages will be reviewed by_the third-party.

Specific information to be reviewed fer each calculation paCtage includes the following:

1) input to analysis including drawings, O-support location, and modeling characteristics; 2) loads including seismic loads; and 3) analysis output including loads, displacements and stresses.

The third-party reviewers will use checMists 4 prepared for both cable tray and conduis supports. Review of the calculation package output will ensure consistency with the - input, including mathematical checks, and conformance to applicable codes and acceptance criteria. Review of Resolution and Modifications This activity relies upon the, reviews 'I described in the previous sections, and its purpose is to ensure that all safety- , significant deficiencies have been resolved. The third-party will verify that external . - source as well as internal issues have been addressed either through analysis / design efforts or through modifications. The third-party will perform an engineering evaluation and review of selected modifications to verify implementation of 4 corrective action in accordance with the- ' provisions of Appendix H of the CPRT Program ~ Plan. 1

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Rzvision: 1 , Page 10 of 62 ) O ( ,) DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Evaluation of Root Causes and Generic j Implications The purpose of this third-party activity is to ensure that the root causes and generic implications of external and internal issues are identified and addressed. The root causes and generic implications identified within the civil / structural discipline will be documented and submitted to the programmatic / generic implicationc Coordinator for evaluation of the applicability to other disciplines within the DAP. In the areas where 100% verification is being performed, the assessment of generic implications is only for the purpose of identifying potential problems in other design areas. As-Built Verification [~'T This DAP third-party activity will' include an

 \                                   overview of the Project activities associated with verifying the accuracy of the as-built information used in the cable tray and conduit support design verification program, mSpecific activities will include a review of the Project procedures for as-builting to verify 1) that attributes important to design are included and 2) that sufficient process controls and checking are defined and implemented to ensure that accurate information is obtained.

The third-party will also overview all sampling plans including population identification, homogeneity, reject criteria and sample selections wherever sampling approaches are applied in the Project's design verification effort. 1, 4.2 TRT-Related Issues The objective of this effort is to verify the adequacy of 'the design of the steam generator restraints / compartment wall assembly. O O f

Rzvision: 1 Page 11 of 62 DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) As previously noted, design review of the Steam Generator Lateral Restraints (ISAP V b) has been transferred to the Civil / Structural DSAP. This review will be performed by CPRT third-party personnel using the same methods developed for the self-initiated review described in Section 4.3.1 below. 4.2.1 Review Scope The design of both the upper and lower steam generator lateral restraints will be reviewed for all load combinations. The components to be reviewed include the beams, the anchorage of the beams to the concrete walls and the walls. . In particular, a review will be performed of the following elements, some of which may only apply to either the upper or lower restraint:- Loads Review of the development of steam generator-to-beam forces (i.e., pipe-break, seismic, thermal). Validity of the combination of , pipe-break and seismic steam generator-to-beam forces and compartment differentist. pressures selected for worst case ane!ysis of i - beam and anchorage. Force and moment resultants on the beam, wall and anchorage as a function of assumed wall stiffnesses; i.e., cracked vs. uncracked concrete' properties. Review of concrete wall design. Adequacy of bolt and plate connection detail with emphasis on the require'd thread engagement length-and significance of thread damage (ISAP V,b). Adequacy of rebar and cadweld-anchoring and embedment. 1

l l Ravision: 1 Page 12 of 62 () DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Self-Initiated Evaluations

              .The objective of the self-initiated evaluations is to review representative elements of the civil / structural design to provide reasonable assurance that all safety-significant design. deficiencies have been identified'and resolved.

Coverage of the civil / structural design discipline is described in Attachment I which identifies homogeneous design activities (HDAs) from which designs will be selected for review. Some of the HDAs shown are representative of common design inputs or processes and have been identified as checklist attributes that will be evaluated as part of the civil /etructural self-initiated review.~ These HDAs which'are listed for competeness in Attachment 1 are identified by an asterisk. 4.3.1 Methodology For each of the~ areas within the self-initiated

  ,,                    evaluation scope, the review process will involve:

Identification (i.e., compilation) of design criteria Review of criteria Review of implementing documents Review of drawings and specifications 4.3.1.1 Identification of Criteria 1 1 l The civil / structural self-initiated evaluations begin with the identification of i criteria and regulatory requirements applicable to specific design areas. The sources of such requirements include the FSAR, documents referenced by the FSAR, regulations (10 CFR), andl correspondence  ; between the NRC and TUGCO. i These and other sources of criteria will be reviewed and applicable criteria and  : requirements extracted and listed. This list l will then contain the fundamental acceptance criteria for the designs and will form the basis for subsequent stages of the review. k

R:: vision: 1 Page 13 of 62 O DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1.2 Review of Design Criteria The criteria list will be subjected to a review for consistency and completeness. The objective of this stage of the review process is to ensure that the list'contains criteria that are consistent and compatible with each other. Furthermore, the review will consider whether the criteria l W is sufficiently complete to allow an experienced civil / structural designer to develop designs that satisfy their functional purpose. Any apparent inconsistencies or lack of completeness in the criteria will be evaluated to determine whether the inconsistency or lack of completeness has potential safety significance for any of the structures. Any inconsistencies or lack of completeness that O k/ could have safety significance will be evaluated for the effect on structures, after determining the correct or additional criteria. Any such' lack of completeness or consistency will be further reviewed for-generic implications. The final consolidated design criteria that are evaluated to be consistent and complete will be used as the basis for evaluating the designs.as reflected

                                   -in design implementing and design output documents.

4.3.1.3 Review of Implementing Documents

,.                                  Implementing documents include design 4

analyses, evaluations, and'other documents used by the architect / engineer to demonstrate compliance of the system with design criteria or to communicate design criteria among

                                  . designers.

Implementing documents are an intermediate step between' design inputs (e.g., design-criteria and loads) and design outputs (e.g..- drawings and specifications). ' Examples of implementing scuments include calculations, evaluations (e.g., DCA), analyses, and (

     /.

similar documentation. L I

Rsvision: 1 Page 14 of 62 g ,) DSAP VIII (Cent'd) 4.0 CPRT ACTION PLAN (Cont'd) The review begins with identification of the implementing documents applicable to the civil structures. The process used in evaluating implementing documents involves the identification of the most significant design criteria applicable to each implementing document. For each implementing document included in the scope of the review, a checklist will be developed. The checklist will contain the design criteria with which the document must be consistent. Furthermore, the checklist will require that any aJsumptions or limiting conditions introduced into the design by the implementing document must be reviewed against the consolidated criteria list for consistency. Where assumptions are validated by tests, l' D test program results will be reviewed to

 \-sl                            determine whether in fact the design as tested is consistent with those assumptions.

Where assumptions cannot be validated.by test, a basis for the validity of the assumption will be determined. 4 Calculations and evaluations will be reviewed for adequacy of the applied methodology as well as accuracy of the implementation of the methodology. Calculation verification will be accomplished by either detailed check of the calculation or by performance of an alternate calculation. Specific attention will be given to the information flow in the design process (e.g., revisions, interface with other disciplines, as-built loads vs. design loads). 4.3.1.4 Review of Drawings and Specifications / Supplier Documentation The review of. design outputs (drawings, specifications and suppliar docuaru:ation) will consider architect / engineer-or1 61nated drawings'and specifications along with Os fabrication drawings and information generated by suppliers in response to

l l Revision: 1 Page 15 of'62 gw I ( ,) DSAP VIII (Cont'd)

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4.0 CPRT' ACTION PLAF (Cont'd) specification requirements. The A/E drawings and specifications include concrete arrangement drawings, reinforcement drawings, concrete and miscellaneous steel specifications', etc. For each document selected, applicable implementing documents and criteria from the consolidated criteria list will be determined and a checklist will be prepared. A review will be made using the checklist to determine whether the drawings and. specifications are consistent with the applicable implementing

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documents and criteria. Inconsistencies determined in this process will be evaluated for safety-significance. Safety-significant deficiencies and adverse trends of deviations and/or observations will be considered further for generic implications. 4.3.2 Review Scope ( Designs representative of HDAs will.be selected for review. HDAs have been grouped into topical areas (as shown in Attachment 1) to facilitate the design review process. The following self-initiated topics and associated HDAs will be addressed: Load Determination

                                 ~ Concrete Design Srtuctural Steel Design Foundation Design l
                                 . Supports / Anchorage Design Other Structures Design Heavy Load Drops Development of Specifications Testing I
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Special Studies

Revision: 1 Page 16 of 62 DSAP VIII (Cont'd) 4'. 0 CPRT ACTION PLAN (Cont'd) The following sections describe the scope of review for each of the review topics. 4.3.2.1 Load Determination Where unique calculations have been performed (separate from individual structural design calculations) to determine and distribute specific loads on structures, representative calculations will be selected for review. These unique calculations are expected to l address the following types of loads: Pressure Wind ) -

                                                       ' Tornado Impact O                                              -

Seismic The more common loads that are addressed within the body of individual structural design calculations will be included as standard checklist review items for the individual structural analyses selected for review. The review of pressure, wind, tornado and impact load determinations-will be performe'd on selected representative calculation . packages. The determination of seismic loads , will be reviewed for the auxiliary / electrical building which has been selected due to its

relative complexity. A review of the

. . building dynamic model, the soil-structure-interaction and seismic analysis will be perf o rmed. The method used to distribute the seisnic forces throughout the building will

                                           'be reviewed as well as its implementation.-

The procedure for developing floor response spectra considering the three components of earthquake motion, closely spaced modes, peak broadening, torsional effects, etc. will be f%, reviewed. A selected number of floor spectra () will be-checked. 4 s

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Revision: 1 Page 17 of 62 O)

 \s-                                    DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2.2  Concrete Design Three buildings have been selected for review: the reactor, auxiliary / electrical, and fuel buildings. The' reactor building has been selected because of its importance and safety-related functions. The fuel building was included because of the configuration of this type of structure, namely the high, unbraced walls. Of the remaining seismic Category I structures, the auxiliary /

electrical building was selected because it is representative of a typical nuclear power plant build.ing. For the reactor building, the method of analysis will be reviewed as well as four sets of calculations. One set of calculations will deal with the shell wall (s and three others with discontinuities in the () shell wall, i.e., penetration areas, wall / dome interface and wall / foundation interface. Particular attention will be given to the assumptions about boundary conditions, the treatment of non-axisymmetric transient and localized loads, treatment of cracking in the concrete and treatment of the l 4 large, thickened penetration regions. The liner plate and its anchorage system will be included in the review with attention given ' to-attachments to the liner and the load transfer path either through the liner or through concrete embedments. -In the internal structure, a set of calculations addressing the radiological shield wall will be reviewed. In the two othe'r buildings, approximately ten slab and ten wall calculations will initially be selected. Based on the results of this review, additional selections may be made. The treatment of exterirr walls as missile barriers will be reviewed and their~ design verified. (' s,_

      '                         -Several concrete equipment foundations will be selected for review of treatment of anchoring and vibration loads.

Revision: 1 Page 18 of 62 DSAP VIII i (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4'.3.2.3 Structural Steel Design The use of structural steel is limited in the CPSES plant, with essentially no major steel framework in any of the Category I buildings. The most significant steel structures are the cable spreading room frame and several components related to pipe rupture protection. Selected portions (br.ys) of the structural steel frame of the cable spreading room will be reviewed. In addition, several structural steel components related to pipe rupture protection will be selected from the following categories: Pipe whip restraint supports C Jet shields A set of calculations related to the design of platforms, monorails and miscellaneous Category I steel will be selected for review. The design of the stop gates 'for the Service Water Intake Structure will be reviewed. j 4.3.2.4 Foundation Design-The design of building foundations will be verified by reviewing the design of the containment mat. The static soil properties. 4 and foundation bearing pressure will be reviewed. The effect of overexcavation'and back fill will be assessed if applicable. 1 Special consideration will be given to the: treatment of overturning, sliding and floatation if applicable. In addition, a representation retaining wall will be selected for review of the earth pressure treatment and design method. The Category I tank review will also include an {} s_- evaluation of the foundation design. 4 l l l i _ . _ _ _

Revision: 1 Page 19 of 62 V DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2.5 Supports / Anchorage Design HVAC Supports HVAC support design has been included within the scope because of similarities with the cable tray supports even though the design responsibilities were with a 'different design organization. The systems analysis for the control room HVAC will be. reviewed in its entirety. including modeling assumptions and analytical procedures. The remainder of the population of HVAC systems supports will be identified. The governing design methodology for these' supports will be included in the review. Approximately 20 supports from this population and 20 supports from the control' room HVAC system will be reviewed. The results of the review will either: 1) indicate the need to expand the scope of the review, 2) identify a sub-population for further investigation, or 3)-provide reasonable assurance that the HVAC support systems will meet their specified* design requirements. Crane Supports The containment polar crane has been selected for review in this category due to its importance and its critical location in the plant. The polar crane supports are also under consideration as part.of TRT Issue VI.b. Attention will be given to the interface between the design organization and the crane

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vendor. In addition, polar crane field I installation problems and their resolutions l will also be reviewed. l Equipment Mounting Q Equipment can be divided into two categories, h mechanical equipment and electrical equipment. A minimum of five pieces of

Revision: 1 Page 20 of 62 O. DSAP VIIII (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) equipment from each' category will be selected for. review. Emphasis will be given to embedment/ anchorage design, field installation problems and design changes. Penetration Sleeve Anchorage 4 The population of' penetrations through the containment wall will be identified and several penetration sleeves, both mechanical and electrical, will be selected for review. Particular attention will be given to consideration of axial load, moments and ";

• torsion,'and resulting stresses in the concrete.

Missile Resistant Doors and Hatches These components can oe sorted into two

.                                    categories, one in which the doors are

! designed by the manufacturer with the ) anchorage designed by the A/E-design organization and the other where the entire component including the anchorage is designed

by the A/E design organization. A minimum of five items from each category will be selected for review.

Seismic Restraints for Recevable Shielding Walls j The population of these corponents will be j identified and a minimum of five items will be selected for review. f Recirculation Sump Pump Screen Support - Crossover Leg Support - Control Rod Drive Mechanism Supplemental Steel Support - RPVRI f Support These four supports have been selected because of their uniqueness in design and the..-importance to safety.. All-structural considerations related to their design will be reviewed. t-

Revision: 1 Page 21 of 62 DSAP VIII (Cont'd) 4.0 CPRT ACTION PLAN-(Cont'd) I&C Tubing Supports The methodology used to analyze and design these systems will be identified and reviewed. Supports and/or systems will be selected to verify the implementation of the design. Fuel Transfer Tube Support i This item has been selected since it is a non-piping-related support designed by the civil / structural group to the ASME code. It , is unique in the plant, and its design will be reviewed. 4.3.2.6 Other Structures Design The design of the following miscellaneous structures will be verified: 4 Non-Primary Walls A selected number of seismically designed secondary. concrete walls and firewalls will be reviewed for load requirements and design. Category I Tanks One of the three outdoor seismic Category I tanks will lue selected for design review. 1 The foundation and mat design will be

                         -reviewed including sliding and overturning considerations. The concrete shell, steel liner and their interaction will be considered. Particular attention will be given to the treatment of dynamic loads such as missile, seismic and sloshing loads.

Underground Structures The design methodology for underground tanks, underground tunnels and underground , electrical duct banks will be reviewed. Soil-structure interaction, differential movement, seismic loads, and floatation will be considered. A selection of these

structures will be reviewed to verify design

implementation.

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Revision: 1 Page 22 of 62 D) i

  \. /                                                                                                 DSAP VIII 4

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Safe Shutdown Impoundment Dam The analysis and design of the safe shutdown impoundment dam will be reviewed. The method. of analysis and computer codes will be reviewed. Treatment of slope stability -

                                                                                               .liluefaction, sliding, seepage and dynamic loading will be considered.

Hatch Design The containment equipment hatch cover and anothar building roof hatch cover will be reviewed. Load requirements, treatment of tornado and seismic loads, and design methodology will be considered. Implementation will be verified through design review. f-'s Fuel Pool Re-Rackink A review of the following will be performed:

1) new requirements resulting from the high-density racking, 2) subsequent analysis including dynamic analysis and impact on floor response spectra and local loads, and

3) design details.

4.3.2.7 Heavy Load Drop. A review will be made of the general methodology, load path and energy dissipation ' assumptions. Treatment of concrete punching, spalling.. shear vs. bending member deformation, ductility ratio, etc. will be reviewed. In addition, several drop studies l will be selected to verify the implementation of the methodology. 4.3.2.8 Development of Specifications Selected specifications prepared by the civil / structural group will be reviewed to verify that design requirements are appropriately reflected and that suppliers / fabricators have conformed co these requirements. ()T

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$ Revision: 1 Page 23 of 62 j O ks/ DSAP VIII (Cont'd) 4 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2.9 Testing is..ing programs providing backup for design

                                               'apris criteria will be reviewed. Test 4

pt.cedures, results, interpretation of results and conclusions will be reviewed for appropriateness and consistency. f ~ Other confirmatory tests, such as the Centainment Structure Integrity Test assessment, will be included in the review. 4.3.2.10 Special Studies During the course of design implementation, circumstances necessitate the development of special studies that validate design assumptions, non-conforming conditions, analytical approaches, etc. These studies 'j support the design bases and have a bearing (f-~j on overall design adequacy. Accordingly, selected areas as defined in Attachment 1

                                              .will be reviewed.

i 4.4 Third-Party Reporting I Third-party review activities will be documented in a Results Report that includes the following: Scope of Activity j This will be a detailed description of the activities reviewed including drawings, analyses, references, specific calculations and procedures. Review Methods This will be a description of the methodology used in performing the reviews including applicable third-party j procedures and checklists used. Evaluation This will be a~ discussion of conclusions and the bases , for conclusions from which recommended actions will be determinad. In addition, the evaluation will address i f root cause and generic implications (if any) applicable ( outside the civil / structural. discipline as well as the adequacy of actions taken to resolve external source issues.

     ,   . -.-, -  _                      ,        ,.               ., , ,-          - , . . . + - . . ,-                   .,

Revision: 1 Page 24 of 62 j

    )

U ~ DSAP VIII ' (Cont'd) l 1 4.0 CPRT ACTION PLAN (Cont'd) Description of Deviations This will be a detailed discussion of deviations or concerns encountered during the. reviews including probable cause and' potential' impact. Recommended Action These will be recommended actions to alleviate the concerns or correct deviations. Follow up Requirements If required, additional review requirements will be identified to assure that potential concerns have been adequately addressed. 5.0 ORGANIZATION AND RESPONSIBILITIES The Civil / Structural DSAP organization has been established to implement all activities associated with this action plan. The organization chart is shown in Figure VIII-1. The third-party effort is to be conducted under the project management direction of the Engineering Manager with the technical guidance and approva.1 of the Civil / Structural Discipline Coordinator. The three major review areas of cable tray supports, conduit supports, and self-initiated evaluation are each managed by individual review area leaders that report to the Engineering Manager for project management direction and interface with the Civil / Structural Discipline Coordinator for technical direction. Project activities including interfaces with the architect / engineer, contractors, other Project organizations and vendors are under the management of the TUCCO Support Coordinator. The primary interface between the Project and third-party efforts is between the TUCCO Support Coordinator and the Civil / Structural Discipline Coordinator. Direct interfaces will also be established between the individual review area leaders and their appropriate Project activity counterparts. The Civil / Structural Discipline Coordinator is responsible for: Developing and revising the Discipline Specific Action Plan 'i

  \

within the civil / structural area.

Revision: 1 Page 25 of 62 0 DSAP VIII (Cont'd) 5.0' ORGANIZATION AND RESPONSIBILITIES (Cont'd) Evaluation / closure of discipline external source-issues and DAP-identified discrepancies. Assuring that the root causes and generic implications evaluations and results are coordinated with the Generic Implications Coordinator. Serving as the principal interface with the Generic Implications Coordinator, the QA/QC Review Team, and the TUGC0 Civil / Structural Support Coordinator. Assessment and conclusions that the DSAP has achieved its stated objectives. Approval of the Civil / Structural DSAP Results Report. Three specialist groups exist to assist in the Civil / Structural DSAP implementation for the following specific technical. areas:

   /       -

Cable Tray Supports , Conduit Supports Self-Initiated and TRT Design-Related issues

These engineers, reporting to the Engineering Manager, are under the direction of third-party group leaders whose responsibilities include

Providing day-to-day technical guidance to assure that the

                    -civil / structural DSAP is being implemented correctly in their area of review.

Review and approval of internally-generated documents such as checklists, criteria lists, etc. Implementation of confirmatory analytical programs. Overview of Project' analysis, design as-builting activities and testing program. Review, tracking, and resolution of identified discrepancies, deviations, and deficiencies. Maintaining group working files. [T - Directing and assisting in the technical design or review

   \s 2              activities of the group.

f 4 Revision: 1 Page 26 of 62 DSAP VIII (Cont'd) 5.0 ORGANIZATION AND RESPONSIBILITIES (Cont'd) i The technical' review group leaders are supported by a team of design review, design verification and testing engineers. The TUGC0 Civil / Structural Support Coordinator, and his support , group, are responsible for: Managing the interface between the CPRT civil / structural team and the Project. i Providing documents and information as requested by the I Civil / Structural Discipline Coordinator. j - Managing Project analysis, design and as-builting activities. 1 i - Coordination and direction of. testing organization activities. ] , k t 8 i i s J i 4 1

l l Revision: 1 Page 27 of 62 l s DSAP VIII (Cont'd) ATTACHMENT'l CIVIL / STRUCTURAL' REVIEW MATRIX SELF-INITIATED EVALUATION l DESIGN ORGANIZATIONS REVIEW AREA /HDA G&H TNE OTHER 1.0 LOAD DETERMINATION 4 C004 Wind Loads X C005 Tornado Wind Loads X C006 Tornado Pressure Loads X C024 Structures / Structural. components-Pressure Analysis ~ Internal Pressure Loads- X CO25 Structures / Structural Components-Pressure Analysis - External Pressure Loads X I CO26 Structures / Structural Components-

    ~~/
       )               Thermal Analysis CO27 Structures / Structural Components-X l

Impact Analysis - Global Response X X i C028 Structures / Structural Components-Impact Analysis - Local Response X X C029 Structures / Structural Components-Seismic Analysis - Computer Programs X C030 Structures / Structural Components-i Seismic Analysis - Idealization /Modeling X C031 Structures / Structural Components-Seismic Analysis - Response Spectrum Analysis X 4 C032 S t ructures/S tructurat Components-Seismic Analysis'- Time History X C033 Structures / Structural Components-Seismic Analysis - Shear Load Distribution X C034 Structures / Structural Components-Seismic Analysis - Generation of Response Spectra X X C035 Structures / Structural Corponents-Seismic Acalysis - Combina'. ion of Responses X C093 Dynamic Soil-Parameters X C098 Dynamid Soil-Structure Interaction X I Cxxx denotes a homogeneous design activity (EDA) within each_ of the ten numbered retlew areas. -The HDAs denoted with an asterisk are (}j

  .(

addressed as checklist attributes and are common to other review areas.

Revision: 1 Page 28 of-62

   \

DSAP VIII ~! (Cont'd)  ! i 1 ATTACHMENT 1 I' CIVIL / STRUCTURAL REVIEW MATRIX

                                                           .SELF-INITIATED EVALUATION i

DESIGN ORGANIZATIONS REVIEW AREA /HDA G&H TNE OTHER j 1.0 LOAD DETERMINATION (Cont'd) I

• C001 Dead Loads
• C002 Live Loads
• CO20 Reaction loads - Pipe Whip Restraints j
• C021 Reaction Loads - Jet Shields

+

• CO22 Reaction Loads'- Other Equipments
• CO23 Structures / Structural Components-j Gravity Load Analysis

;

• C036 Structures / Structural Components-

                                            . Hydrostatic Analysis

• C037 Structures / Structural Components .

Reaction Loads Analysis l

• C038 Subsystems / Components-Gravity Loads Analysis
• C039 Subsystems /Componente-Pressure Analysis j
• C040 Subsystems / Components-4 Thermal Analysis l
• C041 Subsystems / Components-l Impact Analysis

• C042 Subsystems / Components-

{ Seismic Analysis - Idealization /Modeling ' j

• C043 Subsystems / Components- '

4 Seismic Analysis --Equivalent' Static '

• C044 Subsystems / Components-

                                            . Seismic Analysis - Response Spectrum

• C045 Subsystems / Components-

} Seismic Analysis ~- Time. History l

• C046 Subsystems / Components-~ l Seismic Analysis - Combination of Responses' '
• C047 Subsystems / Components-Hydrostatic Analysis
• C048 Service Load Combinations - Containment Structure
• C049 Service Load Combinations - Containment

Internal Structures - Rejnforced Concrete

(

Revision: 1 Page 29 of 62 DSAP Vill (Cont'd) ATTACHMENT 1 CI7IL/ STRUCTURAL REVIEW MATRIX SELF-INITIATED EVALUATION DESIGN ORGANIZATIONS REVIEW AREA /HDA G&H TNE OTHER 1.0 LOAD DETERNINATION (Cont'd)

• C050 Service Load Combinations - Containment Intern 21 Structures - Steel Structures
• C051 Service Load Combinations - Other

 .                      Seismic Category I Structures -

I Reinforce Concrete l

• C052 ' Service Load Combinations - Other Seismic Category I Structures -

Steel Structures

• C053 Factored Load Combinations -

Containments Structure

• C054 Factored Load Combinations - Containment Internal Structures - Reinforced Concrete
• C055 Factored Load Combinations - Containment Internal Structures - Steel Structures
• C056 Factored Load Combinations - Other Seismic Category I Structures -

Reinforced Concrete

• C057 Factored Load Combinations - Other Seismic Category I Structures -

Steel Structures

• C190 As-built Load Verification
• C193 Interface. Loadings 2.0 CONCRETE DESIGN C058 Containment Shell X C059 Containment Dome X C060 Containment Discontinuities - Shell/ Dome X C061 Containment Discontinuities - Shell/ Mat X C062 Containment Penetrations - Electrical X C063 Containment Penetrations - Mechanical X C064 Containment Penetrations - Hatches X C065 Reactor Building Internal Structure -

Concrete Slabs and Beams. X C066 Reactor. Building Internal Structure - Concrete Walls and Columns X C067 Reactor Building Internal Structure - s_, Primary Shield Wall X C068 Reactor Building Internal Structure - Refueling Cavity X

Revision: 1 Page 30 of 62 s_ DSAP VIII (Cont'd) ATTACHMENT 1 (Cont'd)

                                                             ~

DESIGN ORGANIZATIONS REVIEW AREA /HDA C&H TNE OTHER 2.0 . CONCRETE DESIGN (Cont'd) C069 Reactor Building Internal Structure - Primary Loop Compartment X C070 Other Structures - Concrete Slabs and Beams X C071 Other Structures - Concrete Walls and Columns X C072 Other Structures - Exterior Walla X 3.0 STRUCTURAI, STEEL DESIGN C073 Structural Steel X n'~ C074 Pipe Whip Restraints C075 Jet Shields X X X X ! C076 Steam Generator Restraints X i C077 Liner - Liner Plate Anchorage - Containment X C078 Liner - Liner Plate Anchorage - Fuel Pool X C079 Liner - Liner Plate Anchorage - Tanks X C080 Liner - Liner Attachments - Containment X C081 Liner - Liner Attachments - Fuel Pool X

!               C082 Impact Limiting Material                        X            X C083 Miscellaneous Category I Steel                  X C084 Monorails / Platforms                         .X 1

C085 Service Water Intake Structure Stop Cates X C086 Roll-Away Missile Shield X -X 4.0 FOUNDATION DESIGN C087. Containment Mat X C088 Other Structures Mat X C090 Retaining Walls X

• C092 Static Soil Parameters
• C094 Foundation Bearing Pressure
• C095 Back Fill / Retaining Wall

                               ~

• C097 Slope Stabilir.y
• C099 Static Soil-Structure Interaction n

v

m-Revision: 1 Page- 31 of 62 p

    \m-                                   DSAP VIII (Cont'd)

ATTACHMENT 1 (Cont'd) DESIGN ORGANIZATIONS REVIEW AREA / TOPIC /HDA C&H TNE OTHER 5.0 SUPPORTS / ANCHORAGE DESICN C100 HVAC Supports X C101 Crane Supports X C102 Equipment Supports - Mechanical Equipment X X C103 Equipment Supports - Electrical Equipment X X C104 Penetration Sleeves / Anchorage - Mechanical X CLOS ' Penetration Sleeves / Anchorage - Electrical X C106 Missile Resistant Doors ~and Hatches Anchorage X C107 Watertight Doors Anchorage X C108 Fire Dampers Anchorage X C109 Roof Hatches Anchorage X C110 Seismic Restraints for Removable Shielding Walls X O3 C116 Fuel Transfer Tube Supports (ASME) X X C117 Recirculation Sump Pump Screen Support X C118 Cross Over Leg Support X C119 Control Rod Drive Mechanism Supplemental Steel X C120 I&C Tubing Supports X C194 RPVRI Support X 6.0 OTHER STRUCTURES DESIGN C089 Tank Mats X-C123 Non-Primary Concrete Walls X C124 Non-Primary Non-Removal Block Walls X C125 Non-Primary Removal Shielding Block Walls X-C126 Non-Primary Fire Walls X C127 Equipment Foundation X C128 Category I Tanks X C130 Underground Tanks X C131 Underground Tunnels X C132 Underground Electrical Duct Bank X C134 Missile Resistant Doors and Hatches Design X X C135 Watertight Doors X X C136 Tornado Dampers / Blow Out l'anels X X C137 Fire Dampers X X C139 Safe Shutdown Impoundment Dam X X 4 J

                                               . _ _              e    n- e

Revision:. 1 Page 32 of 62 ( t

   \s                                               DSAP VIII              .

(Cont'd) i I ATTACHMENT 1 i (Cont'd) 0 l DESIGN ORGANIZATIONS REVIEW AREA /HDA C&H TNE' OTHER 7.0 ~EEAVY LOAD DROPS C154 Load Drop Analysis Onto Concrete X C155 Load Drop Analysis Onto Steel X

C156 Crane Design X X J

C157 Special Lifting Device Design X 8.0 DEVELOPMENT OF SPECIFICATIONS i C159 Refueling Gates X C160 Installation of Buried Piping X C161 Concrete X ~ C162 Reinforcing Steel. X

                       -C163 Cadweld Connectors for Reinforcing Steel         X

. C164 Containment Liner -X-C165 Containment Personnel Air Lock, Equipment Hatch, and Emergency Air Lock X

C166 Structural Steel X C167 Seismic Criteria for Equipment X l C168 Containment Structural Acceptance Test and '

                           . Preoperational Leak Tests                        X-1 C169 Structural Embedments                            X C170 Watertight Doors                                 X C171 Missile Resistant Doors                          X 4

9.0 TESTING I ! C172 Embedded Steel Anchors and Welds X C173 Test Program for Conduit Supports X C174 Containment' Structural Integrity Test /. i Assessment X C175 Epoxy / Grouting Related Tests. X C176 Bolt Torque Related Tests X

C177 Component Capacity Related Tests X C178 Richmond-Insert Related Tests X

i Revision: 1

,                                                                 Page 33 of 62 4
 ' kO,)                                     DSAP VIII (Cont'd)

ATTACHMENT 1 (Cont'd) I DESIGN 3 ORCANIZATIONS REVIEW AREA /HDA C&H TNE OTHER 1

10.0 SPECIAL STUDIES C096 Over Excavation X C133 Fuel Pool Reracking X C140 Hilti Anchor Bolts X X X C141 Anchor Bolts X

C142 Concrete Inserts X i C143 Embedded Studs X j C144' Nelson Studs X C145 Embedded Plates - Strip Plates and Channels X i C146 Embedded Area Places X j C147 Embedded Isolated Plates X C148 Large Embedments . X C149 Base Plates and Wall Plates X i

C151 Welded Connections X X C152 Bolted Connections X j C179 Concrete Cracking X C180 Reinforcement - Omitted Dowels X C181 Reinforcement -' Rebar Cutting X C182 Reinforcement - Omitted Rebars X

C183 Reinforcement - Reduced Anchorage Length X C184 System / Subsystem Decoupling X j C185 Support Vs. System Analysis X

,            C186 Amplification Factors                         X C188 Effect of Flexible Conduits on' Connected

Equipment X C189 Cracks in Moderate Energy Lines X

 !           C191 DCA Process                                  X                X i

C192 Fabrication Drawings , X } !O

Revision: 1 Page 34 of 62 (s DSAP VIII

                                            -(Cont'd)

ATTACHMENT 2 CPSES PROJECT ACTIVITIES FOR CABLE TRAY SUPPORTS

1.0 INTRODUCTION

This attachment to the Civil / Structural DSAP details the activities that will be executed by TNE, Ebasco and Impell .to verify the design adequacy of cable tray supports for both Units 1 and 2. Cable tray supports for both units were originally installed in accordance with generic criteria developed by Gibbs & Hill. These criteria included standard support designs and associated application guidelines based on tray configurations, loads and span lengths. The criteria were based on equivalent static analysis methods for assessing seismic loads. Where field conditions did not allow the application of standard designs, construction requested design changes. These design changes were reviewed and approved by Gibbs & Hill engineering and issued as qualified specific support designs. As noted in earlier sections of this DSAP, there have been a number of design-related concerns raised by External Sources regarding the existing state of cable tray support designs (see Table VIII.2). These concerns include discrepancies between the as-built and as-designed / qualified configuration and concerns with the original design criteria. Based on the number of concerns and' the need to comprehensively address their individual and cumulative effects, the Project has committed to perform an extensive design verification program. This program has been established to address all cable tray support issues in an integrated manner. It will either confirm -that design criteria are met and adequate margins exist or result in modifications to bring the hardware in conformance with requirements. The program will be implemented for both Units 1 and 2 in a similar manner. Differences axist betwean the two units, primarily related

                                          ~

to inaccessibility of hardware h r UnLt I because of the advaaced state of construction.' The baric ulenents of the program to be implemented are su.amarized as ic11ows: Development of as-built ' drawings for all cable tray supporta. Analysis /dnsign reriew of all cable tray supports to criteria that are respenstye to EArrer71 Soutce cesig concerns and f n compliance with 073ES 11tenstL3 come,itments.

   %- /
                                *               ,,r     e                         w    , _ +

Revision: 1 Page 35 of 62 O ~ DSAP VIII (Cont'd) ATTACHMENT 2 (Cont'd)

1.0 INTRODUCTION

(Cont'd) Testing to verify and/or establish specific component or system behavior characteristics. Hardwa're modifications as necessary to ensure final acceptability of all supports. These program elements are discussed in greater detail in the following sections of this Attachment together with the identification of specific scopes of responsibility for the various crganizations that are performing this effort for the Project. 2.0 AS-BUILT VERIFICATION For both units, all cable tray ' supports will be as-built verified for all accessible attributes that are important to design. This \ will be accomplished by field inspection to appropriate procedures and will result in as-built drawings to be used for subsequent design verification. For Unit 2, where virtually all attributes are accessible, as-built verification will be accomplished by direct field inspection of

      ' design attributes and the production of an as-built drawing for each support.                                                             '

For Unit 1, a number of the support design attributes are inaccessible as a result of congestion or the presence of fire protection material. An alternate approach will, therefore, be taken in developing the as-built drawings. This approach is as follows: As-designed drawings will first be developed for each support. This will be based on the original Gibbs & Hill design plus all documented design changes generated in the construction / design process (via CMC's and DCA's). These drawings will be generated by Ebasco and reviewed and approved by Gibbs & Hill prior to their uss for field inspections. Field walkdowns will then be performed using the as-designed drawings. For all accessible supports and accessible portions " of partially inaccessible supports, as-built conditions will be confirmed or noted as different on the as-designed drawing. [ Final as-built drawings will then be produced specifically noting any items within the scope of the walkdown that were inaccessible. U

Revision: 1 < Page 36 of 62 s/ s DSAP VIII (Cont'd) ATTACHMENT 2 (Cont'd) 2.0 AS-BUILT VERIFICATION (Cont'd) Span sketches (noting span lengths) will also be developed based on field inspections for Unit I supports. The basis for design review of inaccessible items for Units 1 and 2 e will bu addressed and documented in special studies or evaluation reports. The treatment of different attributes will vary but typical approaches would include making conservative bounding assuuptions, further investigation of construction travelers or inspection reports, and conservative assumptions based on the as-designed versus as-built results found for similar items that were accessible. These as-builting activities will be performed by the Project and Ebasco with Gibbs & Hill support of the Unit I as-designed drawing review. O) i 3.0 ANALYSIS / DESIGN VERIFICATION 4 Two methods of dynamic analysis will be utilized in the analysis / design verification of cable tray supports. Both methods are consistent with standard industry practice and conform to CPSES licensing commitments. Both methods are to be implemented in accordance with controlled procedures to criteria that address identified external source design concerns. The first method is equivalent static analysis of individual supports which is consistent with the criteria used in the development of the original support designs. The second method is response spectrum dynamic analysis whici provides an accurate measure of system response. The extent co which each method will be used for Unit 1 and 2 is discussed in the following paragraphs. The design verification of Unit 1 supports will be performed usinE as a minimum actual cable tray fill weights and actual fire protection material weights. Both the equivalent static anelysis method and the response spectrum method will be used. Because.of the more congested environment, the latter is eFpected to be used more frequently in Unit I than in Unit 2. Unit 2 design verification will be performed using maximum specified design cable tray fill weights and conservative assumptions will be made regarding the weight of the (~')T (_, fire-protection material. The equivalent static analysis method

Revision: 1 Page 37 of 62 DSAP VIII-(Cont'd) ATTACHMENT 2 (Cont'd) 3.0 ANALYSIS / DESIGN VERIFICATION (Cont'd) will typically be used to determine support 3 rads. It is anticipated that the response spectrum method will also be used to justify limiting the scope of modifications that would be difficult to implement in a congested environment. For both units, loading combinations and stress limits will be checked in accordance with acceptance criteria specified in the procedures prepared to control the work. The criteria will conform to CPSES licensing commitments. For any support which fails to meet these criteria, design modifications will be prepared that result in acceptable qualification. All Unit 2 analysis / design verification work will be performed by Ebasco. Unit I work will be divided with Impell performing the verification for the Safeguard Building and Ebasco performing the verification for all other buildings. Both Ebasco and Impell will O utilize their own design procedures for performing the work; however, design methods and criteria vill be consistent. 4.0 TESTING A testing program has been defined to support the cable tray support verification effort and is described in detail in Attachment 4 to this DSAP. The objectives of these tests are summarized as follows: Determine actual damping levels to confirm applicability of values used in the design of cable tray systems under representative seismic loading conditions. Confirm the response of members acting primarily in tension under seismically induced compression loads. Confirm the analytical methods and supporting design assumptions for complicated load path geometries (e.g. base angle prying action or clip restraint). TNE and Ebasco have developed the required testing specifications. ANCO is responsible for implementation of the testing program. The third party is overviewing the. development and implementation of the testing program.

L

                                                                                                . Revision:  1.

Page 38 of 62 DSAP VIII (Cont'd) ATTACHMENT 2 (Cont'd) I i 5.0 MCDIFICATIONS As noted in Section 3.0 above, modifications will be prepared for all cable tray supports that fail to meet specified acceptance l criteria. Implementation of these- modifications may be' held pending completion of.the testing program, the results of which may-be used in additional. analytical investigations to limit the scope of modifications which may result from overly conservative. assumptions. All supports will finally be shown to be qualified in their existing state or ' required modifications will be implemented. To achieve qualification, all modifications.will be QC inspected, as-built and design verified.

                                                                                                                  \

P O

Revision: 1 Page 39 of 62 ( ,/ DSAP VIII-(Cont'd) ATTACHMENT 3 CPSES PROJECT ACTIVITIES FOR CONDUIT SUPPORTS t

1.0 INTRODUCTION

This attachment to' the Civil / Structural DSAP details the activities that will be executed by _the Project and Ebasco to verify the design adequacy of conduit supports for both Units 1 and 2. Unit I and common conduit supports were initially installed as field run systems supported in accordance with Gibbs & Hill Specification S-910 which contained criteria for spacing and

,l selection of support types as a function of conduit sizes and loads. The approach followed to generate the S-910 specification is in general conformance with industry practice.for supporting conduits. However, there are a number of concerns that have been 2

raised regarding CPSES conduit support designs that need to be addressed (See Table VIII.3). This need has resulted in specific TUCCO Nuclear Engineering (TNE) activities for the review of Unit 1-and common conduit supports detailed in Section.2.1 below. .These O activities will also address the adequacy of. implementation of the S-910 specification by the craft. In early 1984 TUCCO made the decision to amend and streamline the S-910 specification for application to the Unit 2 conduit and conduit support systems. This decision was based upon the desire to: (1) ease application of the field run criteria; and (2) reduce tha number of conduit supports resulting from.the applicatien of a simplified / conservative criteria. .This resulted in the issuance of j a new specification, " original" S2-910,'which was in general less conservativa than S-910. In late 1984 TUCCO decided to proceed with Unit 2 conduit / conduit supports on a fully' engineered basis to: 1) ' eliminate field running of the systems and 2) fully address the external source concerns. Ebasco was retained by TUCCO to perform this Unit 2 conduit work. The " original" S2-910 specification was revised to address external source issues and comply with design criteria commitments. Details of the Ebasco  ; i activities are presented in Section 2.2 below. 2.0 CPSES PROJECT ACTIVITIES. 2.1 Unit 1 and Common Based upon expericcee with Unit 2, it is expected that few, if any. . conduit support modifications will be required for

   /~'                Unit 1, and and common (except for a generic problem with                                   I

( ,N

       )              Unistrut supports addressed separately below).

i l

t Revision: 1 Page. 40 of 62

   /m.

k, s DSAP VIII (Cont'd) r ATTACHMENT 3 (Cont'd) l 2.0 CPSES PROJECT ACTIVITIES (Cont'd) The Unit.2 conduit supports were-initially installed using methods and procedures (original S2-910) similar to and generally less conservative than the original Unit I and 1 Common S-910 specification. The revised S2-910 (currently in use) was developed from the original S2-910 to resolve known . , external issues and conform with existing CPSES criteria. The revision of S2-910 resulted in overall reductions of the capacity and of the allowable span lengths of several generic supports. In spite of this, the completed design i verification of Unit 2 conduit supports against the requirements of the revised S2-910 specification resulted in a-relatively small number of field modifications. This experience supports the conclusion that the upper bound allowables affected by the specification revision, were not

utilized in practice and that few, if any, field modifications j jrs will be required for Unit 1.

    -e                Based on these favorable findings for Unit 2 conduit supports, a two-step approach to verifying the design adequacy of Unit 1 and common conduit supports has been developed. First, all supports which~ include the specific unistrut configurations which are known to exhibit unacceptable behavior will be identified and modified to be in compliance with appropriate criteria. Second, a verification of the as-built Unit I and common design of conduit run will be performed, using random sampling in accordance with Appendix D, as detailed in the following steps.

Two subpopulations of the entire population have been identified: 1) lighting conduits which typically have i long runs of single conduits and 2) power / control conduits which typically have shorter runs of grouped conduits. For each subpopulation, a random sample of 60 conduit runs will be selected. Each selected. conduit run will be as-built verified by field inspection to produce conduit run isometrics and individual support drawings. 4 i

R vision 1 Page _41.of 62' (% aj DSAP VIII (Cont'd) ATTACHMENT 3 (Cont'd) 4 2.0 CPSES PROJECT ACTIVITIES (Cont'd)'

                -      The design of each selected conduit run and associated

+ supports will be evaluated to determine compliance with specified CPSES acceptance criteria. This will be

                       . performed either utilizing the equivalent static method           !

of analysis or response spectrum dynamic analysis '

!                      rie thods.

l The decision criteria for this verification of conduit runs ' are defined as follows: If all sampled conduit runs and associated supports are j found to be in compliance with appropriate criteria, no i further action will be taken. If one or more conduit runs or associated' supports do 4 not meet the appropriate criteria, the results will be

   .h j b' reviewed to determine the most appropriate form of sample expansion required to ensure complete coverage of the population and to isolate. identified problems i                       and/or take corrective action to meet CPSTS acceptance criteria.

These activities for Unit 1 and cceson conduit supports will

be performed by the Project.

! 2.2 Unit 2 As noted above in Section 2.1, all conduit supports that were i installed in Unit 2 using Specification S-910 have been design verified by Ebasco to the revised Specification S2-910 which addresses known external source issues and complies with CPSES I design criteria commitments. Installation of all remaining , Unit 2 conduit supports has and will continue to be performed ' in accordance with S2-910 which involves the following steps: Permissible conduit spans and support designs are determined directly from S2-910. This includes j anchorage and clamping details. Required deviations are reviewed by Ebasco engineering on a case by case basis prior to installation. . q Individual support drawings are created for any ' specific non-standard design that is not included in S2-910. These supports are individually engineered. j

k Rsvicion: 1 .l Page 42 of 62 f')\ i

  \ ,

DSAP VIII (Cont'd) i ATTACHMEhT 3 (Cont'd) i 2.0 CPSES PROJECT ACTIVITIES (Cont'd) All conduit runs are as-built and recorded on individual isometric drawings with clear identification d of each support type (referencable to S2-910 or.

specific support drawings).

j This work is performed by the Project and Ebasco and will ] ensure that all conduit support arrangements are in compliance with CPSES commitments. i, 2.3 Testina-Testing will b'e employed to establish capacities and-allowables for certain conduit support hardware (e.g., clamps j and certain Unit 1 unistrut members). TNE has developed the required testing specifications. CCL is responsible for 4 implementation of the testing program. Details of the testing j are presented in Attachment 4 to this DSAP. 1 .i l f i l i i 4 I

      . . . _ . _ _ _ , . _ _ ___ _ , _ . . . _ _,. ~ , , . _ _ . . .

_ _ . . _ . . , , _ _ - . - _ _ , _ , _ _ . - . ~ _ . _,

Revision: l' Page -43 of 62 f-~ (m,A DSAP VIII (Cont'd) ATTACHMENT 4 CABLE TRAY / CONDUIT SUPPORTS TESTING 1.0 PURPOSE This attachment to the Civil / Structural DSAP details the testing programs to be used in support'of: Validation'of engineering parameters and procedures'for analytical modeling employed in design verification and system analyses; ' Justification of appropriate damping levels for defining l< loads. The test results will be used to confira design / response parameters J that are incorporated in the procedures of the design verification program for cable tray and conduit supports. The cable tray related tests will be performed by ANCO while the conduit related '. tests will be performed by CCL. 1 ( l {

2.0 BACKGROUND

A number of review issues have'been raised for both the cable tray , and conduit support systems concerning the behavior of these

systems under seismic loadings.

l While many of the support configurations appear geometrically

simple, the load paths on a local or component level can be i

analytically complex, particularly with regard to realistic p representation of boundary conditions. It is design practice'at l Comanche Peak as well as in the industry to conservatively idealize the analytical representation of modeled systems, often utilizing l bounding assumptions. Due to the nature of identified issues, such conservatism may result in difficulty in demonstrating compliance with governing design criteria. More realistic consideration of static and/or dynsmic behavior following testing will facilitate the evaluation of the ability of installed hardwa.re to meet structural acceptance criteria and will help confirm that CPSES design criteria are met. This test data then provides the basis for validating engineering parameters and analytical techniques that are applied in the design verification process. t O s_ -

       ;- -                       _.    ,m , r ~            4 , -  -       r *                  '-

s Revision: 1 Page 44 of 62 (_,) DSAP VIII (Cont'd) ATTACHMENT 4 (Cont'd) 3.0 IMPLEMENTATION 3.1 Cable Tray Tests 3.1.1 A saquence of three testing programs is planned. The first program is a base angle-anchor bolt test. The second program is a cable tray clip / support test series. The third program is a system test. The

           .                   following sections provide details on each of the three programs.
             .          3.1.2 Anchor Bolt / Base Angle and Insert / Rase Angle Tests The objective of these tests is to measure anchor bolt / base plate or insert / base plate force-deflection behavior in order to validate the connection flexibility and anchor force currently assumed in the
 ,S                           design verification analytical models, specifically l     )                      prying factors.
  %_)

The tests will measure the force-deflection characteristics of representative and lower-bound connection configurations for static and cyclic loads. Cyclic loads will be gradually increased to full static load. Both one 'and two- anchor connections will be tested. -Forces developed in the anchors will be measured by load washers located on the anchors. 3.1.3 Clip / Tray Tests The objective of these tests is to measure clip / tray force deflection behavior and to determine load paths at connections between the tray and the support. From these measurements, the following can be validated: appropriateness of assuming that clips / trays act as braces for support member stability; performance criteria for clip / tray slip; and appropriateness of applying only transverse tray loads plus cut-of-plane excitation to transverse supports.

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l l 1 l i

j R3visient 1 Page 45 of 62

V O} DSAP VIII (Cont'd) i

;                                         ATTACHMENT 4 l                                              (Cont'd) 1 3.0 IMPLEMENTATION (Cont'd)

The tests will measure the stiffness characteristics of clip / tray configurations for cyclic loads which are 1 gradually increased until failure occurs (i.e., gross clip distortion or slip). The tests will examine the stiffness of the clip / tray for a number of different conditions, including different amounts of fill (slip-test only) and different amplitudes of response.

 ;                3.1.4 System Testing
 )

i The primary objective of these tests is to selectively measure the dynamic response of cable tray systems to 4 confirm the levels of damping specified for these systems. Seconda'ry objectives include: 1) response l measurements to confirm natural frequencies, mode shapes and boundary conditions of analytical models,

<     n                  and 2) examinations of dynamic load effects on-('                  clip / tray slip, eccentrically loaded members, and buckling of slender members. This information is

directly relevant to the dynamic analyses-performed as

;                        part of the design verification effort. The design
;                        verification analyses will employ bounding assumptions,

'1 and comparison with tests will identify the responne m1rgins provided by the bounding analyses versus the , actual behavior. Response margins will not be combined I with modified structural acceptance criteria for the i design verification of hardware. ' s The tests will measure system response for dynamic  ! loads which simulate seismic-type vibrations. The tests will examine system response and damping for a number of different conditions, including varying cable weight, different degrees of anchor-bolt relaxation, and different icvels of input motion. These tests will be performed in a testing laboratory.

 !            3.2 Conduit Components, Supports and Systems l                3.2.1 Component Testing l
'                       The conduit supports will be addressed on the component level to include the anchor bolt concerns related to i

prying action and their associated load capacity under dead and three dimensional seismic loads. 1 i i

R:vicion: 1 Page 46 of 62 [ DSAP VIII

 \~-                                     (Cont'd)

ATTACHMENT 4 (Cont'd) 1 3.0 IMPLEMENTATION (Cont'd) The component level testing vill address the effects of clamp slippage, the effects of hole teaming on the behavior of the Hilti Bolts and washers, and the cases and possible mitigation of the clamp distortions that were noted in the field. 3.2.2 Support Testing As testing progresses to the conduit support level, the torsional behavior of the Unistruts will be addressed either through direct laboratory testing or by a review of the results of the Unistrut tests previously performed by the Project. The effect of the conduit clamp previding three dimensional translational rotational restraint have been questioned as a point of transfer of longitudinal (~S ( ,)g* loads to the transverse support structures. This matter will be investigated by the testing program. 4

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        , _ - . _ - _ . .       -   . - - _      _ _ _ . .. =_                   --       .-

l 2 R:vicient 1 Page 47 of 62 l' '\ DSAP VIII t (s_s/ (Cont'd) TABLE VIII.1 [ CABLE TRAY AND CONDUIT SUPPORTS ISSUE APPLICABILITY i i j Applicability Category Issue Cable Trays Conduit' l Design Loadings OBE as governing load case X X Other design loads such as X X-pipe whip and jet impingement Combination of loads and X X dynamic amplification t Allowable spans, tray widths X X and accelerations CA type conduit supports X adjacent to flexible spans or loaded with flexible conduits O Exclusion of longitudinal X X loads on transverse supports Weight of Fire Protection X Material Response Spectra Compliance with Regulatory X Analysis Guide 1.92 Representativeness of generic .X X l response spectra analysis Assumptions for boundary X conditions and tray attachment , m'odeling Ceneric Studies As-built applicability of working X point and weld underrun generic studies i As-built applicability cf generic X l studies I i Worst Configurations not X considered in generic design ( V} evaluation i l s

                                                                       . . . . -   . . = . = - .                        .

l l R:vimient 1 Page 48 of 62 t l l DSAP VIII (Cont'd)

                                                                                                                                                              -TABLE VIII.!

(Cont'd) Applicability

• Category Issue Cable Trays Conduit System Concept ' Transverse and vertical loads on X X for Design bolted tray clamp Tray clamp behavior considering X SAP
• Design of longitudinal supports X X for self weight excitation of  :

! transverse supports I

Limitation of clip base X i

, connection rotations by attachment to conduit Component Design Consideration of construction X X r tolerances, component ,. substitutions and specification j requirements in design Effects of prying and load X X eccentricities on base angle. t connection design Design factor of safety for X Richmond inserts and connections in relation to ACl-349-76, Appendix 8 requirements Effects of eccentric load X X application on member and connection design Conformance with the AISC X X , specification Unistrut and Z-clip bane X connection behavior and qualification Qualification of modified X catalog componente l Qualifications of cable trays X X l and conduits I l

i I L Revision 1 ( Page 49 of 62

   )                                          D3AP VIII V                                            (Cont'd) l TABLE VIII.2 CABLE TRAY SUPPORTS l

l Review Issues Identified in Cygna's November 26. 1985 Letter l 1. Controlling Load Case for Design The design of cable tray supports was based on an equivalent static , method with the 1/2 SSE (OBE) seismic event assumed to be the i governing load case. For enveloping elevations, the ratio of SSE to OBE does not exceed 1.33. Thus, the OME appears to govern on a generic basis. However, for specific building elevations, this ratio may exceed 1.33. Therefore, for supports at these elevations, the SSE can potentially be the governing load case. See also Issue 3 for the justification of reduced factors of safety.

2. Seismic Response Combination Method Gibbs & Hill combined the dead load with the seismic loads using the SRSS method. The standard combination method (i.e., algebraic sum of dead load with SRSS of seismic loads) will result in an increase of the resultant load.

Closely spaced : nodes should be treated in accordance with USNRC Regulatory Guide 1.92.

3. Anchor Bolt Design A number of issues were identified Field requirements may produce connections outside the range of anchor tolerances provided by the design. Questions were also raised concerning procedures governing the installation and inspection of Hilti bolts.

l Additional tensile forces induced by the rotation of base angles about the centerline of the bolt pattern could overstress the support anchor connections. Justification is needed for the use of a prying factor of 1.5 l in the cable tray support anchorage design. Justification is required for the selection of the safety factors used for the dif ferent loading conditions. l - Justification is required for the two-bolt base angle modeling l b assumptions. 1

R; vision: 1 Page 50 of 62 m (d ) DSAP VIII (Cont'd) TABLE VIII.2 (Cont'd)

3. Anchor Bolt Design (Cont'd)

Inconsistent applications of the ACI 349-76 to qualify certain l anchor bolt designs need to be addressed. Substitution of Richmond inserts for Hilti expansion anchors: the minimum Hilti anchor spacing is less than the minimum Richmond insert sprcing and, thus, the tensile loads in the Richmond insets will be higher than originally calculated. Technical justification for expansion anchors installed in core bored holes. ". 4 Design of Compression Members - In the design of compress' ion cembers for trapeze type support frames, the entire unsupported length of the channels was not p considered in calculating the slenderness ratios. The y, slenderness ratio of these members may exceed 200 (i.e., exceed the limit specified by A1SC Saction 1.8.4 for compression members) if the correct unsupported lengths and end conditions are used. Justification is needed for the assumed bracing provided by the tray. The effect of weld undercutting on the section properties of compression members was not considered. l The effect of the two degree out-of-plumb installation tolerance on axially loaded vertical members was not considered. Enveloping cases may not have been considered for the design of braces acting in compression.

5. Vertical and Transverse Loading on Longitudinal Type Supports Longitudinal trapeze typo supports are rigidly connected to the cable trays and, tnus, should be designed for vertical and transverse seismic loads.

6. Support Frame Dead and Vertical Loads l Justification is needed for not considering out-of-plane inertial

 \v       support loads. Inconsistencies in the consideration of dead loads also need to be addressed.

                                                                                                       ?

l R:vicient 1 Page 51 of 62 DSAP VIII l O\ (Cont'd)  ; r TABLE VIII.2 (Cont'd)

7. Design of Angle Sections Neglecting Loading Eccentricity ,

Internal and external braces for the cable tray supports are generally angle sections. Bending stresses due to the end  ; i condition eccentricities were neglected in the design. In addition, certain brace connections have welding at one angle les at one end of the brace, while, at the'other end, welding is  ! provided on the other angle leg. Such end conditions may lead to failure by twist buckling at loads below the guler bucking load for which the members were designed, t

8. Dynamic Amplification Factors (DAF) and Ratio Between Continuous  ;

Tray Support Reactions and Tributory Tray ' Support Reactions The use of an amplification factor of 1.0 for the equivalent static , analysis has not been justified.  !

9. Reduction in Channel Section Properties Due to Clamp Bolt holss  ;

Channel sections are the typical beam members for the cable tray supports. In the design of some channel beam members the bolt holes reduce the gross area of the flange in escess of A!JC allowable limits. Reduced section properties in the design of these members were not considered.

10. System Concept i Cygna is concerned that the assumptions used in the system concept may not be consistent with the actual behavior of the clarps used in the field. The system action may introduce loads and responses '

which were not considered in the original design.  ;

11. Validity of NASTRAN Models i The models used in the analysis assused a series of one support j type, all having identical configuration and spans. These acdels i may not be *epresentative of the actual installation where a mixture of support types and spana is used.

I c f

R:vici:nt 1 Page 52 of 62 s (U ) DSAP VIII (Cont'd) l TABLE VIII.2 (Cont'd) l-

12. Working Point Deviation Study The cable tray support brace votking point study was based on the original design details and did not consider the ef forts of all l

generic design change documents. Modelling assumptions used in the

study require justification. The study did not assess which of the i

support components controlled the design.

13. Reduced Spectral Accelerations Reduced spectral accelerations were based on calculated support-tray system frequcncy. These studies assumed that all supports on a tray run are of the same type and have equal spaces they are not representative of the cable tray installations. In addition, some modelling assumptions need justifications.

14. Non-conformance with AISC Specifications V'

Calculattens performed for certain tray supports do not strictly , adhere to the AISC specification requirements. for unbraced l 1engths, bolt holes, and secondary members.

15. Member Substitution Within Cygna's walkdown scope, supports were reviewed and found which did not follow the guidelines of the CMC. This raises concerns regarding the interpretation of the drawing nuebers l 2323-5-900 series by cratt for proper member substitution. In l addition, no requirements for documenting member substitution exist.

16. Weld Design and Specifications Cygna found several problems regarding welding:

Design drawings are missing wold details 1 - Wald sizes on fabriention drawings differ from those on design drawings and those assumed on Gibbs & 11111 calculations Eccentricities were not considered in veld connections v

R:vicion: 1 Page 53 of 62

 /

(m) DSAP VIII (Cont'd) TABLE VIII.2 (Cont'd)

16. Weld Design and Specifications (Cont'd)

The thickness of the connected parts was not considered in the veld design

            -      An incorrect minimum weld length was assumed for the beam /

hanger base angle connection calculations l 17. Embedded Plates Design i l - The allowables for the embedded plates may not have included the ef fects of prying action on the tension of the Nelson stude. Inconsistent requirements exist for the use of stiffeners or moment connections to embedded plates between pipe support l applications and cable tray applications. Capacity reductions for attachment locations given in Specification 2323-SS-30 was not considered. l QC inspection did not consider spacing limitations between attachments to embedded plates.

18. Tray Clamps The cable trays were assumed to provide out-of-plane bracing to the tray supports to prevent buckling of hanger members and to prevent l rotation of the frame. The load transfer capabilities of the various clamp designs have not been assessed.

l 19. FSAR Load Combinations Cable tray support designs consider only dead weight and seismic loads. Pipe ship, jet irpingement and thermal 1cada are not l considered in design.

20. Differences Between the Installation and the Design / Construction Drawings Without Appropriate Documentation Discrepancies were found between the as-built support configuration g and the design requirements. A review of the design drawings, fabrication drawing and Cable tray support design Changes did not reveal any documentation authorising the as-butit field condition of a number of supports.

D

R;visient 1 Page 54 of 62 f% . (V} DSAP VIII (Cont'd) TABLE VIII.2 (Cont'd)

21. Design Control Lack of consideration of the effects of generic CMC's and DCA's on the original design.

j Criteria violations in individual support specifications on . l suppor.t plans. Consideration of as-built support conditions in generic reviews which require a case-by-case review. Inconsistencies in the evaluation of cable tray supports for thermolag application. Tray span between supports used in the original support layout. Lack of calculations for Change Notices. fN h - Design calculation retrievability and completeness. Lack of controlled design criteria. Differences between design drawings and assembly drawings. Design calculation retrievability and cespleteness of support.

                                                                          -                                     Lack of controlled design criteria.

Differences between design drawings and assembly drawings.

22. Design of Support No. 3136, Detail "5", Drawing 2323-5-0905 l Several possible discrepancies have been identified.

l

23. Loading in Stress Model In modeling standard support cases A , 8 C and D i 1 to 4),

usingtheprogramSTRESS,severallokdafp,li$a,tionaksu(m=ptionsmay render the analytical results inaccurata. J

   ~ .      . _ _ _    _    _

R:vioical 1 l Page .55 of 62 [ DSAP V111  ! (Cont'd)  ; TARE V111.2 (Cont'd)

24. Design of Flexural Members l -

In the design of' cable tray support flexural members. (i.e., beams and hangers), perverse design considerations were omitted

            -        Additional major axis bending stresses due to transverse            l Loads.                                                             1
            -        Minor axis bending due to transverse loading.
            -

• Torsion due to vertical loading.

Torsion due to longitudinal loading.

            -        Reduction in beam section properties due to bolt holes and weld undercut.

Effects of shear stresses on beam acceptability. - Effect of the capacity reduction based on the unsupported length of the beam compression flange.

25. Cable Tray Qualification 1

In reviewing the qualification requirements for cable trays Cygna , has identified several areas of concerns 1 t i j - A justification is needed for the dynamic amplification - t factor of 1.0. j A justification is needed for the interaction equation used  ! to check cable tray capacity. l I Instances of modifications to cable tray hardware without justification or documentation. have been identified. For horizontal loading (i.e., in the plane of rungs), the truss-like behavior of ladder-type cable' trays has been i assumed to be that of a simply supported beam. This will j affect the section properties calculated using static test i results.  ! f O  ! 1

i Reviolon 1 Page 56 of 62 V(D DSAP VIII l (Cont'd) TABLE VIII.2 (Cont'd) I l l 25. Cable Tray Qualification (Cont'd)

            -      For horizontal transverse loading, the deflection of ladder-cable trays is due to both flexure and shear l                   deformations. Calculations of the moment of inertia of a cable tray section based on tests must use equations that consider both flexural and shearing deformations.

26. Base Angle Design Justifications are needed for the modelling assumptions made in the design of base angles to ensure an adequate design.

l 27. Support Qualification by Similarity Several support types were qualified by similarity to ancther

  'V        support type. The similarity is not always obvious and should be justified. The establishment of working point deviation for individually designed supports based on similarity to standard l            support types must be justified.

28. Critical Support Configurations and Loadings The limited number of support aspect ration used in the destyn of trapere type supports may not cover all the installed

configurations.

l

29. Cumulative Effects of Review Issues A number of the above issues may have cumulative effects which need l be addressed.

i O t i v

l - Revision: 1 l Page 57 of 62 ()

  ~
                                                'DSAP VIII (Cont'd)
                                             . TABLE VIII.3 l                                           CONDUIT SUPPORTS Review Issues Identified in Cyana's November 26. 1985 Letter l

l 1. Controlling Load Case for Design The design of conduit supports was based on the 1/2 SSE (OBE) seismic event being the governing load case. For supporta of specific buildings elevations, the SSE can potentially be the governing load case. This issue also concerns the use of reduced  ; factors of safety for SSE loading. ' I

2. Dynamic Amplification Factors '

The use of an amplification factor of 1.0 for the equivalent static analysis has not been justified. l 3. Combination of Dead Weight and Seismic Responses  ! l Dead weight is added to the vertical sefsnic response, and then combined with the horizontal acceleration components using an SRSS method. This approach can result not only in a resultant load having a magnitude different than that given by the standard consideration method, but also in a dif ferent v.ctor direction.

4. Measurement of Embedmont from Top of Topping l

l Esbedment depth reduction has been allowed for certain supports resulting in bolts being embedded in topping only. This concern extends to bolts which have reduced embedmonts due to architectural topping. i S. Bolt Hole Tolerance and Edge Violation l Bolt hole tolerances are given as a function of the bolt aire instead of being a fixed quantity (1/16"). Minimum edge distance for oversize holes is not specified. [:

6. FSAR Lead Ccabinations Pipe whip jet impingement. and thermal loads are not considered in ,

l design. Design accelerations are used which do not envelope ! Containment Building and Internal Structure spectra. _ - . . --_______ - _ s_ _ - - . _ - - -

L l R:vi:121 1 Page 58 of 62 DSAP VIII ! (Cent'd) i ! l l TABLE VIII.3 i j (Cont'd) i l

7. Support Self Weight

( Support self weights are not consistently considered in the various [ designs, j

8. Torsion of Unistrut Members Torsional loading of unistrut members is not considered in the support design. Unistrut does not support the use of members for torsional loading.

9. Improper Use of Catalog Components

{ AISC-derived allowables are used in the design process. These values are generally nonconservative for axial allowables since catalog allowables are based on the AISI Code which considers buckling of thin open sections. Components are used in ways not intended by vendors.

10. Anchor Bolts A prying factor of 1.$ was used in most cases without justification. In some cases no prying factor was used.

t In a few cases, the 8th Edition of AISC manual was used to " justify a prying factor of 1.0. The connections addressed in this manual (steel-to-steel) differ from the concrete ' attachments used in the conduit support designs. Bending moments in the anchor bolt were not considered in the design of conduit support CST-17. Type 17. I

11. Longitudinal' Loads on Transverse Supports Since conduit clamps provide restraint in three-directions.

longitudinal loads, which were not considered in the design, may be imparted to transverse supports. , i a

1 R:vicions  ! Page 59 of 62 V DSAP VIII (Cont'd) TABLE V111.3 (Cont'd)

12. Hilti Kwik-Bolt Substitutions Replacement of a bolt by a bolt of a larger mise may reduce allowables ntnce the actual spacing may be smaller than that required.

13. Substitution of Smaller Conduits on CA-Type Supports The replacement of a large (greater than 2") diameter conduit by a small diameter conduit (less than 2") may increase the load on the support since the peak spectral value must now be used instead of ZPA.

14 t!se of CA-Type Support in LS Spans in field installations, when conduits run from walls to equipment, O a transition is made between LA (rigid) spann to LS (flexible) span. Thus CA-type support designed to support LA spans may support L5 spana, resulting in an improper assessment of seismic response loade. I

15. ' Stresses in Cable Trays Due to Attached Conduit Supports l Cable trays have not been designed to carry the additional conduit

! weights.

16. Increases in Allowable Span Lengths l Conduit strenses have not been checked when spans where increamed by the ratio of the unrefined to the refined spectra.

l

17. Substitution of Next Heavier Structural Hamber Most supporta are designed to the allowable loads for the liitti Kwik-bolt. The additional load due to hoevier structural members has not been considered.

i l i Revisient 1 Page 60 of 62  ; DSAP VIII (Cont'd) i I i I

• l TABLE VI!!.3 (Cont'd)

18. Clamp Usage Por small diameter conduits (less than 2"), clamps may be teamed to accommodate 3/8" Hilti-bolts. As a result, the minimum edge distance requirements are violated.

Justification of modification made to C708-S clamps is needed.

                                                                                 -       Clamp distortions were noted in the fteld.

i l l 19. Documentation Deviations Between Inspection Reports, CMC's and  ; ! IN-PP Drawings. i f  ! l Three examples are given. l

20. Nelson Stude i The Nelson stud allowables used by Gibbs & Hill do not conform to '

those given by TRW/ Nelson.  ! i

21. Conduit Pire Protection Configurations [

( Cibbe & Hill fire protection weight was assumed considering a round configuration of Thermolag material around conduits. Square , configurations were also listed in the field installations without I checking whether it is enveloped by design assumptions. t

22. Span Increase for Fire Protected Spans l The allowable spans for some fire protected conduit runs are longer  !

than allowable spans for unprotected runs. This issue relates to justification of the conduit stress allowables used in the design. [

23. Grouted Panetrations Loads on the grouted penetrations have not been estimated.

24 Rigidity of CA-Type Supports  ; l Desian calculations for the CA-Type supports did not include i j stiffness evaluations to validate the use of ZPA in calculatina the design loads.

Revision 1 Page 61 of 62 O , . DSAP VIII (Cont'd) TABI.E VIII.3 (Cont'd) ! 25. Enveloping Configurations for Design i Models used in design evaluation did not reflect the most critical support configurations in some cases. Maximum load eccentricities and installation tolerances are also not considered in designs.

26. Design Drawing Discrepancies l Specific items noted.

27 Wikdown Discrepancies Specific construction discrepancies noted. 1 1 l 28. Systems Concept s) l Interaction between supports and/or the conduit and supports is l used to " validate" use of reduced leads on the support or connection. The validation is not fully justified for generic appitcation of typical supports.

29. Cumulative Effect of Review Issues A number of the above issues may have cumulative ef fects which need t

to be addressed. I l l l v

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l 1 , COMANCHE PEAK RESPONSE TEAM ACTION PLAN DSAP IX

                                                                                        ~

Title:

Piping and Supports Discipline Specific Action Plan l i l Revision No. 0 1 Description Original Issue *h$C91gpents

Prepared and Reconsnended by

Review Team [

• I 1

leader J dd

                                            -jh' igd l

Date bfLh6 l )23 H,, Approved by: Senior Review Team h_ Q, f _ A Os g), f., i oete 4 A<. /s r '<4du I O 4

Revision: 'l Page 1 of 14. DSAP IX PIPING AND SUPPORTS DISCIPLINE' SPECIFIC ACTION PLAN 1.0 PURPOSE The purpose of this action plan is to develop reasonable assurance that CPSES. piping and supports are designed in conformance to CPSES licensing commitments including appropriate codes and standards. 2.0 SCOPE The scope of this action plan encompasses the assessment of design adequacy of all large bore ASME Section III Class 2 and 3 piping and.the assessment, and requalification as necessary, of all large I bore ASME Section III Class 1, 2 and 3 pipe supports. Additionally, the adequacy of small bore piping and supports will be demonstrated through verification of selected piping and supports. The , implementation activities include . reanalysis and' requalification by the CPSES Project as well as third-party review of these activities. For further clarification of the scope, refer to Section B of Attachment 2 to this action plan. O

3.0 BACKGROUND

In the area of piping and support design' a nt.mber of external source issues have been identified from the Independent Assessment Program (Cygna), ASt.B proceedings (including documents originated

by CASE), and NRC reviews (TRT, . SIT and CAT, etc.)'.

To resolve all external source issues and further ensure that all ASME. piping and supports are appropriately designed and qualified, Texas Utilities Generating Company (TUCCO) has committed to-perform a comprehensive requalification program. Stone and Webster Engineering Corporation (SWEC) has been retained by TUCCO to perform this reanalysis and reoualification effort.on behalf of the Project. A third-party review of this effort will be conducted in order to provide assurance that the objectives of the Design' Adequacy Program in the piping and supports area are achieved. O

Revision: 1 Page 2 of 14 s -) DSAP IX (Cont'd) l 4.0 CPRT ACTION PLAN 4.1 Project (SWEC) Actions The objective of the Project (SWEC) actions is to conduct structural qualification of piping and supports to applicable ASME Code requirements and CPSES licensing criteria. Details'of the SWEC requalification effort are presented in. Attachment 2 to this Action Plan. 4.2 Third-Party Review Actions The objective of the third-party review of the Project (SWEC) activities is verification of issue resolution, criteria, methodology, piping analysis and support qualification. The third-party review will be conducted as described in the following paragraphs. This review effort will provide reasonable assurance that all identified issues are resolved and currently unidentified issues are detected and resolved. It will also confirm that CPSES piping and supports.are designed in conformance to CPSES ligensing commitments O including appropriate codes and standards. 4.2.1 Areas of Review 4.2.1.1 Issues ( This area consists of third-party. ' identification, review and tracking of external source identified issues which have-been raised regarding pipe analysis and pipe support design. This effort will also include consideration of TRT Issue V.c which addresses design considerations for piping between seismic cate' gory I and non-seismic Category I buildings. The criteria and methodology utilized by the Project (SWEC) for antlysis of these systems will be reviewed by the third-party. J

                                                                 -Revision:    1 Page 3 of 14 DSAP IX (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Following is a description of the tasks included under this activity: Issue Identification This task involves the identification of all applicable ' issues through the review of related documents such as NRC Review Reports (SIT, SRT TRT. SSER, Region IV), ASLB proceedings (transcripts, exhibits,' filings, motions, orders),

                                         'Cygna Independent Assessment Program reports and letters, etc.

Issue Review and Evaluation This task involves reviews of each issue, determination of the significance with respect to the requalification program, evaluation and review of resolutions and assessment of. generic implications for the purpose of identifying potential problems in other design areas. Issue Tracking This task involves tracking the status of each issue to the point of satisfactory resolution and identifying the applicable activities under the requalification program which address.the resolution l of each issue. I 4.2.1.2 Criteria and Standards This activity involves the verification that commitments which establish piping and support-related design criteria and standards are adequately addressed in procedures and other project documents. .The commitment-sources include-the FSAR, design specifications, and the ASME Code. For each criteria source and standard identified, the

                      -     - 2                 -

Ravision: 1 Page 4 of 14 DSAP IX , (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) appropriate criteria and commitments will be summarized. These criteria will be used in the development of checklists for the review of specific program areas. 4.2.1.3 Review of Project (SWEC) Actions The third-party review of Project (SWEC) Actions are separated into four areas: l Procedure Review Small Bore Selection Review l Analysis Review Construction /As-Built Review Procedure Review This activity involves the review of

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procedures developed by the Project (SWEC) for the performance of all activities 1 detailed in Attachment 2 to verify that they are adequate to achieve their intended purpose. This will include procedures developed for: Initial as-built verification l ASME Class 2 & 3 large bore piping reanalysis l - ASME Class 1, 2 & 3 large bore pipe support requalification

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Small bore piping analysis and support qualification Special analysis or testitig Final as-built verification The focus of these review efforts will be to ensure that the procedures adequately address the following: O

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A DSAP IX (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Compliance with Project licensing commitments, codes, and standards

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Resolution of externally identified issues Ability'to accommodate and resolve additional 1 issues ~as needed Definition and verification of design input (including engineering as-built information) Procedural and interface control-Implementation and verification _of

                                                    . hardware installation / modification as necessary
    -s s                                 Small Bore Selection Review-This activity includes an evaluation of the bases for selection of small bore piping and supports used by the Project (SWEC) to demonstrate the design adequacy. The third-party will also review the. selected piping and supports for conformance with these bases. Finally, the basis. established for the conclusions reached regarding the entire population of small bore piping and supports will be reviewed.

Analysis Review This activity involves the review of selected piping analyses and support designs, using

checklists, for compliance to established requirements. Specific information to be reviewed includes the following

Piping Analysis Input to analysis. including drawings, support locations, modeling characteristics, transient loads, temperatures and pressures, e-' equipment and insulation data..and (g) seismic loads, l j l l l

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V DSAP IX (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Analysis outputs (e.g., loads, l displacements, and support functionality) to ensure consistency with the input'and conformance'to applicable code and specification acceptance criteria. Pipe Support Design Design input, calculations, reference drawings, and support sketches to ensure that the functionality and capacity requirements identified in the piping analysis are met and to ensure conformance to applicable. code and specification acceptance criteria.

   - f ~s                             Construction /As-Built Review This review will include an overview of Project (SWEC) activities associated with the       l verification of engineering as-built information to be utilized in the reanalysis and recualification program. ~ Through an evaluation of SWEC procedures and selected          l verification of irplementation, the reviews will ensure consistency between~ analysis /
                                     ' design assumptions and the resultant physical configurations and identify any critical configurations or physical.

relationships that may_ impact conclusions regarding overall design and acceptance. 4.2.2 Review Petho'dology. The conduct of the procedure.and analysis review activities described above will be performed using checklists developed specifically for the review scope. , The verification program will be subject.to procedures l applicable to other aspects of the Design Adequacy Program. 4.3 . Third-Party Reporting

  '{-              Third-party review activities will be documented in a Results Report that includes the following:

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    .j                                                DSAP IX-(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Scope of Activity This will be a detailed description of the activitics i reviewed including drawings, analyses, references, r specific calculations, and procedures. 1 Review Methods This will be a description of the methodology used in performing the reviews including applicable third-party < procedures and checklists used.

                                ~ Evaluation 5                                   This will be a discussion of conclusions and the bases for conclusions from which recommended actions will be determined. In addition the evaluation will address generic implications (if any) applicable outside the piping / supports discipline as well as the adequacy-of
}                                  actions taken to resolve external source' issues.

O Description of Deviations This will be a detailed discussion of deviatiions or concerns encountered ~during the reviews including

probable cause and potential impact.

i Recommended Action , These will be recommended actions'to-alleviate the concerns or correct deviations. Follow up Requirements i If required, additional review-requirements will be identified to assure that potential concerns have been adequately. addressed. 5.0 ORGANIZATION AND RESPONSIBILITIES i 5.1 -Third-Party Organization and Responsibilities Third-party person}}