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FEB 6 1986
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MEMORANDUM FOR: Larry C. Shao, Group Leader Engineering Group Comanche Peak Project FROM: Shou N. Hou, Subgroup Leader Mechanical / Piping Engineering Group Comanche Peak Project
SUBJECT:
AUDIT OF MECHANICAL TRT ISSUES On December 4,1985, the staff and consultants audited Comanche Peak plant for finding CPRT status on five TRT open issues, which are in the Mechanical / Piping areas as identified in the SSER No.10. These issues are designated by the CPRT in their Program Plan as ISAPs V.a, V.b, V.c, V.d and V.e. See Attactment for CPRT presentation on efforts already completed and on-going activities. We found that approaches taken by the CPRT for resolving specific concerns are generally accept-abl e. However, it is unclear at this time how they are going to address generic implications and root causes of these issues. This audit effort consists of 40 man-hours. S ou N. Hou, Subgroup Leader Mechanical / Piping Engineering Group Comanche Peak Project
Enclosure:
CPRT presentation on Mechanical Open Issue Status cc: V. Noonan R. Ballard G. Bagchi C. Tramel A. Vietti-Cook D. Terao T. Westerman, RIV R. Masterson V. Ferrarini C. Richards P. Chen GGsssaph , G-@
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- 5 CfRT Prc.senf afien on Mechanical Of en AGENDA NRC Audit of Mechanic %l TRT Issues - December 4, 1985 - 8:30 AM - CPRT Conference Room o
NRC Audit Team: Sho-Nien Hou Paul Chen Chuck Richards Victor Ferrarini Robert Masterson 8:30 Overview J. Honekamp/H. Levin (5 min.) 8:35 Va: Skewed Welds J. Honekamp/C. Moehlman 9:00 Vd: Plug Welds J. Honekamp/C. Moehlman 9:30 Vc: SCI /SCII Pipe P. Streeter Transition 9:45 Ve: Main Steam P. Streeter -- Line Lift 10:15 Vb: Steam Generator J. Honekamp/L. Arros Upper Lateral Support 11:00 Plant Inspection Areas NRC wants to see -
- Plug Welds Skewed Welds
- Main Steam Line
- S/G Upper Lateral Restraint
- Aux. Steam Line in the area of support number SA-X-019-700-E-35R 0574/ MISC 3
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Pcgs I of 2 ISSUE V.a INSPECTION FOR CERTAIN TYPES OF SKEWED WELDS IN NT SUPPORTS A. Issue TRT could not substantiate that Brown & Root procedures provided proper inspection criteria and inspection records for Type 2 skewed welds (pipe stanchion to pipe stanchion or pipe saddle). B. Summary of Initiatives
- Review of the history of inspection methods for type 2 skewed welds.
- Revise procedures to clarify inspection criteria for type 2 skewed welds.
- Select a random sample of 60' pipe supports with type 2 skewed welds and reinspect the skewed welds.
C. Program Changes None D. Summary of Implementation
- Review history of inspection methods.
TUGr0 review (complete) Third-party overview (in-process)
- Revise procedure (complete).
- Reinspection of type 2 skewed welds in random sample.
Population of NF supports with type 2 skewed welds
-- 327 B6R supports
-- 32 NPSI supports Reinspected 60 B&R supports
-- 102 type 2 welds
-- 2420 inches of type 2 welds 0574/ MISC 3
Page 2 of 2 ISSUE V.a INSPECTION FOR CERTAIN TYPES OF SKEWED WELDS IN NF SUPPORTS Reinspected 8 NPSI supports
-- 13 type 2 welds
-- 278 inches of type 2 welds 12 B&R welds and 1 NPSI weld were undersize. All meet ASME code requirements.
Evaluating weld size trend.
-- Fraction of undersize welds (12% B&R, 8% NPSI)
-- Fraction of weld length undersize (3% B&R and NPSI)
-- Weld size distribution
-- Weld margin distribution E. On Going Activities
- Third-party review of history of inspection methods.
Evaluation of weld size trend.
- Preparation of Results Report.
F. Steps Required For Closure Same as (E) above. l 0574/ MISC 3
e Page 1 ef 1 HISTORY OF SKEWED WELD INSPECTION 8/82 Inspection methodology questioned by Fegion IV, Type l' Skewed Weld. Stanchion weld inspection questioned by site QA, Type 2 Skewed Weld. 9/82 Rev. 2 of QI-QAP-ll.1-28 issued to address both type 1 6 2 skewed welds. Rc 1. 13 ef QI-QAP-ll.!-28 iesued to incit!de hold point at fitup since most type 2 skewed welds are pressure boundry weld requiring fitup inspection. 12/82 Rev. 9 of QI-QAP-ll.1-26 incorporates stanchion to pressure boundry inspection criteria. QI-QAP-ll.1-28, Rev. 16 issued referencing QI-QAP-ll.1-26. 3/83 Grinding by Paint dept. produc,ed under size welds - Back fit -- inspection. 8/83 Rev. 13 of QI-QAP-ll.1-26. issued to incorp:: ate work sheet for reproductability. 4 & 6/84 Revisions to clean up attachments to 11.1-26. 1/85 QI-QAP-ll.1-28, Rev. 29, issued to specifically to include criteria for stanchien to pipe pad and stanchion to stanchion fillet welds. 0574/ MISC 3
I i Pcg3 1 of-2 i ISSUE V.d PLUG WELDS A. Issue TRT investigsted an alleged generic problem reguarding uncontrolled " plug" welding of holes in pipe and cable tray supports. TRT requested an assessment of the impact of uncontrolled plug welds on the structural integrity of the supports. B. Summary of Initiative
- Selection and testing of inspectors.
- Inspection of two random samples of pipe supports and two random samples of cable tray supports.
- Evaluation of DCA 5347 which provided generic authorization for welding unused holes in cable tray supports.
- Preparation of mockups to assess maximum extent of inclusions in a poor " plug" weld.
C. Program Changes None D. Summary of Implementation
- Inspector Testing
- Fabricated 16 mockup supports with 53 plug welds. Supports painted to specification limit.
- Detection rate - 82% average 94% maximum
- Cable Tray Inspections 2 samples of 60 23 plug velds detected, all meet AWS DI.1
- Pipe Support Inspections
- 131 ASME plus 51 non-ASME SC-I supports inspected No plug welds detected
- Evaluation of DCA 5347 (plug welding unused holes in CT supports)
- Document confusing but correctly interpreted by EBASCO in Cable Tray as-building program.
Project to revise DCA to eliminate confusion and provide backup documentation. 0574/ MISC 3
Pags 2 of 2 ISSUE V.d PLUG WELDS
- Evaluation of mockup plug welds
- 12 mockup welds prepared by welder directed to make worst case welds
- Radiographed and sectioned mockups Preparing evaluation E. On Going Activities
- Evaluation of Results 3
- Preparation of Results Report F. Steps Required for Closure Same as (E) above e i I
i
~ 0574/ MISC 3
1.. .
- Page 1 of 2 ISSUE V.c DESIGN CONSIDER 1 TION FOR PIPING SYSTEMS BETWEEN SEISMIC CATEGORY I AND NON-SEISMIC CATEGORY I BUILDING A. Issue Certain Piping systems were identified as passing from a seismic category I building to a non-seismic category I building without isolation. Because of this, concerns were raised about the seismic isolation criteria in general between seismic and non-seismic category I sections of piping.
B. Summary of Initiatives
- Identify all piping with a seismic /non-seismic interface
- Review / describe events related to pipe which initiated issue.
- Provide recommendations to piping reanalysis effort to insure adequate consideration of seismic /non-seismic interfaces.
C. Program Changes The action plan initially identified that the acceptability of the -- Because of seismic /non-seismic interface criteria would be established. the pipe reanalysis efforts, it was determined tiat this would best be addressed during the reanalysis. The action pla. was revised accordingly~ . D. Summarv of Implementation
- Identification of seismic /non-seismic pipe interfaces All interfaces have been identified.
- Included are eleven (11) where pipes on both sides are non-seismic category I (see below).
- Pipe which initiated issue Pipe identified oy TRT was non-seismic portion of auxiliary steam line.
- Pipe was analyzed seismically (by computer) on one side to minimize postulated breaks (per FSAR).
- The interface anchor was modified without apparent consideration being given to changes in interface loads when this modification was made.
- Ten (10) other pipes have similar interf ace.
0574/ MISC 3
Pcge 2 of ; I 9 ISSUE V.c DESIGN CONSIDERATION FOR PIPING SYSTEMS BETWEEN SEISMIC CATEGORY I.AND NON-SEISMIC CATEGORY I BUILDING
- Recommendation Piping reanalysis program to include adequate justification of interface methods used.
- Eleven (11) non-seismic pipes to be analyzed using criteria consistent with that for seismic /non-seismic. interfaces.
E. On-Going Activities
- Results Report draft in review'
- Piping reanalysis efforts include development / application of justifiable criteria for interface anchors / supports F. Steps Recuired for Closure
- Completion of Piping Reanalysis efforts
- Completion of DAP Action Plan IX results report to insure adequate --
considerations of interface. 0574/ MISC 3
Pcgt I of 3 ISSUE V.e INSTALLATION OF MAIN STEAM PIPES A. Issue Based on allegations, it was identified that there may have been incorrect installation procedures applied to the Unit 1. Loop 1 main steam line. These included use of the main polar crane and come-alongs to restore the line to its correct installation position. Additionally, modifications to permanent pipe supports were necessary during the restoration. Also, it was identified that existing specifications and procedures may not adequately address construction and engineering practices associated with temporary supporting of pipe, especially during flushing. B. Summary of Initiatives
- Modify specification / procedures to assure quality of piping and equipment is not affected during temporary supporting.
- Perform stress analysis of Unit 1, Loop 1 main steam and feedwater piping to address conditions associated with initial installation, flushing and final installation. --
- Periorm NDE at locations indicated by analysis where allowables might have been exceeded.
- Review existing' baseline UT examination for region.= of concern in Unit
- 1. Loop 1 main steam and feedwater.
- Review hydrotest records of Unit 1,. Loop 1 rain steam and feedwater piping to verify piping quality.
- Provide analysis of Unit 1, Loop 4 nain steam line for coldiriens similar to Loop 1.
- Provide assessments of other safety-related riping whf;h may have bee'n involved with similar incidents with tecporaty sur- rting.
C. Program Changes The identified initiatives have had no changes. The scope of the third-party changed somewhat because of changes in RLCA responsibilities en other efforts for TUGCO. 0574/ MISC 3
' Page 2 og 3 ISSUE V.e INSTALLATION OF MAIN STEAM PIPES D. Summary of Implementation
- Specification / procedure modification Specification / procedures revised to address TRT concerns and RLCA recommendations re: temporary supports
- Unit 1, Loop 1 Stress analysis Analyses complete All stresses well below code normal condition allowables
- NDE
- RT, UT performed at two locations based on stress results (although stresses well below allowables)
- Welds met applicable acceptance criteria
- Review of UT Records -
- UT records of Unit 1 Loop 1 main steam and feedwater piping reviewed for shop, field and pre-service inspection welds No concerns identified
- Review of Hydro test records Hydrotest records of Unit 1, Loop 1 mainsteam and feedwater piping reviewed No concerns identified
- Unit 1, Loop 4 stress analysis Analyses complete All stresses well below code normal condition allowables
- Although stress allowables weren't exceeded, NDE was performed at two. locations with acceptable results
- Other piping
- Twelve (12) NCR's identified where pipe fit-up may have been a problem
- NCR's reviewed and dispositions considered acceptable not warranting further. investigation.
0574/ MISC 3
Page 3 of 3 ISSUE V.e INSTALLATION OF MAIN STEAM PIPES
- Construction and mechanical engineering' personnel interviewed to identify any other instances similar to the main steam line; no other instances identified.
E. On-Going Activities Results report under going final review. F. Steps Required For Closure Results. Report.
Pcg2 1 of . ISSUE V.b IMPROPER SHORTENING OF ANCHOR BOLTS IN STEAM GENERATOR LATERAL SUPPORTS A. Issue The TRT was unable to substantiate the alleged bolt cutting incident due to a lack of installation records for the Unit I upper lateral support. Both' the unauthorized bolt cutting and the lack of installation inspection records violate QA procedures and Criterion XVII in Appendix B to 10CFR50. B. Summary of Initiative
- Inspect Steam Generator Upper Lateral (SGUL) bolts in.both Units.
- Evaluate Project calculations for required thread engagement for the SGUL support bolts.
- Evaluate fabrication / installation process for the SGUL support to assess the cause bolt modification / thread damage.
- Assess the potential generic applicability of the bolt thread engagement issue for two other populations:
Richmond inserts in ASME pipe supports Bolted connections using blind holes
- Evaluate process for specifying inspection attributes for thread engagements and the associated dcrumentatic. requirements.
C. Program Changes
- Inspection of SGUL bolts on hold pending reanalysis cf the SGUL bolted connection.
- Embedment design criteria and implementation are being addressed in the Design Adecuacy Program.
D. Sum =ar" of Implementation
- Inspection of SGUL bolts on hold. 120 bolts and bolt holes in Unit 1 inspected. No Unit 2 bolts inspected.
0574/ MISC 3
. Peg 2 2 of 2 7
ISSUE V,b IMPROPER SHORTENING OF ANCHOR BOLTS IN STEAM GENERATOR LATERAL SUPPORTS E. On-Going Activities
- Reanalysis of SG upper lateral support
- Richmond insert sampling
- Other bolted connection sampling Procedure / Process Review F. Steps Required for Closure
- 3rd Party Review Adequacy of Support Calculations
- Complete Inspection of SGUL Bolts
- Complete Inspection of Richmond Insert and other bolted connection populations ~.
- Complete Procedure / Process Review
- Results Report l
i 0574/ MISC 3
[ N February 10, 1986 O Memo to: Bob Masterson From: Ernie Thompson Reference Documents:
- 1. ISAP Vd from CPRT Rev. 2
- 2. TVEC response of 11/22/85 to Staff ccmments on CPRT Rev. 2
- 3. Draft of SSER on the CPRT program play, Item Vd 4 ISAP Vd from CPRT Rev. 3 I have reviewed the above documents and have redrafted the SSER, Item Vd writeup. Please understand that I did not write the original SSER draft. I was sent a copy to critique. In the marked draft I am sending you, item (8) on page 13 is a concern expressed by someone else (Not Charlie Richards as I have checked with him) and I am not sure that I understand what is meant by it. I have merely carried it along. If you cannot find.out who made it, my evaluation is drop it as I have no concern with the meaning'of that paragraph.
Item (7) on page 13 was part of my critique but was omitted from the original Staff comments in a document identified as Board Notification No. 85-087, which is referenced in the redrafted SSER. The most important comment I have made is felt. I am concerned that the ability to detect " plug welds" is of a level which does not provide a high degree of confidence and question its satistical significance but I do not know if the program can be made statistically significant. M Ernie Thompson
( (f) 57pyc SSM 70 mcwm: Lmr w k m u AfS/pos6 7p 3rW cemesm /A~s CN2r'MV') y SECTION IV - 2.4 - Staff Evaluation of Construction Ad;quacy Plan l O l' 2.4.1 Introduction (Cont.) Item V.d: Plug Welds j The TRT investigated allegations that incorrectly located bolt holes in 1 baseplates, pipe supports, and cable tray supports were " plug welded" without authorization, with undocumented weld filler metal and without Quality Control inspection. The TRT concluded that the repair of misdrilled holes by welding was not prohibited by the appropriate ~ ! editions of the. applicable Codes. The TRT review of Brown & Root specifications established that m sdrilled holes were regarded as base ga ' to be dispositioned by NCR. action or material defects and were engineering evaluation. The TRT concluded that the identification of undocumented " plug welds"
! and the difficulty in detecting them raised a generic concern as to the potential existence of an unknown number of unauthorized " plug welds" of questionable quality. Potentially defective welds in highly stressed areas could have safety significance.
The TRT required that the Applicant modify a plan of action already 1 , proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocumented " plug welds" on the ability of pipe supports, cable . tray supports, and [' baseplates to perform their intended function. I e: Repositioning of the Main Steam Line. The TRT investigat n allegation that the 32- line was forced j into position by the polar ne and come-alongs and that i
" tension" induced in the li sult of movement during the alleged incident was still ent in the line.
The determined that repositioning of the Unit i loo MS line had been performed due to settlement of temporary supports. The TRT4garned
. - _ , . . . _ _ , . . _ _ . _ _ _ _ . , _ _ _ , , . _ _ _ . . . , , , _ ., ,__,_,._m.,_~.. _.__..-._..,_._,___m.__ .. . , , . _ _ , _ . , , . , , _ ,
I f SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan .. Y~ 2.4.2 CPRT Approach (Cont.) C[ @ I h
\ Itr V. ince the oject Pioing =ad Supports Pregros. (PPSP) tuyethe ith the Design Adequacy Program (DAP) includes provisions for s1 ificant piping reanalysis and associated support requalificati n, the RT will address the major concerns of this issue within t PPSP and DAP. The scope of this specific action plan will be limi ed to the following a tivities as outlined in Sections 4.1.1 through .1.3 of ISAP Y.c:
o Identification o all Unit 1, 2 and comon, pip g which has a seismic /nonseismic terface which whill incl de:
- Category I piping taring a no -Category I Building.
Pfping with a class c nge f Category I to non-Category I.
- Piping runs which have a rtion which is seismically analyzed to postulate eak
- NNS piping runs whi have a p tion which is seismically analyzed to post ate breaks.
o A review and dicus on of the events related to nd the reasons for the auxiliary eam pipe situation on which this i ue is based. o Recommen tions to the PPSP and/or the DAP based on the sults of the items above. Any potential implications which sho be c sidered during the PPSP and DAP implementation will be highlighted. Item V.d: Plug Welds diEb hbiv3 C? D I4c b M h. ection 4.1 of ISAP V.d the CP"T h:: defin:d inith2 objectives: kev 4 *A
- 1. Th ve, ff;co;.;6n of the presence or absence of undocumented " plug welds" in ASME pipe supports and baseplatesfod aruan k Np h Ut 9 toeOA D.
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,, SECTION IV -
2.4 - Staff Evaluation of Construction Adequacy Plan 1 - 2.4.2 CPRT Approach (Cont.) l bmM~
- 2. Ycrific: tion of the quality of cable tray supports containing undocumented plug welds. . . . . -
o accomplish the first objective, the CPRT in Section 4.1.1.1 has itted to select for examination a sample mem of pipe supports and 1 e p base lates representative of reactor Unit 1 and comon components and a g 4.- secon p g ipe suppg g and g a gplate,s, g resentjt[ve op rgac, tor ,, o b *,w ennrw- i d [si edio'dkN NNUb b5Nb.k
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accepi....:: =&r :=_ As specified in Sections 1.1.2 and 4.1.1.3 when a suspected " plug weld" is found, the paint wi be removed from the support, the presence of a " plug weld" verified, visu 1 inspection made, and comparison made , to prior documentation to determi if the " plug weld" was or was not authorized. NCRs will be issued for nauthorized " plug welds" and engineering evaluation perfomed to eva uate structural integrity of the baseplate of support. In Sections 4.1.1.4 and 4.1.1.5 the CPRT ca....it c that if any support or b \ baseplate lacks structural 'integrit because of a unauthoriz s u, a d or s ite rt_e s p%'u i expandedgor 1 undocumented " plug weld",,jhgaglep will be o in r =:d t; 100% inspection 3ffilounauthorizedoru ocumented " plug welds" are found, it will be concluded that the structur integrity of ASMEpipesupportsandbaseolateshasnotbeendebradedby u h .i,&e+ % a, cow 4,+c>" d6e Nhe esence
-4 b \ v of such welds f structural integrity is not a fe ted, the need for !
I A additional inspection will be based on observed trends in the in pection ( results. i l 1
( l SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan 2.4.2 CPRT Approach (Cont.) , Finally, in Sections 4.1.1. through 4.1.1.8 the CPRT has stated that a review of existing QC inspection and documentation procedur 1 be f made to identify.necessary changes and also a third-party tverview of the total effort will be made. ! / t
/
- To accomplish the second objective, as desyribed in Sections 4.1.2
- through 4.1.5, random samples of cable, tray supports in both Units 1 and 2 will be inspected and, if necessary', subjected to engineering i
/
evaluation. ,The investigative, steps, in general, parallel those for ASME pipe supports and baseplates. Results will be used to assess the 4 root cause and to detemine generic implications. Finally, precedidg either of the above objectives, Section 4.2 describes
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the develo nt of a vige in,spectiogro edugtgigifg" ug gg q welds", giqding g eri {for, paint - .g l4 g y } g , ,.3 1 he c5 U31,it'y Assurance Program or peIsonnel qualification requirements of the CPRT Program Plan. t
\ItemV.e: The CPRT approach to resolve the TRT concerns resultin
! t TRT investigation of the allegations regarding forced mo ent of the M ine and improper welding of temporary supports described in Section 4. "CPRT Action Plan," of ISAP V.e, Rev . A review of Sections 4.1 a 4.2 of the CPRT plan indica that specific engineering evalua ns of the MS line i dent and a generic study of possible damage to othe iping are posed. The specific engineering eva at includes: . reviews of procedures for pipe erection and placem of tempo and pemanent pipe supports; interviews of person involved in the ine incident; evaluations of procedures and p ctices; analytical evaluatio of full parametric variations o analysis inputs for the MS line inci t; significance of stresse nd support loads resulting from the analytica valuations; rev s of existing UT examinations and hydrostatic test dat or the affected MS line; and a possible reinspection program. _ _ . . . - _ _ _ . . _ . . , , , , _ ~ . _ , , , _ . . _ . - , - - -
I
! SECTION IV -
2.4 - Staff Evaluation of Construction Adequacy Plan j
,' f.</ p Tpff GVM-<M GJ6[ W l
- he'ti5T response to the three questions raised in the NRC Staff Ev untion dated September 30, 1985 have been responsed to in a ma r accept le to the NRC staff in Revision 3 of the CPRT Program an.
Item V.c: Th staff has reviewed the action plan for AP Vc, and is f satisfied that t CPRT Plan understands the or 1 concern and has l the potential to ide ify items similar to t original concern. In addition, the NRC staff s perfomed an dit at Stone & Webster EngineeringCorporation(SW offic . The purpose of this audit was to discuss with SWEC their scop nd methodology for addressing this concern. The SWEC method h been emined by the staff to have the potential to identify address this c cern. l The CPRT res se to the four questions raised the NRC Staff Evaluati dated September 30, 1985 have been respon to in a manner i acc able to the NRC staff in Revision 3 of the CPRT Pr am Plan. Item V.d: Plug Wel Prelimin tique he st the CPRT Progr Plan r several conce s which have been adequati yr ed. -The j
- "- following items remains .- oleed:
n.; e;. "Ms I In 41 1 1; +6 re : .d pr::;r;' i; m.; ..... made " le Plan will be based on ide f31ng wi 5 percent confidence a rate detectable plug we s 5% greater. The smallest j random sample which wil ve thi dence level and rate of unauthorized or undocumented plu is 60, with an acceptance number of zero." These statements contradicto . t is not explained whether the Plan is e is ng, with a confidence le 5%, the ! rate of detecta plug we s or the rate of unauthorized or ruso, m e b ^T ..c: t ? ri't::tir- ^o { vedocumertee v ive -E. ~ I s saart- atc.-es- &greate, oF5%Tess. I i r (2) The Staff pxp'ressed co cern that there uncertainty as to the ability to.de'tect a plug ld cover y paint nd that thi certainty should tie factored into he s e size. Th CPRT 1 ction4.15as ~ rep'5rted the results of pection of simul te le tray suppo V { l l l . .- _ .. . _ - , - - - . - _ - . .
g SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan 2.4.4 Conclusions (Cont.) Ntem V.b: The staff concludes that if ISAP V.b is impleriented as in Plan the areas related to the original concern will dentified and resol based on sound engineering practice, FS osmitments and NRC guidelines. owever, the staff has rais concern that the use of trends of inspection ta to detennin e need for additional inspections must be review on case-by-case basis. Item V.c: The st concludes that i AP V.c is implemented as stated in the Plan , areas related to the origina oncern will be identified and r ved in a manner consistent with sound eng ing practice, R consnitments and NRC guidelines. Item V.d: For the issue concerning pl , the staff concludes that thr. J are important ques e ated to the CPRT Program Plan scope and f methodology must be satisfactorily answered prior to approval of th an. J w lleeJ.e: For the issue concerning the repositioning of the main am line, t ecific engineering evaluation and generic escribed in ISAP V.e, Revis 3 of the CPRT Program P des an acceptable basis for resolution o . issues neerns resulting from the TRT investigations of allegatio ding forced movement of the main steam line and impr elding of t ry supports. However, final acceptabili the staff is contingent upo fication by the CPRT of pr implementation o.f the details of the spec ineering j uations of the main steam line incident and the gener c s of possible damage to other piping. l
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$5 8"% UNITED STATES
. 4 NUCLEAR nEGULATORY COMMISsl0N f
.ja WASHINGTON, D. C. 20555 s *"** / JAN 9 1986 MEMORANDUM FOR: V. Noonan, Project Director Comanche Peak Project FROM: L. C. Shao, Engineering Group Leader Comanche Peak Project
SUBJECT:
COMMENTS ON IE INSPECTION OF CPSES DESIGN ADEQUACY PROGRAM SCOPE VALIDATION PROCESS AND REVIEW CHECKLISTS
Reference:
J. M. Taylor draft letter to W. G. Counsil, undated We have reviewed the referenced IE inspection report and consider that it effectively addresses the scope of the Comanche Peak Response Team's
)
Design Adequacy Program. The report clearly documents the inspection ' team s activities and findings. Our coments on the inspection report are provided for your consideration in Enclosure 1 to this memorandum. It is suggested that these coments either be incorporated in the IE inspection report or be used as guidance for future IE inspections of DAP implementation. Please do not hesitate to call me at 37908 if you wish to further discuss our coments. ,. 7 DN L. C. Shao, Engineering Group Leader Comanche Peak Project
Enclosure:
As stated cc: B. Grimes D. Norkin' R J. hewmaker W. Saffell C. Hofmayer R. Masterson D. Jeng S. Hou ! D. Terao V. Ferrarini J. Calvo L. Chandler l l 1 l
'Bb7 J '
- .4 C0tNENTS ON IE INSPECTION REPORT ON COMANCHE PEAK DESIGN ADEQUACY PROGRAM
- 1. We_ agree that the experience of the staff perfoming the Design Adequacy Program is a key element in the strength and validity of the conclusions drawn from this program. Therefore, we concur with the IE team's intent to followup during implementation inspections the appropriateness of the balance between reviewer experience and the prescriptiveness of review checklists.
- 2. TERA oversite of the cable tray and conduit support effort should be 4 strengthened. We don't perceiv.e the current oversite program as suffi-ciently active or timely. This is illustrated by the number of deviations identified by the staff in a recent audit. We expect the CPRT, through an active oversite program using experienced people, to identify deviations and effectively dispose of them.
- 3. NRC-IE may want to consider the following comment during future audits.
TERA has established HDAs and developed checklists for the evaluation of each area. As the supporting documentation is- developed, checklist revision is likely. If checklist revision should occur during the imple-mentation phase, TERA should have a procedure or process for evaluating the effect of checklist revisions on completed evaluations. 4 Since the IE audit, TERA has documented their method for establishing the homogeneity of design activity groups (DAP-21). We suggest that future IE audits address implementation of this procedure. .In this regard, documen-tation packages should be developed for each homogeneous design activity (HUA). Design evaluation documentation should include the design activity definition, the basis for homogeneity, the checklists and its basis, design evaluation with results and conclusions. ) ] 5. Appendix 3, Mechanical Components: With respect to active valves, there j did not appear to be a commitment to establish the root cause and review the generic implications concerning the apparent misinterpretation of certain Gibbs & Hill specifications, e.g. a review of the G&H QA program to detemine how specification discrepancies are addressed and followed up.
- 6. Appendix 8, Item 18, Piping / Supports: The TRT has recently found a violation with the use of later code addenda for piping design use, (Category 51, Allegation AP-43).
- 7. Design and construction problems have been identified for cable tray and conduit supports which are non-ASME related. Therefore, emphasis should be placed on similar types of safety-related supports that are non-ASME related.
- 8. Appendix 7 - Question 1: The NRC comment says that the design process should be looked at as part of the design review scope. Neither the TERA response nor the team evaluation addresses this concern.
O Ts En gin c a rin g A n alysis Servic es Inc. EfS -- = upk,gy. q,,
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To: D. Jeng
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From: V. P. Ferrarini Date: February 11, 1986 g
Subject:
Review Rev. 3 of CPRT Program Plan ing^ rgs brap Civil / Structural Concerns on dw w~~h
References:
- 1) Letter from V. S. Noonan to W. G. Counsil dated August 9, 1985; NRC Staff Evaluation of the M Comanche Peak Response Team Program Plan. ./-
- 2) Letter from V. S. Noonan to W. G. Counsil dated MLa/
September 30, 1985; NRC Staff Evaluation of - the Comanche Peak Response Team Program Plan - Detailed Comments. ITfd
- 3) Letter f rom W. G. Counsil to V. S. Noonan dated November 22, 1986; Response to NRC Staff Evaluation of the Comanche Peak Response Team Program Plan. Mr Wicrv.,.
Attached are my detailed comments on the CPRT response to the NRC Staff questions raised in the above referenced documents relating b< *b to Civil / Structural concerns.
}
V. P. Ferrarini, P.E. .Af VPF/ecm Att. l
1 .' a e CPRT Nov. 22 Current Egy J /_C.o2ERnts. Sj;ittus_. NRC R m L _etter Aug 9 Section A Concern: The basis for selection of the Adequately covered. Pg 6 Pg 11 of major concrete and steel structures to be 48 reviewed is not provided.
. Response: The CPRT answered this concern in response 3.1.A, para. 1. A review of their response with respect to'the C/S 4 issues concludes that response will ade-quately cover this concern.
Aug 9 Section A Concern: The Program Plan does not address Pg 6 Pg 12 of a civil structural wall that has numerous 48 loadings (i.e. due to pipe support and cable tray, etc.) to access the adequacy of this i wall in view of these additional loadings. Response: It appears that a wall will not l be looked at as a part of this plan. Again the CPRT letter ref. 3.1. A, para.1. for its resolution of this concern. I do not see where 3.1.A para. 1 addresses this concern. Aug 9 Section A Concern: Size of the sample in certain Adequately areas may not be adequate. covered. ! Pg 6 Pg 12 of DAP Phase 3 addresses this 48 ' Response: ~ again. 3.1.A para 1 is referenced. The response appears to be adequate in this case. Concern: Cable Tray & Conduit Supports Adequately Aug 9 Section A covered in i Pg 9 Pg 31 of using functionability as the-acceptance 48 criteria. Rev. 3. Response: CPRT Program Plan was revised in Rev. 3 to make sure that the FSAR de-sign comments are the acceptance criteria used. We must get a_ general agreement between Must get l Snpt 30 Section B agreement App. A Pg 12 of all groups as to the definition of Pg 3-8 180 " safety significance" and how it wil? between all be applied for this project. We must NRC groups. determine as a group that " safety signi-ficance not deviation from FSAR commitment is the item that will be used to determine sample expansion. I feel that the use of 4
" safety significance" as a basis for sample expansion must be reviewed on a case by.
case basis. Rev. 3 appears to evaluate the issue in this manner, however, this-imple-i mentation in this area must be reviewed. e
- , , . . . . , . , . . . - _ - - . , - - , - . - - , , , . . , , . , . _ ,,, ,n,,, .., , . . - , , - - . .-,._,.m,,,,,-.n, ,, ,. ,c.,,,mg,..,,,es ,
- i CPRT -
Current Nov. 22 Etatua NRC ReL_ Latt_el Rev. 3/CoDm2Diji Concern: Accessibility of hardware. Adequately Sept 30 Section B covered in App. A Pg 30 of Response: Section II.2 now states "the Pg 3-16 180 bases for decisions on inaccessibility Rev. 3. Item 4 will be documented for each population and records maintained which identify the hardware items and attributes deter-mined to be inaccessible." This response appears to address the concern. ISAP I.c Electrical Conduit Supports This concern deals-with the ability of Adequately Sept 30 Section B App. A Item 2 each conduit support to act independently covered. Pg 22 Pg 40 of in its required. restraint direction and 180 only in that restraint direction (ex. an x rest acts only in x dir, and not in y and z directions.) Response: The conduit runs are analyzed as a system and therefore the loads are system loads developed by a F.E. program. This is an item that the C/S group is following and will be designed to with-stand all applied loadings based upon the stiffness analysis used to qualify the entire conduit system. . ISAP II.a Reinforcing Steel in the Reactor Cavity Concerns have been addressed in Rev. 3 Adequately Section B covered. Pg 48 of by modifying the flow chart which makes 180 the chart. consistent with the text. ISAP II.6 Concrete Compressive Strength It appears that the CPRT did not under- NRC must Sept 30 Section B clarify Item 1 stand the NRC comment. I also do not App. A their Pg 3-26 Pg 50 of understand the comment and think this concern. 180 comment needs either to be withdrawn or additional information must be provided to the CPRT. The CPRT changed the flow diagram to re- Adequately Sept 30 Section B covered. A App. A Item 2 flect the NRC comment and agree with Pg 3-26 Pg 50 of text. This change is incorporated in 180 Rev. 3 to the CPRT Program Plan.
CPRT - 1 Nov 22 Current Letter _Rev. 3/Commentg glatus , NRC Reft _ i ISAP II.d Seismic Design of Control Room Ceiling Elements Sept 30 Section B Concern: It was not clear that there was Adequately Item 1 a Unit 2 damage study group. covered. App. A .
- Pg 3-27 Pg 51 of This concern has been adequately answered
! 180 in the Nov. 22 letter. It is clear that there is a Unit 2 damage study group, however, little work has been undertaken in Unit 2 damage study. Item 2 This concern relating to the flow diagram Adequately has been adequately addressed in the Nov. covered. ] 22 letter. ISAP II.e Rebar in Fuel Handling Building Sept 30 Section B Concern relating to the cutting of rebar Adequately App. A Item I has been adequately addressed. covered. l Pg 3-28 Pg 53 of 180 Sept 30 Section B The CPRT revised their Program Plan flow Adequately App. A Item 2 chart to address these concerns in Rev. 3. covered. Pg 3-28 Pg 53 of j 180 t I ISAP V.b Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports Sept 30 Section B The CPRT response is an adequate method Adequately App. A Item 1 to resolve this concern dealing with the covered. i ! Pg 3-32 Pg 62 of material records of other portions of this 180 restraint. l ? Item 2 The CPRT revised their Program Plan and Adequately Rev. 3 contains the necessary flow covered.
- diagram change.
i i Item 3 The CPRT response to the concern relating. Adequately ; to generic problems in bolt engagement covered. has been adequately _ addressed in the 4 Nov. 22 letter. J l l k-
. 0 CPRT ~
Current Nov. 22 Etattia HPS_Erf Letter HeL_3/49mment_f.i . ISAP III.b Polar Crane Shimming The CPRT response to the concern relating Adequately Sept 30 Section B covered. App. A Pg 71 of to the possible damage continued use of Pg 3-39 180 polar crane could have upon the crane Item I support system, has been adequately addressed in the Nov. 22 letter. The CPRT response to the concern that Adequately Item 2 a repeat load test should be performed covered. if any modifications are made, is con-sidered adequate since the only modi-fications anticipated would not require a retest. The response to the concern that the Adequately Pg 72 of covered. 180 cadwelds discussed are non-structural, Item 3 has been answered since the cadwelds are only used as grounding. This response is considered adequate. The CPRT response to the concern that Adequately Item 4 covered. all the " Crane Manufacturer's Associa-tion of America, Inc." specification 70 will be met, has been satisfactor-ily answered since all the concerns relate to the crane rail supports and not the crane-itself and therefore, the specification does not apply to the support. ISAP VII.b.4 Anchor Bolt Installation This concern deals with the use as Additional Sept 30 Section B NRC review App. A Pg 98 of " safety significant" as the only required. Pg 3-53 180 type of defect that would cause a ' Item 1 sample to be expanded. Since this is a general concern relating to all sample expansion, a general agreement must be reached by the total review I think that " safety signifi- l team. i cant" is not the only indication i that should expand a sample. l
l l- . CPRT . Current Nov. 22 Status NRC Ref2 Letter Rev. 3/Commentg ISAP VII.b.5 Electrical Cable Tray Raceway Support Inspections Sept 30 Section B The concern deals with the general Additional Pg 99 of question of sample size. The CPRT NRC review App. A required. Pg 3-54 180 explained their basis for the sample Item 1 size (95/95 confidence level) . It is now up to the NRC to accept or reject their sampling method and basis. Therefore, the resolution of this concern depends upon the NRC stand concerning sample sire and sample expansion requirements. The CPRT response to the concern A'dequately. Sept 30 Pg 100 of 180 that the standards against which the covered. App. A Pg 3-53 Item 2 review is performed are not listed, has been addressed in the Nov. 22 letter. The specific documents reviewed will be identified in ISAP VII.c record file. DSAP VIII Civil / Structural Discipline Specific Action Plan The concern that the HVAC will not Adequately Snpt 30 Section B covered. App. A Pg 107 of address the design process, includ-Pg 3-58 180 ing all issues raised in the cable Item 1 tray / conduit support areas has been addressed. Reviewed checklists will include the type of concerns that were raised on other non-ASME support designs. Therefore, the NRC concerns have been adequately addressed. The CPRT response in the Nov. 22 Adequately Item 2 letter concerning root cause and covered. generic implications is considered adequate.
CPRT , Nov. 22 Current NRC ReL. Lett3I Hey,_3/_Cpqvacat1 ~ Status Pg 3-59 Item 3 This concern deals with the size of Additional NRC review Pg 109 of samples (i.e. only one mechanical and one electrical mounting) reviewed. required. 180 This is a very general concern and as such, requires a. united response from the NRC concerning their sampling (size, basis method of selecting, etc.) accep-tance criteria, and the acceptance of the Homogeneous Desie:n Activity (HDA) approach. ' The HDA is part of Phase 3 and has been reviewed by various NRC groups. The key to the answer to this question concerns the acceptance and application of the HDA process. I feel that if the NRC accepts the HDA concept, then the .CPRT response is adequate. Pg 3-59 Item 4 The CPRT has answered this question on Additional Pg 122 of embedments as part of their response NRC review 180 to concerns raised in 3.1.A, para 1. required. As noted before, it does not appear that 3.1.A para 1. addresses the issue of ' wall loadings taking into consideration the additional loadings from equipment, pipe supports, cable tray support, etc. Pg 3-39 Item 5 The CPRT response also references Additional Pg 123 of 3.1.A para 1. It also appears that the NRC review 180 liner plate will not be reviewed as was required. requested, however, 3.1.A para 1. gives a justification for excluding the liner. , This item should be reviewed by the t person who was responsible for this. comment. i f u
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Document Name-NUO797 TC ]gg
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Document Co ents: CRESS DRAFT 2/18/86 KEEP THIS SHEET b'ITH DOCIRENT MAR 14 BRS Teledyne Engineering Services h.h
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. o SAFETY EVALUATION REPORT RELATED TO COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN, REVISION 3 1 MAR 1 1 mas Teledyne Engineering Services 02/18/86 NUO797 TC
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Io .- o I TABLE OF CONTENTS 1 l 1 Page ABSTRACT ............................................................. CONTRIBUTORS ......................................................... ACRONYMS AND ABBREVIATIONS ........................................... , I. EXECUTIVE
SUMMARY
II. DESIGN ADEQUACY AND CONSTRUCTION ADEQUACY COMMON ELEMENTS ....... III. STAFF EVALUATION OF DESIGN ADEQUACY PLAN . . . . . . . . . . . . . . . . . . . . . . . .
". IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN . . . . . . .. ' . . . . . . . . . .
V. REFERENCES ...................................................... _E 02/18/86 NUO797 TC
[e - a ABSTRACT The Safety Evaluation Report on the Comanche Peak Response Team (CPRT) Program Plan for the Texas Utilities Generating Company application for a license to operate Comanche Peak, Unit 1 and 2 (Docket Nos. 50-445, 50-446), located in Somervell County, Texas, has been prepared by the Office of Nuclear Reactor Regulation and the Comanche Peak Technical Review Team (TRT) of the U.S. Nuclear Regulatory Commission (NRC). Subject to acceptable resolution of the areas identified in the subject evaluation, the staff concludes that the CPRT -
. Program Plan, if adequately implemented, will provide an acceptable assessment of the Plant's design and construction adequacy.
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02/18/86 NUO797 TC
o a I. EXECUTIVE
SUMMARY
TABLE OF CONTENTS Page 1.0 Introduction .................................................... 2.0 CPRT Program Plan Description ................................... 2.1 Design Adequacy Plan (DAP) .................................
- 2. 2 ConstructionAdequacyPlan(CAP)..n.d..@.kdllk...........
3.0 S umma ry Ev a l ua ti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1 Design Adequacy Plan ...................................'.... L 3.2 Construction Adequacy Plan ................................. 4.0 Summary Conclusions .............................................
- 4.1 Design Adequacy Plan .......................................
4.2 Construction Adequacy Plan ................................. 5.0 Outstanding Issues .............................................. 5.1 Design Adequacy Plan ....................................... 5.2 Construction Adequacy Plan ................................. 6.0 Co n f i rma to ry I s s u e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1 Design Adequacy Plan ....................................... 6.2 Construction Adequacy Plan ................................. 02/18/86 NUO797 TC
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Document Name:
- NUO797 SEC I Requestor's ID:
LO Author's Name:
- c. trammell Document Comments:
CRESS PH-303 KEEP THIS SHEET WITH DOCUMENT s D I
, C - O i e I. EXECUTIVE
SUMMARY
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Evaluate and recommend solutions for all issues raised by the TRT, ASLB, SSER, CAT, SRT, SIT, Region IV, Intervenors, Applicant and CYGNA IAP.* Determine root cause and generic implications of each found safety significant deviations or trend of non-safety significant deviations. deviations. Perform self-initiated evaluations for the purpose of assuring that M there are no undetected and uncorrected safety significant' deficiencies at CPSES. The CPRT's role through this Program Plan is to develop and implement a program designed to resolve issues and determine root cause and generic implications of each safety significant deficiency and trends of non-safety j significant deviations and for the self-initiated evaluation of the quality 4 of construction and adequacy of design. CPRT is also charged with advising h TUEC management as to that CPSES has been designed, constructed, and tested
$> k in a manner which assures it can be operated without undue risk to public health and safety. _
- c.
, The NRC staff reviewed the Comanche Peak Response Team Program Plan, Revision 2, with programmatic and detailed concerns provided TUEC in August and September of 1985, respectively. TUEC responded to the staff's concerns by letter dated November 22, 1985, and by Revision 3 to the CPRT Program Plan, Reference 1. Since the completion of its review o of Revision 2 to.the CPRT Program Plan, the staff continued its evaluation with numerous audits and concluded this review phase with detailed examination of Revision 3 to the Plan. This SSER describes the staff's evaluation of the CPRT Program Plan through Revision 3. It addresses the scope, approach, and evaluation aspects of the plan.
Region IV will inspect and audit the implementation of_the Plan for those areas related to construction quality and reflect any finding it may have in periodic inspection reports. Self-initiated design aspects of the Plan
- Acronyms are defined on page fii of this report.
03/10/86 I-2 NUO797 SEC I
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will be inspected and audited by the Office of Inspection and Enforcement with the results also documented in periodic inspection reports.4 NRC will continue its effort by reviewing and auditing the root cause and generic implication evaluations, the conclusions drawn from these evalu-ations and adherence by CPRT to implementation of the overall process described in the Program Plan. p pwg x 'tY S 8 5, w&a. - - w'M'* W*Le~e y7 g g.g.* gg4.;gg M Q A f wW b t 9 G S (2.** :.r . w, 03/10/86 I-3 NUO797 SEC I
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eack s s . 2.0 CPRT Program Plan Description The CPRT Program Plan, Revision 3, is the TUEC document which describes the scope and method of operation of the Comanche Peak Response Team. The responsibilities of the Comanche Peak Response Team include the resolution of all open issues, the identification of the root cause of each found safety significant deficiency or trend of non-safety significant deviations and the completion of a self-initiated evaluation of the design adequacy and construction quality of CPSES.4The Program Plan itself includes the
@V0 CPRT charter, program principles, structure, methodology, process and organization. Three appendices form the nucleus of the Program Plan.
Appendix A addresses the design adequacy aspects of the Program Plan. The-quality of construction and the adequacy of the QA/QC program are addressed in Appendix B. All individual issue and disciplin5 specific action plans are included in Appendix C. All evaluations are performed using a similar process regardless of whether itisaIE: EmMSNN % - ' S: = evaluation. This process is initiated by defining the scope and methodology for the topic or issue to be evaluated. Procedures and checklists are then developed as guidance for the reinspection effort and document review. All relevant standards and applicable acceptance criteria ar lected in the develop-ment of checklists. Any discre,tarcy identified during the reinspection reevaluation or document review process are evaluated for their safety significance. Mikr,Ppotcauseevaluationsareperformedandadeter-mination regarding potential generic implications is made for each identi-fled discrepancy. Finally, corrective actions are identified as are actions designed to preclude recurrence in the future. While the process for evaluation is identified in each issue specific or discipline specific action plan, the output from this effort will be docu-mented in individual results reports. Each results report will identify any found deficiencies.along with the evaluation of these deficiencies. The results of individual issue specific evaluations are collectively i evaluated within the construction quality and design adequacy programs. I l i 03/10/86 I-4 NUO797 SEC I
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E & A Summary Report for each discipline area will be prepared summarizing the r results of the effort and fulfillment with the objectives of the CPRT Program. , 2.1 CPRT Design Adequacy Program Plan The Design AdequiFy~ Program-Plan (DAP) is the CPRT's approach for evaluating and resolving a number of concerns regarding the adequacy of the CPSES design and design process. Its objective is to provide assurance that there are no undetected safety significant errors in the CPSES design. The CPRT intends to accomplish this objective by performing the following three activities:
- a. Evaluation of specific design and programmatic designs process issues raised by external sources.
. IN6M
- b. Investigation of the the root cause of each htmd safety significant deficiency. ,
- c. Performance of a self-initiated evaluation of selected additional l design areas.
. External source issues are addressed by an independent documentation W . rdi~ew of the design methodology and process related to 'each issue. This includes drawings, calculations, specifications, acceptance criteria, and
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procedures. , The self-initiated evaluation is performed by categorizing the design activities into the following specific disciplines:
- a. Electrical, Instrumentation and Control Systems and Components.
- b. Mechanical Systems and Components.
- c. Civil and Structural
- d. Piping and Supports.
03/10/86 I-5 NUO797 SEC I
F A Discipline Specific. Action Plan (DSAP) describes the scope of each. discipline and the approach for evaluating each discipline. Each DSAP includes the categorization of design activities within each discipline and the refinement of these groupings into homogeneous design activity groupings. Items from each homogeneous design activity (HDA) will be evaluated. The auxiliary feedwater system is the focus of this review activity but items from other systems will be selected to assure that all design activities are reviewed and represent a level of complexity typical of the design process. Results of specific reviews provide the basis for conclusions made regarding the design process. The b' asis for extrapolation of specific reviews to other systems is the homogeneous nature of the design activities and the level of complexity of the activities selected for review. Results reports and a final design adequacy program report will document the implementation of the DAP and the resulting conclusions. e; Piping and pipe supports design are not addressed by the DAP in the maiiner r described above because "a complete reevaluation of this area is being e performed by Stone and Webster Engineering Corporation (SWEC). The work u of SWEC and other outside organizations performing in a ~similar manner 5 will be reviewed by the CPRT. All identified deficiencies will be evaluated individually for its safety significance as will trends of nonsafety significant findings. Summary reports will be prepared for each discipline. An evaluation of
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the overall adequacy of the CPSES design and design process will be made by integrating the results of the individual discipline specific action plans. This evaluation will be reported in the final design adequacy j program report. 2.2 CPRT Construction Adequacy Program Plan ! l The adequacy of the construction QA/QC program and the quality of con-struction performed within scope of that program have been questioned by a number of sourc'se external to TUEC. The CPRT has been charged by TUEC with responding to and resolving these concerns. The CPRT's 03/10/86 I-6 NUO797 SEC I i _. _ _ _ _ -._. _ _ _ _ _ ___ _ _ _ _ _ _ - _ _
er o l construction adequacy program is designed to evaluate questions concerning i construction QA/QC and the adequacy of installed hardware. Specifically, the CPRT's objectives for the construction adequacy program , are to fully resolve all of the external source issues, assess in an inte-grated fashion all identified safety significant deficiencies and to make a statement about both the adequacy and quality of construc' tion' at CPSES. i
. The CPRT's program has the following three components: '
- a. Evaluation of external source issues, .
- b. Root cause evaluation and generic implication assessment for each ,
identified safety significant deficiency or trend of nonsafety sig-nificant. deviations, and
- c. Self-initiated reinspection of a sample of the balance of the hardware within the scope of the QA/QC program.
4 Issue-specific action plans (ISAP) document the CPRT plan for resolving
& each external source issue. All construction QA/QC issues whether of a
- V. hardware nature or a QA/QC programmatic concern, will be the subject of an 1 issue-specific action plan. A single ISAP describes the process and 4 methodology for the CPRT's self-initiated hardware reinspection and docu-2 mentation review. A matrix is then de,veloped to provide a cross reference between each issue or concern and thA respective action plan which addresses
, , it. This matrix provides assurance Wa't.al1@ xternal source issues have been addressed by the CPRT. .
The self-initiated construction reinspection / documentation review program is designed to collect information on the quality of construction work activities at the Comanche Peak Steam Electric Station. Construction activities are divided into the following three areas: Civil / Structural Electrical Mechanical 03/10/86 I-7 NUO797 SEC I
s o This program consists of a sample reinspection of,QC-accepted safety related construction work supplemented by review of related quality
' documentation for nonrecreatable in process inspections. Both units and ? ,
the common areas are being addressed by this program. The methodology , used for construction evaluation is to first categorize the installed safety related hardware into populations made up of homogeneous work activities. Samples will be selected from these populations and the work activities evaluated for the quality of construction. Two' samples will be selected from each population for evaluation. First, a ; :t random selection will be made from the complete population. Then, engineered samples will be selected at random by expanding the initial sample to ensure evaluation of a like number of items located in systems required for safe shutdown. Items will be evaluated using checklists and inspec-tion procedures developed from the original installation documents. All deviations will be f ir " ^" : " evaluated to determine their safety
, significance. The totality of the information will be evaluated for adverse trends. Results will be documented in results reports which wi'll , document the' inspections of individual populations and well as the overall results of the construction adequacy evaluation effort.
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F L . Document Name: NUO797 SEC II TC Requestor's ID: 9820 Author's Name: XEROX 860 SS Document Comments: CRESS REDRAFT 2/18/86 KEEP THIS SIEET WITH DOCL7ENT 4 9 h h-,_ .________.______._____-.__--__)
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II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PLAN COIN 0d ELEMENTS e 9 9 4
F i - u . II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PLAN COMMON ELEMENTS TABLE OF CONTENTS Page
- 1. QA/QC Activities ................................................. _ . . _ .
1.1 I n t ro d u c ti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . .
- 1. 2 CPRT Approach ..............................................
1.3 Staff Evaluation ........................................... 1.4 Conclusions ................................................ 2.
"T<acm y { 0iscrep e 45 neu er ...mc ........ ............................................
2.1 Introduction ............................................... 2.2 CPRT Approach .............................................. 2.3 Staff Evaluation ...........................................
- 2.4 Conclusions ................................................
- 3. Corrective Actions ..............................................
3.1 Introduction ............................................... 3.2 CPRT Approach .............................................. 3.3 Staff Evalc3(ion 4f;l....................................... 3.4 Conclusions ................................................
- 4. CPRT/SRT Independence ...........................................
4.1 Introduction ............................................... 4.2 CPRT Approach .............................................. 4.3 Staff Evaluation ........................................... 4.4 Conclusions ................................................ 03/10/86 11 NUO797 SEC II TC
m . TABLE OF CONTENTS (Continued) Page
- 5. Interfaces ......................................................
5.1 Introduction ............................................... 5.2 CPRT Approach .............................................. 5.3 Staff Evaluation ........................................... ; 5.4 Conclusions ................................................ 4 h 1 h i I f 4 9 e f l l 03/10/86 111 NUO797 SEC II TC
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NUO797 SEC II Requestor's ID: 9820 Author's Name:
- TRAMMELL, C.
Document Comments: CRESS PH-303 KEEP THIS 'SEET WITH DOCUMENT
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- 1. 0 QA/QC OF CPRT ACTIVITIES - 0 1.1 Introduction f
bheCPRThasbeenorganizedtoconsistofi..J:;; t, third party experts who will advise TUGC0 of existing plant conditions, and who will make recommendations for the resolution of any problems which may exist. , The Program Plan, Revision 3, Appendix G entitled "CPRT-Third Party. Quality Assurance Program" was developed in response to direction from the CPRT, Senior Review Team (SRT) and is founded on the importance and scope of the third party review.
- 1. 2 CPRT Approach The CPRT QAP is structured in line with the three categories of CPRT' activities.
A separate program is provided for each activity. (1) Overall Responsibility Overall responsibility for the quality of CPRT activities resides with the SRT. This is accomplished in the following manner:
$TU OM
- SRTwillEi$55 the results of all audits of CPRT activities, SRT will N : corrective action response to audit findings, SRT will perform, or have performed for them, special audits or reviews of CPRT activities as deemed necessary and documentation adequacy will be determined by reviews performed by the File Review Committee.
(2) Issue-Specific Actions Plans - QA Elements . It is the position of the SRT that the principles of the CPRT Program Plan, the CPRT Policies and Guidelines and the implementation requirements specified in each ISAP generally provide the QA elements 03/10/86 II-1 NUO797 SEC II
necessary for ISAP activities. Supplemental instructions were prepared and issued in the civil / structural and mechanical / miscellaneous areas because of the extent of third party activities related to engineering evaluations and calculations in these areas. The CPRT Program documents address the following criteria of 10 CFR 50, Appendix B,' b uffi:f =t datzi' t: m ; Jy U = 'iRT that act' 2 !:: p;rf:r::d b, the third p;rt, respe,-dS;; t: ISfP: " h = =d- - +a Qb.vveiaga. Criteria No. Descriotion CPRT Program Guidance . 1 Organization CPRT Program Plant Section VIII 2 QA Program CPRT Program Plan Section III.k 5 Instructions, CPRT General Policy for Conduct Procedures and of Action Plants Section 5.3 and Drawings each ISAP 6 Document Control CPRT Program Plan Section III.j
- and Guide on Central and Working Files 10 Inspection CPRT Program Plan Section III.k and Policy on Inspection Personnel 15 Non-conforming CPRT Program Plan Section III.k Conditions and Policy for Conduct of Action Plans (Section 5.5) 16 Corrective Action CPRT Program Plan Section III.k and General Policy for Conduct of Action Plans Section 5.5 17 QA Records CPRT Program Plan Section III.j and Guide on Central and Working Files 18 Audits Checks of the activities per-formed under TRT ISAPs are accom-plished by Review Team Leader overview of activities (CPRT Pro-gram Plan Section VIII.b.3); the reviews and audits conducted by the CPRT Results Report and File Review Committee (Attachment 4 to CPRT Third-Party QA Program);
' and SRT review and approval of Results Reports (CPRT Program Plan Section VIII,b.1) 03/10/86 II-2 NUO797 SEC II L
' O In addition to the generically applicable guidance listed above, the direction provided by specific ISAPs implement measures of other QA elements (e.g. control) as they are appropriate to the specific issue. (3) Quality of Construction Program A Quality Assurance Program has been developed for the Quality of Construc (QOC) activities and addresses the following 10 CFR 50, Appendix 8 Criteria: Criteria Title 1 Organization 2 Quality Assurance Program 4 Procurement Document Control 5 6 Instructions, Procedures and Drawings Document Control 7 Control of Purchased Material, Equipment, and Services 10 Inspection 15 16 Nonconforming Materials, Parts or Components ' Corrective Actfon 17 QA Records 18 Audits JM Overall responsibility for QA activities rests with the ERC Division Manag Quality Assurance who has the authority to issue Corrective Action Reques Step Work Orders. The Procedures and Project Assurance Group are the on-site representatives of the ERC Division Manager of Quality Assurance and are sible for identifying and reporting on the status of the quality program by conducting surveillances of the QOC activities. The results of these surveil-lances are documented and reported to the Manager of Quality Assurance a Review Team Leader. In addition, the Manager of Quality Assurance conducts audits of QOC activities in accordance with ERC QA requirements. The Division Manager of Quality Assurance is organizationally independent froni the CPRT . l i 03/10/86 II-3 NUO797 SEC II
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(4)' Design Adequacy Program A Quality Assurance Program has been developed for the DA'P activities and ad-dresses the following 10CFR50, Appendix B Criteria: - Criteria Title 1 Organization 2 Quality Assurance Program 3 Design Control . 4 Procurement Document Control 5 - Instructions, Procedures and Drawings 6 Document Control 7 Control of Purchased Material, Equipment and Services 15 Nonconforming Materials, Parts or Components 16 Corrective Action , 17 QA Records 18 - Audits In addition, should activities in the areas of Inspection, Testing or Measuring, and Test Equipment be required appropriate Quality Assurance requirements will be established or subcontractors with applicable Quality Assurance Programs , will perform the activity. Responsibility for ensuring effective implementation of the DAP QA Program resides with the DAP Quality Assurance Manager who reports directly to the DAP Review Team Leader. Audits will be performed, or led, by individuals qualified to the requirements of ANSI N45.2.23 Sections 2.3.1 through 2.3.4 for Lead Auditors. 1.3 Staff Evaluation The Qualit.v Assurance Program provided by Revision 3 of the Plan establishes a level of program quality commensurate with the activities of the CPRT. II-4 03/10/86 _ NUO797 SEC II
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' g#
(1) Overall Responsibility p Overall responsibility for the quality of CPRT activities is with the SRT. Results of audits and corrective action in each category are provided to the SRT. The program for implementation of audits needs to be detailed with re-spect to frequency, type, areas, technical assistance, reporting and distribu-tion for those QA audits that will be performed by (or for) the SRT. These audits are important to assure SRT QA involvement and control that is commen-surate with their responsibility. Sufficient experience in Quality. Assurance requirements is available in the SRT to understand the magnitude of audit find-ings, to determine the impact on program quality and to properly administer their responsibility for quality. (2) Issue-Specific Action Plans Although a formal QA Program is not provided for ISAPs, 10CFR50, Appendix B. e Criteria applicable to all ISAPs are provided in the various sections of the ' 4 Program Plan and Policies. In addition, individual ISAPs implement measures of l 0 other QA criteria as they are appropriate to the issue of concern. Tim e;; a d iet.. w.m u, pyg. gg . . i go . ..; ;;, Criterion 12, Control of Measuring and TestEquipment,lameoftheNAPsrequirefieldmeasurementandtheuseof tools, gages and instruments, and Criterion 12 provides assurance that instru-ments are properly calibrated and controlled. Since' formal QA audits are not being performed within the ISAP organization it is important that the SRT assure that its' audit activities sample ISAP efforts: (3) Quality of Construction Program A formal QA Program is provided for the QOC activities. Eleven criteria of 10CFR50, Appendix 0, are addressed in the QOC QA Program. However, Criterion 12, Control of Measuring and Test Equipment is not a part of the QOC QA Program. QOC personnel will be performing inspections which include measurement, there-fore it is important that the tools, gagas and instruments used are properly calibrated and controlled. Adoption of Criterion 12 by QOC will assure that this occurs. - 03/10/86 II-5 NUO797 SEC II
6 . QA activities are the responsibility of the ERC Division Manager of Quality Assurance who is independent of the CPRT organization. Ongoing QA surveillances of QOC activities are performed by the Procedures and Project Assurance Group. This group has two reporting responsibilities; (1) to the ERC QA Manager for QA surveillance activities and (2) to the Review Team Leader for non-QA activities. This dual reporting responsibility could appear to create conflicts. However, since the ERC QA Manager performs independent audits and is organizationally removed from all CPRT activities, and the Project As'surance Group non-QA activi-ties are essentially Engineering Inspection Assurance activities, QA. activities are sufficiently removed from day-to-day inspection and evaluation activities. Since SRT retains overall responsibility for qualitpmplementation of the CPRT activities, the QOC organization chart % re 2.13 should indicate that the ERC Division Manager of QA has reporting obligations to the SRT. (4) Design Adequacy Program , A formal QA Program is provided for DAP activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the DAP QA Program. Should inspection activities ; be required appropriate QA requirements will be established or subcontractors with applicable QA Programs will perform this activity. Inspection activities, if required, should be covered by formal adoption of Criteria 10 and 12 of 10 CFR 50, Appendix 8. DAP QA responsibility resides with the DAP QA Manager who reports directly to the Design Adequacy Review Team Leader. Although this reporting chain is not as separate as that used in the QOC Program, it is acceptable under Criterion 1 guidelines. In addition, the DAP QA Manager has reporting responsibilities.to the SRT. This responsibility to SRT should be clearly indicated on Figure 1 of the DAP QA Program. Since the DAP has the responsibility of reviewing and accepting activities being performed by the Comanche Peak project it is important that the DAP QA Program be structured to assure audit of these project _ activities. Extensive reanalyses of piping, supports and cable trays are being performed by the Comanche Peakproject. Since the organizations performing the reanalysis activities are 03/10/86 II-6 NUO797 SEC II
o . implementing their own QA Programs, subject to TUGC0 audits, it is important that the DAP sample these QA activities. For example, an important input to this ef fort is the as-built configuration of hardware. In the piping and pipe support area, SWEC has performed sample walkdowns to determine the adequacy of current as-built data for elements they consider to be critical to design. In addition ~, SWEC will be relying on any deficiencies in piping and support as-built data reported by QOC. Based on this, it is critical that DAP assure that suffi-cient data is obtained and that the quality of the data is acceptable. In the area of cable trays and supports, a complete walkdown is being perfo.rmed by Ebasco/Impell to develop as-built geometry prior to analysis. It is critical that DAP assure that the quality of this as-built data is acceptable.
- 1. 4 Conclusions The CPRT QA Program provided in the Program Plan is acceptable for the current
- CPRT activities. During implementation of the Program Plan the staff will ,
confirm that the following staff requirements have been satisfactorily resolved: 1 (1) Details as to frequency, type, areas, technical assistance, reporting and
- distribution of QA audits, including audits of ISAP activities, must be provided.
(2) Revise Figures 2.1 (QOC Organization Chart) and Figure 1 (DAP Organization Chart) to indicate reporting responsibility of the QA manager to'the SRT. (3) Describe how the DAP QA Program is to be implemented to assure the quality of as-built data obtained for extensive reanalysis programs. (4) The Program Plan must address how 10 CFR 50, Appendix B, Criteria 10 and 12 will be implemented for those activities in ISAPs, QOC and DAP where applicable. I l i 03/10/86 II-7 NUO797 SEC II
b 4 7 d. A c t t % oF Dit cS&# hcMS
- 2. 0 ^CCCPT."'C: C'"TE?lA e 2.1 Introduction As the CPRT Program Plan is implemented, discrepancies will be identified between the intended and actuci design or construction details of the CPRT. These dis-crepancies will vary widely in importance. Itisessentialtoaver/ification or reinspection program to be effective that a systematic procedure be estab-lished and implemented to assure that they are all properly evaluate.d, both individually and collectively, to identify safety signifiance, root causes, generic implications and corrective action.
2.2 CPRT Aoproach Revision 3 of the Program Plan includes Appendix E, "CPRT Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Dis-crepancies Identified by the CPRT." Appendix E provides requirements for the classification of items, the evaluation process to be used, discussion of a tracking system and roles and responsibilities for CPRT personnel. The classi-
; fication and evaluation process sections of Appendix E provide separate guidance for Design, Construction and Testing adequacy, including more detail definitions and the evaluation process used for individual and programmatic discrepancies.
The approach to adverse trending of related observations, deviations or defici-encies indicative of a pattern exhibiting a discernible commonality are provided. Root cause and generic implications will be evaluated for all deficiencies and adverse trends.' In addition, Appendix E provides root cause and generic impli-cation evaluation for special cases. For example, when a deviation results in a substantial loss of design margin a root cause and generic implication evalua-tion will be performed. Identification of special cases will be situation-spec-ific and cannot be generically defined. 2.3 Staff Evaluation The evaluation process defined in Appendix E does not provide sufficient de-tail on safety-signific, ant evaluation. This concern is primarily related to . the fact that safety-significant evaluations of discrepancies are currently 03/10/86 II-8 NUO797 SEC II
- 4 I
underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern are piping and cable trays and their supports.) Until this revised information becomes available as " plant record documentation" then the safety-significance evaluation process cannot be completed. Any evaluations made using existing documentation must be revisited when the new documentation becomes available. The major reason for this is that TUGC0. has elected to perform extensive reanalysis of piping, cable trays and their supports which could result in hardware modificatfori related to optimization or deficiencies or, different design documents and values which form the basis for the safety-significant evaluation. Based on this, the staff feels that safety-significant evaluation and the potential for scope expansion must be based on final plant documentation. This position does not preclude the fact that exist-ing issues which led to the current reanalysis of piping and cable trays must be evaluated for root cause and generic implication to assure that programmatic deficiencies do not extend beyond the boundaries covered by the reanalysis efforts. 4 .A second concern is rel'teda to the f::t th:t ::fety- significant evaluations 7 must be performed using Code or Regulatory approaches. That is, the techniques
.1 used and the extent of the evaluation must address each critoria which formed v the basis for the original design. For example, the use of actual material
< properties versus Code defined material properties could be acceptable but does
.not preclude the fact that all evaluations. committed to in the FSAR must be
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addressed in order to establish margins on all segmygs of tg, acceptance cri-teria.' Actual material properties (if higher than Code minimums) may be of value in evaluating primary stresses and functionality but do little to change the fatigue margin. This concern is not limited to Design discrepancies but
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includes Construction discrepancies for which safety- significance is determined through the use of Design evaluations. t$ b
..m .4. is .mm M ..hr. ti.ut There W e lack of discussion in the Plan on the approach to be used in root cause and generic implication determination. In order to understand any CPRT proposed evaluation, the Plan needs to define the terms " root cause" and " generic implication." This ir critical, since the depth and breadth of the root cause evaluation will be a function of the CPRT understanding of these terms. The sta,ff~ anticipates that the CPRT will consider the following, as a minimum, in determining the root cause of deficiencies:
03/10/86 II-9 NUO797 SEC II
~ < Personnel Process Procedures Design (as it effects construction) Materials ' Management "TL A b w M T
- Atk g Ar. th;r r g ui = Loir eu.. . .. : reiaceu co auve, ac 'T, c.. ding. Me discussion in Appendix E is general in nature and uses a set of examples to define,the pro-cess by which a set of items could create a pattern for concern. The examples given are related to a design process. The approach used by the CPRT is to evaluate Homogeneous Design Activities (HDA) rather than to review the design process. The concern is that evaluation of HDAs may not provide the appropriate information for trencing as defined in Appendix E.
2.4 Conclusions tmWg f DISe g w sr l a s The A;;;pte..:: C #+
#2 is acceptable and during the implementation phase of the Program Plan the staff will confirm that the following staff concerns have been satisfactorily resolved. -
(1) The techniques used and the extent of the safety significant evaluation must address each criteri)(which formed the basis for the original design. SA (2) Safety significant evaluation of discrepancies related to the self initiated design or construction program and the potential for scope expansion must include evaluation using final plant documentation. This does not preclude the fact that existing issues must be evaluated for root cause and generic implication. (3) The Plan must define the terms " root cause" and " generic implications" including those items to be considered in making these evaluations. (4) The Program Plan must provide that design process as well as Homogenous Design Activities will be reviewed to determine an adverse trend. 03/10/86 II-10 NUO797 SEC II
3.0 CORRECTIVE ACTIONS 3.1 Introduction The CPRT Program Plan provides for appropriate corrective action for all deviations or. deficiencies identified during the CPRT's verification and reinspection program. Corrective actions will be implemented by the CPSES Project. The extent of third party overview depends upon the nature of the corrective actions and the third party's assurance that such activities are being properly implemented. 3.2 CPRT Aoproach Revision 3 of the Plan includes Appendix H, "CPRT Procedure and Policy for the Development, Approval and Confirmation of . Implementation of Corrective - Action" which describes: , the process through which corrective action will be defined for deviations or deficiencies identified by the CPRT, the process through which the CPRT third party will review and approve the definition of corrective actions for all deficiencies and for certain C, categories of deviations identified by the CPRT, and the nature and extent of CPRT third party ;;c.-o; overviews of the implementation of defined corrective actions. (1) Corrective Action Definition . Once the individual CPRT Review Team Leader (RTL) classifies a discrepancy l as a deviation (failure to meet a design commitment or specification) or a I l deficiency (a deviation determined to be safety-significant) the CPSES Project is responsible for: performing 10CFR50.55(e) reportability evaluations, defining appropriate corrective action, 03/10/86 II-11 NUO797 SEC II
obtaining CPRT RTL concurrence in the defined corrective action for a safety-significant deficiency; programmatic deviation or deficiency; design deviation involving failure to meet FSAR, licens-ing or regulatory criteria or commitments; and a deviation reportable unde'r 10 CFR 50.55(e). The CPRT RTL is responsible for determining the adequacy of the corrective actions submitted by the CPSES Project for review. In the event that the RTL determines the proposed corrective action is inadequate and cannot r.esolve the situation with the Project, the SRT is responsible for resolving t.he concern. The Executive Vice President of TUGC0 is responsible for responding to the SRT with the TUGC0 position. In addition, the CPRT RTL may recommend proposed corrective action to the CPSES Project. SRT approval is required for CPRT recommendations for corrective actions that: ,
- a. Are programmatic in nature,
- b. Resolve safety-significant deficiencies, and
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- c. Resolve design deviations that could involve a change to existing licensing or FSAR commitments.
(2) Overview of Implementation The CPRT must be satisfied that, when implemented as defined, the CPSES Project corrective action will correct the nonconforming condition identified and, will preclude the recurrence of similar conditions in the future. The CPRT RTL will be responsible for performing w..T: - '^ 7 overviews of the implementation of corrective action for which f. hey were responsible for reviewing and approving. These wiii....:t: g overviews are intended to ensure that the corrective actions have been effectively implemented for each:
- a. Programmatic deviation or deficiency,
- b. Safety-significant deficiency, l ,
I 03/10/86 II-12 NUO797 SEC II
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- 3. Design deviation involving a failure to meet FSAR and licensing commitments, and
- 4. Specific deviation that meets reportability criteria of 10 CFR 50.55(e).
In general, the overview involves a review of documentation. In addition, l where reinspection is required for corrective actions related to QOC activities, the CPRT will either witness the reinspection performed by the CPSES Project or perform independent reinspection. 3.3 Staff Evaluation
.,evision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirmation of implementa-tion and responsibilities of the CPRT and the CPSES Project. The only majo,r
- comment the staff has is related to the timing of SRT approval of CPRT RTL determination of the adequacy of corrective actions defined by the CPSES Project. Appendix H provides two alternatives, approval on an ongoing basis as corrective actions are developed, or approval as part of the Action Plan Results Report approval process.
The Staff feels that the SRT should approve (or disapprove) corrective actions on an ongoing basis as they are developed. This approval should follow that of the CPRT RTL. It is felt that this would keep the SRT more in line with CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES Project involved in lengthy discussions when the RTL does not agree with the proposed corrective action. 3.4 Conclusions The CPRT Procedure and Policy for the documentation, approval and confirma-tion of implementation of corrective actions is acceptable. However, we require that the SRT approve corrective actions on an ongoing basis subsequent to approval by the CPRT RTL. 03/10/86 II-13 NUO797 SEC II-
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[ 4.4 Independence of the CPRT/SRT Orcanization 4.4.1 Introduction j The Comanche Peak Response Team (CPRT) Program Plan, Revision 3, was initiated by the Texas Utilities Generating Company (TUGCO) to address concerns and issues raised by allegers, the NRC Technical Review Team's (TRT) inspection of the l Comanche Peak Steam Electric Station (CPSES) and oth'er external' sources. The 4 verification and corrective action program.is a comprehensive, detai. led and fully documented effort to determine the adequacy of the plant's design, con-struction,~ quality assurance.and pre-operational testing. An essential part of a verification program requires that the persons and organizations implementing the plan should have sufficient authority, organiza-tional freedom, independence, and objectivity to identify quality problems and to verify the implementation of solutions. Such persons and organizations per ' forming quality assurance functions should report to a management level such f[
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.: that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations are provided as delineated in 10 CFR 50, Appendix B. In addition, the individuals assigned the responsibility for assuring any portion of a verification program should have direct access to such levels of management as may be necessary to
. perform their functions. .
4.4.2 CPRT Approach The Applicant recognized the necessity for the objectivity of verification per-sonnel to implement a credible CPRT program. In this regard CPRT personnel had r to meet specific requirements such as knowledge and experience, integrity, objectivity, no financial interest, and no previous involvement in the Comanche . Peak Steam Electric Station (CPSES) project activities related to their CPRT activities. To meet this objective the CPRT developed a "CPRT Objectivity Questionnaire" that all personnel, except for clerical and certain administra-tive personnel were required to answer and sign. In the few cases where these objectivity criteria were not met, they would'be promptly identified by the CPRT and provided to the NRC along with any necessary justification. 03/10/86 _ II-14 NUO797 SEC II
- a The organization for the CPRT effort is essentially all third party personnel except for the Senior Review Team.(SRT) Chairman and the CPRT Program Director.
These two individuals, while they are TUGC0 employees do not have any responsi-bility for the construction cost and schedule of the CPSES. To further assure the objectivity, independence, and credibility of this effort all the verification and corrective action activities will be performed under CPRT quality assurance programs that meet the requirements of 10 CFR 50, Appendix B. f n aidition to the quality assurance program, the applicant has established an , Overview Quality Team (0QT) to assure senior TUGC0 management that the CPRT meets the objectives established for this verification program. The CQT will l not have any active part in the implementation of the CPRT program but will g function as an independent audit group. The OQT will review the elements of ( the program to a depth and frequency as necessary to assure management that,all
< the program directives are met. All necessary documents will be available to the OQT as needed. The necessary auditors / inspectors and assistance will be E ded to enable them to evaluate the implementation of the effort.
M CPRT program will be documented effort. In addition, : .t F@s meetings are held in the Arlington Texas vicinity so that interested 0 parties may review the progress of the ver CP)m T W i sgl effort. The applicant has committed, when the final Issue Specific Results Reports are filed with the NRC, to make them available at the site for public review along with the sup-( g documentation. y 9 4.4.3 Staff Evaluation To determine that the independence of the CPRT effort met the requirements of 10 CFR 50, Appendix B and that there existed the required authority and organi-zational freedom, including sufficient independence from cost and schedule the NRC Staff reviewed the TUGC0 and CPRT organization charts and position descrip-tiot,s, intekviewed the managers and key personnel of the TUGCO, CPRT, SRTM Review Team [eaders, .;;d OQT.J In addition, the staff reviewed the work and experience Gesumes and the "CPRT Objectivity Questionnaires" of the managers, engineers and inspectors associated with the CPRT effort. l 03/10/86 II-15 _ NUO797 SEC II i _.
g
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principal objective of these interviews and reviews, b the J the C"", managare ="d '~" ;:r::rn:! was to _ m r t itude towards Quality Assurance; +": :::::it; ':- it, : - - m: :.., ::::. th;t th:;' c^"'d l eet perform an in' dependent and objective review. 4.4.3.1 Organization l i i The overall charge to the CPRT is to advise TUGC0 ma'nagement whether there is reasonable assurance that the Comanche Peak Steam Electric Station c.an be opera-ted without undue risk to the public. Th= a g ri::th.J m um. : :'feCPRT o m <. ~ % , +uno n,.nnni73 H nn +b " consists of a Senior Review Team which formulates policy and directs the activities of five Review Team Leaders for issue specific and discipline specific action plans. The Chairman of.the SRT is a TUGC0 employee, Mr. John Beck, a Vice President and Manager of Licensing. The five other members of the SRT are experienced senior engineers who are not TUGC0 employees but are associated with independent
. consultant firms. The CPRT Program Director and an ex-officio member of the SRT is Mr. Terry Tyler, a TUGC0 employee. Both Messrs. Beck and Tyler were interviewed by the NRC staff, their position descriptions reviewed, and neither were found to have any responsibility for the project's construction cost and schedule. The interviews also indicated that both individuals were committed to perform a quality verification, were of the opinion that they could perform their duties objectively and independently and had direct access to senior levels of TUGC0 management if problems arose.
The Review Team Leader's duties are a critical component of the CPRT effort. , Ea'ch Review Team Leader is responsible to ensure that the action plans within . their areas are properly implemented and results reports prepared in addition p g.g to their w. wil;ry- administrative duties. GO jv3 In addition to tha - .i.C k Quality Assurance Program j discussed in Section II, g ig Item 1 of this report, which will be used for surveillances and audits of the j CPRT effort, there is an Overview Quality Team consisting of four senior members W who will periodically review, audit and comment to the CPRT chairman on activ-ities, results and programs of the CPRT effort. The NRC staff interviewed the [k 03/10/86 II-16 NUO797 SEC II k
1 CPRT Chairman, Review Team Leaders, SRT. members and the Chairman of the 0QT in .h order to determine their qualifications, experience and commitment to quality i assurance, and their understanding of the functioning of the organization and were all committed to performing their duties in an objective and responsible i manner. A series of five 1-week inspections was carried out by the NRC. staff in the latter half of 1985. The CPRT organization was found to be functioning in an objective and sufficiently independent manner. In addition to the interviews and reviews of the CPRT organization,,the TUGC0 site construction organization was reviewed to determine whether responsibility for project construction cost and schedule was not an area of responsibility for any members of the CPRT. The responsibility for cost and schedule was found to be directly vested in Mr. J. George, the Vice President and General Manager of the Comanche Peak Station Electric Project. Reporting directly to Mr. George are a Mr. R. Camp, Project Manager for Unit #1 and Mr. J. Merritt, Project Manager for Unit #2. These three individuals are directly responsib,le
.., for the cost and schedule of the project and interviews with them indicated that they did not have any influence or impact on the CPRT verification effort.
These individuals are involved in the corrective action process only after the t CPRT recommends corrective action.that requires modification or replacement of physical construction work. i 4.4.3.2 CPRT-Site Personnel . Each site individual participating in the CPRT program was required by TUGC0 to answer and sign a "CPRT Objectivity Questionnaire." The purpose of the ques-tionnaire was to ascertain if the individual had any financial, previous employ- ; ment, or other interest in TUGC0 or Texas Utilities Electric Company subsidairies that would inhibit the individual from being completely objective and indepen-dent in the performance of the tasks assigned to him in the CPRT program. The. NRC staff reviewed essentially all of the inspector objectivity questionnaires g g on file at the time of the inspection / ndIthe related work experience resumes.) In general, these were considered to be satisfactory. Three inspectors were identified who had previously worked for Brown & Root at the South Texas Project. The NRC staff opinion in these three cases was that there was no apparent loss of objectivity or independence as a result of their previous employment and their current work assignments for the CPRT. 03/10/86 II-17 NUO797 SEC II \
In addition to the reviews of inspector questionnaires and work resumes, the objectivity questionnaires and work reviews of essentially all CPRT managerial and key personnel were also reviewed. These personnel files were found to be satisfactory except for two members of the SRT and three key members of the CPRT. These individuals had previous contractural involvement with ,CPSES. Additional NRC staff review of this condition was made and the staff deter-mined that their prior employment would not result in any loss of objectivity or independence in the performance of their current assignments. 4.4.3.3 TERA Personnel In addition to the site personnel, TERA offsite personnel engaged in CPRT design verification activities were also required to answer and sign the objectivity questionnaires as previously described. The questionnaires and work experience
.. resumes of TERA personnel were reviewed by the NRC staff and with one exception !
g were found to be satisfactory. The staff was of the opinion that some of the b TERA Civil / Structural and Mechanical Engineering personnel had limited or no j commercial nuclear power plant design experience. This weakness was identified 6,to TERA management and subsequent to the inspection the necessary corrective
+ action was taken and 25 additional, experienced nuclear design engineers were 4 added to satisfactorily reinforce those personnel performing the design verifi-cation activities.
4.4.4 Conclusion On the basis of its evaluation, the staff concludes that the persons and organi- i zations performing the CPRT verification, evaluation and corrective action activities have sufficient authority and organizational freedom to identify quality problems and to initiate or recommend corrective actions. The indi-viduals and organizations performing the CPRT functions report to a management level such that there exists a required authority and organizational freedom, g/g. including sufficient independence from cost and schedule of construction of the y project when opposed to safety considerations. The staff concludes that the ) , persons and organizations implementing the CPRT program have sufficient l authority and independence from cost and schedule and meet the requirements of j Criterion I of 10 CFR 50, Appendix B. l 03/10/86 II-18 NUO797 SEC II
= , Over and above the inherent independence and objectivity in the CPRT effort, the NRC has established a large overview team (approximately 40 engineers) :nat will conduct surveillances, inspections, over-inspections, design reviews,
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calculation reviews and audits of a significant sample of all CPRT activities. This NRC overview effort will assure that the verification effort is independent, objective, and credible. To date, numerous overview activities have occurred ag ave been documentec 3 and have been included in the monthly Region IV Comanche Peak Jnspec, tion Rgoorts. These reports are available for review in the public document rooms established for the Comanche Peak Steam Electric Station. It is the intent of the NRC staff to maintain a documented, verifiable, and auditable trail of the CPRT activities. ec $w t*M While the present CPRT m is found to meet the requirements of 10 CFR 50, ~ r Appendix B, Criterion 1,- the applicant shall notify the NRC staff of any pro- -
.f posed changes in managerial or key personnel in the CPRT effort prior to its implementation, unless the changes are a result of work completion. .
03/10/86 II-19 NUO797 SEC II
5.0 DISCIPLINE INTERFACES 5.1 Introduction The design and construction process requires transmittal of proper information across a number of interfaces. Failure to have a process in place which controls the transmittal of information and assures proper reviews and approvals can result in inadequte design and construction activity. Interface control must be provided between engineering and construction disciplines and betwee.n engineer-ing and construction activities. The scope of the CPRT effort, including the TUGC0 project reanalysis activity, requires tne same kind of interface control. 5.2 CPRT Acoroach
.. Revision 3 of the Plan includes Appendix F, "CPRT Interfaces", which indicates t,< that implementation of the Plan requires the establishment, execution and con-r trol of interfaces among the participants. The principal participants for whom interfaces are defined.by the CPRT are:
TUGC0 Senior. Management
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CPRT - SRT CPRT - RTL CPRT Program Director Q. CPRT Support Staff - CPRT Advisers CPSES Project, including major subcontractors, QA/QC organization and projectpersonnel. articipant interfaces that are defined in detail are summarized in the l llowing matrix.
'03/10/86 II-20 NUO797 SEC II
Y CPRT MAJOR PARTICIPANT INTERFACES SRT RTL ' PROGRAM DIRECTOR TUGC0 MANAGEMENT X SRT X X RTL X X PROGRAM DIRECTOR X X SUPPORT STAFF X . ADVISERS X CPSES PROJECT X X X NRC X X CYGNA X SAFETEAM X a Detailed matrices are provided for the major organizational interfaces within the CPRT. A list of these follows: QOC to DAP QOC to CPSES Project' DAP to QOC DAP to CPSES Project DAP to Other Design Organizations RTL to Program D-irector RTL to CPSES Project RTL to DAP RTL to QOC Other CPRT interfaces are discussed in detail with individual responsibilities, extent of the interface and documentation concerns provided. In addition, matrices of interfaces between CPRT and Stone and Webste.r Engineering Corpora-tion (SWEC), and SWEC and other CPSES Project Organizations, are provided. Three levels of responsibility are applicable to each item of information transmitted across an interface. The transmitting organization has the re-sponsibility for categorizing the item of information which automatically 03/10/86 II-21 NUO797 SEC II
-x_
fixes the level of responsibility as defined by the appropriate matrix. The three levels of responsibility are: (1) Information, (2) Review and Comment, and (3) Action. 5.3 Staff Evaluation The definition of interfaces provided in Appendix F esta'blishes measures for the identification and control of design and construction interfaces and for coordination among the CPRT participant organizations. The availabi,lity of matrices will provide each affected organization the specific areas and items of information that must be executed and controlled. There are a number of areas where interface between various CPRT organizations and CPSES project organizations is defined. In some cases, the interface appears to be duplicative and prime' responsibility is not defined. It is v important that prime responsibility for interface control be defined to assure
-j that involved organizations understand who is responsible for establishing, executing and controlling the interface.
7 The following are staff observations on the individual matrices provided in Appendix F.
- 1. QA/QC-RTL and Q RTL to, Unit I an'd Unit 2 APGMs. Responsibility for 50.55(e) repertabil'ity Ys' assigned to the TUGC0 Project per Appendix H of the Plan.
- 2. DAP-RTL to SWEC. Information on root-cause analyses, generic implications, Evaluatio, reports and Results reports is provided to SWEC for "Informa-tion" when pertaining to the SWEC scope. Since this information could impact the SWEC analysis effort, it should be provided for " Action by SWEC". Since DAP is auditing SWEC activity, this matrix should address those items associated with that effort, including Corrective Action.
- 3. DAP-RTL to Other Design Organizations. Information on root-cause analyses, generic implications, Evaluation reports and Results reports should be 1
03/10/86 II-22 NUO797 SEC II
provided for " Action" to EBASCO and Impell, who are reanalyzing cable trays and supports. The CPRT may find it more appropriate to develop a separate matrix for the cable tray and support effort activities of EBASCO and Impell.
- 4. RTLs .o CPSES Project. Action Plans are designated as both " Info" and
" Action by Project". It is the Staff's understanding that Action Plans are provided to the CPSES Project for information only.
- 5. SWEC to Interfacing Organizations. Design- and construction-related concerns found during walkdown and document reviews should require action by DAP and QOC RTLs. That action should include evaluation of the deviation in the same manner as if it were discovered as part of the CPRT self-initiated program. Loading from the piping system should be provided to QOC through
. the DAP since this information may be needed for safety-significance evaluation. - -- 6. Interface details (or matrices) could not be found for the interface
- activities between Other Design Organizations and DAP-RTL and EBASC0/
- Impell and Interfacing Organizations.
5.4 Conclusions The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT activities provided the following concerns are satisfactorily resolved: (1) Define the organization with prime responsibility for duplicative interfaces. (2) Information on root-cause analyses, generic implications, Evaluation reports and Results reports should be provided to SWEC, EBASCO and Impell since it could impact their reanalysis effort. (3) Design- and construction-related conceras found during SWEC, EBASCO or Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action". l 1 03/10/86 II-23 NUO797 SEC II
(4) Loadings from the piping system to equipment, structures, penetrations, etc., should be provided to QOC through the DAP for use in safety-significant evaluations. (5) Interface details (or matrices) should be provided for Other Design Organizations and DAP-RTL and for EBASC0/ Impell and Interfacing Organizations. (6) The CPRT auditing of SWEC activities involves interfaces which should be , defined. (7) Define more clearly CPSES project responsibility for action plans and 50.55(e) reportability. 2 The concerns related to .50.55(e) and to Action Plan responsibility in the RTL s to CPSES Project Matrix are editorial in nature and can be confirmed during the
; implementation phase of the Plan.
[ q f J . l 03/10/86 II-24 NUO797 SEC II
e . Document Name: NUO797 SEC III TC Requestor's ID: 9820 Author's Name: C.Trammell Document Comments: PH-303--KEEP THIS SHEET WITH DOCUMENT 4 O O e i I l - 6 4. A
4 s
, , III. STAFF EVALUATION OF DESIGN ADEQUACY PLAN -
TABLE OF CONTENTS P.a.fte
- 1. 0 INTRODUCTION ....................................................
2.0 EXTERNAL SOURCE ISSUES .......................................... 2.1 Methodology for Identifying and Resolving New External Source Issues .............................................. 2.1.1 Introduction ........................................ 2.1.2 CPRT Approach .......................................
.- 2.1.2.1 Identification of Issues ...................
2.1.2.2 Definition of Issues .......................
- 2.1.2.'3 Development of the Action Plan .............
2.1.2.4 Imp 1dmentation of Action Plan . . . . . . . . . . . . . . 2.1.2.5 Corrective Actions ......................... 2.1.2.6 Results Reports ............................ 2.1.3 Staff Evaluation .................................... 2.1.4 Conclusion .......................................... 2.2 Electrical, Instrumentation and Control Systems and Component Issues ........................................... 2.2.1 Introduction ........................................ 2.2.2 CPRT Approach ....................................... 2.2.3 Staff Evaluation .................................... 2.2.4 Conclusion .......................................... i
. - _ - _ 7
= .
TABLE OF CONTENTS (Continued) P. age 2.3 Mechanical Systems and Components Issues ................... 2.3.1 Introduction ........................................ 2.3.2 CPRT Approach ....................................... 2.3.3 Staff Evaluation .................................... 2.3.4 Conclusion ........................................'.. 2.4 Civil and Structural ....................................... 2.4.1 Steam Generator Restraints .......................... 2.41.1 Introduction ............................... 2.4.1.2 CPRT Approach ..............................
.. 2.4.1.3 ,
Staff Evaluation ........................... 2.4.1.4 Conclusion .................................
'2.4.2 Design of Seismic Category ~II Items .................
2.4.2.1 Introduction ............................... 2.4.2.2 CPRT Approach .............................. 2.4.2.3 Staff Evaluation ........................... 2.4.2.4 Conclusion ................................. 2.4.3 Cable Tray Supports ................................. 2.4.3.1 Introduction ............................... 2.4.3.2 CPRT Approach .............................. 2.4.3.3 Staff Evaluation ........................... 2.4.3.4 Conclusion ................................. 11
- ~ ---.s,, . ,m
TABLE OF CONTENTS (Continued) Page 2.4.4 Conduit Supports .................................... 2.4.4.1 Introduction ............................... 2.4.4.2 CPRT Approach .............................. 2.4.4.3 Staff Evaluation ........................... 2.4.4.4 Conclusion ...............................'.. 8 . 2.5 Piping and Supports ........................................ 2.5.1 Piping Isolation (ISAP VC) .......................... . 2.5.2 Third-Party Overview ......... ...................... 2.5.2.1 Introduction ...............................
. 1
. 2.5.2.2 CPRT Approach ..............................
- 2.5.2.3 Staff Evaluation ...........................
2.5.2.4 Conclusion ................................. 2.6 Evaluation of Closed External Source Issues ................ 2.6.1 Introduction ........................................ 2.6.2 CPRT Approach ........'............................... 2.6.3 Staff Evaluation .................................... 2.6.4 Conclusion .......................................... 3.0 SELF-INITIATED EVALUATION ....................................... 3.1 Design Activities Evaluation Process ....................... 3.1.1 Introduction ........................................ , 3.1.2 CPRT Approach ....................................... l i 111 l 4
TABLE OF CONTENTS (Continued) Page 3.1. 3 Staff Evaluation .................................... 3.1. 4 Conclusion .......................................... 1 3.2 Electrical, Instrumentation and Control Systems and Component's Design Activities .............................. 3.2.1 Introduction ........................................ 3.2.2 CPRT Approach ....................................... 3.2.3 Staff Evaluation .................................... 3.2.4 Conclusion .......................................... 3.3 Mechanical. Systems and Component's Design Activities .......
. 3.3.1 Introduction ........................................
3.3.2 CPRT Approach ....................................... 3.3.3 Staff Evaluation .................................... 3.3.4 Conclusion .......................................... 3.4 Civil and Structural Design Activities ..................... 3.4.1 Introduction ........................................ 3.4.2 CPRT Approach ....................................... 3.4.3 Staff Evaluation .................................... 3.4.4 Conclusion .......................................... 3.5 Piping and Pipe Supports Design Activities .................. 1
- 3.5.1 Introduction ........................................
3.5.2 CPRT Approach '....................................... j 3.5.3 Staff Evaluation ....................................
- 3.5.4 Conclusion ..........................................
i i iv 1 l
,,- -- . ~ . . - . - . , , -
= o TABLE OF CONTENTS (Continued) 4 Pag
! 4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW ........................... 4.1- Introduction ............................................... 4.2 CPRT Approach .............................................. 4.3 Staff Evaluation ...........................................
! 4. 4 Conclusion ...............................................'..
5.0 OVERALL
SUMMARY
AND CONCLUSION .................... ............. O e l k V i 1
,, . _ ,- , - - - .~ ., , _ , , . . . , . . .
t Document Name: NUO797 SEC III
- - Requestor's ID
LO Author's Name: C. Trammell Document Comments: PH-303 CRESS DRAFT 2/18/86 KEEP THIS SHEET WITH DOCLHENT i 9 1 j r I e f i i 8
! 8 4 e l
i i 4 1 i i t e 9
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- 1. 0 INTRODUCTION F -
The U.S. Nuclear Regulatory Commission (NRC) Executive Dir or for Operations issue irective on March 12, 1984, establishing a program for ass ring the overall coor ' ation, integration, and resolution of technica ncerns and 'I
' ' 9 allegations prior the NRC staff licensing decision o omanche Peak. In l' '-I ,
k
~
response to this direc 've, the NRC formed jTechpical Review Team (TRT). Th[ applicant, in order to resp to questions <toncerns, and issues identified by TRT and others, established the Com ch ak Review Team (CPRT) and charged them with the responsibility of etIvingou a ing issues and determining that there is reasonable ass e that the Comanc lant can operate without undue risk to t public. Some of the issues identifi by TRT and I others brought _ a"act$n the adan"x3 ef 4he ComanGc Peak o fF q esign proc g
. The CPRT, 6 ..uc. i.v fd'"; ami. .cagvu=. "" , .ur se=ulv-
' d .claucu .= sues, developed the D ~
equacy Program (DAP). The
$/ d DA three components. ~
. The first component consists of evaluation of the nature or implication of each
- specific design related issue identified by TRT and others. Issues identified
; by TRT and others have been defined in Section 1 of the DAP plan as External
- Source Issues. A further definition of each external source issue along with
. its associated staff evaluation (of the DAP approach for determining its impli-cation on an issue specific basis) is presented belqw.Jn section 2.0,ef--tMs
<!e ort. In addition, the staff evaluation of the DAPilan a$e'ptance criteria and corrective actions for identified issues is presented in Part II, sections 2 and 3 of this report.
The second component of the DAP plan involves investigation of root cause or adverse trends so that generic implication to other safety systems can be determined. The staff evaluation of the DAP approach for determining generic implication of identified issues is presented in Part II section 3.0 of this report. The third component of the DAP plan consists of the evaluation of selected additional design areas such that all significant design disciplines, activities, and processes employed during the design of the Comanche Peak Plant will have 03/10/86 III-1 NUO797 SEC III
been covered with the exception of vendor supplied standard equipment and systems. The staff evaluation of the DAP approach for selection of design areas such that all significant areas are covered is presented below in section 3.0. The staff evaluation for exclusion of vendor supplied standard equipment and systems is addressed in section 4.0 below. t e 1 l l r 03/10/86 - III-2 NUO797 SEC III
l . o l 2.0 EXTERNAL SOURCE ISSUES l The program plan defines r ': : 5 external source issues as being those issues identified by the following sources: The NRC Technical Review Team (TRT), the NRC Atomic Safety Licensing Board (ASLB), NRC Supplemental Safety Evaluation { Reports (SSER's), NRC Construction Assess g T g KAT), NRC Special Investiga-tion Team (SIT)',~NRC Region IV (RIV) d Cygna Independent Assessment Program (IAP). The design implication of each issue identified by these sources, will be evaluated by the CPRT to assure that all design deficiencies are corrected. The CPRT program plan has identified a six-step methodology to respond to ex-ternal source issues. The staff's evaluation of this six-step methodology, and evaluation of each external source issue identified by the CPRT in the program plan, is presented below. New issues, that may be identified during the imple-mentation phase of the CPRT program plan, will be reviewed by the staff when they are identified by the CPRT. The results of the staff evaluation of new issues will be contained in future reports.
;2.1 Methodolooy For Identifying and Resolving New External Source Issues 2.1.1 Introduction External Source Issues are those design concerns identified by past and ongoing review, inspections and audit activities outside the DAP. These activities
. @ -include SIT, SRT, CAT, TRT, open SSER issues, RIV, IAP and ASLB proceedings.
In order for'the DAP to be complete,f4 the External Source Issues must be in-cluded in the review. The[Tincludesa program for identifying and resolving new external source issues. ,t-2.1.2 CPRT Approach cf4 TheC[Thasdevelopedasix-stepmethodology(ref.CPRTProgramPlan,AppendixA j Section II para.1, pages 6 thru 9, Rev.1) for identifying issues, and provide
! resolution. The process will be continuous throughout the implementation of the DAP and the following steps will assure adequate disposition of the issue:
03/10/86 III-3 NUO797 SEC III
'1) Identification of Issue,
- 2) Development of Issue,
- 3) Development of Action Plan,
- 4) Implementation of Action Plan,
- 5) Corrective Action, and
- 6) Results Report.
The approach associated with each of these steps will be discussed in the . following sections of the report. 2.1.2.1 Identification of Issue This step in the methodology is accomplished by a review of the various documents !- and reports associated with the audits, reviews and inspections that had been ! performed outside the DAP. The review is intended to gather the necessary back-
- - ground information about an issue, as well as, identify any other issues that a w may be associated with it. Issues that have been resolved will also be re .
i j a evaluated to assure adequate resolution. All the issues identified will be / t entered into the DAP Tracking System (DAPTS) by means of an Issue Record (IR)
. and issues will be assigned to either an ISAP or are appropriate DSAP.
2.1.2.2 Definition of Issue i , The IR is used for defining an issue. Using the information on the IR, the i following three determinations are made; 1) adequacy of available documentation, l 2) identification of potentially affected hardware and 3) nature of programmatic f issues. This will determine if additional evaluation of the issue is required.
- At this point a Discrepancy / Issue Report (DIR) is completed which assigns the l
! . issue to a particular DSAP or requires a separate Issue-Specific Action Plan l (ISAP). l l 2.1.2.3 Development of the Action Plan s l Once the issue has been assigned an ISAP or to a DSAP, the next step is to l develop the tasks associated with the required investigations and evaluation. l l I 03/10/86 III-4 NUO797 SEC III l
P In developing the details of either type.of action plan, two approaches will , be considered:
- 1) the cumulative effect of the issue on other issues, -
- 2) proceed directly to corrective action without further engineering evaluation.
2.1.2.4 Implementation of Action Plan The approach to implementation of an action plan (either ISAP or DSAP) will involve one or more of the following initiatives:
- 1) Verification of project evaluations, ,
- 2) Engineering evaluations,
- 3) Engineering walkdowns,
- 4) Hardware inspections,
- 5) Special studies, ,
- 6) Testing,
- 7) Direct hardware modification,
- 8) Reanalysis on a sampling basis, and a 9) Complete reanalysis of affected design.
. This step in the methodology will include an investigation of root cause and generic implication. The results of the aforementioned initiatives will be tracked by revisions to the issue specific DIR.
2.1.2.5 Corrective Action .
- There are three possible approaches to corrective action which dependent on the final classification of the issue
- 1) If.the issue is deemed to be an Observation (error without design impact) no hardware corrective action is required.
- 2) If the issue is deemed a Deviation (non-safety-significant with design impact) either a hardware change will be made or the deviation is accepted only after a non-conformance evaluation had been completed.
k 4 -
'p 03/10/86 ,, III-5 NUO797 SEC III
- 3) If the issue is deemed a Deficiency (safety-significant Deviation) a hard-ware change ~will be made to bring the design into conformance with the original commitment. The corrective action.taken will be documented on the final revision of the issue specific DIR.
2.1.2.6 Results Report The issue will be further documented in the end products of the DAP. These include
- 1) Individual DSAP (except, Pipe and Piping Supports) Results Report in which all tasks performed will be discussed.
- 2) The third part CPRT Results Report which will address only the Piping and Pipe Supports DSAP tasks'in a manner to concur with criteria, process used and implementation.
.; 3) Final DAP Results Report which documents the collective evaluation of the adequacy of the CPSES design and identifies any necessary improvements in , either CPSES design process, plant operation or hardware modifications.
2.1.3 Staff Evaluation The staff evaluated the six-step methodology (process) for identifying External Source Issues on the basis of whether or not:
- 1) The process would be continuous throughout the implementation of the DAP,
- 2) The issues identified would be evaluated equally with concerns produced directly by the Self-Initiated portion of the DAP,
- 3) The' issues identified would be addressed individually, through resolution, and
- 4) The issues identified would be evaluated for root cause and potential generic implication and be included in the overall trend analysis.
03/10/86 III-6 ,NUO797 SEC III
- l. .
2.1.4 Conclusions The staff has concluded that the methodology for identifying new External Source Issues meets the basis for their evaluation with the exception of continuous , review of external documents. The staff will confirm the continuous review of External Source documentation for new issues as part of their inspection of the DAP implementation. 2.2 . Electrical Instrumentation and Control Systems and Components Issues 2.2.1 Introduction The applicant in the Program Plan, Appendix C (DSAPS), item I Section 3-1 has identified for resolution issues that' have been previously identified by the NRC TRT and the CYGNA Independent Assessment Program (IAP) of the Component Cooling Water System (CCWS). The NRC TRT issues relate to: , wu tt l 1. Qualification of splice $ for the expected service conditions and
- 2. Qualification of SERVICAIR flexible metallic conduit as an acceptable barrier for the purposes of electrical separation.
The CYGNA IAP deficiencies relate to:
- 1. Temperature / Pressure Rating of Instruments
- 2. System Short Circuit Currents
- 3. AC Distribution Voltages
- 4. Overcurrent Protection
- 5. Cable Signing, and
- 6. CCW Pump Motor Sizing 2.2.2 CPRT Approach With regard to the issues identified by the NRC TRT the Program Plan proposes:
03/10/86 III-7 NUO797 SEC III
I
- 1. Identification of all site-initiated procurement of safety-related j electrical components. l l
- 2. Review cf Qualification Documentation of all identified components.
i i ! 3. Identification and evaluation of acceptance criteria.
- 4. Evaluation of components capability to perform its intended function, and I .
! 5. Development of Corrective Action for identification deviations. For the Temperature / Pressure Ratings of Instruments deficiency identified by f CYGNA the plan requires that all instruments in other plant safety related fluid j systems, 'where design changes or re-evaluation of. system operating conditions I by the A/E may have resulted in higher pressure or temperature process conditions,
- be checked for adequacy of the component ratings. Any deviations will be p -. used to determine the root cause and generic implications as described in the l Design Adequacy Program.
) c For the remaining deficiencies identified by CYGNA the plan proposes DSAP review ! : of similar issues in the electrical system selected for review by CPRT, and any deficiencies identified to be resolved in that review. l i 2.2.3 Staff Evaluation
- The review proposed by the applicant for addressing the design related concerns
[ identified by the NRC TRT on qualification of Amp but-splices and SERVICAIR conduit has been evaluated by the staff. The proposed review is sufficiently [ comprehensive to identify and correct any deficiencies in the site initiated procurement of safety related electrical components.
- The review proposed by the applicant for addressing the deficiencies identified j by CYGNA, regarding Temperature / Pressure Rating of instruments has also been evaluated by the staff. The applicant's commitment to review all instruments in other plant safety related fluid systems will reveal the adequacy of all 3 such instruments to meet their functional requirements.
t 03/10/86 III-8 NUO797 SEC III L d ._ _ ,. . _ . _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ - _ _ . _ . _ _ _ _ _ . _ _ . . _ ~ . . _ - . . _ . _ , _ . _
s . The review proposed by the applicant for addressing the remaining deficiencies identified by.CYGNA is unclear as to how generic implications will be assessed prior to review of an equivalent issue in the self initiated program (DSAP).
~
Results of review of an item similar to that focus deficient will not provide meaningful data for assessing overall design adequacy, particularly when generic implications and root causes of the initial deficiency have not been assessed to determine whether one or more similar items should be reviewed. R 2.2.4 Conclusions Based on our evaluation of the applicant's proposed plan for addressing integral source issues / deficiencies we have concluded that: 4
- 1. For the NRC TRT related concerns, on qualification of amp but-splices and --
SERVICAIR conduits, the proposed review is comprehensive and therefore acceptable. i ic 2. For the CYGNA. identified deficiencies regarding Temperature / Pressure Ratings
; er of instruments, the proposed review is comprehensive and therefore acceptable.
I i l r 3. For the remaining deficiencies . identified by CYGNA above, the breadth of , the proposed review appears inadequate. Therefore, we require that during implementation of their program plan a generic implications and root cause assessment must be conducted for each identified deficiency in order to determine the breadth of review that must be conducted for a given design
; activity.
l 2.3 Mechanical Systems and Components Issues i j 2.3.1 Introduction 4 The applicant in the program plan Appendix C (DSAPS), item X Section 3.0 has identified for resolution issues that have been previously identified by.the CYGNA Independent Assessment Program (IAP) of the Component Cooling Water. System h (CCWS). t 03/10/86 III-9 NUO797 SEC III h
The CYGNA issues relate to:
- 1. CCW System Maximum Temperature-Pressure - incorrectly specified ratings.
! 2. Class 5 piping inadequately designed to retain pressure integrity during j and after an SSE. 'l ] 3. Potential release of reactor coolant outside containment following single ! failure in temperature controlled isolation valve. ' i
- 4. CCW Surge Tank Isolation on High Radiation Signal - Removal of isolation -
! signal may result in releases to exceed 10 CFR 100 limits. i
- l. 5. Valve Sizing Calculations - Pressure drop and flow calculations have not j been provided for certain CCW equivalent.
. q - 6. CCW Surge Tank Sizing - Design did not include sizing calculations to l- n account for potential leakage from higher pressure systems.
- r 7. CCW Pump Sizing - Motor sizing calculations may not have included most
; limiting conditions.
\ l
- 8. Loss of CCW tank vent-relief due to failure in single vent-relief / vacuum l breaker.
) 2.3.2 CPRT Approach i { With regard to issues 1, 2, 3, 5, 6, 7 & 8 identified in the introduction sec-l tion 2.3.1 above the program plan proposes DSAP review of similar issues in the AFWS or another system to ascertain whether similar situations exist'in other l similar designs. i For issue 4 identified in the introduction section 2.3.1 above the program plan proposes documentation review of all Westinghouse-supplied process radiation
- monitors to assure that all radiation instrumentation requirements identified l
t ! 03/10/86 III-10 NUO797 SEC III i
- , _ , . _ _ _ _ _ _ _ -,-,,_ ~ _ , _ . . _ . - _ _ _ _ . . _ . - _ - . - - - . _ - - . - - ~ - - - - - - - - . . . - - - . - - - - - - --
by Westinghouse, FSAR and regulations have been met. Deviations from criteria will be reviewed to determine adequacy of basis for exceptions. l 2.3.3 Staff Evaluation The review proposed by the applicant for addressing issues 1, 2, 3, 5, 6, 7 & j 8, identified in the CPRT. Approach section 2.2.2 above, is unclear as to how generic implications will be assessed prior to review of an equivalent issue in the self initiated program (DSAP). - Results of review of.an item similar to that found deficient will not provide meaningful data for assessing overall
, design adequacy, particularly when generic implications and root causes of the
{ initial deficiency have not been assessed to determine whether one or more similar items should be reviewed. 4 I J 4 The review proposed by the applicant for addressing issue 4, identified in sec-l tion 2.2.2 above has been evaluated by the staff. The proposed review is suf-l y ficiently comprehensive to identify and correct any deficiencies in the radiation
- monitoring instrumentation. '
j 2.3.4 Conclusions i i y Based on our evaluation of the applicant's proposed plan for addressing external source issues / deficiencies we have concluded that: i
- 1. For issues 1, 2, 3, 5, 6, 7 & 8 identified in section 2.3.3 above, the breadth of the proposed review appears inadequate. Therefore, we require j that during implementation of this program plan a generic implications and i root cause assessment must be conducted for each identified deficiency in order to determine the breadth review that must be conducted (or a given j design activity.
i ) 2. For issue 4 identified in section 2.2.3 above, the proposed review by the ! applicant is comprehensive and therefore is acceptable. l l [ l 03/10/86 III-11 NUO797 SEC III 1
- - . _ . . _ . . . . , _ , . - . - - - - . . . , ~ , - . . _ - - _ . . . . _ . . . - . - . - _ _ - - . . _ , . . - - - - . , _ _ _ . - - . - _ - . , , _ . _ . . _ .
2.4 Civil and Structural 2.4.1 Steam-Generator Restraints 2.4.1.1 Introduction The overall design adequacy of both upper and lower steam generator lateral restraints is to be reviewed for all appropriate loading conditions. This review
-is due to the TRT issue concerning the improper shortening of anchor bolts in the steam generator lateral supports. he TRT was informed that anchor bolts P-ffFthe steam-generator upper lateral supp t beams were installed to lengths less than that shown on drawings on. This was apparently the result of s being cu the hole of the anchor device illed with debris or concrete stuck to the threaded y rtion of the bolt.
.Y
[TheTRT=ai.t.esptedtnreviewTUECreco
- and general ins
' ii.rasonic (UT measurementresults}
practic . Th; N = = told that ultr onic testing of/ +
-(the ypes of bolts was not a procedural reouirement; oweverjTUECwasunable t{to provide any ohr installation records pertainina to length of anchor bolt t thre or TRTirevie f The TRT concluded that such unauthorized -
, bolt cutting ana lack or installation inspection records was a violation of QA procedures and Criterion XVII in Appendix B of 10CFR50. Since the support beams
%:p.-
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 , I conformance with General Design Criterion 1 of 10CFR50. t 2.4.1.2 CPRT Approach
- ESAt*V.gb
-Men Vb of'the CPRT Program Plan outlines the measures to be taken to ensure that the anchor bolts in the steam generator upper support beams meet the appro-priate design requirements. Also included is a review of similar installations to determine if the issue pertains to other designs. The concern that the anchor bolts in the steam generator upper-lateral support were improperly shortened is addressed in paragraph 2.4.2 of Section IV of this report. In addition to the 03/10/86 y III-12 NUO797 SEC III
= -
= . _
.. _ _ _ _ =- _. - - .-
O o \. specific issue of the improper shortening of anchor bolts in the steam generator upper lateral supports, the design of both upper and lower steam generator j lateral supports is addressed under Discipline Specific Action Plan (DSAP) VIII, l which is the Civil / Structural Design Adequacy Plan (DAP). I I The design of all components of the upper and lower steam generator lateral supports, which include the beams, beam anchorage to the concrete walls and the concrete wall, will be reviewed for all load combinations. This design review includes a review of the development of steam generator-to-beam forces, the
. validation of the appropriate, load combination, evaluation of force and moment resultants on the beam wall and achorage as a function of cracked and uncracked concrete properties, review of concrete wall and steel-beam design, and the adequacy of the bolt and plate connection.
2.4.1.3 Staff Evaluation i 4 The staff's evaluation.of this section of the Program Plan is based on a review v of Revision 3 of the CPRT Program Plan and Supplement 10 of NUREG-0797, which
& address the specific concern of improper shortening of the upper-lateral steam-3 generator-support anchor bolts. The plan in DSAP VIII goes beyond addressing w this specific issue and includes a review of the design of both upper and lower steam generator supports to assure that the FSAR commitments are met.
2.4.1.4 Conclusions The staff concludes that the Program Plan appropriately addresses the issue and is acceptable. 2.4.2 Design of Seismic Category II Items Design considerations related to Seismic Category II items is addressed Para-graph 2.3.4 of Section IV of this SSER which addresses ISAP II.d. This is a j design identified by the TRT. As noted by the CPRT in their Program Plan there are a number of civil / structural design issues identified by the TRT that are
$ being addressed by previously established ISAPs. These ISAPs will document the specific TRT issue and its resolution. However, design related technical or 03/10/86 III-13 NUO797 SEC III
[
- o i
l programmatic conclusions will be included in the civil / structural root cause l and generic implication evaluation. 2.4.3 Cable Tray Supports l 2.4.3.1 Introduction f { A number of potential design concerns related to the cable tray support design j have been raised due to the CYGNA~IAP. Some examples of these concerns include: l the controlling load case of support designs, seismic response combiilation, l anchor-bolt design, design of compression and flexural members, accounting for support weight, dynamic amplification factor, design of angle sections, reduc-l tion of channel capacity due to bolt holes, weld design, and the cumulative effedcts of all concerns. j 2.4.3.2 CPRT~ Approach l l - Based on the number of design concerns identified, TUGC0 is performing additional j reviews of the cable tray support designs and has retained outside contractors j- . to perform 100% verification. All Unit 2 analysis / design verification work l > will be performed.by Ebasco. Unit 1 work will be divided with Impe11 performing
. the verification for the Safeguard Building and Ebasco performing the verifica-l tion for all other bu,f.ldings. These design verifications will be subjected to I -
{ third party overview. wThis p% g. ram includes: the development of as-built draw-ings for all cable tray supports; analysis and ' design review of all cable tray supports to criteria that are responsive to External Source design concerns and . i in compliance-with CPSES licensing commitments; testing to verify and/or establ-f ish specific component or system behavior characteristics;.and hardware l modifications as nece\ qsary to ensure final acceptabilitygof %allf* supports Y y / All cable tray supports in both units will be as-built verified forg all access-l ible attributes. For Unit 2, where virtually all attribut'es are accessible, an , as-built drawing will be developed 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 I i 03/10/86 III-14 NUO797 SEC III
l* i I taken in developing the as-built drawings. As-designed drawings will be devel-
- oped based on the original Gibbs and Hill design plus all documented design j changes. Field walkdowns will then be performed using the as-designed drawings.
j For all accessible supports and accessible portions of partially inaccessible ' supports, as-built conditions will be confirmed or differences noted. Final as-built drawings will note items that were inaccessible. The determination of l span lengths will'also be developed based on field inspections for Unit 1 sup-i parts. The basis for design review of inaccessible items for Units 1 and 2 will be addressed and documented in special studies or evaluation reports. , i I j Two methods of dynamic analysis will be utilized in the analysis / design verifi-l cation of cable tray supports. The first method is equivalent static analysis ) of individual supports, which is consistent with the criteria used in the devel-opment of the original support designs. The second method is response spectrum , tem dynamic nalysis, which is considered to provide a more accurate measure of
. system response. Both Ebasco and Impell will utilize their own design procedures a for performing the work; however, design methods and criteria will be consistent.
. 7. The design verification of Unit 1 supports will be performed using, as a minimum,
- . actual cable tray fill weights and actual fire protection-material weights.
{ 9 Unit 2 design verification will be performed using maximum specified design 4
- cable tray fill weights, and conservative assumptions regarding the weight of
! the fire protection material. For both units, loading combinations and stress limits will be checked in accord-
- ance with acceptance criteria conforming to CPSES licensing commitments. For f' any support which fails to meet these criteria, design modifications will be prepared.that result in acceptable qualification.
l . A testing program has been defined to support the cable tray support verification effort. The objectives of these tests are to determine actual damping levels
- to verify applicability of values used in the design of cable tray systems, to l
l confirm the response of members. acting primarily in tension under seismically j j induced compressiod loads, and to confirm the analytical methods and supporting design assumptions for complicated load path geometries. l i 03/10/86 III-15 NUO797 SEC III i i
1
! Modifications will be prepared for all cable tray supports that fail to meet specified acceptance criteria. All supports will be qualified in their existing state, or required modifications will be implemented.
The planned design-verification activities for the cable tray supports will be subjected to third party overview.gn Addition, the third party will review]
^
resosuuan vi aii external source issu ghe, ghg A. h9 2.4.3.3 Staff Evaluation The staff has reviewed the approach and methodology of the TUGC0 expanded cable tray support review, along with the third party overview as described in DSAP VIII. In addition, the staff has reviewed all identified external source j issues, the original project cable tray support design criteria and licensing commitments. Staff audits of walkdowns, test procedures, tests, design criteria and instructions, analysis methods verification and sample analyses have also been performed. 2.4.3.4 Conclusion
> The staff concludes that the CPRT Program Plan, as described in Revision 3,
.will adequately address the issues identified with the cable tray supports and j will assure that these supports will meet the licensing criteria. This is pred-
] icated on the satisfactory resolution of the following comment on the CTCS subprogram. y[
\
u* A concern is that the testing program may generate design and acceptance criteria YK which do not comply with FSAR commit:nents. If licensing commitments aregmet, I the proposed acceptance criteria must be identified for approval by the staff prior to implementation. 4 Another staff concern is the observation that inconsistencies exist between the DF,DSAPVIIIandImp/ ell-Ebascoprojectinstructions. The inconsistencies involve the statements describing the methodologies that may be used to evaluate the cable tray support. In the DAP it is stated that the established Ebasco a 03/10/86 III-16 NUO797 SEC III
.- .o 3
INSERT A The third party will identify external source issues raised by the Cygna IAP and NRC reviews and inspections, review and evaluate the significance of the issues, and track them to ensure satisf actory resolu-tion of each issue. Other functions of the third party review, which is performed by TERA, include o Verification that commitments establishing design criteria and standards are identified, consistent and complete. o Review of design procedures and supporting analytical studies by TNE, EBASCO and Impell. o Review of tests by ANC0 and CCL. o Verification of analysis calculations by TUGC0 and its consul-tants including verfication of modifications. o Review of resolutions and modifications including corrective actions.
/
o Evaluation of root causes and generic implications. g
... 'o Overview,gid' verifications of the as-built condition of cable tray and conduit supports.
H *: rd;c;;;;d .a.c. [he third party will use checklists in its overview in those cases where it is appropriate to do so. In any event, it is expected that all third party review activit'ies will be documented. ROC:mam o
s' , l methodologies will be used while the DSAP allows the use of Impe11 and Ebasco design procedures. Further in the DSAP it is stated that only two methods of dynamicanalysiswillbeusedinQnaly verification of cable tray supports. The Impell project instructions, however, advance the use of time history methods, overlap methods and multi level, response spectrum methods in addition to the two methods referred to in the DSAP. These inconsistencies must be resolved and the appropriateness of the above methodology demonstrated to the staff. 2.4.4 Conduit Supports 2.4.4.1 Introduction A number of design concerns with conduit supports were identified as a result of the CYGNA IAP. Examples of these issues include: controlling load case for 2 design, design amplification factor, ccmbination of loads, expansion anchor design and embedments, installation tolerances, increasing conduit spans without
. justification, improper enveloping of design. configurations, which resulted in t
the installation of support with an unacceptable unistrut configuration. 2.4.4.2 CPRT Approach The TUGC0 project has developed a program to perform a review of the conduit supports. Under this program THE will sample the design of existing Unit I and common conduit support to evaluate design adequacy. TUGC0 has retained Ebasco to fully engineer all Unit 2 conduit supports. it ': th: '-t::t c' t'r ,- jert W+='c:nLR ay... r mm ui n siew CrZ 16... :. 3 :::. Itz: .t1 A two-step approach to verifying the design adequacy of Unit 1 and common conduit supports will be implemented. First, all supports, (including unistruts) with unacceptable configurations will be identified and modified to be in compliance with appropriate criteria. Second, a verification of the as-built Unit 1 and common design conduit runs will be performed using random sampling consisting of two subpopulations: one population being lighting conduits, which typically have long runs of single conduits, and the other, power / control conduits, which 03/10/86 III-17 NUO797 SEC III
typically have shorter runs of grouped conduits. For each subpopulation, a random sample of 60 conduit runs will be selected. Each sample conduit run will be as-built verified by field inspection to produce conduit-run isometrics and individual support drawings. The design of each selected conduit run and associated supports will be evaluated to determine compliance with specified CPSES acceptance criteria. If all sampled conduit runs and associated supports are found to be in compliance with appropriate criteria, no further action will be taken. t If one or more conduit runs or associated supports do not meet the appropriate criteria, the results will be reviewed to determine the most appropriate form of sample expansion required to ensure complete coverage of the population and to isolate identified problems and/or to take corrective action to meet CPSES acceptance criteria. r All conduit supports that were installed in Unit 2 the original design spec
- 1 ification, S-910, have been design verified by Ebasco to the revised Specifica-tion 52-910, which addresses known external source issues and complies with CPSES design criteria commitments. Installation of all remaining Unit 2 con-
-, duit supports has been, and will continue to be, performed in accordance with
. 52-910. This includes, determining the permissible conduit spans and support designs directly from 52-910. Ebasco Engineering review of all deviations on a case by case basis prior to installation, creation of individual support drawings forany;p;;f'_ra--t::d:rd[designthatisnotincludedinS2-910andtheas building of all conduit runs recording the data on individual isometric drawings with clea" identification of each support type.
Deviations are reviewed by Ebasco engineering on a case-by-case basis prior to , installation. Individual support drawings are created for any specific nonstandard design that is not included in S2-910. These supports are designed individually. All conduit runs are as-built and are recorded on individual isometric drawings with clear identification of each support type. 03/10/86 III-18 NUO797 SEC III m,r. .r~._ . ., .-w__.. -- - , _ . - - ,.
4 Testing will be employed to establish capacities and allowables for certain conduit support hardware (e.g. , clamps and certain Unit 1 unistrut members). TNE has developed the required testing specifications.
, This review of both Units 1 and 2 conduit support designs will be subjected to third party overview for additional assurance of resolution of external source issues and compliance to CPSES licensing commitments. E NS Ed.T- S (M ft) 2.4.4.3 Staff Evaluation The staff has reviewed the approach and methodology of the TUGC0 revised designs and expanded conduit support review as desciibed in DSAP VIII. In addition, the staff has reviewed all identified external source issues, the original project conduit support design criteria and licensing commitments.
2.4.4.4 Conclusion
.< The staff concludes that the CPRT Program Plan, as described in Revision 3, ss eneM
. w$4T adequately address the issues identified with the c m t=y supports and will assure that these supports M meet the licensing criteria. ,
h Piping and Supports Issues p
-W 2.5.1 Piping Isolation (ISAP V.c) , , .The design consideration for piping systems between seismic Category I and non-seismic Category I buildings is addressed in detail in IV. Staff Evaluation of b
Construction Adequacy Plan, Section 2.4.3. The implementatiori of this ISAP will be performed under the Project Piping and Supports Program by Stone & Webster Engineering Corporation (SWEC). In addition, a third party overview under the Design Adequacy Program by TERA Corporation will be performed in the implementation of the ISAP. The staff evaluation of I the implementation of this ISAP (V.c) will be discussed in a supplement to thi SER. l 03/10/86 III-19 NUO797 SEC III
- . o ) O i i . i 1 ! INSERT B
- fu utTs%
! The third party overview i: :: ten:1::; it includes the same -ettri - ! bu4es as those used for overview of cable tray activities (Section III - l 2.4.3.2 of this SER). It wi'? k well d; s ;, cat;d, :in; d ::E'ict: "e-e
- appropriate.
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Third party ' 2.5. rview(PSO# [I r
*) I 2.f. 2. Introduction A number of external source issues have been raised in the area of piping analysis and pipe support design. These external source issues have resulted from several sources; the primary sources being the Cygna Independent Assessment Program (Phases 1-4), the ASLB hearings and related filings, and the NRC staff reviews. As a result, the CPRT initiated a special piping and pipe support requalification program under the' direction of TUGC0 projects which has resulted in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. Stone & Webster Engineering Corporation (SWEC) has been j retained by the applicant to perform this requalification program. In addition,
! a third party overview of this effort is being conducted by TERA Corporation i (TERA) to provide assurance that the objectives of the Design Adequacy Program
- . in the piping and pipe support area are being achieved. The {in'p!'n (F"Aii' jetfer g! a ("""' .'.. The piping and pipe support requalification and overview program is described in the CPRT Program Plan l- !t;....".c..icr IX.
D'J A P i In this section of the SER, we will discuss the staff review and evaluation of j the TERA overview effort. The staff review and evaluat n of the SWEC piping g j and pipe support requalification program is provided in III7 ftz Er h;t*;n ? of da i;- m a"~y D' , Section 3.5 of this SER. 4 The staff has reviewed the CPRT Program' Plan DSAP IX,e..J th: :ppli ni k p;rtica j c' /.gpendice. ...J ." ,,c hi ' ; te pfpi ; 2-1 p'p- "rp--t irrrr. In addition, } the staff has performed several audits at the TERA offices to further understand the scope of the TERA effort. Our review focused on the adequacy of the scope l and the completeness of the CPRT Program Plan details in addressing the technical l concerns associated with piping and pipe support design which have been raised ! by external sources and self-initiated reviews. a R Approach The scope of the third party review is described in the CPRT Program Plan 1 ] DSAP IX;nd ?;pudi:= 0 =d " and consists of three major activities: ' 03/10/86 III-20 NUO797 SEC III
- i. .
e (1) identification, review, and tracking of all external source and self-initiated issues; (2) verification that all design criteria and applicable standards are addressed in project procedures; and, (3) overview of SWEC piping and pipe support requalification program. 1 (1) Identification Review, and Tracking of Issues The CPRT Program Plan describes the third party area of review related to the identification, review, and tracking of external source,=d =ii-
; 4.i;.: a i;; = . The process includes not only issues related to the piping and pipe support discipline but also issues related to mechanical a systems and components, electrical and instrumentation / control, and civil /
veten.sikt<nI per structural disciplines. identifying the external source issues, the
! , third party is reviewing re ated documents such as the Cygna Independent i Assessment Program (Phases 1-4), including related meeting transcripts, the ASLB hearing transcripts and related filings, the NRC staff reviews
.- including inspections performed by Region IV, the Special Inspection Team
. (SIT),'the Construction Appraisal Team (CAT), the Special Review Team (SRT), and the Technical Review Team (TRT), and the JNPtTSelf-Initiated Evaluation. ?,
votp>dtM4 k h ,,,, 'g The third party is greviewing each identified issue and determine, ts significance with respect to the requalification program. Upon resolution of the issue by the responsible organization, the third party reviews and evaluates the resolution and performs an investigation of root cause and generic implication.
\M The issues and their status are tracked by the third party on a computer 9
system. The computer also tracks the applicable activity for each issue under the requalification program which addresses the resolution. t
.I 03/10/86 III-21 NUO797 SEC III
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I (2) Verification of Criteria and Standards The third party has verified that the commitments used to establish the piping and support design criteria and standards are adequately addressed in procedures and project documents. The commitments include satisfying FSAR, design specifications, and ASME Code requirements. For each criteria source and standard identified, the affected scope within the piping krso l analysis / support design requalification program yaeeesadelineated. The cri-teria N$ sed in the development of checklists for the review of specific program areas. (3) Overview of SWEC Recualification Effort The third party overview of the SWEC piping and supports requalification program consists of three major activities.
\s e49eE%
e ele t d ov-First, the third party i" 5: '-.J .;d ' a review of the SWEC project' s procedures to e used for the performance of the six major activities described in R;t!;.; 5.5.2 of this SER. The third party will verify that the procedures are adequate to achieve their intended purpose. ts w s p ewlib le b Second, the third party e!" i: ' ;:P :d
- a review of selected piping analysis and support designs performed by SWEC. The third party review will use written procedures and checklists to assure compliance with established requirements, gg aspedt4t* b &
Third, the third party w&.1-1 reviewgthj SWEC activities associated with the verification of as-built information to be used in the piping and supports i requalification program. 2, . f. 5 (*>++t)
! Staff Evaluation (1) Identification, Review, and Tracking of Issues The staff has reviewed and evaluated the third party isivolvement in the j identification, review, and tracking of issues. The CPRT stated in their 03/10/86 III-22 NUO797 SEC III
November 22, 1985 letter that the third party will provide reasonable assurance that all identified issues are resolved by reviewing SWEC pro-cedures and selected implementation documentation in conjunction with identification, review, and tracking of all issues until closure. SWEC procedures and implementing work will be reviewed to checklists which explicitly identify the issues in order to assure that they are adequately - addressed. For yet unidentified issues, the third party will review scope and depth of the SWEC piping and supports requalification effort to ensure their comprehensiveness. The third party role in the resolution of newly identified issues is to document the issues, track them, identify them to SWEC, review SWEC's proposed resolution, review SWEC's implementation, and ensure that they are resolved. Based on mr review of the scope of the third party issues, the staff finds an adequate process exists to identify all external source issues. The _, issues as they are identified are logged into a computer and their status e is tracked based on a periodic updating of the issue evaluation. The
- identification of external and internal issues is an on going process.
- Based on the scope of the external source issues including all issues
.c identified by Cygna, the ASLB, the intervenor, and the NRC staff irrespec-tive of their previous disposition, the staff concludes that the scope is -
all-encompassing and, thus, acceptable. The staff will continue to monitor the issue tracking system to assure 'all external source issues are identi-
. fled. The staff considers this to be a confirmatory issue and will report
.stre findings in a supplement to the SER.
The staff reviewed the extent to which root caus,e and generic implication evaluations will be performed. Root cause and generic implication evalua-tions will be performed on: (a) external source issues, (b) TERA - identified discrepancies in SWEC interfaces (c) TERA - identified discrepancies in the SWEC overview, and (d) SWEC - identified discrepancies from yet unidentified issues, 03/10/86 III-23 NUO797 SEC III
e . } tLa., Based on. swr review, it was not evident that a process existed for identi-fying discrepancies (or deviations) in external source issues by SWEC. The SWEC requalification effort will assure that ASME Code requirements , will ultimately be. satisfied for all piping and supports although it is l recognized that modifications can be made to existing hardware. It is not l clear to the staff that a root cause and generic implication evaluation can be adequately performed for external source issues without input from SWEC regarding the impact 'of such issues on hardware design. Although the , , staff recognizes that not all hardware modifications will be attributed to discrepancies or deviations, the staff requires that a root cause and l u generic implication evaluation be performed for all hardware modifications ! in order to document the reasons for such modifications. The staff con-siders this to be an open issue and will report our findings in a sup'ple-ment to the SER. { ; (2) Verification of Criteria and Standards ) i
+
! N- The staff reviewed the procedure used by TERA for the design criteria and :
, standards verification. The staf'f finds a sufficient process exists to
- 4 assure that all relevant design criteria and standards are addressed in design procedures. The TERA process involvf a review of FSAR commitments, ,
design specifications, ASME Code requirements, and other industry standards
- (e.g., ANSI, AISC, and MSS) in accordance with design adequacy procedure DAP-1.
i l j In conjunction with a staff audit of the TERA scope, the staff raised a ' ! concern regarding the TERA acceptance of certain design criteria. The j staff found that several design criteria are based on paragraphs from an l edition of the ASME Code later than the edition stated in the FSAR. Recently, the staff stipulated certain requirements for the use of later j Code editions and new ASME Code Cases (e.g., Code Case N-411). The staff ) discussed with TERA the basis to be used for the acceptance of portions of s j later Code editions. TERA responded by committing to review Project /SWEC l documentation for compliance with ASME Section III paragraph NA-1140 for the Code edition of record. Because the FSAR states that conditionally i approved Code Cases will show justification for their use in the design 1 ! I i 03/10/86 III-24 NUO797 SEC III 1 _ , - - - . - , - _ , , - - _ . ,n.-.-.----,
* -,,,,...,,--,,,-.--..-.-_.J--__,-,----.-- --- .-,
specification or the Brown & Root QA Manual, the commitlaent by TERA to review the applicable documents for compliance with NA-1140 is appropriate. Thus, the staff finds the scope of review for the design criteria to be acceptable contingent upon a satisfactory finding by TERA in its implement-ing review of the project documents The staff considers this to be a confirmatory issue and will report # findings in a supplement to the
~
SER. (3) Overview of SWEC Requalification Effort x The staff reviewed the checklists to be used by TERA in their overview of i the SWEC piping and pipe support requalification effort. The staff found the development of only one out of three checklists have been completed to date. The completed checklist pertained to the review of SWEC procedures. i The checklists to be used for the review of piping analysis implementation r and support design implementation were not available for staff review. The staff review of the checklist for procedure review (Checklist Number e DAP-CL-P-001, Revision 0, dated 10-25-85) found the checklist to be a suf-i ficient method to assure that the design criteria (identified in accordance
~
with DAP-1), external source issues (identified in the computer tracking
. system), and standard QA requirements (ANSI N45.2.11) are addressed in design procedures. However, unlike typical check.Lf sts (e.g. , Cygna check-Itsts) which are used to verify the adequacy and ~completi$e'ss of the design documents being reviewed, the procedure review checklist was found to be more of an inventory checklist which is used to assure that all design criteria, external source issues, and standard QA requirements are being addressed by at least one of several procedures. The procedure review
- checklist does not address the adequacy or completeness of the procedures i
with respect to the engineering assumptions and design input to be used l for analysis. The staff was informed that these items would be included in the checklists for the review of the implementation of piping analysis ! and pipe support design. Thus, the staff cannot reach any conclusion regarding the depth of the TERA review of the SWEC piping and support re-qualification effort without reviewing the applicable checklists. The 03/10/86 III-25 NUO797 SEC III
r l, . l staff considers this to be an open item and will report our findings in a supplement to the SER. The staff review of the third party overview of the SWEC construction / as-built review finds that no TERA procedures were available at the time - of the staff audit. Thus, it is not clear to the staff what actions are being planned by TERA for their overview of the SWEC construction /as-built review. The staff considers this to be an open item and will report on. this item further in a supplement to the SER. t The DAP scope of work under DSAP X, " Mechanical Systems and Components," and DSAP XI, " Electrical /I&C Systems and Components Discipline," will include a self-initiated review of' the auxiliary feedwater (AFW) system. However, the scope of work did not include piping and pipe support design. The basis for excluding piping and pipe support design from the self-initiated review of the AFW system was that the SWEC reanalysis effort included all ASME Class 2 and 3 piping systems (including the AFW system). Furthermore, the basis included a TERA review of a selected sample of the SWEC piping stress analysis. Although the SWEC reanalysis of the AFW piping system will adequately address the concerns associated with the previous Gibbs & Hill analyses, the scope of the self-initiated review of the AFW system under DSAP X and DSAP XI does not fully address the adequacy of the implementation of the interface requirements between the mechanical systems and the SWEC piping reanalysis (e.g., design considerations for water-hammer evaluation). The staff noted that the TERA review of a sample of the SWEC piping reanalysis did not specifically include the AFW piping l system. During the staff audit, TERA committed to include a portion of the AFW piping system in their selected sample of the SWEC piping re-analysis review. Contingent upon the inclusion of a portion of the AFW piping and supports in the TERA scope of review, the staff finds that the scope of the TERA overview of the SWEC piping and supports requalification effort is acceptable. The staff considers this item to be confirmatory and will report their findings in a supplement to the SER. 03/10/86 III-26 NUO797 SEC III
2.5 Conclusions Based upon the staff review of the CPRT Program Plan, the staff review of the CPRT response to staff questions provided in the November 22, 1985 letter, and staff audits performed to date, and contingent upon acceptable resolutions of , the above open and confirmatory items, the staff concludes the following. j The scope and depth of the third party (TERA) effort provides an adequate pro-j gram for the resolution of the identified external source issues and for the j identification and resolution of yet unidentified issues which would' result from self-initiated reviews. The staff finds the CPRT Program Plan in DSAP IX 1 r-f f.;;:.dk:: E rd " provides reasonable assurance that all safety significant j piping and pipe support deficiencies have been identified and resolved. However, j proper implementation of the program must be conducted in order to conclude that the objective of the Plan has been achieved. The staff review and evalua-i ~ tion of the implementation of the program.will be addressed in a supplement to the SER. 2.6 Evaluation of Closed External Source Issues i 2.6.1 Introduction i i Closed external source issues are those concerns identified by sources other l D 'than the CPRT (e.g., R IV Inspection Reports CAT, SIT, etc.),which are evaluated j and resolved by activities performed outside of the CPRT. %,4 0.~._,.% , the NRC's acceptance of the Applicant's corrective actions responding to notices of 1 violations.) 2.6.2 CPRT Approach l l The Program Plan Appendix A describes that the CPRT will identify the issues { by a systematic review of the documents containing the external source issues f for concerns implicating either the CPSES design or design process. The i documents reviewed include: 1 l l 03/10/86 III-27 NU0797 SEC III l- - - - _ . - - - - . - . - - - - . - . - . - .. -
- s. ,
NRC Special Ins,pection TEAM (SIT) Report 1 NRC Special Review Team (SRT) Report NRC Construction Appraisal Team (CAT) Report NRC Technical Review Team (TRT) Reports NRC Supplemental Safety Evaluation Re' ports (SSERs) NRC Region IV Inspection Reports q Cygna Independent Assessment Program (IAP) Documents
- i -
ASLB proceeding documents including transcripts, exhib'its, motions, filings and Board Orders. ! J 3
.z , -
Transcripts of meetings involving the NRC, CASE, Cygna and TUEC. e Other documents referenced from the above documents that have relevance to design or the design process. -j Where a review of the document by a member of the Design Adequacy Review Team i reveals a potential design concern, the concern is entered in the DAP Tracking /, System. This process is controlled by procedures and ensures thoroughness in h the issues screening process, control over the issue resolution proc.ess and the sorting of related issues for efficient resolution. a . 1 Where during the review of external source documents described abo've, an identi-d fied issue has previously been resolved to the satisfaction of the source, the r Design Adequacy Review Team will review the resolution. The issue will be con-sidered resolved with no further initiatives if determined to be consistent
- 0. with existing knowledge including consideration of generic implications. How-ever, relevant information will be retained for use in trending and generic '
i, implications evaluations. H n H ! 03/10/86 III-28 NUO797 SEC III
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e . As potential issues are identified, the Design Adequacy Review Team will review documentation pertinent to the issue. The Design Adequacy Review Team may also make a preliminary evaluation of available documentation, including engineering walkdowns, to qualify potential issues and to identify those issues requiring further review. The objective of this effort is to define the issue sufficiently to allow a determination of whether additionai evaluation' s 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 root cause and' generic-implications evaluations. An Action Plan is generated when an issue has been sufficiently defined. Where an issue appears to be isolated, an Issue-Specific Action Plan (ISAP), or addi-tional tasks within a DSAP may be devoted to that issue alone. Where the issue re appears to have a potentially cumulative effect with other issues, tasks will e be developed that permit an integrated solution to the set of potentially cumu-2, lative issues. Where identified, apparent or suspected root causes may be es-
- s. played in determining the scope of an ISAP or DSAP. Implementation of DSAPs 3- that address specific CPSES design issues "will also provide input into the y collective evaluations of design a CPSES and the design process employed.
2.6.3 Staff Evaluation Evaluation of the Plan, Revision 3, finds that the CPRT's ~ review of documenta-tion to identify issues includes the appropriate sources and describes how the issues will be tracked and evaluated in the DAP. Additionally, CPRT activities performed during implementation will determine the impact on construction ade-quacy, safety significance, root cause and generic implications, collective significance and programmatic implications. This evaluation finds that the Plan adequately describes how the CPRT will handle the closed external source issues; and is responsive to the NRC's concern. 03/10/86 III-29 NUO797 SEC III l s?
. . .. = . __ - . o 2.6.4 Co'nclusion Based on its evaluation that found that the closed external source issues related to design are now adequately addressed in the Plan, the staff concludes that the Plan is acceptable in this regard.
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03/10E86 . III-30 NUO797 SEC'III
l O 4 3.0 SELF-INITIATED EVALUATION 3.1 Design Activities Evaluation Process l . . 3.1.1 Introduction A self-initiated evaluation of selected design areas has been proposed by the CPRT in the design adequacy program plan (DAP) in order to increase confidence in the adequacy of the CPSES design and design process. The results of this ' evaluation and the results of the internal source issues review will' determine the adequacy of the overall balance of plant (BOP) design and design process at CPSES.
- The implementation of the DAP is divided into Discipline Specific Action Plans (DSAPS) related Civil / Structural, Piping / Supports, Mechanical Systems and
., Components, and Electrical / Instrumentation and Control. systems.
3.1.2 CPRT Approach ,
- . The initial scope identification was conducted through review of Independent
_ Design Verification Programs (IDVPS) and Integrated Design Inspections (IDIS)
. conducted at other nuclear power plants. Design areas addressed in the IDVPS and IDIS were compared against previous services conducted in behalf of CPSES (such as CYGNA, SIT, SRT, CAT, TRT, etc) to determine the depth and breadth of the review required under the new self-initiated program. A list of safety-i
, significant system design characteristics were compared against the AFW system l and a portion of the Class 1E electric system to determine whether their design
. adequacy could extrapolate the adequacy of the over all CPSES BOP design.
- j. The CPRT program plan states that an engineering process validation,has deter-mined that the selected systems for evaluation (i.e. AFW and portion of Class 1E Electric) are representative of the safety-related systems, structures and components at the plant.
l l In order to assure that evaluation results could be used to extrapolate the i adequacy of the remainder of the A/E safety-related scope of design, the CPRT 03/10/86 III-31 NUO797 SEC III
4 0 pW X identifies a finite number of homogeneous design activities (HDA) that are used to ensure that the DAP has adequate breadth and the evaluation is carried to sufficient depth. The elements that are important for determining homogeneity of design activities are the following: Criteria Design consideration, approach and methodology Organization / discipline Design control process Design interfaces Homogeneous design activities identified in the DSAPS matrices present the review scope for each discipline. The HDSAS have been grouped into topical areas within which review checklists will be developed. 3.1.3 Staff Evaluation e The staff has evaluated the proposed design adequacy review scope to determine O whether review of sufficient number of safety systems and comPoaents are beino e considered in the review to reach a reasonable assurance that all safety systems and components in CPSES are adequately designeri. Our evaluation has reved y? that the initial scope of review of the Auxiliary Feedwater System and the portion of the Electrical System did not include suf-ficient number of design activities to allow an assessment of the overall plant BOP design adequacy. However, the augmented scope of review identified in the DSAPS homogeneous design activity matrices and the potential for scope expansion during implementation of the review can provide the reasonable assurance that all safety systems and components are adequately designed. 3.1.4 Conclusions Based on our evaluation of the review scope proposed in the CPRT program plan for determining the overall design adequacy of the plant, we conclude that homo-geneous design activities will provide adequate basis for. determining the breadth of ,that review. 03/10/86 III-32 NUO797 SEC III
= _ - - _ _ _ __
3.2 Electrical Instrumentation and Control Systems and comoonents Desian Activities I 3.2.1 Introduction . The self-initiated evaluation of selected design areas of electrical, instrumen-tation and control systems, and components has been proposed by the CPRT in the design adequacy program plan (DAP) in order to increase confidence in the ade-quacy of the CPSES design and design process. The results of this evaluation and the results of the internal source issues review will determine the adequacy of the overall plant design and design process in these areas. 3.2.2 CPRT Approach The CPRT program plan has identified for review design activities from the
- .. Standby Power, Auxiliary Feedwater, Ventilation Safety Chilled Water, Component , <
. Cooling Water, Station Service Water, and Station Service Water Intake Structure .. Ventilation Systems.
2 The Homogeneous Design Activity matrices associated with the E/I&C system, iden-
; tify the areas that will be selected for review. The technical characteristics required to be reviewed for assuring adequate depth of review, will be contained in technical review check lists. Overall design adequacy (breadth) will be determined by the cumulative assessment of the design adequacy of the homogeneous
- design activities and the external source issues.
3.2.3 Staff Evaluation The staff has evaluated the proposed design adequacy review scope for the Elec-trical Instrumentation and Control Systems (E/I&C) and Components, to determine whether sufficient number of safety related areas are being considered in the I review to reach a reasonable assurance that all safety systems and components in the CPSES are adequately designed. 03/10/86 III-33 NUO797 SEC III
l Our evaluation has revealed that the scope has been significantly augmented, as indicated in the homogeneous design activity matrices, with the potential . for scope expansion during. implementation of the review. 3.2.4 Conclusions Based on our evaluation of the review scope proposed in the CPRT program plan for determining the overall design adequacy of E/I&C systems and components, we conclude that homogeneous design activities will provide adequate basis for determining the breadth of that review. 3.3 Mechanical Systems and Components Design Activities 3.3.1 Introduction a Normally, the technical areas of A/E design responsibility assigned to the
- w. Mechanical Discipline involves fluid systems, hydraulics, HVAC, process, nuc' lear v and operational considerations. In .the capacity the Mechanical Discipline pro--
O duces impiementino desion documents such asi fiow diaorams, e aad ID , gigins
, drawings, equipment (installation, bid and purchase) specifications and calcula-
- . tions. The calculations involve entire system revaluation as well as sizing of individual pieces of equipment. The result of these calculations are made part of the specifications and the various drawings. The Mechanical Discipline also produces and receives design requirements from other disciplines (internal inter-
- faces). These interfaces usually involve the disciplines. of Instrumentation
) and Control, Electrical and Structural. Also, the equipment vendors provide ! the Mechanical Discipline with equipment design data and requirements (external
- interfaces).
Therefore, the evaluation of the adequacy of the design produced by the Mechani-cal Discipline will focus on both the implementing design documents and the various interfaces. .O l 03/10/86 III-34 NUO797 SEC III
iO , 9 ~1 3.3.2 CPRT Approach The CPRT through the Scope Development Process of the DAP plan intends to inspect the various implementing design documents produced by the Mechanical Discipline and its various interfaces. The Mechanical Discipline design effort has been. ! divided into Review Areas. The Review Areas have been further broken down into ! Homogeneous Design Activities (HDA's). A Review Area is a general category of design effort, whereas, a HDA is a particular aspect of the area. An example l of a Mechanical Systems HDA under the Design Area of Auxiliary Feedwater and ! Fluid Systems would be Steam System Pressure Drop. Other examples o'f Mechanical Systems HDS's are Open System Heat Removal and Closed System Heat Removal which are also part of the Auxiliary Feedwater and Fluid Systems Review Area. An ;
; example of a HDA associated with Mechanical Component in the same Review Area f 1 is Centrol Valves.
u !
; . In the DAP plan there are five Review Areas assigned to the Mechanical DSAP.
? These are broken down into 126 HDA's. Each HDA will be reviewed via the imple-o mentation of technical checklists. An individual checklist covers what is termed g 4 a Review Topic. In some cases it is necessary.to complete several checklists 2before a'particular HDA has been fully inspected,~ conversely a single checklist
- may apply to more than one HDA. An example of this in the Mechanical DSAP is the HDA; System Fluid Temperature-Minimum / Maximum (M026). This HDA requires the completion of three checklists. These checklists are: 1) System Operating
- Modes, 2) System Maximum Conditions and 3) Heat Removal Capacity. An example of a checklist apply to more than one HDA is the one associated with the Review Topic of System Maximum / Minimum conditions. This checklist applies to the HDA's of Flow Requirements (M014), Pressure Conditions (M015), System Fluid Temperature (M026) and Expected Loss of Cooling Transient (M027).
3.3.3 Staff Evaluation { The staff performed two audits specifically aimed at reviewing the scope of the i DAP plan are represented by the HDA's. The initial audit addressed the scope l of Revision 2 of the program plan. The staff had several comments on the scope l which included a listing of Mechanical Discipline design elements. This listing 03/10/86 III-35 NUO797 SEC III o
I
. , l indicated which of the design elements were contained in the Mechanical DSAP and which apparently needed to be added.
At a subsequent audit, the staff reviewed an intended scope expansion. The expansion was in the form of additional HDA's. At this audit a generic master logic diagram was presented as the basis for the composite list of HDA's for the Mechanical DSAP. Documentation relating (application of the logic diagram to the Mechanical Discipline A/E design responsibility was not presented. Based on their background and experience the staff did evaluate the composite list of HDA's with respect to whether or not the totality of the Mechanical Discipline A/E design responsibility was substantially represented. 1 Recently, TUEC raised a concern regarding an issue pertaining to whether active valves were designed in accordance with FSAR commitments. The staff reviewed- 7 t j , the TUEC response of November 22, 1985 concerning the issue of active valves jg and considers the response to be too general. # The CPRT should specify where in Section 3.1.A Paragraph 1 this issue is being O. addressed. secause the Pien intends to provide compiete coverage of aii areas
. with safety significance, the CPRT should consider the issue of active valves in the Plan's root cause/ generic implication evaluation. The CPRT's response .
to the staff concern did not specifically address the issue of active valves nor did it provide any commitment to evaluate the significance of the errors. _
%2. ,
I The CPRT should specifically review whether there exists any procedure to docu-ment deficiencies in specifications detected by vendors, whether there exists any documentation of or prompt follow-up of such deficiencies such as those identified with active valves, and why the system to control the quality of design documents did not detect that the specifications had deviated from FSAR ' commitments. The staff considers this to be an open item. 3.3.4 Conclusions , The staff has concluded that the composite list of HDA's subst o tially represents the A/E design responsibility for the Mechanical Discipline. l 03/10/86 III-36 NUO797 SEC III
L. , During implementation, the staff will verify that documented justification exists for the development of the HDA breakdown of the Mechanical Discipline. Concerning active valves, the staff requires the CPRT to consider the root cause and generic implications of inadequacies in specifications identified by vendors. This evaluation also should include a review to determine why the system to control the quality of design documents did not detect the incorrect specification and provide corrective action.
, 3. 4 Civil and Structural Design Ac'tivities 3.4.1 Introduction Due to the number and types of potent.ial concerns identified in the civil /
4 structural area by previous reviews, namely, the shortening of the bolts in the steam generator upper-lateral supports, design of seismic Category II items,
. along with the numerous issues identified with the design of the cable trays,
- 2. conduits, and their supports, the CPRT has expanded the scope to include self-initiated reviews.
The purpose of this self-initiated action is to expand the scope of review in i the Civil / Structural Design. Area beyond that of the investigation of the External l Source Issues to provide an additional level of assurance that all safety-significant design deficiencies are identified. The Self-Initiated Evaluation of the' Civil / Structural Design Activity is outlined in Item VIII,. Civil / Structural
- Discipline Specific Action Plan, of the CPRT Program Plan.
! 3.4.2 CPRT Approach
; The approach outlined by the CPRT in Item VIII of the Program Plan involves an initial scope which consists of an overall review of the Civil / Structural Design Activity to identify either generic ' issues or trends in issues with a final ; scope based en any findings.
1 The scope of the Civil / Structural Self-Initiated Evaluation is intended to encom-pass all safety-related civil / structural design processes not covered by the 03/10/86 III-37 NUO797 SEC III i-. . . -.
l> . l i TRT-related reviews. The review areas are esta'blished through the identification ! of associated homogeneous design activities from which the designs for review will be selected. Designs representative of HDAs will be selected for review. HDAs have been grouped into topical areas to. facilitate the design review process. The follow-- ing sections summarize the scope of the CPRT review for each of the topics. The review scope is more fully discussed in Section 4.3.2 of DSAP VIII. j Load Determination i, Where unique calculations have been perfomed (separate from individual structural
- design calculations) to determine and distribute specific loads on structures, representative calculations will be selected for review. -These unique calcula-tions are expected to address pressure, wind, tornado, impact and seismic-loads.
l < The review of pressure, wind, tornado and impact load dete'rminations will be'
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i ec' performed on selected representative calculation packages. The determination l of seismic loads will be reviewed for.the auxiliary / electrical building, which l has been selected due to its relative complexity. The procedure for developing l- floor response spectra, considering the three components of earthquake motion, i closely spaced modes, peak broadening, torsional effects,.etc., will be reviewed. I i l Concrete Design Q: - C. i i j Three buildings have been selected for review: the reactor, auxiliary / electrical,. l and fuel buildings. For the reactor building, the method of analysis will be l l reviewed as well as one set of calculations dealing with the g wall and - l l three others with discontinuities in the g wall. The liner plate and its -- ! anchorage system will be included in the review along with a set of calculations ' . addressing the radiological shield wall in the internal structure. In the two j other 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 exterior walls as missile barriers will-be reviewed and their design verified. Several concrete equipment foundations will also ba
- reviewed.
i 03/10/86 III-38 NUO797 SEC III 1- - - - - . - _
}* , l l Structural-Steel Design
. l The use of structural steel is limited in the CPSES plant, with essentially no major steel framework in any of the Category I buildings. Selected portions of the structural-steel frame of the cable-spreading room will be reviewed.
i In addition, several structural-steel components related to pipe-rupture protec-tion will be selected for review including pipe whip restraint supports and jet shields. A set of calculations related to the design of platforms, monorails and miscell-aneous Catregory I steel will be selected for review along with the design of the stop gates for the Service Water Intake Structure. 9 Foundation Design
,4
, g The design of building foundations will be verified by reviewing the design.of j . the containment mat. In addition, a representative retaining wall will be [ - reviewed along with a review of the foundation design of a Category I tank. I i j HVAC Supports i 4 { HVAC support design has been included within the scope because of similarities l with the cable-tray supports. The systems analysis for the control room HVAC will be reviewed in its entirety. Approximately 20 supports from the remaining population and 20 supports from the control room HVAC system will be reviewed. t
- The results of the review will either
- 1) indicate the need to expand the scope j of the review, 2) identify a subpopulation for further investigation, or 3) pro-vide reasonable assurance that the HVAC support systems will meet their specified
! design requirements. ! Crane Supports l 5 The containment polar crane has been selected for review in this category due i to its importance and its critical location in the plant. l'
- 03/10/86 III-39 NUO797 SEC III t
}
l Equipment Mounting Equipment can be divided into two categories: rtecnanical equipment and elec-trical equipment. A minimum of'five pieces of equipment from each category will be selected for review. Penetration Sleeve Anchorage The population of penetrations through the containment wall will be identified and several penetration sleeves, both mechanical and electrical, will be selected ~ for review. Missile-Resistant Doors and Hatches i . Tnese components can be sorted into two categories, one in which the doors are '
- r. designed by the manufacturer with the anchorage designe,d by the A/E design T organization and the other where the entire component including the anchorage
- r is designed by the A/E design organization. A minimum of five items from each category will be selected for review. -
l
. Seismic Restraints for Removable Shielding Walls l The population of these components will be identified, and a minimum of five i items will be selected for review. -
l 2 Recirculation Sump. Pump Screen Support - Crossover Leo Support - Control Rod I Drive Mechanism Supplemental Steel Support - RPVRI Support i These four supports have been selected because of their uniqueness in design and their importance to safety. All structural considerations related to their , design will be reviewed. 1 i j I&C Tubing' Supports t The , methodology used to analyze and design these systems will be identified and reviewed. Supports and/or systems will be selected to verify the implemention of the design. 03/10/86 III-40 NUO797 SEC III
i i Fuel Transfer Tube Support This item has been selected since it is a nonpiping-related support designed by the civil / structural group to the ASME code. It is unique in the plant,.and its design will be reviewed.
$Ve*p 94 4
Other Structures Design N p[ The design of the following miscellaneous structures will be verified: A selected number of seismically designed secondary concrete walls and firewalls will be reviewed for~ load requirements and design. l One of the three outdoor seismic Category I tanks. - r- The design methodology for underground tanks, underground tunnels'and underground electrical duct banks. ) - The analysis and design of the safe shutdown impoundment dam.
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i ;,- The containment equipment hatch cover and another building roof hatch cover. Fuel Pool Re-Rackinq A review of th'e following will be performed: 1) new requirements resulting
- from the high-density racking, 2) subsequent analysis including dynamic analysis i and impact on floor response spectra and local loads, and 3) design details.
, Heavy Load Drop The general methodology, load path and energy-dissipation assumptions of heavy load drops. 1 ) f
) 03/10/86 III-41 NUO797 SEC III
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i Development of Specifications Selected specifications prepared by the civil / structural group. Testing programs providing backup for design-basis criteria. Other confirmatory tests, such as the Containment Structure Integrity Test assessment. Special Studies 4 Special studies that validate design assumptions, nonconforming conditions, analytical approaches, etc. For each of the areas of review, the review process will involve the identifi-v-cation and review of. design criteria, implementing documents, drawings and-
~
specifications. 3.4.3 Staff Evaluation
.The staff's evaluation of the Self-Initiated Civil / Structural Design Activities
-is based on a review of Revision 3 of the CPRT Program Plan, the CPSES FSAR and audits of the Comanche Peak DAP scope validation process and HDA methodology which established the breadth of the review.
As.part of its continuing review, the staff will audit further the implementation of the DAP scope validation process and HDA methodology to determine whether the design activities included within selected HDAs are indeed homogeneous and. l that the review scope includes an adequate sample from each identified HDA.
.3.4.4 Conclusion The staff concludes that the CPRT evaluation plan for the Self-Initiated Civil /
Structural Design Activity is generally acceptable and does provide a comprehen-sive probe of the civil / structural design area. The breadth of the review is
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! 03/10/86 - III-42 NUO797 SEC III w- ry . - - - e.- - ,w- - , - - -yw- -, . __p._., y , . --.,e- -
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l: o , established-through the identification of associated HDA's from which the design
; reviews will be selected. The staff intends to audit further the implementation
- i of the DAP scope validation process and HDA methodology to confirm the adequacy of the program.
I r S 03/10/86 III-43 NUO797 SEC III
s . SELF-INITIATED EVALUATION - DESIGN ADEOUACY PLAN 3.5 Piping and Supports Design Activities
~
3.5.1 Introduction A number of external source issues have been raised in the area of piping analy-sis and pipe support design. These external source issues originated from several sources; the primary sources being the Cygna Independent Assessment Program, the ASLB hearings, and the NRC staff reviews. As a result,'the appli-cant has initiated a special piping and pipe support requalification program
~
which will result in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. Stone & Webster Engineering Corporation (SWEC) has been con tracted by the applicant to perform this requalification program. In addition, a third party overview of this effort is being conducted e by TERA Corporation .(TERA) to provide assurance that the objectives of the
- Design Adequacy Program in the piping and pipe support area are being achiev'ed.
e The CPRT Program Plan describes the piping and pipe support program and over-view in DSAP IX.
, In this'section of the SER, we will discuss the staff review and evaluation of the.SWEC piping and pipe support requalificati gram.
Theg,taffgegiewand evaluation of the TERA effort is provided in L.= III pempep4 2#of this SER. 3.5.2 CPRT Approach The scope of the SWEC program for the requalification of piping and pipe supports includes: . 100% of all ASME Code Class 2 and 3 piping larger than 2 inches (large bore), excluding portions within the boundary of Westinghouse Class
~
auxi11ary branch line stress problems, 100% of all ASME Code Class 1, 2, and 3 1arge' bore pipe supports, l l 03/10/86 III-44 NUO797 SEC III
small bore piping and pipe supports on a sampling basis, all Class 5 piping and pipe supports within ASME Code Class 2 and 3 stress analysis problem boundary, and all Class 5 supports within the ASME Code Class 1 stress problems. The CPRT Program Plan in DSAP IX Attachment 2 describes the outline of the SWEC Action Plan. The SWEC Action Plan consists of the following six elements:
- 1. Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria.
- 2. Verification of Existing As-Built Information.
l 3. Review and Verification of System Design Input, Seismic Acceleration and
, Fluid Transients.
i - 2:4. Verification of Existing Pipe Support Design Documents. 1
- 5. Resolution of Special Technical Concerns. -
- 6. Reanalysis of Piping Systems and Reevaluation of Pipe Support Designs.
I
- 1. Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria The Design criteria and procedures to be used for the pipe stress and support requalification effort by SWEC.are included in procedures listed below:
Procedure Title
- I CPPP-1 Management Plan for Project Quality, Rev. 2 l CPPP-2 Project Organization Charts, Rev. O CPPP-3 Document Control Procedure, Rev. 2 CPPP-4 Project Records Ma:,agement Procedure, Rev. 1 CPPP-5 Field Walk Procedure, Rev.1
. CPPP-6 Pipe Stress / Support Requalification Procedure - Unit No. 1, l Rev. 1 I 03/10/86 III-45 NUO797 SEC III '
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- . ._ .__ _ _. , . -._,.,_.,_.,,,_,_.m _
Procedure Title CPPP-7 Design Criteria for Pipe Stress and Pipe Supports, Rev. 1 CPPP-8 Support System Verification Walkdown Procedure, Rev. O CPPP-9 Pipe Stress / Support As-Built Procedure - Unit No. 2 Rev. I l CPPP-10 Power Division Procedure for Documented Review of Plant Operating Mode Conditions, Rev. O l CPPP-11 Administrative Control of Calculations, Rev. O CPPP-12 Cost and Schedule Control Procedure, Rev. 0 4 CPPP-13 Site Construction Support Activities, Rev. O j CPPP-14 Procedure for the Preparation and Control of Project ! Procedures, Rev. 1 ) _ CPPP-15 Small Bore Stress / Support Requalification Procedure j I PM's Project Memoranca . f PM-001 Pipe Support Computer Program Usage ! PM-002 Design Criteria fop Pipe Stress and Pipe Supports PM-003 Design Information Request Procedure PM-004 Embedment Plate Evaluation PM-005 Valve Modeling PM-006 Use of Code Case N-411 for CPSES Stress Requalification These procedures will reflect all CPSES FSAR commitments and the ASME Sec-tion III Code of Record (with NRC approved changes). In the process of re-qualification, it is expected some changes to this.FSAR and ASME Section III Code of Record will be requested by TUGCO. For example, TUGC0 has requested (W.G. Counsil letter dated 11/18/85 to V. Noonan) approval for the use of Code Case N-411 from the NRC. This request is presently under consideration by the Staff. In addition, Procedures CPPP-6 and -7 will includ@spe boet
% ired for the proper treatment of all external source issues /which are not covered by the standard SWEC procedures and which are unique to the CPSES plant.
i At this time, Procedures CPPP-6 and -7 do not include all of the methods required for the resolutions of these issues. _ s
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- ... - . _ ~ _ _ g 03/10/86 III-46 NUO797 SEC III l
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- 2. Verification of Existing As-Built Information Because the existing as-built data will be used as input for the SWEC requalifi-cation effort, it is important to develop confidence in its accuracy.
The process being ,s.a usedmtorau devel,op w eramthis,*confid.oence w n -. involves w walkdowns v a m -s performed by SWEC, a relian,ce on previou,s j g by TUGCO, and o othe,rg.orJJbycothe m oeus CPRig, w iro.c.t w e. The walkdowns by SWEC include: (a) CPPP-5 Field Walkdown (b) CPPP-8 Walkdown (c) SWEC " Stress Reconciliation Walkdown" 2 Previous work by TUGC0 includes their((1) j%eneral Program for As-Built Piping Verification,(and (2) " Penetration Scheduled M/*C" ""* Md## '8 ####
. - FM co weafs su /t=sucs<w y -/'/,ph~df)x(Laspm 3 gy/ Y ,,
c The activities by CPRT to be considered here include the reinspection performed
~., under the QA/QC Construction Adequacy Program, specifically for those samples l related to piping and supports. The various as-built'walkdowns and reinspec- ; tions are discussed in the following paragraphs. )
CPPP-5 Walkdown - The purpose of this walkdown by SWEC was to establish con-l fidence in the adequacy of dimensions and functions shown on the existing as-built drawing to support the initiation of the piping analysis effort. This walkdown is described in SWEC procedure CPPP-5 and the results will be published in a walkdown report. The walkdown procedure provides for the field verifica-tion of random samples of four attributes selected by SWEC, which represent geprs. those attributes most likely to affect piping analysis 4 The attributes selected ) include valve location, pipe support location, pipe support function and support 3 4 orientation. CPPP Walkdown This as-built walkdown procedure requires a piping and support system walkdown by experienced SWEC engineers who will perform the piping and support reanalysis. The objectives of the walkdown are: l 03/10/86 III-47 NUO797 SEC III l 2
e . (1) To determine whether there are technical configuration issues, other than existing technical findings from previous reviews, that should be evaluated relative to the functional behavior of the system, and (2) for experienced SWEC personnel to become familiar with the physical aspects of the design and determine whether additional, or refinements of, design inputs, guidelines, or procedures are necessary for the pipe stress and supports requalification effort. The procedure requires the walk.down of 70 stress problems out of approximately 360 which are within the scope of the SWEC requalification effort. SWEC Stress Reconciliation Walkdown - This, as in other nuclear plants, will be performed by pipe stress analysts when the piping stress analyses are completed. Examples of the attributes to be inspected during this walkdown include gaps and interferences.
, TUGC0 General Pro @ ram for As-Built Piping Verification - These activities repre-sent the walkdowns performed by TUGC0 to satisfy NRC IE Bulletin 79-14. The ,
TUGC0 procedures issued included CP-QP-11.3, Rev. 6, QI-QP-11.13-1, Rev. 8, CP-EI-4.5-1, Rev. 9 and TNE-DC-24-1, Rev. O. [ Penetration Schedule - The penetration schedule is a detailed computer listing 48 describing all of the penetrations in the plant. The schedule lists the type of sealant, type of penetration, openings and a number of other parameters. The stress analyst can obtain all required information related to penetrations from this document.
. 3. Review and Verification of Systems Design Input, Seismic Acceleration and Fluid Transients SWEC will review all drawings and specifications for systems within their scope.
The specifications will be reviewed to assure compliance with licensing commit-
- ments and that all operating modes and conditions are identified appropriately.
l Existing fluid transient loads will be reviewed and, if required, new loadings generated. SWEC Procedure CPPP-10 describing the operating conditions for the plant has been prepared and includes some of the above data. l 03/10/86 - III-48 NUO797 SEC III
I 4 , l l The third party will review this activity including verification that the SWEC l procedures are adequate to perform their intended purpose. The primary focus ! I of this review will be the definition and verification of design input. =
- 4. Verification of Existino Pipe Support Design Documents 4
Revision 2 of the CPRT Program Plan in DSAP IX Attachment 2 stated that the ) existing pipe support calculations would be-reviewed to determine their tech- ! nical adequacy. SWEC originally intended to review existing large bore support calculations on
- asamplingbasistodeterminetheiracceptabjlitgbyusingaloadcomparison j method. However, the approach mesws has,now beentftUIEbto include evaluation of all l large bore pipe supports THdiviauall Q SWEC Project Procedures CPPP-6 and CPPP-7 describe the approach to be used, the design criteria to be satisfied, and
{ j the extent of the review required for the pipe support requalification effort. Thus, this Action Plan element has been incorporated into Action Plan Element #6. Etntw s
- voec S /HM5 e
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- 5. Resolution of Special Technical Concerns- w* '*v ca"' "Md# V l vs,ai,. .r n,, m a w 4 rr e.*<- rot ** "'k' sces.
The CPRT Program Plan describes the SWEC approach to be used in the resol _ ion { I of special technical concerns. The special technical concerns are those issue (outsidethescopeofthetypicalproblemsencounteredintneconventionalpiping I~ stress analysis and pipe support design, n 'aWfo'bEaTd5Is'e'6 fy"5's'pYcial Sev6C. snosam os M l technical group. Many of thef external mee a ,, source issuesp included in the special n Sn c-technical concerns,atna are re8uun1reo to ce consicerra im thg p[ ping and pipe j support reanalysis. The resolutions of the special technical concerns will be ! incorporated in the SWEC Project Procedure CPPP-6, " Pipe Stress / Support Requali-
- fication Procedure" and CPPP-7, " Design Criteria for Pipe Stress and Pipe l Support". The approach to resolution and the background information for the '
I resolution, however, are contained in supporting SWEC calculations, special i studies and/or reports. C i 1 f, 6. Reanalysis of Pipino Systems and Reevaluation of Pipe Support Designs i 1 Attachnent 2 of DSAP IX of the CPRT Program Plan describes'the reanalysis of piping systems and the reevaluation of pipe support designs. The Plan states
; 03/10/86 III-49 NUO797 SEC III l
I
s . N{ s
.y , s thatthepipestressreanalysiseffortwillfollowprojectproceduresCPPP-f(.[
" Pipe Stress / Support Requalification Procedure" and CPPP-7, " Design Criteria h-j , ,.
for Pipe Stress and Pipe Supports". The large bore piping reanalysis will'in- % clude all ASME Class 2 and 3 piping larger than 2 inches (nominal pipe size) o ~b D excluding portions within the boundary of Westinghouse Class auxiliary branch "f Y line stress problems and all Class 5 piping within the ASME Class 2 and 3 stress q g 3 problem boundaries. The large bore pipe stress analysis will utilize verified e
~8 d as-built data (see Action Plan Element #2 above) and verified system design
\,-
tj l input (see Action Plan Element #3 above). New seismic ampiffie : using the damping values per ASME Code Case N-411 NRC approval g - will 1 [S - g
'Q Elimination of unnecessary pipe supports (including snubbers) to y i optimize system performance will be performed by pipe stress engineers where
{ N , judged appropriate. The large bore piping stress reanalysis will be used as k the analysis of record to qualify the structural integrity of the piping systems. Yk Gibbs & Hill will remain the designer A/E of record for the piping systems with full responsibility for the system functional design. The SWEC piping stress I . results will also be evaluated for consistency with the postulated pipe break ' ,l locations. i f For small bore piping systems, the CPRT Program Plan states that reanalysis of small bore'(2 inches and under) piping and supports will be performed on a sampling basis to verify adequacy. SWEC is preparing a project procedure (CPPP-15) for the requalification of small bore piping systems. The specific
~~
I approach to be used for the requali ication effort is being developed at this [ t e. y ,
, y d>Phhhhf -
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~
A ., f For large bore pipe supports, SWEC is reevaluating all ASME Class 1, 2, and 3 pipe supports and Class 5 supports within the ASME Class 1, 2, and 3 piping l l stress analysis problem boundaries. Each pipe support calculation will be re-viewed for technical adequacy including the need to address those aspects of
=l the calculation which are associated with_ external source issues.
i j a 03/10/86 111-50 NUO797 SEC III l l l o ! I_ _ -- -._.: - -
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h' 3.5.3 Staff Evaluation [ ,d 1 Development of Comanche Peak Pipe Stress and Pipe Support Desian j i g - , ;. 4 8ecause th ajor details of the SWEC requalification effort ars-d$ained in '[ . I the SWEC project cedures CPPP-5, CPPP-6, CPPP-7, an e 4nd becau $ i V'
~
- I (these procedures have JUh4agg_made available f.e-tig)$taffgeva1uation as not y hl 8 yet been completed y / During audits starr at swtt, and at tne cPsts sne,
(.M
]s draft copTeref'the procedur re reviewed. these reviews were prelim-ontingent upon a
'. j' na g ,re._and a raft dgcuments onlyhpproval thorougt and sa cryp ev g by the staff. This review is pre in
\ tf F
'y progress. ontinued work by SWEC in thie = = = = += at the risk of the licensee Y, g',~, ,pc, , , ar-m-wSrxs_cws,,oriu rm rv M *~ sN~Au a af sov t ns ea u a sao wi a-ns.< *L.< ec ., , s g.g-g
. 2. Verification of~fsT~
~
Bull't Information
$ $G. l >01 R LT y The results and the compilation of SWE'C and QA/QC walkdowns and previous work peformed by TUGC0 will determine the acceptability of the Plan with respect to
- the " Verification of As-Built Information". Therefore, a review of the imple-mentation of these procedures is required.
During staff audits at the SWEC offices and at the CPSES site, the topics of I CPPP-5, the CPPP-5 walkdown report, CPPP-8, the TUGC0 as-built procedures, the , penetration schedule and the QA/QC piping and pipe supports samples were dis-cussed and reviewed. In addition, the staff and its consultants performed sample walkdowns. As a result of our review, the staff has identified several areas where addi-tional information is required:
- a. The CPPP-5 wa kdown procedure allows the valve and support location toler-ances used by SW range from +/- 3 inches to + nches depending on the dimension used on e drawing. T a ly, a tolerance for such a
/ dimension is a function of the ter of the piping system. In this A case, there is no r s ip to pipe e. Using this CPPP-5 approach, V./
a valve or pport could be mistocated more o a 3-inch ifne than on a 30-inch line and is still within the acceptabilit' imits established I 03/10/86 III-51 NUO797 SEC III
, . I w e s ,-- u QW F-77't .f/ h /. I T %k -+uhnied d<.fni[s eg. e f +Su. salec r<74c -ttan l
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<qp e <+s nr< no+ -+= += lly ec m 1 i & f ai?h +1v. dt.sf3 n avif--fIe (n ukJ ..k cPff-7. Car < rdy , +4.a- 1=3 'ht lup to 4 Ih cle d y . W C 7.) es-f le.e+5 +Aa disrgn enke 4 dalg.n ru d.edeleyy va.a J by 1Aa. preaie a.s o.cch Hect - .
y ia- -< , G l k.r de H ill . % e. , -fur- +Aa. Atsrg n are pl y ,>y J y,l Th.s , 4An- . s+=-fF re-yaire.s tK :t- fl.a. SuJEc da. syn a rI ts<tz
-.... asJ de s!9n m 4 4odelogy . .: frevidt.) 4 ofPP-7~ L*. r vir-=={
- -hr- m s!s k y witk rle Fs g tm< n.ts a.s skied 4 da. ..C M T be9 ~ P1an . #!:w -. g., -lAc !=skR . hail Le l . r evIsaJ to aee% re-Ra.c.t rb. Au.3Ign cc;Is<ig. anJ me-Madelayy no.<J bySul.Vc 4=< tA.a. m ulo'Ec-;Hen
,ppnyda4e juidiceMo n Sev- -th s e. e%:e r uthac4 cedd QQ iedeLa tL.
bap.sct y + kue skFF swMy evalua%.s er u>hief coule( a-fre c+ <.articr- +cstkony L< fere. -tAs A-s L a , Th s f.ff usil/ ca., hmu. . Hs *% ef- -/Ae- dii!!T Q acA c c ceph6o.lif Pr-a.k f e U < e-t P, - A - _- M -
-tAa. e , &:y ef +A - crR.T frog rnm flo. &. conhoye~T upon m etcc.<ple $f't. r<-'elu4t h c-/- -t.E d l Us.se _ _ _ _ _ _
4 a , 1 1 p s k CPPP-5. The licensee must provide further justification for these toler-ances (e.g., the 12-inch tolerance must be justified by SWEC for small \
! diameter piping. ;
i i
- b. SWEC Stress Reconciliation Walkdown Procedure CPPP-6 indicates tnat a final i field walkdown will be performed at the completion of the requalification I effort. The purpose o,f this walkdown will be to verify that sufficient i clearance exists between the piping systems and nearby structures. Based on the preliminary conclusions from the CPPP-8 walkdown data (observed .
during staff audits), the scope of the stress reconciliation walkdown i should be expanded to reconcile concerns related to improper clear-ances between pipe and pipe supports and improper alignment and inter-farences with the snubber / strut rear bracket which were identified in the f CPPP-8 walkdown.
- c. TUGC0 Penetration Schedule - During an audit at the CPSES site, the content i of this schedule was discussed with TUGC0 employees. It appears that the information required by the pipe stress analysis is available in this sche-l dule. The apparent lack of reference of this penetration schedule, however, in the SWEC Procedure CPPP-7, is of concern to the staff. Specific refer- f 4 ence to this schedule must be included in CPPP-7 along with directions for t '
its use by the pipe stress analysts. In addition, the staff plans a walk-down to verify the accuracy of the data in the penetration schedule in tim ;
- near future. l i
- d. QA/0C Construction Adeauacy Procram Reinspection - During audits at ;
j the site of the procedures being used, it was determined that there is a difference of tolerances used within this reinspection versus those used f by SWEC in the CPPP-5 walkdown. In addition, it is not clear to the staff ' that the tolerances used here for gaps (e.g., on box frame supports) would j l j be acceptable for the SWEC pipe stress requalification effort. SWEC must i j review all tolerances used and document their acceptance. As described above, the total verification of the as-built drawings is a function j of a compilation of a number of walkdowns and work by at least three organiza- j tions. The need for an evaluation to integrate all of this information 03/10/86 III-52 Nuo797 SEC III
s , b'N document the results is apparent. Without such a document, it is not clear to the staff if all of this information is compatible and it is not clear that it will lead to the proper conclusions. The licensee must prepare this document and submit it to the staff for review. In addition, because the need for the 100% walkdown of valve and strut orienta-f tion came about in CPPP-5 as a result of the failure 6f one of the four attri-butes chosen by SWEC, and because this failure affects any conclusion relative to the accuracy of the as-b'uilt data, the staff requires that the applicant address this failure and its effect on the accuracy of the as-built data. The comparison of the 100% TUGC0 re-walkdown with the existing as-built data would be helpful in reaching a conclusion.
- 3. Review and Verification of Systems Desion Input Seismic Acceleration and
- Fluid Transients The staff has reviewed SWEC Procedure CPPP-10 and discussed all system design I inputs during audits at SWEC offices. The staff feels that the approach used
- to assure that all operating modes and systems loading conditions are identi-f fied is appropriate. However, prior to staff approval of these, one document describing ~ all of them, including response spectra, must be prepared and satisfactority reviewed by the staff.
~
~
- 4. Verification of Existino Pipe Support Desian Documents The staff has reviewed and evaluated the CPRT Program Plan Revision 3 DSAP IX, Attachment 2 action plan details related to the verificaton of existing pipe support design documents, and determined that the effort associated with this Action Plan Element has been changed. Thus, the SWEC approach to requalify pipe support designs has been addressed as part of Action Plan Element #6 and l
the staff evaluation is provided therein. i 1
- 5. Resolution of Soecial Technical Concerns s
i The staff has reviewed and evaluated the CPRT Program Plan details related to the resolution of special technical con cerns, which are ceing developed by a III-53 NUO797 SEC III 03/10/86 l
h e T Ryu y N kt ni.. 4 ; n; ~ ~ ~^ _ m , - _ ;,,,,,,,;u un g ,, ; ;, 'ng5
+w- nec est J,. es d its preliminarv finMncs-on-the adequacy of the as-bu'ilt verif" at'on w -
~-
ta kdown p. a ne WPP-5 and its implementation by ster gineerlig 3 G Cor ao ion (SW . The NRC-staff indicy e g h,,at tha fpp2 On meen
} ade avaYe:1, e h sa.cu s-uu i si. oitriM" associated h IE Bulletin 79- L4. Ho ised concerns during that other ine as- auilt attributes required t examined ogletin t79-14 w re not beiog Q i adc ressed and reverified u F- S e that meeting, t f has
.[ aui ited the con ion adequacy pro . eino ennduc+=d by EcC M pt f tLe
;CP T Progra lan an[nenginee walkdown conducted by SWEC lur der Pro D ~~h EPP -Ee in cJdi-tic d"ri_ a site audit held on
!Fabruary 18-19, 1986, the C staff and its consu eied Q fE 1gineering Services ( ) discussed _with THf;CO and_the var s or ~ ati fperfoming as-buil T awi.ivities, the relationship and int faces oetweel I
e the o e ta involved. k$ A sar a t of3ur_auo t ts -- ' ~earniDt1n%2%- and support Theillowing '
$ as uilt verification have remained unre y .-
;- ; g--+ea to % ess- :;_ y ,,,,, , g g , gen u S. The staff has a concern regarding the lack of infomation in the CPRT kv.N% g Program Plan which explains the process used to assure the adequacy of the as-built data used in the SWEC piping reanalysis effort. There appears to
{j\ 9' be several CPSES activities which, in some aspect, are related to (I
'M " verifying the as-built plant condition, but it is not clear in the CPRT k Program Plan exactly how the various activities are relatedg The darious
?M s 3 o i hs-built activities include the original as-built walkdown perfonned by tQ 4o. d ed ! TUGC0 QA in accordance with IE Bulletin 79-14, the construction adequacy l
- s. t 4. \. program currently heing perfomed by ERC as part of the CPRT Program Plan Appendix B on a sampling basis, two SWEC piping walkdowns performe f
q- ' accordance with Project Procedures CPPP-5 and CPPP-8[ sampling basip and a third SWEC as-built walkdown which will be performed after n' Ek0 l
! }
.V A completion of the piping reanalyses for each piping system reanalyzed.
Provide a description of the process followed by ERC and SWEC for the evaluation of as-built discrepancies including the interface among ERC, SWEC, and TUGC0 projects and the applicable procedures used in the process. k, f. Based on our preliminary review of the as-built process and interfaces, the staff has identified a concern relating ~to the interface between ERC and SWEC. The staff understands that when ERC identifies construction deviations from the design drawings, ERC issues a deviation report (DR). The DR is then transmitted to: (1) TUGC0 projects for initiating an NCR and evaluating the NCR per 10 CFR 50.55(e) and (2) the ERC Safety , Significance Evaluation Group (SSEG) for evaluating the significance of the deviation and whether the sample is to be expanded. The NCR's t initiated by TUGC0 will either be dispositioned as " rework" or "use-as-is." All NCR's dispositioned as "use-as-is" are transmitted to SWEC. However, the staff requests that the applicant address the need for SWEC to review DR's identified by ERC in order to assess the impact of the construction deviations on the design activities associated with the SWEC piping reanalysis and pipe support requalification effort.
, c., 4,. During the NRC/TUGC0 public meeting held on October 2 and 3,1985, the NRC
- staff presented its preliminary findings on the adequacy of the CPPP-5 procedure e its imoienentation nv w. Our staff indicated that CPPP-5 procedure adequately addressed four attributes (valve location, support type, support location, and support / valve orientation) that are otherwise j required to be examined as part of an as-built inspection walkdown conducted to fulfill the requirements of IE Bulletin 79-14. However, our j staff pointed out that CPPP-5 did not address other as-built attributes
,l (e.g., pipe run geometry, clearances including those at floor and wall l penetrations, embedments, and pipe attachments) which are required to be examined under IE Bulletin 79-14. Our staff recognizes that the Applicants did not intend this reverification to be a substitute for the 1 h P s b
' e
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3-Applicants' 79-14 as-built inspection currently in place. 'Nonetheless, it is our staff's understanding that the excluded attributes may have an i impact upon the pipe stress analyses, which the reason why examination is N required under 79-14. The Applicants have not explained why there appears to be no verification of the accuracy of these attributes now excluded i from reverification under CPPP-5. Accordingly, the Applicants are requested to provide the basis for not reverifying the as-built attributes that are excluded under CPPP-5. In particular, the Applicants should indicate the basis for believing that the results of the as-built program conducted by the Applicants to satisfy IE Bulletin 79-14 are accurate and reliable, such that reverification of the attributes not included in CPPP-5 is not necessary.
! d,4 The staff is concerned that the design criteria and procedures used in the i . SWEC pipirig and support reanalysis effort might be impacted by as-built
' plant conditions which are not reflected in the design documents used by SWEC. SWEC has perfonned two as-built walkdowns in accordance with
! Project Procedures CPPP-5 and CPPP-8. Several concerns were identified as f
-- a result of both walkdowns which were based on a sampling selection. In some cases, the design criteria or procedures used for the piping and support requalification effort were revised to specifically address and resolve those identified concerns. However, because the concerns which were found were based on a sampling selection, it should be detennined whether yet unidentified concerns could exist in other areas of piping and L supports which were not sampled. For example, staff audits of the SWEC implementation of CPPP-5 have noted that grouted sleeves for piping penetrating floors and walls are not always shown on piping isometric l drawings. Although a penetration schedule lists grouted sleeves and the type of grout used, it is not evident that the SWEC piping analy'st can identify crwtad slaeves on the oicing isometric using the penetration
- schedule when modelling the piping stress problem for analysis. Thus, the staff requests that the applicant address the means for ensuring that all as-built conditions which can adversely affect the acceptability of the piping reanalysis and pipe support requalification program will be identified and corrected.
r .. . e,4. The staff has identified an unresolved item concerning the need for root cause/ generic implication and adverse trend evaluations of as-built deviations identified in the SWEC as-built walkdowns and the need for a procedure and process to properly evaluate any resulting design , deficiencies. Whereas the process usgig the ERC sampling program for y construction adequacy does provjde for, root cause/ generic implication and adverse trend evaluations, and an evaluation of identified construction E 3 deficiencies per 10 CFR 50.55(e), the process used in the SWEC as-built walkdowns for design adequacy does not. For example, as a result of the SWEC as-built walkdown perfomed under CpPP-5. several deviations were identified relating to snubber, strut, and valve orientations. The corrective action implemented by TUGC0 resulted in a 100 percent reinspection of snubber, strut, and valve orientations. Although the , staff finds that the cprrective actions implemented by TUGC0 adequately addresses the orientation deviations identified by SWEC, the actions taken did not address the generic implication of the' deviations in areas other than pipe support and valve orientation. Furthermore, there does not appear to be any procedure which requires an evaluation of identified l design and construction deficiencies resulting from the SWEC walkdowns per
; -- 10CFR50.55(e). The applicant is requested to address the need for a program for ensuring that the results of the SWEC walkdowns will be adequately evaluated for root cause/ generic implications and adverse trends and that design and construction deficiencies identified as a j result of SWEC walkdowns will be properly evaluated per 10 CFR 50.55(e). l
'l l
i 4
t afssst vs. 3 E special SWEC technical group not directly involved in the piping streshd[FaTWT]b4 effort. Thisdivisionofresponsibilityallowsthereso1ugns,t,o,bjjogducted independent from the daily pressures involved with beyp,roduction effort and, thus, assures a thoughtful and uniform resolution. The SWEC special group has reviewed past studies, analyses, and reports on certain technical issues in 4 addition to the transcripts and filings associated with the CPSES hearings in order to understand the concerns of all parties. SWEC has developed approaches for the resolution of several piping and pipe support con-cerns and has incor-1 porated their resolution in SWEC Project Procedures CPPP-6 and CPPP-7. Based
. on preliminary reviews, the staff finds that the procedures allow an adequate process to exist for the resolution of the special technical concerns. However, b the staff has not yet reviewed the details of the resolutions. The staff plans to engage in a series of audits specifically to review the technical adequacy 1 of the resolution. Thus, the staff has not yet completed its evaluation of the i adequacy of the technical resolutions. Staff approval of this, therefore, is
] I contin gent upon satisfactory review by the staff of the procedures and evalua-j tion of the technical resolutions. l I .l
- 6. Reanalysis of Pipi Syste:ns and Reevaluation of Pipe Suoport Designs o
The staff has reviewed and evaluated the CPRT Program Plan details' associated with the reanalysis of piping systems and reevaluation of pipe support designs. j-t The staff review of the scope of the large bore and small bore piping stress
- i reanalysis finds it to be adequate contingent upon an acceptable resolution of
$ the'following concerns.
(a) The scope of the large bore piping stress reanalysis includes certain Class 5 piping. Specifically, the scope will include only those Class 5 piping within the boundaries of ASME Class 2 and 3 piping stress problems. The staff requires further justification for excluding the remaining Class 5 piping from reanalysis.- i (b) In Revision 3 of the Program Plan the CPRT states that SWEC is responsible a for the structural qualification of piping and supports. However, it is
]
- ! also stated that Gibbs & Hill will remain the designer A/C of record for 03/10/86 III-54 NUO797 SEC III l
l \; l
the piping systems with full responsibility for the system functional ' design. The , staff review of the CPRT Program Plan Appendix F (Revision 1) Secton II.F finds that interfacing information from SWEC related to design, construction, and QA/QC concerns found during walkdowns will not be pro-vided to Gibbs & Hill. Because Gibbs & Hill has the full responsibility for ensuring the piping system functional design, it is not clear why Gibbs&Hillwouldnotneedthisinformation.jInaddition,ifGibbs~&N g H'ill will remain the designer A/E of record for the piping systems, then the licensee should provide justification _for_.a_. lack of review of the SWEC ~
& Hill. # k k /[$ ***/ w IS P M M rV A" b 'f l%analysisbyGibbsa,4. ged4, }% Bd(i1 -fk</*
. W17 AW'L&4 ebd ck (c) The staff has reviewed the CPRT Program Plan response related to small bore piping and support requalification. Because the SWEC approach to be used for the requalification effort has not been completed at this time and will be addressed by SWEC Project Procedure CPPP-15, the staff has not yet completed its review and evaluation of this ites. Staff approval for this is contingent upon a satisfactory review by the staff of this procedure.
' (d) The staff has reviewed and evaluated the CPRT Program Plan details related ! to the reevaluation of large bore pipe supports. The staff finds the scope ! of the large bore pipe support reevaluation to be acceptable except for ! the following concern. Similar to concern raised by the staff for Class 5 piping, the licensee should provide further justification for excluding
~~
Class 5 pipe supports other than those Class 5 supports within ASME Class 1, 2, and 3 piping stress problem boundaries from the pipe support *requali-fication effort. 3.5.4 Conclusions g Based upon the staff review of the CPRT Program Plan Revision 3, and staff O audits performed to date, and contingent upon acceptable resolutions of the y items listed below, the staff concludes the following. i The scope of the piping and pipe support requalification effort being performed I by SWEC provides a comprehensive program for addressing many of the technical concerns raised in the external source issues related to the design adequacy of i 03/10/86 III-55 NUO797 SEC III
l f piping and pipe supports at CPSES. However, proper implementation of the pro- ' gram must be conducted in order to assure that the program design criteria.have been met and licensing commitments have been satisfied. .
. satisfactory review by the staff of the SWEC procedures 4
a. ! b. justification of tolerances
- c. stress reconciliation walkdown scope expansion
- d. cross reference of penetration schedule with CPPP-7
- e. documentation of tolerance difference between QA/QC walkdowns and SWEC ,
walkdowns
- f. preparation of a document to compile all work done to verify as-built data
- g. justification of one attribute out of four failing to meet acceptance criteria of CPPP-5
$,@ preparation of a document compiling all operating modes. and system loading conditions l
M @ j nti'ftst'- *a- - L.L .i ...;.". 7 ... on.Z; ri...;y.;. L, 0;... ; niii M,.@ justification for exclusion of Class 5 piping and pipe supports l @ Satisfactory review by the staff of the small bore piping and support t procedure CPPP-15.
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4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW 4.1 Introduction The staff in an earlier evaluation of Revision 2 of the program plan (submitted to the applicant by letter dated 8/9/85) requested additional information to justify the exclusion from the design adequacy review program the design activ-I ities provided by Westinghouse, the NSSS supplier. . The applicant in response to the staff's request on November 22, 1985 trans-mitted for staff review their justification for the exclusion of Westinghouse from the design adequacy review program. 4.2 CPRT Approach The applicant has stated that Westinghouse designs are included from the design adequacy review of the CPRT because Westinghouse has been subjected to numerous reviews and audits by the NRC and other utilities. However, interface require-ments proposed by the A-E to Westinghouse will be reviewed to assure that the ; requirements were properly communicated and that hardware comply with those requirements. Additionally, wherever Westinghouse imposes conditions on the A-E, the design adequacy program will review A-E documentation to determine whether the plant design complies with those conditions. With regard to vendors and design organizations that may have limited nuclear experience and/or have only supplied hardware or designs to CPSES, the design l adequacy program will evaluate the scope of work performed to determine the cxtent of the review required of those organizations' product. 4.3 Staff Evaluation The staff has evaluated the applicant's basis for excluding Westinghouse plant
- design activities from the design adequacy review plan and has confirmed that l Westinghouse NSSS designs are sufficiently standard and have been subjected ;
i l to numerous reviews and operational tests by other utilities and by the NRC. ! l l 03/10/86 III-57 NUO797 SEC III
s . However, it is unclear whether other design services non-NSSS performed by Westinghouse for CPSES have been subjected to the same rigor of review as the NSSS designs and.whether such non-NSSS designs are performed by the same disci-plin,e design departments within Westinghouse. 4.4 Conclusions ' On the basis of our evaluation of the CPRT scope of. design adequacy review plan we have concluded that excluding from review the Westinghouse supplied NSSS designs services is acceptable. However, we required that during implementation of the design adequacy review program the applicant confirm that other non-NSSS design services provided by Westinghouse are performed by the same organizations that designed the NSSS systems or that the non-NSSS designs are not unique to CPSES. t i Furthermore, we have concluded that design adequacy review of services performed
-t by organizations that may have limited nuclear experience and/or have only sup-E plied hardware or designs to CPSES, is acceptable.
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- Document Name:
NUO797 SEC IV TC Requestor's ID: LO Author's Name: Pe88Y Document Comments: PH-303 keep this sheet with document 4 e r 4 i e i e e em v 6
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IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN TABLE OF CONTENTS
- 1. 0 Introduction 2.0 External Source Issues 2.1 Electrical, Instrumentation and Control Systems and Component Issues 2.1.1 Heat Shrinkable Insulation Sleeves (1.a.1) 2.1.1.1 Introduction '
2.1.1.2 CPRT Approach , 2.1.1.3 Staff Evaluation l
! 2.1.1.4 Conclusion !
2.1.2 Butt Splice Inspection Reports (1.a.2) l 2.1.2.1 Introduction l 2.1.2.2 CPRT Approach
- 2.1.2.3 Staff Evaluation 2.1.2.4 Conclusion 2.1.3 Butt Splice Qualification (I.a.3) 2.1.3.1 Introduction 1 2.1.3.2 CPRT Approach 2.1.3.3 Staff Evaluation .
2.1.3.4 Conclusion l l 3 2.1.4 Field Terminations - Comparison of Drawings With As-Built l Configuration (I.a.4) l l 2.1.4.1 Introduction j 2.1.4.2 CPRT Approach 2.1.4.3 Staff Evaluation 2.1.4.4 Conclusion 2.1.5 Vendor Installed Amp Terminal Lug NCRs (1.a.5) 2.1.5.1 Introduction 1 2.1.5.2 CPRT Approach 2.1.5.3 Staff Evaluation 2.1.5.4 Conclusion i 2.1.6 Flexible Conduit Separation (1.b.1) 2.1.6.1 Introduction 2.1.6.2 CPRT Approach l _. , _ , _ _ . _ , _ - . - , , - . ~ , _ - - . -
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2.1.6.3 Staff Evaluation 2.1.6.4 Conclusion 2.1.7 Flexible Conduit - Cable Separation (1.b.2) 2.1.7.1 Introduction 2.1.7.2 CPRT Approach 2.1.7.3 Staff Evaluation 2.1.7.4 Conclusion 2.1.8 Conduit to Cable Tray Separation (I.b.3) 2.1.8.1 Introduction 2.1.8.2 CPRT Approach .
.2.1.8.3 Staff Evaluation 2.1.8.4 Conclusion 2.1.9 Barrier Removal (1.b.4) 2.1.9.1 Introduction 2.1.9.2 CPRT Approach 2.1.9.3 Staff Evaluation 2.1.9.4 Conclusion 2.2 QA/QC Issues -
1 2.2.1 QC Inspector Qualifications (I.d.1) . . 2.2.1.1 Introduction 2.2.1.2 CPRT Approach
, 2.2.1.3 Staff Evaluation 2.2.1.4 Conclusion 2.2.2- QC Inspector Test Administration (I.d.2) 2.2.2.1 Introduction 2.2.2.2 CPRT Approach 2.2.2.3 Staff Evaluation 2.2.2.4 Conclusion 2.2.3 Craft Personnel Training (I.d.3) * !
2.2.3.1 Introduction 2.2.3.2 CPRT Approach 2.2.3.3 Staff Evaluation 2.2.3.4 Conclusion l 2.2.4 Material Traceability (VII.a.1) 2.2.4.1 Introduction
. 2.2.4.2 CPRT Approach 2.2.4.3 Staff Evaluation 2.2.4.4 Conclusion .
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2.2.5 Corrective Action System (VII.a.2) 2.2.5.1 Introduction 2.2.5.2 CPRT Approach 2.2.5.3 Staff Evaluation 2.2.5.4 Conclusion
, 2.2.6 Document Control (VII.a.3) 2.2.6.1 Introduction 2.2.6.2 CPRT Approach 2.2.6.3 Staff Evaluation 2.2.6.4 Conclusion
, 2.2.7 Audit Program and Auditor Qualification (VII.a.4)
- 2.2.7.1 Introduction 2.2.'7.2 CPRT Approach 2.2.7.3 Staff Evaluation 2.2.7.4 Conclusion 2.2.8 Management Assessment (VII.a.5) 2.2.8.1 Introduction n 2.2.8.2 CPRT Approach
- 2.2.8.3 Staff Evaluation 2.2.8.4 Conclusion 2.2.9 Exit Interviews (VII.a.6) ,
2.2.9.1 Introduction 2.2.9.2 CPRT Approach 2.2.9.3 Staff Evaluation 2.2.9.4 , Conclusion 2.2.10 Cleanliness (VII.a7) 2.2.10.1 Introduction 2.2.10.2 CPRT Approach 2.2.10.3 Staff Evaluation 2.2.10.4 Conclusion 2.2.11 Fuel Pool Liner (VII.a.8) 2.2.11.1 Introduction 2.2.11.2 CPRT Approach 2.2.11.3 Staff Evaluation 2.2.11.4 Conclusion 2.2.12 Onsite Fabrication (VIIb.1) 2.2.12.1 Introduction I 2.2.12.2 CPRT Approach ; 2.2.12.3 Staff Evaluation 2.2:12.4 Conclusion
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2.2.13 Valve Disassembly (VII.b.2) ~ 2.2.13.1 Introduction 2.2.13.2 CPRT Approach 2.2.13.3 Staff Evaluation 2.2.13.4 Conclusion , 2.2.14 Pipe ' Support Inspections (VII.b.3) 2.2.14.1 Introduction 2.2.14.2 CPRT Approach ' 2.2.14.3 Staff Evaluation 2.2.14.4 Conclusion
- 2.2.15 Hilti Anchor Bolt Installation (VII.b.4)
I , 2.2.15.1 Introduction . i 2.2.15.2 CPRT Approach ' ! 2.2.15.3 Staff Evaluation 2.2.15.4 Conclusion .; 2.2.16 Cable Tray Raceway Support Inspections (VII.b.5) 2.2.16.1 Introduction I i'
. 2.2.16.2 CPRT Approach. .
2.2.16.3 Staff Evaluation 2.2.16.4 Conclusica 2.3 Civil / Structural Issues 2.3.1 Reactor Cavity Reinforcing Steel (II.a) 2.3.1.1 Introductior 2.3.1.2 CPRT Approach 2.3.1.3 Staff Evaluation 2.3.1.4 Conclusion 2.3.2 Concrete Compression Strength (II.b) i 2.3.2.1 Introduction * - 2.3.2.2 CPRT Approach 2.3.2.3 Staff Evaluation 2.3.2.4 Conclusion 2.3.3 Concrete Structure Air Gaps (II.c) , 2.3.3.1 Introduction 2.3.3.2 CPRT Approach
'2.3.3.3 Staff Evaluation A 2.3.3.4 Conclusion /\
A ,Ni 2.3.4 Control Room Seismic Design (II.d) (h - 2.3.4.1 Introduction - 2.3.4.2 CPRT Approach t
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-2.4.5.2 CPRT~ Approach - - - - - - - - - --
2.4.5.3 Staff Evaluation 2.4.5.4 Conclusion
i 2.4.6 RPV to Biological Shield Gap (VI.a) l 2.4.6.2 Introduction 2.4.6.2 CPRT Approach . 2.4.6.3 Staff Evaluation 2.4.6.4 Conclusions 2.4.7 Polar Crane Shimming (VI.b) 2.4.7.1 Introduction 2.4.7.2 CPRT Approach 2.4.7.3 Staff Evaluation 2.4.7.4 Conclusions 2.5 Testing Program Issues 2.5.1 Hot Functional Testing Data Packages (III.a.1) i 2.5.1.1 Introduction 2.5.1.2 CPRT Approach 2.5.1.3 Staff Evaluation
- 2. 5.1. 4 Conclusion 2 2.5.2 Test Data Approval (III.a.2) ,
2.5.2.1 Introduction i 2.5.2.2 CPRT Approach
- 2.5.2.3 Staff Evaluation 2.5.2.4 Conclusion t 2.5.3 Deferred Test Technical Specifications (III.a.3) 2.5.3.1 Introduction 2.5.3.2 CPRT Approach 2.5.3.3 Staff Evaluation 2.5.3.4 Conclusion 2.5.4 Test Equipment Traceability (III.a.4) 2.5.4.1 Introduction
- 2.5.4.2 CPRT Approach 2.5.4.3 Staff Evaluation 2.5.4.4 Conclusion 2.5.5 CILRT (III.b) 2.5.5.1 Introduction 2.5.5.2 CPRT Approach 1 2.5.5.3 Staff Evaluation ,
1 2.5.5.4 Conclusion l t l
e i Document Name: NUO797 SEC IV Requestor's ID: LO Author's Name:
. , omen Document-Comments:
CRESS PH-303 KEEP THIS SHEET WITH DOCUMENT h 1 9 9 e 4 l l l I i b e 9
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;W~ c? 6 MTSC11 - safety evaluation i Draft 2 - 1/16/86 I
l 1 1 1 SAFETY EVALUATION REPORT i l RELATED TO COMANCHEPEAKRESPONSETEAM(CPRT) PROGRAM PLAN, REVISION 3 GL0 i
TABLE OF CONTENTS 4 #1 ABSTRACT 1
/r# CONTRIBUTORS /T 9 ACRONYMS AND ABBREVIATIONS
- 1. EXECUTIVE
SUMMARY
II. DESIGN ADEQUACY AND CONSTRUCTION ADEQUACY COMMON ELEMENTS III. STAFF EVALUATION OF DESIGN ADEQUACY PLAN IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN
\
d V. REFERENCES
- PLAN - plan Draft 1 - 1/28/86
. ABSTRACT The Safety Evaluation Report on the Comanche Peak Response Team (CPRT) Program Plan for the Texas Utilities Generating Company application for a license to operate Comanche Peak, Unit I and 2 (Docket Nos. 50-445,50-446), located in Somervell County, Texas, has been prepared by the Office of Nuclear Reactor Regulation and the Comanche Peak Technical Review Team (TRT) of the U.S.
Nuclear Regulatory Comission (NRC). Subject to acceptable resolution of the areas identified in the subject evaluation, the staf f concludes that the CPRT Program Plan, if adequately implemented, will provide an acceptable assessment of the Plant's design and construction adequacy. o -, _ n __.. m -. - __ _y ,. - ,-. p---, , - ,
7 I. EXECUTIVE
SUMMARY
TABLE OF CONTENTS SS 1.0 / Introduction
/JS 2.0 /CPRT Program Plan Description 2.1 Design Adequacy Plan (DAP) 2.2 Construction Adequacy Plan (CAP)
J r 3.0 Sumary Evaluation M 3.1 Design Adequacy Plan 3.2 Construction Adequacy Plan Jr 4.0 Sumary Conclusions 8F 4.1 Design Adequacy Plan 4.2 Construction Adequacy Plan JC 5.0 Outstanding Issues F 5.1 Design Adequacy Plan 5.2 Construction Adequacy Plan - 6.0 Confirmatory Issues 6.1 Design Adequacy Plan 6.2 Construction Adequacy Plan l l l l J
SECTION I - EXECUTIVE
SUMMARY
Draft 1 - 1/28/86 1.0 Introduction The U.S. Nuclear Regulatory Comission's (NRC's) Executive Director for Operations established on March 12, 1984, a program to assure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a coordinated and integrated manner by the NRC staff. As a means of executing its programatic responsibilities, the NRC's Comanche Peak Project fomed five Technical Review Teams (TRT) representing the following disciplines: o Electrical / Instrumentation o Civil / Mechanical i o QA/QC e o Protective Coatings N o Testing Programs
< The TRTs initiated a series of onsite inspections and evaluations in July 1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report.
In response to the concerns and issues identified by the TRTs, Texas Utilities Electric Company (TUEC) fomed the Comanche Peak Response Team (CPRT) for the purpose of addressing all TRT concerns. The CPRT, in response to TUEC direction, submitted in October 1984, its initial Program Plan which included Issue-Specific Action Plans (ISAPs). TUEC, in Revision 2 to the Program Plan, has expanded the CPRT scope to address all issues identified by external sources and has also consnitted to perform self-initiated evaluations of design adequacy and quality of construction. Specifically, Revision 2 of the CFRT Program Plan is intended to address all NRC concerns and demonstrate the quality of design and construction. The Program Plan, as revised, has the following principal objectives: 1
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l l 2 o Evaluate and recommend solutions for all issues raised by the TRT, .; ASLB, SSER, CAT, SRT, SIT, Region IV, Intervenors. Applicant and CYGNA I AP.* o Determine root cause and generic implications of each found non-safety significant deviations or trend of non-safety significant deviations. o Perform self-initiated evaluations for the purpose of assuring that ! there are no undetected and uncorrected safety significant 4
- deficiencies at CPSES.
1 l The CPRT's role through this Program Plan is to resolve issues and determine root cause and generic implications of each safety significant f deficiency or trends of non-safety significant deviations. The NRC. staff reviewed the Comanche Peak Response Team Program Plan,
- p. Revision 2, with programmatic and detailed concerns provided TUEC in Di ~ August and September of 1985, respectively. TUEC responded to the staff's concerns by letter dated November 22, 1985, and by Revision 3 to the CPRT Program Plan, Reference 1. Since .the completion of its review of Revision 2 to the CPRT Program Plan, the staff continued its evaluation with numerous audits and concluded this review phase with detailed examination i of Revision 3 to the Plan. This SSER describes the staff's evaluation of the CPRT Program Plan through Revision It addresses the scope, approach,
- and evaluation aspects of the Plan. Region IV will inspect and audit the i implementation of the Plan for those areas related to construction quality and reflect any finding it may have in periodic inspection reports. 4 Design aspects of the Plan will be inspected and audited by the Office of . Inspection and Enforcement with the results also documented in periodic-inspection reports.
- Acronyms are defined on page _? of this r port.
4 l
~ _ , _ _ _ _ _ _ _ , _ _ _ _ _ _ _ . . . _ _ _ _ _ _ _ _ _ , . _ _ _ . . _ , , . _ _ _ , _ , _ , . , _ _ _ , . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ .
2.0 CPRT Program Plan Description The C RT Program Plan, Revision 3, is the TUEC document which describes The the scope and method of operation of the Comanche Peak Response Team. responsibilities of the Comanche Peak Response Team include the resolution of all open issues, the identification of the root cause of each found safety significant deficiency or trend of non-safety significant deviations and the completion of a self-initiated evaluation of the design adequacy.and construction quality of CPSES' The Program Plan itself includes the CPRT charter, program principles, structure, methodology, process and organization. Three appendices form the nucleus of the Program Plan. Appendix A addresses the design adequacy aspects of the Program Plan. The quality of construction and the adequacy of the QA/QC program are addressed in Appendix 8. All individual issue and discipline specific action plans are included in Appendix C. All evaluations are performed using a similar process regardless of A
~~ whether it is a design, construction or a very focused issue evaluation.
This process is initiated by defining the scope and methodology for the topic or issue to be evaluated. Procedures and checklists are then developed as guidance for the reinspection effort and document review. All relevant standards and applicable acceptance criteria are reflected in the development of checklists. Any deviations identified during the reinspection reevaluation or document review process are evaluated for , their safety significance. Further, root cause evaluations are performed l and a detennination regarding potential generic implications is made for l each identified deficiency. Finally, corrective actions are identified as j are actions designed to preclude recurrence in the future. While the process for evaluation is identified in each issue specific or f l discipline specific action plan, the output from this effort will be documented in individual results reports. Each results report will f identify any found deficiencies along with the evaluation of these deficiencies. The results of individual issue specific evaluations are collectively evaluated within the construction quality and design adequacy ) programs. A Sunmary Report for each discipline area will be preparea
T.' 4 D sunnarizing the results of the effort and fulfillment with the objectives of the.CPRT Program. : . 2.1 CPRT Design Adequacy Program Plan .' The Design Adequacy Program Plan (DAP) is the CPRT's appmach for evaluating and resolving a number of concerns regarding the adequacy of the CPSES design and design process. Its objective is to provide. assurance that there are no undetected safety significantarrors in the CPSES design. TheCPRTintendstoaccomplishthisobjectiveby' performing the following three activities:
- a. Evaluation of ~ specific design and programmatic designsJprocess issues raised by external sources. '
- b. Investigation of the root cause of each found safety significant deficiency.
.p- c. Performance of a self-initiated evaluation of selected' additional Y design areas. g External source issues are addressed by an independent doceentation review of the design methodology and process related to each issue. This includes drawings, caj[iculations, specifications, acceptance criteria, and i procedures.
;V The self-initiated evaluation is perfomed by categorizing the design ,
activities into the following specific disciplines: }.
- a. electrical, Instrumentation and Control Systems and Coeiponents,
- b. Mechanical Systems and Components. .
I'
- c. Civil and Structural
- d. Piping and Supports.
P.: A Discipline Specific Action Plan (DSAP) describes the scope of each ' discipline and the approach for evaluating each discipline,. Each DSAP includes the categorization of design activities within ehch discipline q. 3 .-
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.f .
and the refinement of these groupings into homogeneous design activity groupings. Items from each homogeneous design activity (HDA) will be , evaluated. The auxiliary feedwater system is the focus of this review activity but items from other systems will be selected to assure that all design activities are reviewed and represent a level of complexity typical of the design process. Results of specific reviews provide the basis for conclusions made regarding the design process. The basis for extrapolation of specific reviews to other systems is the homogeneous nature of the design activities and the level of complexity of the activities selected for review. Results reports and a final design adequacy program report will document the implementation of the DAP and 4 the resulting conclusions. Piping and pipe supports design are not addressed by the DAP inasmuch as a complete reevaluation of this area is being performed by Stone and Webster Engineering Corporation (SWEC). The work of SWEC and other outside (= organizations performing in a similar manner will be received by the CPRT. Y[ All identified deficiencies will be evaluated individually for its safety significance as will trends of nonsafety significant findings. Summary reports will be prepared for each discipline. An evaluation of the overall adequacy of the CPSES design and design process will be made by integrating the results of the individual discipline specific action plans. This evaluation will be reported in the final design adequacy program report. 2.2 CPRT Construction Adequacy Program Plan
-The construction reinspection / documentation review program is designed to -
collect information on the quality of construction work activities et the ) Comanche Peak Steam Electric Station. Construction activities are divided ) into the following three areas: o Civil / Structural o Electrical o Mechanical
8-This program consists of a sample reinspection of QC-ac'c epted safety related, construction work supplemented by review of related quality
- documentation f or nonrecreatable in-process inspections. Both units and the common areas are being addressed by this program.
The methodology used for construction evaluation is to first categorize the installed safety related hardware into populations made up of homogeneous work activities. Samples will be selected from these populations and the work activities evaluated for the quality of construction. Two samples will be selected from each population for evaluation. First, a purely random selection will be made from the complete population. Then, engineered samples will be selected at random by expanding the initial sample to ensure evaluation of a like number of items located in systems required for safe shutdown. Items will be evaluated using checklists and inspection procedures developed from the original installation documents. All deviations will be identified and evaluated to determine their safety significance. The totality of the 5(_ itf-7 information will be evaluated for adverse trends. Results will be documented in results reports which will document the inspections of individual populations and well as the overall results of the construction adequacy evaluation effort. 4
II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PLAN COMMON- ELEME TABLE OF CONTENTS
/
7g53 1.v QA/QC Activities l 1.1 Introduction 1.2 CPRT Approach 1.3 Staf f Evaluation 1.4 Conclusions Acceptance Criteria
.'26 5 2. 2.1 Introduction 2.2 CPRT Approach 2.3 Staff Evaluation 2.4 Conclusions jrp5 3. d Corrective Actions 3.1 Introduction -
3.2 CPRT Approach 3.3 Staff Evaluation ' 3.4 Conclusions f O 4. CPRT/SRT Independence A4 4.1 Introduction 4.2 CPRT Approach 4.3 Staff Evaluation
, 4.4 Conclusions g j 5.Q Interfaces 5.1 Introduction /) , l 5.2 CPRT Approach l
-n 5.3 Staff Evaluation '
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J-m m [e s r , a) n zX nyd a y w l 1.2 CPRT Approach The CPRT QAP is structured in line with the three categories of CPRT activities. A separate program is provided for each activity. (1) Overall Responsibility Overall responsibility for the quality of CPRT activities re- l Si rias with the SRT. Thisisaccomplishedinthefollowingmannerl
SECTION 1.0
. ~
1 - - SRTwillreceivetheresultsofallauditsof CPRT activities.
- SRT will receive corrective action response to audit findings.
- SRT will perform, or have performed for them, special audits or reviews of CPRT activities as deemed necessary and
- documentation adequacy will be determined by reviews performed by the File Review Com-mittee.
(2) Issue-Specific Actions Plans - 0A Elements It is the position of the SRT that the principles of the CPRT g Program Plan, the CPRT Policies and Guidelines and the implementation
$' requirements specified in each ISAP generally provide the QA elements necessary for ISAP activities. Supplemental instructions were prepared and issued in the civil / structural and mechanical / miscellaneous areas be-cause of the extent of third-party activities related to engineering evaluations and calculations in these areas. The CPRT Program documents address the following criteria of 10CFR50, Appendix B, in sufficient detail to satisfy the SRT that activities performed by the third party
' responding to ISAPs will have adequate QA coverage.
Criteria Description CPRT Program Guidance No. 1 Organization CPRT Program Plant Section VIII 2 QA Program CPRT Program Plan Section III.k 5 Instructions, CPRT General Policy for Conduct of Action Procedures and Plants Section 5.3 and each ISAP Drawings . W
SECTION 1.0 6 Document Control CPRT Program Plan Section III.j ahd Guide on Central and Working Files 10 Inspection CPRT Program Plan Section III.k and Policy on Inspection Personnel 15 Non-conforming CPRT Program Plan Section III.k and General Conditions Policy for Conduct of Action Plans (Section 5.5) 16 Corrective Action CPRT Program Plan Section III.k and General Policy for Conduct of Action Plans Section 5.5 17 QA Records CPRT Program Plan Section III.j and Guide on Central and Working Files
)
18 Audits Checks of the activities performed under TRT ISAPs are accomplished by Review Team Leader overview of activities (CPRT Program Plan Sec-tion VIII.b.3); the reviews and audits con-ducted by the CPRT Results Report and File Review Consnittee (Attachment 4 to CPRT Third-Party QA Program); and SRT review and approval 1 of Results Reports (CPRT Program Plan Section l VIII.b.1) ] In addition to the generically applicable guidance listed above, the l direction provided by specific ISAPs implement measures of other QA ele-ments (e.g., test control) as they are appropriate to the specific issue. (3) Quality of Construction Program A (tM4//7,Y e,c Op.r7#acf; A Quality Assurance Program has been developed for the[QOC activities and addresses the following 10CFR50, Appendix B Criteria-f' l
II 1/31/86 SECTION 1.0 -
~ .
DRAFT ' Criteria Title 1 Organization 2 Quality Assurance Program 4 Procurement Document Control 5 Instructions, Procedures and Drawings 6 Document Control 7 Control of Purchased Material Equipment and Services 10 Inspection 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 QA Records 18 Audits
- L Overall responsibility for QA activities rests with the ERC Division Manager of Quality Assurance who has the authority to issue Corrective Action Requests or Stop Work Orders. The Procedures and Project Assurance Group are the on-site representatives of the ERC Division Manager cf Quality Assurance and are responsible for identifying and reporting on the status of the quality program by conducting surveillances of the QOC activities. The results of these surveillances are documented and re-
,ported to the Manager of Quality Assurance and the Review Team i.eader. In addition, the Manager of Quality Assurance conducts audits of QOC activi-ties in accordance with ERC QA requirements. The Division Manager of Quality Assurance is organizationally independent from the CPRT.
(4) Design Adequacy Program A Quality Assurance Program has been developed for the DAP activities and addresses the following 10CFR50, Appendix B Criteria: Criteria Title 1 Organization 2 Quality Assurance Program
/
I l II 1/31/86 SECTION 1.0 ; DRAFT ..
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3 Design Control 4 Procurement Document Control 5 Instructions, Procedures and Drawings 6 Document Control 7 Control of Purchased Material, Equipment l and Services 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 QA Records 18 Audits In addition, should activities in the areas of Inspection, Testing or Measuring, and Test Equipment be required appropriate Quality Assurance requirements will be established or subcontractors with applicable Quality k D Assurance Programs will perform the activity. Responsibility fer ensuring effective implementation of the DAP QA Program resides with the DAP Quality Assurance Manager who reports directly to the DAP Review Team Leader. Audits will be performed, or led, by individuals qualified to the requirements of ANSI N45.2.23, Sections 2.3.1 through 2.3.4 for Lead Auditors. 1.3 Staff Evaluation The Quality Assurance Program provided by Revision 3 of the Plan Jf el 5 - e T *f'---t ' ; r. n...t c... ...._.U...wrn. . u . .qw @t'it W establishes a level of program quality comensurate with the activities of the CPRT. ; i 1 i i I
and S:rvices 15 Nonconforming Materials, Parts or Components 16 Corrective Action . 17 QA Records 18 Audits
- In addition, should activities in the areas of Inspection, Testing or Measuring, and Test Equipment be required appropriate Quality Assurance requirements will be established or subcontractors with applicable Quality Assurance Programs will perform the activity.
Responsibility for ensuring effective implementation of the DAP QA Program resides with the DAP Quality Assurance Manager who reports directly to the DAP Review Team Leader. Audits will be performed, or led, by individuals qualified to the requirements of ANSI N45.2.23, Sections 2.3.1 through 2.3.4 for Lead Auditors. 1.3 Staff Evaluation The Quality Assurance Program provided by Revision 3 of the Plan j 4., g w_. ,u.ac, ... u___. - - 1 -j j ,,g gg7 , , , , , , , _.
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.; establishes a level of program quality comensurate with the activities of the CPRT.
(1) Overall Responsibility p f a n y M mr m 'a mn& Amu -
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II lj337gg SECTION 1,0 DRAFT x git 4 EF e t% Qf .W i b i..mt ai" M aarra--d-by-(or 'c')--the-SRT. These audits are important to assure SRT QA involvement and control that is conrnensurate with their responsibility. Sufficient experience in Quality Assurance requirements is available in the SRT to understand the magnitude of audit findings, to determine the impact on program quality and to properly administer their responsibility for quality. (2) Issue-Specific Action Plans Although a formal QA Program is not provided for ISAPs,10CFR50, Appendix B Criteria applicable to all ISAPs arc provided in the various sections of the Program Plan and Policies. In addition, individual ISAPs O implement measures of other QA criteria as they are appropriate to the issue of concern. The one criterion that appears to be missing is Cri- [g, ? ' terion 12, Control of Measuring and Test Equipment. Some ,of the ISAPs_ l require field measurement and the use of tools, gages anY instruments, and , , D
'Criierion 12 orovides ace""= nstruments are properly calibrated ' '
and controlleA Since formal QA audits are not being performed within the ISAP % nization it is important that the SRT assure that its audit activities sample ISAP efforts. (3) Quality of Construction Program i A formal QA Program is provided for the QOC activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the QOC QA Program.
, l H y Criterion 12, Control of Measuring and Test Equipment is not a 6 part of the QOC QA Program. QOC personnel will be performing inspections 1 which include measurement, therefore it is important that the tools, gages and instruments used are properly calibrated and controlled. Adoption of [
Criterion 12 by QOC will assure that this occurs. i, QA activities are the responsibility of the ERC Division Manager of Quality Assurance who is independent of the CPRT organization. Ongoing QA surveillances of QOC activities are performed by the Procedures and d
SECT!nN 1.0 --
~
Project Assurance Group. This group has two reporting respdnsibilities; (1) to the ERC QA Manager for QA surveillance activities and (2) to the Review Team Leader for non-QA activities. This dual reporting responsi-bility could appear to create conflicts. However, since the ERC QA Manager performs independent audits and is organizationally removed from all CPRT activities, and the Project Assurance Group non-QA activities are essen-tially Engineering Inspection Assurance activities, QA activities are suf-ficiently removed from day-to-day inspection and evaluation actvities. Since SRT retains overall responsibility for quality implementa-tion of the CPRT activities, the QOC organization chart (Figure 2.1) should 3 indicate that the ERC Division Manager of QA has reporting obligations to the SRT. k,
%g-(4) Design Adequacy Program A fomal QA Program is provided for DAP activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the DAP QA Program.
Should inspection activities be required appropriate QA requirements will be established or subcontractors with applicable QA Programs will perform this activity. Inspection activities, if required, should be covered by
. formal adoption of Criteria 10 and 12 of 10CFR50, Appendix B. %
L.a. - . DAP QA responsibility resides with the DAP QA Manager who re-ports directly to the Design Adequacy Review Team Leader. Although this reporting chain is not as separate as that used in the QOC Program, it is acceptable under Criterion 1 guidelines. In addition, the DAP QA Manager has reporting responsibilities to the SRT. This responsibility to SRT should be clearly indicated on Figure 1 of the DAP QA Program. Since the DAP has the responsibility of reviewing and accepting activities being performed by the Comanche Peak project it is important that the DAP QA Program be structured to assure audit of these project , activities. Extensive reanalyses of piping, supports and cable trays are l l l
SECTION 1.0 Since the ortjanizations - bei g perf ormed by the Comanche Peak project. performing the reanalysis activities are implementing their own QA Pro-grams, subject to TUGC0 audits, it is important that the DAP sample these QA activities. For example, an important input to this effort is the i as-built configuration of hardware. In the piping and pipe support area, I SWEC has performed sample walkdowns to determine the adequacy of current In as-built data for elements they consider to be critical to design. addition, SWEC will be relying on any deficiencies in piping and support as-built data reported by QOC. Based on this, it is critical that DAP assure that sufficient data is obtained and that the quality of the data is acceptable. In the area of cable trays and supports, a complete walkdown l is being performed by Ebasco/Impe11 to develop as-built geometry prior to analysis. It is critical that DAP assure that the quality of this as-built l data is acceptable. /~ U 1.4 Conclusions
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C. Cse44k / f 2f 7 oG - a//2/N XLL, oc - m, II - SECTION 3.0 1/31/86 l(ggggg, , 3.0 CORRECTIVE ACTIONS 3.1 Introduction V ' W/& fffhf" Y&
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Policy for the Development, Approval and Confirmation of Implementation of Corrective Action" which describes: the process through which corrective action will be defined for deviations or deficiencies identified by the CPRT,
- the process through which the CPRT third-party will review and approve the definition of corrective actions for all deficiencies and for certain categories of deviations identi- !
fied by the CPRT, and
- the nature and extent of CPRT third-party confirinatory over-views of the implementation of defined corrective actions. l (1) Corrective Action Definition Ar<nta 724p frnffCr (p'
I 4 Once the individual CPRT(ItTL) classifies a discrepancy as a deviation (failure to meet a design comitment or specification) or a
_[ i the Pla ressed con-The N ff comentsjonev.isitrh cern with the failure to p Ecriteria and guidelines to be hped by the s CPRT in defining correc,ti e actlo and judging implementation of' he cor-Revision only addressed corrective \ action rective action by[IDGCO. source issues and di'dmot provide a process fo related to externa sing correcti [ action resulting from self- itiated activities. Further, the TUGC0 orrective action system was an item of concern to the Stiff which creased the necessity for CPRT invbvenent in implementatio'n
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acti ties. h. vp 3.2 CPRT Approach Revision 3 of the Plan includes Appendix H, "CPRT Procedure and Policy for the Development, Approval and Confirmation of Implementation of Corrective Action" which describes:
- the process through which corrective action will be defined for deviations or deficiencies identifted by the CFRT, 1
- the process through which the CPRT third-party will review and approve the definition of corrective actions for all l
deficiencies and for certain categories of deviations identi-l fied by the CPRT, and l l t ion of rr i o v ew of he (1) Corrective Action Definition Arwrd 7Ep dinoff pp' Q
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4 Once the individual CPRT(ItTL) classifies a discrepancy as a deviation (failure to meet a design comitent or specification) er a , p
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SECTION 3.0 deficie~ncy (a deviation determined to be safety-significanf) the CPSES Project is responsible for:
- performing 10CFR50.55(e)reportabilityevaluations.
- defining appropriate corrective action.
- obtaining CPRT RTL concurrence in the defined corrective action for a safety-significant deficiency; programatic deviation or deficiency; design deviation involving failure to meet FSAR, licensing or regulatory criteria or comit-ments; and a deviation reportable under 10CFR50.55(e).
The CPRT RTL is responsible for determining the adequacy of the corrective ( actions submitted by the CPSES Project for review. In the event that the RTL determines the proposed corrective action is inadequate and cannot resolve the situation with the Project, the SRT is responsible for resolv-ing the concern. The Executive Vice President of TUGC0 is responsible for responding to the SRT with the TUGC0 position. In addition, the CPRT RTL may recommend proposed corrective
. action to the CPSES Project. 5 T approval is required for CPRT recomenda-tions for corrective action -
I t#et re programatic in nature. 1 solve safety-significant deficiencies, and y 4tr[ solve design deviations that could involve a change to existing licensing or FSAR conmitments. (2) Overview of Implementation The CPRT must be satisfied that, when implemented as defined, the CPSES Project corrective action will correct the nonconforming
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SECTION 3.0 condition identified and, '% R a % will preclude the recurrence of similar conditions in the future. The CPRT RTL will be responsible for performing confirmatory overviews of the implementation of corrective action for which they were responsible for reviewing and approving. These confirmatory overviews are intended to ensure that the corrective actions have been effectively implemented for each: 1[ogramatic deviation or deficiency. . ? /afety-significant deficiency, f [ sign deviation involving a failure to meet FSAR and licensing conrnitments, and 4[ecificdeviationthatmeetsreportabilitycriteriaof 10CFR50.55(e). In general, the overview involves a review of documentation. In ( Y addition, where reinspection is required for corrective actions related to QOC activities, the CPRT will either witness the reinspection performed by the CPSES Project or perform independent reinspection. 3.3 Staff Evaluation Revision 3 of the Program Plan provides a comprehensive approach 4 to the specification and approval of corrective action confirmation of / implementation and responsibilities of the CPRT and the CPSES Project. The only major coment the staff has is related to the timing of SRT approval / of CPRT RTL determination of the adequacy of corrective actions defined by / ; the CPSES Project. Appendix H provides two alternatives, ! l
- approval on an ongoing basis as corrective actions are
, developed, or
- approval as part of the Action Plan Results Report approval process.
/ ,
CTION 3.0 - 1 The Staff feels that the SRT should approve (or disapprove)' corrective j actions on an ongoing basis as they are developed. This approval should follow that of the CPRT RTL. It is felt that this would keep the SRT more I i in line with CPRT-CPSES Project interfaces and reduce the potential for
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having the RTL and the CPSES Project involved in lengthy discussions when the RTL does not agree with the proposed corrective action. r' 9 V f..A 3.4 Conclusions The CPRT Procedure and Policy for the documentation,, aporoval is a.ceef/vHe h and confirmation of implementation,of. corrective actionsj t c earchens ke - aad is eacponsiv23n st:#' :I.5r.t? E Esiska g n fer,<4ael -ereat-fahility is ne=A4c=+=A aa +ha RDT annenval nf d r: ^ 5: :thr ' :d'-t:17 I rn11 ~ 4 ,,
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MISC 11 - 4.0 tC A0 DRAFT ? - 1/31/86 L - 4.4 - -Independence of the CPRT/SRT Organization
- 4.4.1 Introduction The Comanche Peak Response Team (CPRT) Program Plan, Revision 3, was initiated by the Texas Utilities Generating Company (TUGCO) to address concerns and issues raised by allegers, the NRC Technical Review Team's (TRT) inspection of the Comanche Peak Steam Electric Station (CPSES) and other external sources. The verification and corrective action program is a comprehensive, detailed and fully documented effort to determine the adequacy of the plant's design, construction, quality assurance and pre-operational testing.
4 An essential part of a verification program requires that the persons and organizations implementing the plan should have , sufficient authority, organizational freedom, independence, and objectivity to identify quality problems and to verify the implementation of solutions. Such persons and organizations performing quality assurance functions should report to a management level such that the required authority and organiza-tional freedom, including sufficient independence from cost and schedule when opposed to safety considerations -are provided as $L . delineated in 10 CFR 50, Appendix B. In addition, the individuals assigned the responsibility for assuring any portion of a j verification program should have direct access to such levels of . management as may be necessary to perform their functions. 5J Twn accsc, 4.4.2 CPRT Approach The Applicant recognized the necessity for the objectivity of verification personnel to implement a credible CPRT program. 46-dCPRT personnel had to meet specific requirements such as knowledge and experience, integrity, objectivity, no financial interest, and no previous involvement in the Comanche Peak Steam Electric Station (CPSES) project activities-4 +:stiod To meet this objective the CPRT developed a "CPRT 0 jectivity Questionnaire" A'f a r o m TWE/r Cfff Arf"A(N7/fS. y-,._--
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, , personnel were required to answer and sign. In the few cases where -
-these objectivity criteria were not met, they would be promptly identified by the CPRT and provided to the NRC along with any necessary justification.
M The organization for the CPRT effort is essentially all third-party personnel except for the Senior Review Team (SRT) Chaiman and the CPRT Program Director. These two individuals, while they are TUEC FCCe employees do not have any responsibility for the-construction cost and schedule of the CPSES. To further assure the objectivity, independence, and credibility of this effort all the verification and corrective action activities , will be perfomed under CPRT quality assurance programs that meet the requirements of 10 CFR 50, Appendix B. M In addition to the quality assurance program, the applicant has established an Overview Quality Team (0QT) to assure senior TUGC0 management that the CPRT meets the objectives established for this verification program. The 0QT will not have any active part in the implementation of the CPRT program but will function as an independent audit group. The OQT will review the elements of the i program to a depth and frequency as necessary to assure management that all the program directives are met. All necessary documents will be available to the OQT as needed. The necessary auditors / inspectors and assistance will be provided to enable them to evaluate the implementation of the effort. TheCPRTprogramwillbeagu)1ygogumentedeffort.[naddition/ public monthly progress meetingsdin the Arlington, Texas vicinity so that interested parties may review the progress of the verification effort. The applicant has committed, when the final Issue Specific Results Reports are filed with the NRC, to make them available at the site for public review along with the supporting ' documentation.
4.4.3 Staff Evaluation To determine that the independence of the CPRT effort met the ' 1 ~ requirements of 10 CFR 50 Appendix B and that there existed the required authority and organizatio.n al freedom, including sufficient independence from cost and schedule the NRC Staff reviewed the TUGC0 and CPRT organization charts and position descriptions, interviewed the managers and key personnel of the TUGCO, CPRT, SRT, In addition, the staff reviewed the Review Team Leaders and 0QT. work and experience resumes and the "CPRT Objectivity Questionnaires" of the managers, engineers and inspectors associated with the CPRT effort. A principal objective of these interviews and reviews, in the case of the CPRT managers and key personnel was to detemine their attitude towards Quality Assurance,' the necessity for it, and if there was any reason that they could not perfom an independent and objective review.
&@J 4.4.3.1 Organization The overall charge to the CPRT is to advise TUGC0 management whether there is reasonable assurance that the Comanche Peak Steam Electric Station can be operated without undue risk to the public. The organizational structure of the CPRT is a functional type organization that consists of a Senior Review Team which fomulates policy and directs the activities of five Review Team Leaders for issue specific and discipline specific lans.
sericW The Chaiman of the SRT is a TUGC0 employee, Mr. John Beck, a Vice President and Manager of Licensing. The five other members of the SRT are experienced senior engineers who are not TUGC0 employees but are associated with independent consultant fims. The CPRT Program Director and an ex-officio member of the SRT is Mr. Terry j.
; Tyler, a TUGC0 employee. Both Messrs. Beck and Tyler were 2
interviewed by the NRC staff, their position descriptions reviewed, ( and neither were found to have any responsibility for the project's l
i
. 4 construction cost and schedule. The interviews also indicated that i ification.
,- - both individuals were connitted to perfom a qual ty ver
- 'were of the opinion that they could perfom their duties objectively "
and independently and had direct access to senior levels of TUGC0 management if problems arose. The Review Team Leader's duties are a critical component of the I p CPRT effort. Each Review Team Leader is responsible to ensge,that the action plans within their areas are properly implementede results reports prepared in addition to their corollary administrative duties. l In. addition to the umbrella Quality Assurance Program discussed in Section 11, Item 1 of this report, which will be used for surveillances and audits of the CPRT effort, there is an Overview Quality Team consisting of four senior members who will M periodically review, audit and consent to the CPRT chairman on
%~. activities, results and programs of the CPRT effort. The NRC staff interviewed the CPRT Chairman, Review Team Leaders, SRT members and the Chaiman of the OQT in order to detemine their qualifications, experience and commitment to quality assurance, and tneir understand-The ing of the functioning and purpose of the CPRT program. I individuals interviewed were found to be experienced, qualified.
understood the functioning of the organization and were all committed to perfoming their duties in an objective and responsible manner. A series of five 1-week inspections was M carried out by the NRC staff in the latter half of 1985,a8f [he CPRT organization was found to be functioning in an objective and sufficiently independent manner. In addition to the interviews and reviews of the CPRT organization,
' the TUGC0 site construction organization was reviewed to detemine
#NM 4hft responsibility for project construction cost and schedule was The not an area of responsibility for any members of the CPRT.
responsibility for cost and schedule was found to be directly ~ vested in Mr. J. George, the Vice President and General Manager of i 4
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the Comanche Peak Station Electric Project. Reporting directly to Mr. Geurge are a Mr. R. Camp, Project Manager for Unit il and -
~ ~ Mr. J. Merritt, Project Manager for Unit (2. These three individuals are directly responsible for the cost and schedule of the project and interviews with them indicated that they did not nly .iff have any influence or impact on the CPRT verification effort ifica-after-the CDDT r^cz ::t nrieet.i w in.i.iun i.hai , equiroy
[hese t?cr. J, icgc.xnt Of physhi sun:,truction worr are individuals 4 involved in the corrective action processp cosArer;wt .fenodootwr* r' serr#' THE CAdf~AU~com A?fWor.s nroo rse4ynJos w os s s e m ge.7 , , ,y- o ; 4.4.3.2 CPRT-Site Personne1_ Av.ror4 c d o k r s a r d
- s ic .
Each site individual participating in the CPRT program wasThe required by TUGC0 to answer and sign a "CPRT Objectivity Questionnaire." purpose of the questionnaire was to ascertain if the individual had any financial, previous employment, or other interest in TUGC0 or Texas Utilities Electric Company subsidiaries that would inhibit the individual from being completely objective and independent in the h-p~ performance of the tasks assignedsato.ssrcrof him in the CPRT program. The r NRC staff reviewed essentially all of theobiectivity ADD questionnaires xcx4rro addit 44h tdr'the%ork on file at the time of the inspection g .s ia 7wgst utst cod.ressss experience resumes,and frend 1 .... /n general, to be satisfactory. Three inspectors were identified who had previously worked for The NRC staff opinion in Brown & Root at the South Texas Project. these three cases was that there us no apparent loss of objectivity or independence as a result of their previous employment and their current work assignments for the CPRT. In addition to the reviews of inspector questionnaires and work resumes, the objectivity questionnaires and work reviews of essentially all CPRT managerial and key personnel were also reviewed. These personnel files were found to be satisfactory except for two members of the SRT and three key members of the CPRT. These individuals had previous contractural involvement with Additional NRC staff review of this condition we r was mad g{ CPSES. 4 the NRC staff detemined that their prior employement would result l in any loss of objectivity or independence in the performance of l their current assignments. \
4.4.3.3 TERA Personnel
- -In addition to the site personnel, TEPA offsite personnel engaged *
'in CPRT design verification activities were also required to answer and sign the objectivity questionnaires as previously described.
l The questionnaires and work experience resumes of TERA personnel were reviewed by the NRC staff and with one exception were found to be satisfactory. The staff was of the opinion that some of the TERA Civil / Structural and Mechanical Engineering personnel had limited or no comercial nuclear power plant design experience. This weakness was identified to TERA management and subsequent to j the inspection the necessary corrective action was taken and 25 additional, experienced nuclear design engineers were added to satisfactorily reinforce th[se personnel performing the design l verification activities. 4 l 4.4.4 Conclusion Or, the basis of its evaluation, the staff concludes that.the
.5 tz : - persons and organizations performing the CPRT verification, O
evaluation and corrective action activities have sufficient authority and organizational freedom to identify quality problems The individuals and to initiate or recomend corrective actions. 1 and organizations performing the CPRT functions report to a management level such that there exists a required authority and organizational freedom, including sufficient independence from cost and schedule of construction of the project when opposed to safety , considerations. The staff concludes that the persons aad organizations implementing the CPRT program have sufficient authority and independence from cost and schedule and meet the p requirements of Criterion I of 10 CFR 50, Appendix B.
' Over and above the inherent independence and objectivity in the CPRT effort, the NRC has established a large overview team l
(approximately 40 engineers) that will conduct surveillances, i inspections, over-inspections, design reviews, calculation reviews This
' and audits of a significant sample of all CPRT activities.
i NRC overview effort will assure that the verification effort is independent, objective, and credible. i
To date, numerous overview activities have occurred and have been
, , documented and have been included in the monthly Region IV Comanche -
- -Peak inspection reports. These reports are available for review in the public document rooms established for the Comanche Peak Steam Electric Station. It is the intent of the NRC staff to maintain a documented, verifiable, and auditable trail of the CPRT activities.
Andswx 0, 7w oc-While the present CPRT pr is found to meet 4 requirements as-te [ the applicant shall notify the NRC staff
-Crit:rbr ! .. .. .. n suf of any proposed changes in managerial or key personnel in the CPRT effort prior to its implementation, unless the changes are a result of work completion.
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L'k hYk b- h,$ " D II b 2/5/86 SECTION 5.0- - eq 5.0 h15CIPLINEINTERFACES M/I
- l 5.1 Introduction Si..f'-bieu d Davirit: 2 cf the Program P4annmpressed-e-number of r oncerns wi+h nrhani,2+ 4^nal-Interfaces:---These Tt3fFconcerrisNtr-in!
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, ,seces withindhe CPRTmrganiraTTtn.
The design and construction process requires transmittal of proper infor-mation across a number of interfaces. Failure to have a process in place which controls the transmittal of information and assures proper reviews s and approvals can result in inadequte design and construction activity. 55 Interface control must be provided between engineering and construction gj disciplines and between engineering and construction activities. The scope of the CPRT effort, including the TUGC0 project reanalysis activity, requires the same kind of interface control. 5.2 CPRT Approach Revision 3 c7 the Plan includes Appendix F,;'CPRT Interfaces", l which indicates that implementation of the Plan requires the establish- ! l ment, execution and control of interfaces among the participants. The principal participants for whom interfaces are defined by the CPRT are:
- TUGC0 Senior Management
- CPRT - SRT
- CPRT - RTL
- CPRT Program Director l
- CPRT Surport Staff
- CPRT Advisers l
l E _ -_ _ _ _ _ _
i II SECTION 5.0 2/5/86 h{
- - CPSES Project, including major subcontractors. QA/QC organization and project personnel.
The participant interfaces that are defined in detail are sum-marized in the following matrix. CPRT MAJOR PARTICIPANT INTERFACES 4 8 RTL' PROGRAM DIRECTOR TUGC0 MANAGEMENT X X X SRT X X RTL PROGRAM DIRECTOR X X X . SUPPORT STAFF ADVISERS X
-9 X X X CPSES PROJECT X X NRC CYGNA X SAFETEAM X Detailed matrices are provided for the major organizational interfaces within the CPRT. A list of these follows:;
QOC to DAP QOC to CPSES Project DAP to QOC DAP to CPSES Project DAP to Other Design Organizations RTL to Program Director
' RTL to CPSES Project RTL to DAP RTL to QOC
___ , . - _ - . ~ . - - _ . . . - - - , , .
, _ - , , , - - - - - ._ . _ . v
n SECTION 5.0 u5,8e DRAFT g/T 7026 4bo Nf r x LC~s G
'? 10ther CPRT interfaces are discussed in detail with individual responsibilities, extent of the interface and documentation c neerns pro-and SWEC vided. In addition, matrices of interfaces between CPRT andQWEC, and other CPSES Project Organizations, are provided.
Three levels of responsibility are applicable to each item of information transmitted across an interface. The transmitting organiza-tion has the responsibility for categorizing the item of information which automatically fixes the level o'f responsibility as defined by the appro-priate matrix. The three levels of responsibility are: (1)Information, (2) Review and Consnent, and (3) Action. 5.3 Staff Evaluation I f//f p;// M/od ef /A)ffg f4cds fAocood'o sa 47p/faesxp* gs
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d*J r4 c4/3 Ut;v f o r d f s s s e s f*s' o d fpe Codf4 4. pog g;WOS*VZds 7/fd* Af3/c:a) Ado coasF4efred /Affs/4cA*.7 a b Of Coodo/dg n*J pode yzyr 4~sW7' f4fncssds' l
/~o/2 and4D/zenowr. h4 Atax/441/4/77 m (5Ald&ht There are a number of areas where interface between various CPRT organizations and CPSES project organizations is defined. In some cases, the interface appears to be duplicative and prime responsibility is not defined. It is important that prime responsibility for interface control be defined to assure that involved organizations understand who is re-sponsible for establishing, executing and controlling the interface.
4,4y f??%5ffl# ' The following are cds on the individual matrices provided ( l in Appendix F.
- 1. QA/QC-RTL and DAP-RTL to Unit I and Unit 2 APGMs. Respon- j sibility for 50.55(e) reportability is assigned to the ,
TUGC0 Project per Appendix H of the Plan. 1 I
SECTION 5.0 /k86 DRAFT 1 l DAP-RTL to SWEC. Information on root-cause analyses. - l
~? ; 2.
generic implications, Evaluation reports and Results ,, reports is provided to SWEC for "Information" when pertain- 8 cg-ing to the SWEC scope. Since this information could impact ;ik , I the SWEC analysis effort, it should be provided for " Action by SWEC". Since DAP is auditing SWEC activity, this matrix
~ [ {'
should address those items associated with that effort, including Corrective Action.
- 3. DAP-RTL to Other Design Organizations. Information on root-cause analyses, generic implications. Evaluation reports and Results reports should be provided for " Action" to EBASCO and Impe11, who are reanalyzing cable trays and supports. The CPRT may find it more appropriate to develop a separate matrix for the cable tray and suppor't effort activities of EBASCO and Impe11.
- 4. RTLs to CPSES Project. Action Plans are designated as both
" Info" and " Action by Project". It h th Staff's under- [
standing that Action Plans are provided to the CPSES Pro-ject for information only.
- 5. SWEC to Interfacing Organizations. Design- and construc-tion-related concerns found during walkdown and document reviews should require action by DAP and QOC RTLs. That action should include evaluation of the deviation in the same manner as if it were discovered as part of the CPRT j
self-initiated program. Loading from the piping system should be provided to QOC through the DAP since this infor-nation may.be needed for safety-significance evaluation. id : [J Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and DAP-RTL and EBASC0/Impe11 and Interfacing Organizations. l lO -
IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN TABLE OF CONTENTS M 1.0 ntroduction 2 xte nal Source Issues
,5 g k.0W .1 Electrpal,InstrumentationandControlSystetsandComponentIssues (r' 2.1.1 Heat Shrinkable Insulation Sleeves (I.a.1) 2.1.1.1 Introduction 2.1.1.2 CPRT Approach 2.1.1.3 Staff Evaluation Conclusion 2.1.2 /2.1.1.4 Butt Splice Inspection Reports (I.a.2) 2.1.2.1 Introduction 2.1.2.2 CPRT Approach 2.1.2.3 Staff Evaluation
/ 2.1.2.4 Conclusion 2.1.3 v Butt Splice Qualification (I.a.3) 2.1.3.1 Introduction 2.1.3.2 CPRT Approach A 2.1.3.3 Staff Evaluation 5 2.1.3.4 Conclusion 2.1.4 } Field Terminations - Comparison of Drawings With As-Built Configuration (I.a.4) 2.1.4.1 Introduction 2.1.4.2 CPRT Approach 2.1.4.3 Staff Evaluation Conclusion 2.1.5 12.1.4.4 Vendor Installed Amp Terminal Lug NCRs (I.a.5) 2.1.5.1 Introduction 2.1.5.2 CPRT Approach -
2.1.5.3 Staff Evaluation 2.1.5.4 Conclusion 2.1.6 1FlexibleConduitSeparation(I.b.1) 2.1.6.1 Introduction 2.1.6.2 CPRT Approach 2.1.6.3 Staff Evaluation Conclusion 2.1.7 J2.1.6.4 Flexible Conduit - Cable Separation (I.b.2) 2.1.7.1 Introduction 2.1.7.2 CPRT Approach
,2.1.7.3 Staff Evaluation 1 2.1.7.4 Conclusion 2.1.8 JConduit to Cable Tray Separation (I.b.3) 2.1.8.1 Introduction 2.1.8.2 CPRT Approach 2.1.8.3 Staff Evaluation 2.1.8.4 Conclusion
2.1.9 arrier Removal (I.b.4) 2.1.9.1 Introduction
- 2.1.9.2 CPRT Approach ,
; - 2.1.9.3 Staff Evaluation
; 2.1.9.4 Conclusion _ . _ _
T
' Yg9 2.uyA/ycjssues2 "?.1; QC Inspector Qualifications (I.d.1) 2.2.1.1 Introduction f 2.2.1.2 CPRT Approach 2.2.1.3 Staff Evaluation j2.2.1.4 Conclusion 2.2.2 vQC Inspector Test Administration (I.d.2) 2.2.2.1 Introduction p 2.2.2.2 CPRT Approach-2.2.2.3 Staff Evaluation \*/ (
2.2.2.4 Conclusion A2,3- RPV to Biological Shield Gap (VI.a) . A R'g rv
/ 2.2.3.1 Introductior.
.g.c/./#
f t's /4 92.2.3.2 CPRT Approach 2.2.3.3 Staff Evaluation .g . v . 7 o 2.2.3.4 Conclusion n 2r i7 6 .s.BW</. 7 Polar 2.2.4.1 Crane Shimming (VI.b) Introduction p'b,j j E 2.2.4.2 CPRT Approach 2.2.4.3 Staff Evaluation Q AB
, 2.2.4.4 Conclusjon 4.2.5./ Material Traceability (VII.a.1) 2.2.5.1 Introduction 2.2.5.2 CPRT Approach 2.2.5.3 Staff- Evaluation 2.2.5.4 Conclusion 2.2.6lCorrectiveActionSystem(VII.a.2) 2.2.6.1 Introduction 2.2.6.2 CPRT Approach 2.2.6.3 Staff Evaluation 2 .2.6.4 Conclusion J
2.2.7 Document Control (VII.a.3) 2.2.7.1 Introduction 2.2.7.2 CPRT Approach i 2.2.7.3 Staff Evaluation j2.2.7.4 Conclusion 2.2.8 Audit Program and Auditor Qualification (VII.a.4) ( 2.2.8.1 Introduction 2.2.8.2 CPRT Approach
, 2.2.8.3 Staff Evaluation 2.2.8.4 Conclusion 2.2.9 J' Management Assessment (VII.a.5) 2.2.9.1 Introduction 2.2.9.2 CPRT Approach 2.2.9.3 Staff Evaluation 2.2.9.4 Conclusion l
2.2.10v' Exit Interviews (VII .a.6) f 2.2.10.1 Introduction r
' 2.2.10.2 CPRT Approach .
- 2.2.10.3 Staf f Evaluation 2.2.10.4 Conclusion
-2.2.11/ Cleanliness (VII.a7) 2.2.11.1 Introduction 2.2.11.2 CPRT Approach 2.2.11.3 Staff Evaluation 2 Conclusion
, 2.2.12 j .2.11.4 Fuel Pool Liner (VII.a.8) 2.2.12.1 Introduction 2.2.12.2 CPRT Approach 2.2.12.3 Staff Evaluation 2 Conclusion
!, 2.2.13 / n.2.12.4O site Fabrication (VIIb.1)
; 2.2.13.1 Introduction 2.2.13.2 CPRT Approach l
2.2.13.3 Staff Evaluation 2.2.13.4 Conclusion j 2.2.14 / Valve Disassembly (VII.b.2) i 2.2.14.1 Introduction
! 2.2.14.2~ CPRT Approach l 2.2.14.3 Staff Evaluation !
Conclusion
/2.2.14.4 Pipe Support Inspections (VII.b.3)
Q 2.2.15 2.2.15.1 Introduction 2.2.15.2 CPRT Approach 2.2.15.3 Staff Evaluation j2.2.15.4 Conclusion l 2.2.16 Hilti Anchor Bolt Installation (VII.b.4)
' 2.2.16.1 Introduction 2.2.16.2 CPRT Approach 2.2.16.3 Staff Evaluation Conclusion l b 2 .2.17} 2.2.16.4 Cable Tray Raceway Support Inspections (VII.b.5)
I 2.2.17.1 Introduction 2.2.17.2 CPRT Approach 2.2.17.3 Staff Evaluation gy 2.2.17.4 Conclusion
,62.3
/ Civil / Structural Issues 2.3.1 ' Reactor Cavity Reinforcing Steel (II.a) 2.3.1.1 Introduction
!' 2.3.1.2 CPRT Approach 2.3.1.3 Staff Evaluation Conclusion 2.3.2}2.3.1.4 Concrete Compression Strength (II.b) 1 2.3.2.1 Introduction 2.3.2.2 CPRT Approach j
{ 2.3.2.3 Staff Evaluation i 2.3.2.4 Conclusion 2.3.3 ' Concrete Structure Air Gaps-(II.c) 2.3.3.1 Introduction 2.3.3.2 CPRT Approach ; 2.3.3.3 Staff Evaluation 2.3.3.4 Conclusion { 1 i D - - -. . - - , _.
4 2.3.4 M Control Room Seismic Design (II.d) 2.3.4.1 Introduction 2.3.4.2 CPRT Approach 2.3.4.3 Staff Evaluation ., 2 - / 2.3.4.4 Conclusion 2.3.5 / Fuel Handling Building Rebar (II.e) 2.3.5.1 Introduction 2.3.5.2 CPRT Approach 2.3.5.3 Staff Evaluation 2.3.5.4 Conclusion 2.3.6 / Electrical Conduit Supports (I.c) 2.3.6.I Introduction 2.3.6.2 CPRT Approach 2.3.6.3 Staff Evaluation 2.3.6.4 Conclusion g74 2.4 Mechan} cal / Piping Issues 2.4.1 / NF Support Skewed Weld Inspection (V.a) 2.2.4.1 Introduction 2.2.4.2 CPRT Approach 2.2.4.3 Staff Evaluation 2.4.2 /2.2.4.4 ImproperConclusion Shortening of Anchor Bolts in S.G. Upper Lateral Support (V.b) 2.4.2.1 Introduction 2.4.2.2 CPRT Approach 6 2.4.2.3 Staff Evaluation W- 2.4.2.4 Conclusion
~~
2.4.3/PipingSystemDesignBetweenSeismicandNon-seismicCategory 1 Buildings (V.c) 2.4.3.1 Introduction 2.4.3.2 CPRT Approach fI 2.4.3.3 Staff Evaluation b 2.4.3.4 Conclusion 2.4.4 } Non-seismic Category 1 Buildings (V.d) l 2.4.4.1 Introduction
,2.4.4.2 CPRT Approach
, 2.4.4.3 Staff Evaluation (~
hgggf7
.gg 2.4.4.4 Conclusion 7. y 7 2.4.5 Main Steam Pipe Installation (V.e) 2.4.5.1 Introduction 2.4.5.2 CPRT Approach /
2.4.5.3 Staff Evaluation j _j l 2 2.4.5.4 Conclusion _s 2.5J Testing Program Issu'Es g 2.5.14 Hot Functional Testing Data Packages (III.a.1)
/ 2.5.1.1 Introduction 2.5.1.2 CPRT Approach 2.5.1.3 Staff Evaluation '
2.5.1.4 Conclusion 2.5.2 A Test Data Approval (III.a.2) 2.5.2.1 Introduction 2.5.2.2 CPRT Approach j 2.5.2.3 Staff Evaluation 2.5.2.4 Conclusion l l .y .
2.5.3 4. Deferred Test Technical Specifications (III.a.3) 2.5.3.1 Introduction
-- 2.5.3.2 CPRT Approach -
;- 2.5.3.3 Staff Evaluation 2.5.3.4 Conclusion 2.5.4 4 Test Equipment Traceability (III.a.4) 2.5.4.1 Introduction 2.5.4.2 CPRT Approach 2.5.4.3 Staff Evaluation 2.5.4.4 Conclusion 2.5.5 \ CILRT (III.b)
- 2. 5. 5.1 Introduction 2.5.5.2 CPRT Approach 2.5.5.3 Staff Evaluation Conclusion 2.5.6(2.5.5.4PrerequisiteTesting(III.c) 2.5.6.1 Introduction 2.5.6.2 CPRT Approach 2.5.6.3 Staff Evaluation 2.5.6.4 Conclusion 2.5.7 5 Preoperational Testing (III.d) 2.5.7.1 Introduction 2.5.7.2 CPRT Approach 2.5.7.3 Staff Evaluation c 2.5.7.4 Conclusion 2.6 ethodology for Resolving New External Source Issues p*_ ' 2.7 valuation of Closed External Source Issues 4 9 3.0 Self-Initiated Evaluation
'/ 3.1J Construction Activity Evaluation Process 3.1.1 J Introduction 3.1.2jCPRTApproach 3.1.3 Staff Evaluation 3.1.4 Conclusions 3.2 Electrical Populations fn f 3.2.1 Staff Evaluation ' '
3.2.2 Conclusions '
.7 3.3vMecnanical Populations 3.3.1 ' Staff Evaluation ;
3.3.2 / Conclusions 7gg 3.4dCivil and Structural Populations '. 1 3.4.1 3.4.2 $ Staff Evaluation Conclustons Activities N 4.0 dExclusion 4.1d Introductionof 4.2 >CPRT Justification 4.3 / JtaffEvaluation 4.4 JConclusions 5.0 Overall Sumary Conclusions
SECTION IV - STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN - Draf t 1 1.0 Introduction
- The adequacy of the construction QA/QC program and the quality of construction perfomed within scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC with responding to and resolving these concerns. This section of the SSER documents the staff evaluation of the CPRT formulated program to evaluate questions concerning construction QA/QC and the adequacy of installed hardware.
The CPRT's objectives for the construction adequacy program are to fully resolve all of the external source issues, assess in an integrated f ashion all identified safety significant deficiencies and to make a statement about both the adequacy and quality of construction at CPSES. The CPRT's program has the following three components: 6 a. Evaluation of external source issues, Root cause evaluation and generic implication assessment for each . b. identified safety significant deficiency or trend of nonsafety significant deviations, and
- c. Self initiated reinspection of a sample of the balance of the hardware within the' scope of the QA/QC program.
The objective of the staff's evaluation is to ascertain if the CPRT Program Plan describes the framework and process for perfoming a meaningful reinspection of the QA/QC and the construction activities perfomed within the scope of that program. The staff's evaluation has consisted of document reviews and audits; the scope of the review has ranged from a review of the Program Plan to the documentation characteristic of the evaluation prepared for assessment of specific hardware populations. Subsequent sections of this SSER section address both the CPRT proposed process and the staff's evaluation of this process. The staff's evaluation addresses both the CPRT's plan for addressing
-- . - - . .a _ _ _ _ . _ _ , _ _ . . _ _ . . _ . . . _ . _
i external source issues as well as their self-initiated evaluation. I,ssue-specific action plans (ISAP) are key elements in the CPRT's process for-evaluating construction adequacy. The ISAPs document the CPRT plan'
- for resolving external issues. All construction QA/QC issues whether of a hardware nature or a QA/QC programatic concern, will be the subject of an issue-specific action plan. A single ISAP describes the process and methodology for the CPRT's self-initiated hardware reinspection and documentation review. A matrix is then developed to provide a cross l
' reference between each issue or coacern and the respective action plan which addresses it. This matrix provides assurance that all external source issues have been addressed by the CPRT. The ISAPs, which are prepared to address specific external source issues, describe the process for evaluation of these issues. This process may include reinspection of hardware, documentation review, engineering I analysis and evaluation, assessment of TUEC corrective action programs and an evaluation of data collected from other CPRT review team action plans. Q ~ The results report prepared for each ISAP documents each individual issue evaluation. The self-initiated hardware reinspection and documentation review program addresses all safety related construction work activities at CPSES. This program will ensure that areas not addressed by the external source evaluation are evaluated. The self-initiated program also provides additional confidence that any currently unidentified concerns related to construction quality are identified, evaluated, and resolved. The process for accomplishing this self-initiated program is to evaluate the work activities required to construct the Comanche Peak plants. This i evaluation will be performed on a sampling basis primarily through l reinspections of safety significant attributes. Documentation reviews As with l will be used to assess inaccessible or nonrecreatable attributes. other ISAPs, a results report will be prepared documenting the results of f the total self-initiated evaluation program. CPRT proposes to integrate and collectively evaluate the findings from their external source . issue evaluations with the results of the self-initiated program in order to make a statement about construction
quality at the Comanche Peak Steam Electric Station. Three reports will be prepared in addition to the individual action plans results reports to Two collective d_ocument the results of the integrated evaluation. - eyaluation reports will be prepared to address the adequacy of the construction QA/QC program and the quality of installed hardware. Finally, a sununary report which integrates the results of the two collective evaluation reports, and state the CPRT's conclusions regarding the quality of construction and the QA/QC program at Comanche Peak plant. The staff's review of the Program Plan has included a review of each individual ISAP including the ISAP describing the self-initiated evaluation program. In addition to the review of each individual ISAP, a number of onsite audits of the documentation being prepared in support of the self-initiated evaluation have been perfomed. The purpose of these audits was for the staff to develop an in-depth understanding of the CPRT , process for resolution of external issues and the scope of its self-initiated evaluation program. These audits also served to establish that the Applicant was documenting construction adequacy evaluation [, The D' activities in sufficient detail to pemit audit now or in the future. staff's evaluation addressed not only the framework and process of the construction adequacy review program but the degree of documentation to be provided by the applicant. Review of the construction adequacy program plan has been accomplished by teams of NRC staff and consultants. External source issue review teams have been organized in a manner similar to the technical review teams and include the following disciplines:
- a. Electrical and instrumentation issues
- b. Test program issues
- c. Mechanical and piping issues
- d. Civil and structural issues
- e. QA/QC issues
- f. Miscellaneous issues 1
Many of the individuals responsible for reviewing the scope methdology and impicmentation of the external source ISAPs were members of NRC's Review of the self-initiated evaluation program is Technical Review Team. a'ccomplished by multidisciplinary team compassing most of the disciplines This team has reviewed the methodology addressing external source issues. for the self-initiated program and performed an audit of each of the
- categories of safety related hardware.
In sumary, the staff's review and evaluation of the program plan _ has included an assessment of the scope, methodology, and process for resolution of external source issues and a This self-initiated review has evaluat the construction adequacy and. quality at Comanche Peak. been broad in scope in that it has encompassed all disciplines being In addition, it has been deep addressed by the CPRT program plan. inasmuch as the staff has audited a number of the processes down to level In addition, the staff required the of inspection checklist preparation. CPRT to document the scope, methodology, implementation, results, and evaluation of each ISAP in sufficient detail to permit audit now and in c % the future.
TV 1/30/86 3 == SECTION 2.0 _1- $- MJ ?., W?=; . 2.0 EXTERNAL SOURCE ISSUES , oncerns regarding the adequacy of the CPSES construction QA/QC
~
- program and the adequacy of the constructed safety-related hardware 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 ("SSER's"), the NRC Staff's 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"). Collectively, these concerns are referred to as the " External Source Issues (ESI). The Quality of Construction and QA/QC Adequacy Program (QOC) was formulated by CPRT to respond to and resolve the External Source Issues. [ The 00C has two comporients to resolve and bound the safety-significant 1 implications of any ESI identified or found deficiency in either the hardware or the CPSES construction QA/QC program. These components are: First, the CPRT will evaluate each of the specific hardware and program-matic concerns raised by the External Source issues. It will determine the nature of any safety-significant hardware deficiencies and the cor-rective actions necessary to resolve them. Second, the CPRT will deter-mine the root cause of each discovered safety-significant deficiency (or trend of nonsafety-significant hardware deviations) and will analyze the generic implications of each root cause in order to determine the extent of any additional hardware that might be deficient for the same program-
~
matic reasons and to determine if changes need to be made in ongoing programs to prevent recurrence in the future. Implementation of the QOC program is by execution of Issue-Specific Action Plans (ISAPs). To assure that all issues / concerns from External Sources are addressed, CPRT will develop a matrix that provides a cross-reference
ZV 1/50/86 rD Q g .=. SECTION 2.0 -c-J=/ 0 gf g" between each issue / concern and the iction plan (s) that addresses it. This mitdix will also serve as an aid in the collective evaluation process. The matrix format will present information such that valid concern can be tracked to the appropriate criteria of 10CFR50, Appen-dix B, ano/or hardware area, and tracked to ~ the ISAP or DSAP -governing the concern.
- g. .
k i I
- n. _
- f. / El I r ationj I- " MIb .5 MS
.c ' 1 ~ :.. a m _. uen
"
- 1 I' t : .cA L6FCe 155ue I d c;. 4 L a 'ic_+3 O'l lhe f ollowing E::ternal Source Issue items have been identified in the Electrical and Instr umentation and Control area:
1.A.1 Class IE Heat Shrinkable Cable Insul ati on Sl eeves 1.A.2 Inspection Reports on Butt Splices 1.A.3 AMP Butt Splice Dualification 1.A.4 Agreement ~Between Drawings and Class IE Fiel d Terminatiens 1.A.5 Nonconformance Reports on Vendor Installed AMP Ternins2 Lugs 1.B.1 Flexible Conduit to Flexible Conduit Separati on 1.B.2 Fle::ible Conduit tu Cable Seperation 1.B.3 Conduit to Cab]e Tray Seperation 1.B.4 Separ ati on Barri er Mat eri al Removal a_- 3- 2 77 7- __ The CPPT Program Flan states that a portion of the E"ter nal Source h eurs are currentl y identified by ISAPs and DSAFs, and thst the Plan must include a complete listing of all E::ternel Source Issues to assure that the CPRT pr operl y addresses earh item E 1 J. Ia addition, an i r.t r r i e t s has been'estsblished between the design and construction CA/DC adequacy programs to sseure that c onst ructi on issues e-e identified in the dr. sign adequar.y pecry mi document revi en process [ 2 3. To accure that all
~~trrnal F c".ir c e Issues are capttred, a cross-reference mat'i: will 1.1 r '
jch issee with c spe:ific ac tion plan [ 3 J. _ , , , , , y .. ; e, ,,- m These CPRT Progran Pl an commitments appear sufficient to assure that e=.ch E::ternel Source Issue will be identified, tracked, and evslutted. The staff will moniter the implementstio'n phase to assure thtt each C:: tern +1 Source Issue has been captured by the program. Ot5er issues that may be identified during the implementation phases of the program plan will be pursued, and the results of .the staff evaluttien will be repcrted in a future repert. Similarly, the results of implementation of the CPRT Action Plan for the listed itens will be
~
dc cumented in a f uture results report. The staff will evaluate the implementation results as they become available. M . 2- 2 m c : _ _ _ __- - The CPRT Program Pl an commitments shoul d provic'e f or the ident:ficatitn and disposition of each External Source Issue during the implenentstion phase of the program. E 1 J TUGCO Letter CFRT-113, Section A, Item 3.3, page 23, 11/22/25. E 2 3 TUGCD Letter CPRT-113, Section A, Item 3.3, page 25, 11/22/S5. 3 J TUGCO Letter CPRT-113, Section A, Item 3.3, page 28, 11/22/85. CPSES Draft SER: Section B, External Source Issues, Electrical QA/DC Author and Date: L. Stanley, Zytor, Inc., rev. O, 12-27-S5 HSB: PAR 0004.DRO, page 1 l M
_ - - 1; uc !.^.
*2 ./."/ " t. 1 s Shrinkable N Insulation Eletver h C/.
o./. /. / .Zhdt>abe:E
- -at-chrintable r7 insuletion Hhcsier.'ec t are required f or unirmul?ted tutt
,plices, 480 volt and 6.9kv motor terminations, at cable reduction.
spJ i c es, end,a,t electrical penetration assembly cable connections. The f>PC concern centered on the lack of awareness by craft and inspecti on , perso,nel as to where the sleeves should be installed and the high
~
cercentage of mi ssed or i mp roperl y document ed inspections requiring witnessing. One specific action re:onnended was additional CC trspector trai n ng to ensu e thet heat shrinkeble sleeven wer e installed where re qui r ed. 2./.i. 2 4.2.Z.Z CPRT Approach ISAP 1.A.1 r evision 3 was issued on June 26,1C85 to address this concern, and the eveluati on process will use qual ity instruction procedure 01-003 E 4 3. Two activities have been committed; naaelv. (2) retraining of TUGCO craft and DC inspectors after revisions have been made to construction installation procedure EEI-8 and inspection l procedure 01-OP-11.3-28, and (2) initiation of a records review serp]Ing program to provide reasonable escurance that heat shrink &ble sleeves a E installed where reqtired. This records review sampling program will include systems important to saf ety. Each hardware instellation requiring the installation of e. heat shrinkable sleeve.will be visually inspected if the records review does
-not indicate that it was installed. In plant areas where cable redettion 83plices were not required but may nevertheless have been used f or x Yel ectrical terminations, 7 cables and 26 equipment components vill be visually inspected to confirm that reduction splices were not use:!.
Should any cable splices be detected f rom thi s exa.mination, the corresponding records will be reviewed to confirm the adequacy of installation documentation. Decision criteria regarding expencion of the records review sample sice are described in the Action Plen. 2././a3
- 1. _. _. e Staf f Eval usti on Based on the two activities committed in the Action Plan to provide a retraining af ter the applicable procedures are revised and to review cample of heat shrinkable sleeve installations, the steff believes that the Action Plan is adequate to resolve this External Source Issue. NRC personnel will review the implementation of the Action Pl an and precedure 01-003 to assure their adequacy.
JP /. / #L t'2-~" Con c l u si o n s The proposed Action Plan appears adequate to establish the accuracy and completeness of documentaticn records f o- the heat shrinkable. Fleeve External Source Issue. E4 J TUGCO Letter CPRT-113, Appendix G, Management Program Plan, Fi gure 3.3, Quality Instruction 003, " Procedure for Cl as.s IE Heat Shrinkable Cable Insulation Sleeves." CPSES Draft SER: Section B, External Source Issues, Electrical DA/DC Author and Date: L. Stanley, Zytor, Inc., rev. 2, 01-11-26 HSB: PAR 0004.DRO, page 2
1.2.2 E t ; n c.I E:_ cr Irruc 1 ^.2 h 1 'm t ; = . P = x = em Butt 5p1 ices [nspeckcy; kpm k (Z,q.2) 2/.2/i nsperti OC [n h6 ol0t* cn r ke-7? eports for 12 butt splices were found to be deficient in ene or more respects. Nine reports used a post-installation inspection form instead 'of a wi tnessing-type i nspecti on form. Six of these nine reports didfihdicale that installation of the heat shrinkable sleeves h@d been witnessed, but did not indicate thtt such witnessi ng was requi red. - The other three of these nine forms did not indicate that instellation of the spli ces had been wi tnessed. The remaining three recorts using the correct form indicated that witnessing of the inst allation cf heet sh-inhable sleeves was not appliceble (or required). The NRC recomnendation was that all OC incpections requiring witnessing f o-splices be performed and proper 1v documented, end that all butt splices be identified on design drawings and physically identified w: thin the appropriete penEls. 2./. 2 2 n- - .2 CFRT Approach ISAP 1.A.2 revision 3 was iscued on June 26, lo85 to address this concern, and the evaluation process will use quality instruction procedure 0I-002 E 5 J. A TUGCO phase i program cerf ~irned the s eli di t . O' the documentation problems noted by the NRC. The Action P3 r, pro ei ver e second phase commitment to determi7e whether the installed butt s p ? " c .: + src techr.i cell y eccept abl e, end if not, a third phase commitmer.t e:?! espsnd the inspectior to til Class 1E end associated circuits. the second phase, a review of all drawings and design change documents involving butt splices will be pcrformed to assure thet the splices are dh$)In
$$$kshown in design documents. From this document review, each effected CetIF will be inspected for cable splices relative to the FSAR Anendnert 44 commitment and the requirements of the Safety Evelusticn Report. PcIIcut tests will be perf ccmed on those butt splices rejected and replaced during the phase 2 evaluation. To assure completeness, the popu!stien of Class 1E control rocm cabinets will be inspected on a sample besis fcr the absence of butt splices.
If two or more butt splices from the phase 2 inspection a-e found tc be improperly installed, a phase 3 program will be ini ti eted to identi f y er.d inspect all other essentiel circuits where AMP insulated butt splices me,- have been used.
/ /.2. 3
- e. 2 _ z- z. Staff Evaluation The proposed Action Plan fails to make the connection between the phase i confirmation of documentation report deficiencies and the phase 2 review of design documentation in conjunction with an inspection of a semple of butt splices. The Action Plan implicitly suggests that:
E 5 3 TUGC0 Letter CPRT-113, Appendin G, Management Program Plen, Figure 3.3, Duality Instruction 002, " Inspection Report on Butt Splices." CPSES Draft SER: Section B, External Source Issues, Electrical OA/DC Author and Date: L. Stanley, Zytor, Inc., rev. 3, 01-12-86 HSB: PAR 0004.DRO, page 3
i (1) if none of the inspected butt splices are rejected,. pullout tests will- not be performed, and the population of butt solices will be presumed to be satisfactory. The documentation records will not be corrected f or. installation and witnessing aspects: i (2)' if one butt splice is rejected, it will be subjected to a pttilout test. If this test is satisfactory, the population , will be peesumed to be acceptable. The d:cumentation- records will not be corrected for installation arm witnessing, s.n d 3 (3) if more than one butt splice is rejected, .11 be.
;ati on recor ds subj ected to pullout testing, - but. the doct atnessing.
4 will-not.he corrected for installation enc In addition, the Action Plan does not comn.it to physically identi f y butt ! spl i ces ' wi thi n thc- panel s. The staff's preference is that butt splices not be used in Class 1E or , associated circuits except where absolutely necessary. If butt solices are used, the documented procedures and installation records shculd te correct and suf ficiently detailed to permi t any independent review .to confirm the technical adequacycof their use. Since the existing document stien re:ords have been unable to confirm their adequacy, the 4 staf f 's posi ti on i s that acceptability of butt splices must be demonstrated by other means. A suf fici ent amount of additional inspecti on and testing must be performed to clearly demonstrate the. technical
! adequacy of the butt splices'in order to overcome the present inadequacy l ,
of the documentation records.
. -4/ The proposed Action Plan docs not take this approach: ratter, it presu.te i that the butt splices'are satisfactory regardless of the state cf the j
documentation records. The Action Plan simply does not centain stificiert rigor to clearly demonstrate the adequacy of ~ installed butt splices."To overcome-this weakness, the Action Plan:should be revised to explicitly i 4 state how many butt splices w'ill be inspected and pullout tested. end how the documentation deficiencies will be corrected. In' addition, the i physical identification of butt splices must be addressed. 2./2 4C 5._ _.- Concl usi ons j The proposed Action Plan for this External Source Issue is unsatisfactor', i both in its approach and in the lack of quantitative commitments for , inspection and pullout testing of existing butt splices. CPSEG Draft SER: ' Section B, Enternal Source Issues, Electrical- OA/CC l' Author and Eate: L. Stanley, Zytor, Inc., rev. 3, 01"12-86 1 HSS: PAR 0004.DRO, page 4 } i I i , i L l 1
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2M./ Znfric/w r lim?.ted dm batir as dectribed in FSAR Amendmer.t 44, the practice e# tutt splicing cable conductors in panels has been permitted sub;ect tc: (1) sdequate brovisions in inste11ation procedures to verif y the , cp er abi li t y: of circuits using butt splices; (2) qualification of the wic= ' splices for anticipated service conditions, and (3) staggering of the sp12:es so thGt the/ are not adjacent to or pressing ageinst one snother in the same wire bundle. In additic.n. reinspection of all enist i r.g but t sp? l c.es was to be accomplished using adequate installaticn and :nspactice procedu es. Circuits ccntaining butt splices were to be tested, and retestcd if reworked. during plent preoperati onal and startup tssis to essure their operability. 2./4 2. t .. ._ CPRT Approach ISAP 1.A.3 revisic.n 3 was issued June 26, 1983 to address this conce-n. and the es alvati on process will use quality instruction procedure DI-002 [ 5 3. In revision 3 of the CPRT Program Plan, the ISAP was to be revised to reflect construction 'and inspection procedures, a craf t trai r.i r.g lesson plan, and formal classroom training C6 3. Construction procedure EEI-8 will be revised to require a conti nui ty check of all circuits containing butt splices and an inspection o# butt sp12ces to assure that they are staggered or separated. Inspectior procedure OI-DP-11.3-28 will be revised to require that the " circuit d[3 continuity checks be mede and thet the splices be inspected for adequsts ((([ separation. Inspection of adjacent butt splices within panels is included as e part of ISAo 1.A.2. The acceptance criteria requiret that no splice touch another splice, and the configuration of wire bundles will be corre:ted where splices are pressing on one another. A qualification dets package will be assembled, reviewed, and approved for the butt splices used in the panels. 2./d. 3
^ .iu i Staff Evaluation j The Program Plan commitment to inspect all butt splices in various panels to assure that no butt splice touches another one wi' thin a wire bundle.
and to rework splices in nonconf orming wire bundles is responsive to the butt splice separati on concern. Preparation and issue of a qualification data package for the butt splices for their service conditions is deemed to be adequate. Except for its proposed method of testing butt splice circuits, the plan to' revise construction and inspection procedures and conduct training sessions for craft and inspection personnel is appropriate. l E 5 3 TUGC0 Letter CPRT-113, Appendin G, Management Program Plan, Figure 3.3, Duality Instruction 002, " Inspection Report on Butt Splices." l' E63 TUGC0 Letter CPRT-113, Section B, page 32, " Butt-Splice' Dualification." CPSES Draft SER: Section B, External Source Issues, Electrical OA/DC ! Author and Date: L. Stanley, Zytor, Inc., rev. 2, 01-11-86 HSB: PAR 0004.DRO, page 5 1 a
Circuit continuity checks proposerj in the Action Plan to test Dutt splice c2rcuits use a very small current value that is unlikely to be s representati .e of actual circuit current values when system functional l tes t s are perf c: med. Hence, the Action P1an should either justify the vs.e
?f ci-cuit continui ty tests in lieu of actual circuit current values or should be modified to use actuel circuit values that would be present during pr eope?ati ons1 and st a;-t op tests.
2./.3 4 - _
- _ 4.e Concl usi ons
- The proposett Action PJan fer tutt splice qualificaticn is adequate to cddress this E::ternal Source issue provided that f uncti onal operability I cf there circuits containing butt splices can be demonstrated by t5c prcposed use of circuit conti nui ty checks.
l CPSES Dreft SER: Section B, En t er nal Source 1ssurs., Ele:tricel 04/QC Aci.her and Dste: L. Etanley, Zytor, Inc.. rev. D. 01-11-E6 HSB: PAR 0004.PFO. pace 6 Om S l
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- 2. /-[ 2- CPRT Approach
...L.2 ISAP 1.A.4 revision 3 was issued June 26, 1905 to addrers this ccnce n.
end the evaluation process will use quali ty instruction procedure CI-00' [ 7 3. The sit. cables identified by NRC were reinspected with the f ollowi ng resul ts: (1) three cables were correctly terminated, but the drawings were in error regarding conductor color code details. All three drawing errors were subsequently corrected; (2) or.e cabl e had two conduct ors i nterchanged, bst this would nct affect proper circui t operati on. The conductors have nos been 4 changed to conform to the current drawingt
~7 (3) one cable was designated as a spare, but the design change authorization was found to be incomplete. This cabl e wes subsequentl y deleted f rom the interconnection drewing. and (4) one cable had spare conductors terminated even though wiring on the vendor side of the terminal blocks had been remosed.
Thes.e spare conductors have been removed from the terminel . blocks. The Action Plan states that a sampling inspection will be developed t o" reinspect cable terminations versus current drawing requirements in Class 1E safe shutdown circuits that interface with the alternate shutdown panel in the Unit I control room and caole spreading room. Sefe shutdovn circuits comprise approximately 27% of all Class 1E terminations in these rooms, and a random sample of 300 terminations will be reinspected to an acceptance criter.<a of ero errors. Enpansion of the sample size up to e manimum of 3812 terminations will result if one or mere terminatien errors are identified. Should more than f ourteen errors be detected, ell Class 1E end associated terminations in Unit 1, Unit 2, and common will be reinspected.
~
[ 7 3 TUGCO Letter CPRT-113, Appendin G, Management Program Plan. Figure 3.3, Duality Instruction 001, " Procedure for Class IE Cable Terminations Inspection." CPSES Draft SER: Section B, Enternal Source Issues, Electrical DA/DC Author and Date: L. Stanley, Zytor, Inc., rev. 4, 01-13-86 HSB: PAR 0004.DRO, page 7 r
2./.4 3
.2.i T Staff Eval uati on TUGCO .hes provided reinspection results of the conductor termir.stien errors for si:: cables identified by the NRC staf f. The proposed Action Pl an f or a reinspection sample of 300 terminations in Class 1E circuits
! with an acceptance criteria of no errors is responsive to the NRC concern. E::pansion of the sample to all safe shutdown terminations, and to all Class '1E terminations at the Comanche Peal Station is also ; provi ded by- thi s plan. 2./44
...L.0-Cont]usicns i
The TUGCD reinspection results of conductor termination errors for s i :, tabl es identified by the NRC staff are satisfactory. The proposed Action i Plan to reinspect a minimum of 300 terminations for conformanco to current drowing requi rement s is adequete f or thi s E::ternel Source Issue. The proposed ecceptance criteria for sample sire e::pansion appear satisfactory for this concern. CPSES Draft SEP: Section B. E::ternal Source Issues, Electrical DA/CC Author and Da.te: L. Stanley, Zytor, Inc., rev. 4, 01 Ef 6 HSB: PAR 0004.DRO, page S 2s i 4 I
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f./f,/ _Zn~ yychkgy, l Tab m G2::tec n nonconf ormence report s issued in early April !?94 documented ccndi tion degcribed by all egation ADE-36 involving vendor installed AMP terminal logs in ITT Gould-Brown Boveri 6.9 Ev switchgear. Terminal lugt described 1p thesE nonConf or mance reports were bent in the arei. bCtwef} - the ring and barrel either in excess of 69 degrees or were twisted. The initial acceptance criteria f or bending of the terminal lugs was 60 a degrees, end was modi fied by the terminal lug manufacttrer to pe-mit one time bend up to 90 degrees and that lugs bent to 120 degrees might ts ecceptab} e dependi nD on an end user engineering evaluation. These acceptance criteria were subsequently changed by the manufacturer tc be t wo bends up to 43 degreen, one bend up to 90 degrees, and dependent cn an engi necring evaluation f or bends between 90 and 120 degrees. No criteri e were stated f or twisted terminal lugs. The NRC concerns centered on the "use-as-is" dispecition of the nonconformance reports in that engineering evaluations had r.ot been performed and the suitability of twisted terminal legs had not been addressed. A reevaluation and redisposition of each nonconf o:~mance r epo-t was requested taking into account both bent and twisted termina! Jugs End the documentation of engineering analyses to justif y any "as-is" di s p osi ti ons. 2./E 2-
*. .e.2-CPRT Approach L~2 ISAP 1.A.5 revision 3 was issued on June 26, 1985 to address thi s
({4 ~ concern. An examination was.made of the terminal lugs identified in ths nonconformance reports, and it was determined that the bend angle ranged between 60 and 90 degrees. These nonconformance reports were end dic' dispositioned rel ative to the manuf acturer's re vised criteri a, not require an engineering evaluation. The proposed Action Plan makes a commitment that the nonconformance term 2rd reports will be redispositioned to more cles.rly stete the actual lug bend and twist condition and will provide an engineering justification for any "use-as-is" dispositions. In~ addition, AMP will be requested to provide a documented analysis to support the change from the initial 60 degree bend to the present 90 degrees bend acceptance criteria, and will include an evaluation cf twisted terminal lugs. Any lugs that cannot be justified based on AMP criteria will be repl aced. The action plan also identifies Mil. Spec MIL-T-79286 as a source of acceptante criteria f or both bent and twisted terminal lugs. CPSES Draft SER: Section B, External Source Issues, Electrical CA/DC 4, 01-13-96 Author and Date: L. Stanley, Zytor, Inc., rev. HSB: PAR 0004.DRO, page 9 9 - _ ~~ ~' - -_
2*/S. 3
.~_.i.T Etaff Evaluation The proposed action plan commits to a fincI rsevaluation and redisposit2 cn of the nonconf ormance reports f or the previously identified terminal lugs using acceptance criteria for bending and twisting to be-Improv be feveloped by the manufacturer. terminal. lug and justification f or "use-as-is" dispositions w each provided.
The. manufecturer's analysis of acceptable bend Review and twist Team. values The actiog will be reviewed and approved by the Electrical pl an acceptan'ce criteria states that conf ormance with an applicabl e Military Specification will also be accomplished. Any terminal lugs not in conformance with these criteria will be replaced. 2/E 6 Conclusions e._.c.- The proposed Action Plan appears to be adequate ir that definitive AMP terminsi
- acceptrnce criteria f or acceptable bending and twisting and each nonconformance report will be of lugs will be established, reevalueted to these criteria.
CPSES Draft SER: Section B. External Source Issues, Electrical OA/CC Stanley, Zytor, Inc., rev. 4, 01-12-86 Author end Date: L. HSB: PAR 0004.DRO, page 10 y i e 1 9
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s t_ - 21 1 _ m 1.E.: 2./.. .6F F1enible Cond_..t tasmS84pEEEEisisuussetut' Sep ar ati on [f. h. /) a. 2./4 Industry / Z%rha/w Am as IEEE Std. 384-1974, have established minimum criteria, such separation distances to be maintained between redundant safety-related cables and between safety-related and non-safety-related cables within control r:com panels and cable. spreading room termination cabinets. . Lesser separation distances mey be justified if supported with engineering : analyses of the invol ved circuits ar.d components. The Techr.ical Revi ew Team observed that flexible conduits containing saf ety and non-saf ety cables within there panels were in direct physical contact. end could rm' find evidence that analyses had been perf ormed to justi f y this devi ation from requiremer.tc in the industry standards. Wi thi n mein control room panels, for example, flexible conduit identificd with one separation division (orange color) has been bundled together with fle::ible ccnduit identified with the redundant separation divisic' (green color). In this instan:e, E tschnical justification for the lect of one inch sep?r ati on distance between redundant conduits containi ng safety-related circuits has not been provided. A reinspection of all panels containing redundant safety-relsted condrit or both sef ety-related and non-saf ety-related conduits was requir ed to either correct each violation of the separation criteris or to dem nstrate by analysis the acceptability of the' conduit as e ba-ris' 2/62 . 4E25%?L CPET Approach b. 47E; ISAP 1.B.1 revision 3 was issued June 26, 1955 to address this cor cern.h "I and the evaluation process will une quality instruction procedurs CI-C i E8 3. The Action Plan includes a review of Gibbs and Hill seperatier. criteria and inspection procedures f or condu t installeticr. E9 3. Physical tests will be conducted on the SERVICAIR flenible conduitbasis under design used in the panels'to evaluate its. adequacy as a berrier short circuit or overload conditions. A c'etailed seperation enal ysis wil! be performed of the main contr ol room panels and vertical panels. and will incl ude cables to control switch modules, instrument controllers. meters, indicators, recorders, cathode ray tubes, . indicating lights, and the annunciator. Inspections of these panels will be performed to en'sure
; that required separation distances have been attained, and that berri ers have been installed where required. If the tests and analysis results do not qualify SERVICAIR conduit as a barrier, the cable installation within
( the panels will be modified either to achieve acceptable separation distances or to install appropriate barriers, and the ef f ected drawi ngs will be revised to reflect the final configuration. E 8 3 TUGCO Letter CPRT-113, Appendix G, Management Program Plan, i Figure 3.3, Quality Instruction 004, " Flexible Conduit to Flexible Conduit Separation Action Plan." l E 9 3 TUGCO Letter CPRT-113, Section B, pages 33 and 34,- " Flexible Conduit to Flexible Conduit Separation Action Plan. " i
.I CPSES Draft SER: Section B, External Source Issues, Electrical DA/DC 4, 01-13-86 Author and Date: L. Stanley, Zytor, Inc., rev.
HSB: PAR 0004.DRO, page 11 k x
Tc.1 teoposed Action F.or m' : s acceptanto criteria for the quzlif:cetion tests on EEFNICATR ccaduit and f or the inspection of installed conduit relative to the final separation criteria to be de vel oped by Gibbs and Hill. 2./.4.3
=.Z. .5-Staff Evaluation The proppsed Action Plan requires conformance of internal panel cabl>s and conduits to applicable industry separation criteria by ach2 eveme'nt cf minimum separation distances, installed barriers, c' by appropriate engineering analyses of the actual installation to justif y lesser sepcration distances.
Dualification testing of SERVICAIR flenible mete.1 conduit as a suitst'e barrier fcr redundant safety-reltted cables and for sefety te non-s.=fet, tables will be performed. Detailed analysis of the separation provisirnt Ins. tall ed in main control room and vertical panels, and inspsetion of installed SERVICAIR condui ts relative to final separation criteria is committed. If tne installed conduits do not satisfy the finel sepsrat:cm criterie, the inst alled cables and conduits will be modified to esser e the echievement of minimum separation distances or the Installation cf barr2ers. Draw 2ngs will be revised to reflect the final configuretion. The Staff notes that for a similar configuration at the Shearon Herris Nuclear Power Plant, Westinghouse has analyced the effect of each ef f ected circui t within flenible conduits in the main control room panels. This analysis demonstrated that no Class 1E circuit waald be degraded belcw a minimum acceptable level due to the direht contr.ct c3 one flexible conduit with another in these panels. A similar analysis J: the demonstration of applicability of the SHNPP anelysis to Comanche il Peak, is anticipated. 2 / 4 4-
- Conclus: ens i The prcposed Action Plan is responsive to the External Source issue o' adequate separation of flenible conduits in main control room pr.nels O
vertical panels. However, the Action Plan does not specifically addies_ achievement of minimum separation distances at the cable spreading re:S termination cabinets or at instrument racks located throughout the pis-t. Hence, the Action Plan should be modified to include all Class 1E penelr. cabinets, and instrumentation racks. CPSES Draft SER: Section B, Enternal Source Issues, Electrical DA/DC Author and Date: L. Stanley, Zytor, Inc., rev. 4, 01-13-86 HSB: PAR 0004.DRO, page 12
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2.t. z 7 Fl e.: 1ble Conduit im Cable Separation [T. h . 2 ) OM 2/. Thi s7/particular In1%dxNRC &mconcern is similar in many respects to External Source Issue 1.B.1 regarding the accomplishment of minimum separation distances between flexible conduits within main control room panels and vertical pa:hel s. In Enternal Source Issue 1.B.2, the Technical Review Team identi-fi'ed twenty-one cables within f our panels where the minimum separation di. stance of 6 inches specified in industry standards had not" been maintained relative to SERVICAIR flexible metal conduits containing safety-related cables. NRC required that a reinspection be performed of main control room panel s, other panels located in the control room, and panels located 2n other areas of the plant where tables and flenible conduit had been used. TUGCO was requested to either correct any separation criteria violations in these panels or demonstrate that the flexible metal conduit was an adequate barrier in accordance with IEEE Std. 384-1974. If the flenible conduit could not be shown to be a suitable barrier, a minimum separation distance of 6 inches was to be maintained between cables and flexible conduit within the panels. In addition, drcwings and related documents were to be revised to indicate the revised minimum separation distances. 4? / 7 Z h i f CPRT Approach ISAP 1.B.2 revision 3 was issued June 26, 1985 to address this concern. cnd the evaluation process will use quality instruction procedure CI-004 m s E 10, la 3. The Action Plan states that SERVICAIR flenible metal conduit jwill. be qualified as a barrier by test or analysis and that Unit i s_)sceparation deficiencies will be corrected through inspection nonconf ormance reports as part of Action Plan 1.B. I. Unit 2 installation procedures and the post construction inspection program will ensure that geparation requirements are met for this plant. The Action Plan provides acceptance criteria that are equivalent to those provided for Enternal Source Issue 1.B.I. 2/.73
.2.5.9 Staf f Evaluation The proposed Action Plan provides for reinspection of panels containin,g cables and flexible metal conduits to determine if the separation criteria have been met, qualification of the SERVICAIR flexible metal conduit as a barrier, installation of barriers or achievement of 6 inches neparation if the SERVICAIR conduit cannot be qualified as a barrier, relocation of cables to assure that cables are not in direct contact with the SERVICAIR metal conduit, issue of nonconformance reports for ceparation violations in Unit 1 panels, and inspection of Unit 2 panels for conformance with the separation criteria.
E 10 3 TUGCO Letter CPRT-113, Appendix G, Management Program Plan, Figure 3.3, Quality Instruction 004, " Flexible Conduit to Cable Separation Action Plan." E 11 3 TUGCO Letter CPRT-113, Section B, pages 35 and 36, " Flexible Conduit to Cable Separation Action Plan." CPSES Draft SER: Section B, External Source Issues, Electrical DA/DC Author and Date: L. Stanley, Zytor, Inc., rev. 5, 01-14-86 HSB: PAR 0004.DR1, page 13 Y, - n , *
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._.E.- Conclusions The proposed Action Plan is adequete for assuring compliance with minimem separation requirements for main control room panels and vertical panel s.
This Action Plan, however, does not e::plicitly address panels located in the Unit 1.and 2 common areas nor the revision of drawings and related
- documents to specify the final separation criteria being developed by Gibbs and Hill . The Action Plan should be expanded to address other panels in Unit 1, Unit 2. and their common areas, and to provide a commitment to revise drawings end other documentation as appropriate.
CPSES Draft SER: Section B, External Source Issues, El ect r i c e.1 DA/DC Auther and Date: L. Stanley, Zytor, Inc., rev. 5, 01-14-86 HSS : P AF.0004. DR 1, page 14 t e
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~'. minimum e <kd*?? distance of one inch between an enclosed rigi d U / 3 ? b separation conduit and open ladder type cable trays was established by Gibbs and Hill in specification 2322-ES-100; however, the~Gibbs and Hill anelysis supporting th2 s sep aration criterion was neither ref erenced in the FSAR * -
nor reviewed by the NRC f or acceptability. IEEE Std. 384-1974 requires the installation of a barrier between a conduit and an open cable are tray g unless greater minimum seperation distances are maintained or otherwise justi4ied by an engineering analysis. The Technical Peview Teem requested that the Gibbs and Hill analysis supporting the one inch in sufficient detail to separation distance be submitted f or. NRC review permit an independent evaluation of the establishment of this criterion. 2/.82 50-CPRT Approach ISAP 1.B.3 revision 3 was issued June 26,~1985 to address this concern, cnd the evaluation process will use quelity instruction procedure CI-004 E 10, 12 J. The proposed Action Plan commits to a review of the Gibbs and Hill analysis of this separation criterion in conjunction with a (SAND 77-1125C), and supporting Sandia report on Cable Tray Fire Tests its submittal to NRC following approval by the Review Team Leader end a third-part'y consultant. In addition, the Electrical Review Team will review nonconf ormance reports and inspection reports applicable to this External Source Issue. If compliance with IEEE Std. 394-1974 cannot be drmonstrated, conduits and cable trays will be modified to as'sure
" ompliance with the standard.
U./ ?.3 M M 1 5taff Evaluation The proposed Action Plan commits to compilation, review, and approvel of the appliceble documentation to support the one inch minimum separation distance between rigid conduits and open. cable trays, and submittal of this material f or NRC independent review. Compliance with the separation requirements of IEEE Std. 384-1974 is committed either by this of the modificetion Engineering justification analysis or by physical conduit and cable tray installations. A?A $ 4L 2: 2. 0. - Conclusi ons The proposed Action Plan is responsive to this External Source Issue. NRC review and approval of the engineering justification analysis is required. If the analysis does not justify the. minimum separation distance, the Action Plan should be expanded to provide for drawing and other documentation revisions to reflect the various installatico configurations. C 10 3 7UGCO Letter CPRT-113, Appendix G, Management Program Plan, Figure 3.3, Quality Instruction 004, " Flexible Conduit to Cable Separation Action Plan." E 12 3 TUGCO Letter CPRT-113, Section B, page 37, " Conduit to Cable Tray Separation Action Plan." CPSES Draft SER: Section B, External Source Issues, El ectri cal DA/DC Stanley, Zytor, Inc., rev. 5, 01-14-86 Author and Date: L. HSB: PAR 0004.DR1, page 15
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'uringV* the/ Dhecbe Technicalt/m Review Team inspection of auxiliary feedwater panel
_P3-EC-PRCB-09, two barriers used to separate redundant devices and cables were,found to be missing. Within panel CP1-EC-PRCB-03, field wiring was not separated by the minimum separation distance of 6 inches, NRC required 'that a barrier be installed in panel'CB-00 to separate redundant flow and pressure instruments, and that field wiring in pang [ CB-03 be separated by the minimum distance or by an installed barrier. E /.V 2-4._.:v x CPRT Approach ISAP 1.B.4 revision 3 was issued June 26, 1985 to address this cencern. and the evaluation process will use quality instruction procedure 0I-004 E 10, 13 J. The Action Plan commits to the re-installation of the barrier material in the auniliary feedwEter panel and the reworking of field cables in the other panel to resolve the identified separation violations. Nonconformance reports will be issued f or these violations. snd maintenance procedures will be revised to ensure that separation ' requirements are met f ollowing modification or maintenance acti viti es. As a part of Action Plan 1.B.1, physical inspection of other main centrol room panels and vertical panels will be performed to identify &ny other undetected separation violations. 2 !'?] 4FOr l i ; Staff Evaluation QThe proposed Action Plan commits to correction of two identified
- rparation violations, revision of maintenance procedures to ensure compliance with separation requirements, and the physical inspection of other control room panels for undetected separation viclations. The Action Plan states that compliance with applicable industry seperation criteria will be achieved.
2/96 A T_ii-4 Conclusiens The proposed Action Plan is responsive.to this External Source Issue Jor main control room panels. To assure that existing separation violetions have been detected in a timely _ manner, the physical inspection portion c4 the Action Plan should be expanded to include the cable spreading room termination cabinets and safety-related instrument racks located throughout the plant. E 10 J TUGCO Letter CPRT-113, Appendix G, Management Program Plan. Figure 3.3, Quality Instruction 004, "Flexi ble Conduit to Cabl e Separation Action Plan. " [ 13 J TUGCD Letter CPRT-113, Section B, page 38, "Berri e r Removel . " CPSES Draft SER: Section B, External Source Issues, Electrical DA/DC Author and Dater L. Stanley, Zytor, Inc., rev. 5, 01-14-86 HSB: PAR 0004.DR1, page 16 1 i M
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-1 SECTION 2.2 g %
f/b.+ -e { M 72 QA/0C Issues (( ' . The QA/QC issues are the identified concerns which resulted from the TRT QA/QC group's assessments of allegations pertaining to the QA/QC Program at Comanche Peak. These issues were initially presented to the Applicant by letter from the NRC dated January 8,1985 and the detailed assessments were ublished in NUREG 0797 Safety Evaluation Report Supple-mentyll hat wa issued in May 1985 (reference Appendix 0, Pages 0-277 f through 0-303). s h Additionally;SER11containsan ppendix P (reference Pages P-1 through P-56) which presents the result of the TRT QA/QC Group's integrated evaluation of the QA/QC issues identified in Appendix 0, together with those QA/QC issues which were either; specifically referred to the QA/QC p:b Group by other TRT groupj or, implied in each of the assessment's presented in the Appendices to the SER Supplements 7, 8, 9 and 10. {y Since the QA/QC issues arose from sources other than the CPRT (e.g. 5SERs, CAT, SIT, R IV inspection reports, etc.) it has become common terminology to refer to them as external source issues. Under the Program Plan, Appendix B, Quality of Construction and ' QA/QC Adequacy Program Plan, the CPRT developed iss'ue specific action plans to address and resolve the QA/QC issues related to construction adequacy. (Reference Appendix B Attachment 1). As the CPRT determines it appropriate to the specific' issue being considered, each of the listed ISAPS will employ one or more of the following evaluative approaches: re-inspection of hardware, review of hardware documentation, walkdown inspec-tions, data collected from other CPRT review team action plans, engineer-ing review and analysis, and review and verification of TUGC0 corrective acti plans. pg g Also under Appendix B, the CPRT issued a self initiated QSAP) and documentation review plan. The F VII[, construction reinspection f o.
IV 1/31/86 SECTION 2.2 . Program Plan defines the interaction of the results of the iimplementation of this Plan (VII.[) to assist in the resolution of QA/QC issues addressed in other action plans. The Program Plan further states that to ensure that all issues are identified including these listed in SSER-11 Appendix P, the CFRT, in an ongoing activity, is reviewing external source documents and developing issues tracking matrices that provide a cross reference between each issue / concern and the action plan (s) that address it. During imple-mentation of the Program Plan, the Staff will review these matrices to ensure compliance with the Plan, that any required interfaces have been performed, and that the issues identified in SSER-11, Appendix P, are i identified and listed in the matrices. The staff's evaluations of each of the action plans that address the QA/QC issues related to the construction adequacy program are pre-sented in the following sections of this report.
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IV 1/31/C6 SECTIONS 2.2.1 and 2.2.2 . 2.2.1 QC Inspector Qualifications (I.d.1) 2.2.1.1 Introduction This ISAP addresses the validity of the train-ing, qualification, certification and recertification in accordance with project procedure and FSAR comitments for all electrical QA inspectors, all current ASME inspectors and current non-ASME inspectors. 2.2.1.2 CPRT Approach p' Accenn
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The Plan defines a three-phased approach which will review inspector qualification documentation for compliance with pro-ject documents, Codes, and standards which were in place at the time of the inspector's certification. This review will be conducted by an au'dit group A using prepared checklists and the results overviewed by a special evalua-E- tion team. The Plan provides for reinspection of a sample of work com-pleted by those inspectors whose qualifications could not be verified. The Plan identifies implementing procedures, standards and acceptance criteria and describes its interface with ISAP I.d.2 " Guidelines for Administration of QC Inspector Tests" and ISAP VII.c " Construction Reinspection / Documentation Review Plan." The action plan results report will contain a , conclusion regarding the impact of the remaining work on Unit 2 and the operations QA/QC program. , i, 2.2.1.3 Staff Evaluation i The staff has evaluated the Plan methodology, reviewed the checklists to be used in its implementation and verified the accuracy of the interface requirements with other identified action plans. l TheTlan addresses a review of the qualifications of all current inspectors; l and by its interface with the results of ISAP VII.c will provide a conclu-sion regarding the impact of the quality of construction which may have l l i i
Iy 1/31/86 SECTIONS 2.2.1 and 2.2.2 resulted from the work of inspectors whose qualifications were' found to be .
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questionable. This evaluation finds that the Plan will deter-mine the acceptability of QC inspector qualifications in compliance with standards and acceptance criteria in place at the time of certification of the inspector. The FSAR comitment includes: CPSES QA Program Require-ments, Regulatory Guide 1.58, Rev.1. ANSI N45.2.6-1978 and ASME/ ANSI Code ! requirements. l
" 1 2.2.1.4 Conclusion The Plan adequately addresses the NRC's concern pertaining to QC inspector qualifications and adequately describes the evaluation process that will resolve the issue and enable a conclusion regarding inspector qualifications in compliance with the stated FSAR com-
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mitments. Accordingly, the staff concludes that this ISAP is acceptable. l l I 2.2.2 QC Inspector Test Administration (I.d.2) l 2.2.2.1 Introduction
- This ISAP addresses guidelines and procedural
; requirements for the testing and certifying of electrical QC inspectors.
2.2.2.2 CPRT Approach Although the specific issue primarily addressed the training and certification of electrical inspectors, the CPRT in-creased the scope of this Plan to include all QC inspectors. The Plan j
' describes a three-step approach as follows:
(a) Step 1: A [pecial [ valuation [eam (SET) will i evaluate the adequacy and acceptability of the pro-l l l l l
O IV 1/31/86 SECTIONS 2.2.1 and 2.2.2 ject procedures - that control the structuring and
- ~ administration of tests and provide recommendations for improvement of the procedures.
(b) Step 2: The CPRT will forward the SET's findings to TUEC for procedure revisions in accordance with the SET recomendations. All inspector certification exams currently in use will be reviewed and revised, appropriate, to comply with the revised as procedures. (c) Step 3: The CPRT will conduct a review to determine whether other improvements should be made to the training program. Utilizing the results of implementation of this Plan, ISAP I.d.1 and VII.c g will enable the QA/QCMTL) to reach a conclusion regardingQCinspectorltestingpractices.
'/EsureJ Nx+1/fxDF/2 2.2.2.3 Staff Evaluation This evaluation finds that the Plan methodology describes the process whereby the CPRT will assure that TUGC0 has provided '
- adequate procedures to implement and control the training and testing program for QC inspectors. Additionally, this evaluation verified the existence of an interface with ISAPs I.d.1 and VII.c.
2.2.2.4 Conclusion The Plan methodology adequately describes the 'l evaluation process that will ensure that the QC inspector testing program l* is % compliance with project procedures, regulatory requirements and FSAR . comitments. Accordingly, the staff concludes that this ISAP is accept- ) able. l l l I
6 n SECTION 2 2.3 Gee b DRAFT % This cocid rep!" a MCTE:; Th h :hculd logically be 'r.scrted cfter 2.2.2.
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2.2.3 Craft Personnel Training (I.d.3)
- 2. 2.3./ Introduction [?
The objective of this ISAP is to evaluate the Craf t Training Program to determine if it was adequate in the past, and also to
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evaluate the current program. J d.d. 2-CPRT Approach The requirements of ANSI N45.2-1971, set forth in part, that personnel performing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and main-("# tained. To determine that these requirements are implemented, this ISAP has formulated a Special Evaluation Team (SET), comprised of individuals with no direct responsibility to CPSES, who will perform the evaluation of the Craf t Training Program including the craft personnel selection, train-ing, assignment and retraining. The following items will be considered during the SET review: i
- How requirements for craft skill levels are estab-lished.
- How craft personnel (when selected and while on assignment) are determined to meet the skill and per-formance requirements.
- How craft personnel classifications are established for crew loading.
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- How craft personnel become aware of changes in design and construction requirements and how retraining occurs.
- How craft personnel are informed and become knowl-
> edgeable of QA/QC requirements / criteria and changes to those requirements / criteria.
- How management is assured that the craft personnel selection, training, assignment and retraining pro-gram complies with project requirements.
- How supervisory personnel are selected and trained.
- How background of education and experience 'of craft g
personnel is verified and documented. [ The SET evaluation will be accomplished through reviewing those craft procedures that were in existence, interviewing craft person-nel, and observing training and field activities. Craft personnel will be. interviewed, from the general superintendent / building manager level to the craft level including the following disciplines: icechanical, civil coatings, electrical and paper-flow group to determine how craft personnel were selected and trained. Treinirg and field activities will be observed to deter-mine if adequate training is provided and to evaluate how well the craft personnel performed in the field after training has taken place. Based on this review, conclusions will be drawn by the QA/CC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are
4 IV 2/5/86 SECTION ; determined to be inadequate, recomendations for improvement will be pro- i i vided'to TUGC0 prior to the closure of this action plan. The decision criteria detailed in the Plan provide that the results of inspections conducted during the implementation ISAP VII.c will provide an indication of the adequacy of hardware construction. This information will be categorized by major discipline, e.g, 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, recomendation will be provided to TUGCO. IEU Staff Evaluation This evaluation finds that the CPRT approach will ~ provide a broad-scope in-depth evaluation of the essential elements of the train-ing program and will determine the effectivness of both past and current f training and its impact on the construction of the. physical plant, and compliance with ANSI N45.2.6 and 10CFR50, Appendix B, Criterion II, as I comitted to in the FSAR. i The staff finds, however, that Section 4.4, Procedures, i 1 does not comply with the Program Plan, Attachment 3, ISAP format, which j requires that existing procedures be referenced. 2.'2.7. V Conclusion
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The staff's evaluation finds that the ISAP adequately addresses the NRC's concern pertaining to craft training, 'and implemen-tation of the plan will determine compliance with FSAR comitments. Accordingly, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished. 1
IV 1/31/86 _g SECTIONS 2.2.5, 2.2.6, 2.2.7 .
- - 2.2.5 Material Traceability (VII.a.1) 2.2.5.1 Introduction This ISAP assesses the adequacy of the material traceability control systems implemented during construction. It also evaluates all NRC, TRT and SSER findings relating to material traceability that are not covered in other action plans.
2.2.5.2 CPRT Approach The Plan methodology describes a seven step ap-proach to resolution of the issue as follows:
--- (a) Interface with ISAP VII.c to ensure that reinspec-
# tions verify material traceability.
(b) Evaluate the TRT's findings regarding failure to maintain material traceability as identified in the October 1981 ASME Code survey. (c) Review and identify all SSER findings (including , Appendix P) relating to material traceability and verify that action is being taken to resolve the finding. Develop action plans if necessary. (d) Review the results of ISAPs VII.b.3 and VII.b.1 to verify that material traceability concerns for pipe supports and site f abrication chop activities have
; been addressed.
- (e) Review the results of Action Plan VII.c as they
- apply to material traceability and review the re-suits of the remainder of the action plans for any
' impact on the overall evaluation.
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IV 1/31/86 U SECTIONS 2.2.5, 2.2.6, 2.2.7 -_ _ I.5 (f) Collectively evaluate the results of the above to [_ identify programatic deviations which require cor-rection of procedures for Unit 2 and operations and ; i areas of hardware which require further evaluation because of programatic weakness. 1 (g) Prepare an action plan results report which ad-dresses the overall adequacy of current and his-torical material traceability controls. 2.2.5.3 Staff Evaluation The staff's evaluation finds that the descriptive methodology will adequately address the resolution of concerns regarding material traceability. In addition, to assure the identifica-g tion of all issues, Appendix B of the Program Plan describes the develop-ment and utilization of issue tracking matrices that identify the issue, the source of the issue and the action plan that addresses it. 2.2.5.4 Conclusion A review of the Plan's methodology that describes the evaluation process and the interface with'other action plans finds that the implementation of this Plan adequately addresses resolution of the NRC's concerns with material traceability. Therefore the staff I concludes that this ISAP is acceptable. 2.2.6 Corrective Action System (VII.a.2) l i k 2.2.6.1 Introduction This ISAP evaluates individual NRC, TRT and SSER l findings and provides a comprehensive evaluation of the CPSES construction l site nonconformance corrective action and 10CFR50.55(e) reporting system. I 1 l l l
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O CTIONS 2.2.5, 2.2.6, 2.2.7 . Beca[useofthecloseinterrelationshipofTRTconcernsinvol'vingthenon-conformance systems, the corrective action systems, and the 10CFR50.50(e) reportability system, all identified issues will be addressed under this one Issue-Specific Action Plan. 2.2.6.2 CPRT Approach Because of the differing complexity of the three systems being evaluated, the methodology for the evaluation of each will vary somewhat. For the nonconformance systems, all the various methods (populations) of documenting nonconformances will be identified. Popula-tions will be reviewed to determine if nonconformances were properly pro-cessed and resolved. In addition, the procedures applicable to the selected nonconformance will be reviewed for compliance with 10CFR50 Appendix B and PSAR/FSAR requirements. I For corrective action systems, applicable site procedures will be reviewed for adequacy. This procedural review will be followed by a review of the implementation of the site corrective action systems. Also, a detailed review of the trending system, both procedures
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and implementation, will be conducted as part of this evaluation. i The approach for evaluating the 10CFR50.55(e) reporting system is similar to that for corrective action. Applicab~le { procedures will be reviewed for adequacy followed by a review of the
~ ! implementation of the 10CFR50.55(e) reportability system.
i The results of the evaluation of the noncon-formance system shall be utilized in the evaluations of the corrective action and 10CFR50.55(e) systems. The results of the evaluation of the the corrective system will be considered in the evaluation of i 10CFR50.55(e) system. 2.2.6.3 Staff Evaluation l l
/86 SECTIONS 2.2.5, 2,g,g, g,g,, .
The staff has evaluated the Plad methodology . with! respect to the standards and acceptance criteria applicable to the issues addressed. These criteria are contained in 10CFR50 Appendix B criteria XV and XVI,10CFR50.55(e) and the FSAR. Additionally, Appendix B of the Program Plan describes the development and utilization of issues tracking matrices to ensure that all issues are identified and resolved. 2.2.6.4 Conclusion The staff's evaluation finds that the Plan adequately addresses the NRC's concerns and proper implementation of the Plan will resolve the issues in compliance with the FSAR connitments. Accordingly, the staff conicudes that this ISAP is acceptable. 2.2.7 Document Control (VII.a.3) 2.2.7.1 Introduction Problems were identified over a period of time in the implementation of the Document Control Program during the construc-tion phase of CPSES. The scope of this Action Plan is to provide confi-dence that Document Control Program problems did not impact the installa-i tion and testing of hardware and that current design requirement are satis-fied.
- 2.2.7.2 CPRT Approach The concerns identified in this Plan are addressed by review and evaluation of the results of the implementation of I ISAP III.d "Preoperational Testing" and ISAP VII.c " Construction Reinspec-l tionTUocumentation Review Plan" to detennine if deficiencies identified :
under~ those plans are attributable to Document Control problems. Imple-mentation of the action plans requires verification that the latest design I i i I
IV 1/31/86 SECTIONS 2.2.5, 2.2.6, 2.2.7 ' infoimaltion (e.g., drawings, design change authorizations and component , modification cards) is used in the preparation of checklists used in the reinspections and documentation reviews. Programs and procedures will be evaluated for adequacy against the applicable sections of the FSAR and 10CFR50 Appendix 8 Criterion VI. 2.2.7.3 Staff Evaluation The staff's evaluation finds that implementa-tion will determingthe adequacy of the document control system in com-pliance with 10CFR* Appendix B, Criterion VI, and will identify the impact of Document Control problems in the physical plant. However, the staff finds that Section 4.4 procedures refers to Program Plan and Issue Specific Action Plans instead . of identifying the existing project procedures p. applicable to implementation of the Plan. This p e wjth the e Program Plan Attachment 3 ISAP format which requires identification of existing procedures. 2.2.7.4 Conclusion This evaluation finds that the methodology and interface with other action plans adequately addresses the NRC's concerns ~ regarding document control. However, Section 4.4 must be revised to comply l ! with the Program Plan Attachment 3. During implementation of the Plan the staff will confirm that the revision has been accomplished. t I l i I
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1v SECTION 2.2.8 us,85 DRAFT ['.2.2.8 ISAP VII.a.4 Audit Program and Auditor Qualification 2.2.8.1 Introduction This ISAP addresses the NRC's concern regarding the adequacy of the TUGC0 Audit Program from its inception to the present and will evaluate the program to determine the effect of any identified inadequacies on the Quality Assurance Program and/or the physical plant, and to recomend appropriate corrections and/or improvements to the cur-rent program. This evaluation will be accomplished through a review which will address audit planning and scheduling, preparation, performance, reporting, follow-up and closecut, and audit personnel qualification. 2.2.8.2 CPRT Approach 6 All revisions of the program and procedures g pertaining to the QA Audit Program that have been in effect at CPSES will be evaluated to identify comitments and the degree to which the written program conformed to these comitments. Included in this evaluation will be the CPSES PSAR/FSAR (Appendices 1A(N) and 1A(B), Chapter 17.1), and NRC QA branch questions and answers); TUGC0 Corporate Quality Assurance Pro-gram; CPSES Project Quality Assurance Plan (Design and Construction); Dallas Quality Procedures / Instructions Manual. 4 Reports, documentation, and data generated during the implementation of the program will be reviewed on a selective basis to evaluate the effectiveness of implementation. The selection of srecific items to be reviewed will be based on concerns identified by the NRC; significant revisions to comitments, program description, and/or organization; and to pursue questionable areas identified during the review. Specific topics to be addressed include the following. . i j
CTION 2.2.8 -
-. Audit Planning Criteria .
Published and as-run Schedules Audit Plans and Checklists Audit Reports
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- Audit Deficiency Follow-up
- Audit Team Members, Including Qualifications and Staffing Levels
- Organizations Performing Audit Activities
- Application of Audit Activities to Hardware e ..
h:7 versus Program Procedures a /Ac/ W The object of this evaluation is to de/clep a conclusion concerning the adequacy of program assessment provided by the Audit Program. This information will be used as an input for recom-mendations for revision of the current program, as appropriate. Should audit program deficiencies or weaknesses l related to construction activities be identified, they will be evaluated ) to determine whether action beyond that specified in ISAP VII,c is re- l quired to identify potential areas of concern regarding construction I quality. 2.2.8.3 Staff Evaluation
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that the I The staff evaluation has consipe source documents (e.g., SSERs, R IV Inspection Reports 4etc.) that V
/MAC bons,
SECTION 2.2.8 3 identjfied the issue have reported the ineffectiveness of the TUGC0 QA . Audit Program for a time frame that covers the period from 1978 through 1984. Since this period covered almost all of the construction activity, the staff wishes to emphasize its understanding of the ISAP that the CPRT's evaluations will include the PSAR/FSAR and all revisions, and the TUGC0 QA Audit Program and Procedures and all revisions thereto; and that the CPRT's evaluations will determine and report compliance / noncompliance with each of the documents as applicable from inception of the TUGC0 QA Audit Program to the present period of activity covered by this ISAP. During implementa-tion of the Plan the staff will confirm the CPRT's documented objective evidence in this regard. The staff finds that the FSAR comitments are identified in this plan and that the plan methodology is of adequate scope and depth to determine compliance with those comitments. This evaluation
,c also finds that this plan's interaction with ISAP VII.c will assist in the h_ identification and the determination of the impact of audit program deficiencies on construction quality. However, the staff finds that Sec-tion 4.4 Procedures; refers to Program Plan and Issue Specific Action Plans instead of identifying the existing prolect, yr,oc,edures applicable to implementation of the plan. Thisij e - [ k with the Program Plan, Attachment 3, ISAP format, which requires ientification of existing procedures.
1 2.2.8.4 Conclusion Based on the staff evaluation that FSAR commit-msnts are identified in the plan, and that implementation of the plan will cover sufficient scope and depth to determine compliance with those comitments and any resultant impact on construction quality, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be - J revised to comply with the Program Plan, Attachment 3. During implementa- l tion of the plan, the staff will confirm that the revision has been l l t I y --
i CTION 2.2.8 f accomp.ished, l and the staff will also confirm that the CPRT's evaluations .
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have considered all revisions of the PSAR/FSAR and the TUGC0 QA Audit Program and Procedures. l C
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SECTION 2.2.9 ,.- I 2.2.9 ISAP VII.a.5, Managment Assessment - . 2.2.9.1 Introduction
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This plan addresses the NRC's concern regard-
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ing the TUGC0 management assassment of the effectiveness of implementa-tion of their QA Program during construction of CPSES. The issue arose because of TUGCO's failure to implement periodic management review of QA Program in compliance with 10CFR50, Appendix B, Criterion II, QA [ Program,4 states in part: The applicant shall ~ regularly review the status and adequacy of the Quality Assurance Program. 2.2.9.2 CPRT Approach The purpose of this action plan is to assess the adequacy of the current CPSES Periodic Review of the QA Program The Review Team against criteria to be developed as part of this plan. will review in-place Periodic Review of QA Programs in other organiza-tions and will consult with INPO to define criteria for an adequate and an effective Periodic Review of the QA Program. The Review Team will then evaluate the current CPSES Periodic Review of the QA Program against the criteria developed above and will recomend appropriate
' revisions to the CPSES Program.
Utilizing the information gathered, .a set of criteria will be developed to define an effective Periodic Review of the QA Program for CPSES which addresses, among others, the following:
- Scheduling and performance of reviews at least annually.
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- Reports directed to, and responses received '
f from, a sufficiently high level of manage-ment to ensure effective correction action.
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l f ' ~~ 2/3/86 L , IV SECTION 2.2.g Ongoing contact by management with program
,- status.
. Identification of corrective action, l
- Tracking and follow-up.
The current TUGC0 program will be evaluated against the criteria developed above, and, if appropriate, revisions to the TUGC0 written program will be proposed to assure that an effective Periodic Review of the QA Program is in effect for the remaining con-struction phase of Unit 2 and for the operations phase. Copies of the Results Report for this ISAP will be provided to TUGC0 for their consideration in responding to the NRCNoticeofViolation(445/8432-02;446/8411-02)(detailedbeiow). m Background information detailed in this plan states:
- 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 the 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 I findings and subsequent corrective action follow-up.
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- This ISAP is not intended to perform evalu-ations which would result in conclusions i
IV 2/3/86 ' " m-> SECTION 2.2.9 a -- __ J regarding the installed hardware. The of hardware and any: potential
- - quality safety implications will be assessed from other hardware and programatic 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 require-ments, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the con-struction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the construction
'7 quality assurance program.
2.2.9.3~ 5taff Evaluation The staff's evaluation of the CPRT's stated intent finds that this plan is responsive to the action identified by the NRC, which requested that the applicant propose an action plan that
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will ensure that such problems (lack of a management assessment program) de not occur in the future. The plan methodology adequately describes a viable approach to establishing a management review program. Nith regard to additional action identified by the NRC that the applicant evaluate the TRT's findings and address potential safety significance, root cause, generic implications and col-lective significance, this plan states that these factors are addressed l in other hardware and programatic ISAPs and the self-initiated ISAo VII.c. The staff finds that this is a satisfactory response to the action identified. i l
IV 2/3/86 ' " ' ' ' * ' ~- SECTION 2.2.9 M_._ , The staff finds that Section 4.4.1, procedures refers to the Program Plan and Issue Specific Action Plans' instead of . identifying the existing projg,rocedures applicable to implementation of the plan. Thi(isg'..g. a with the Program Plan, Attach-ment 3, ISAP format, which requires identification of existing pro-cedures. 2.2.9.4 Conclusion Based on the evaluation, and the plan's deter-mination of compliance with 10CFR50, Appendix B, Criterion II, the staff g concludes that this ISAP is acceptable. However, Section 4.4.1 $be revised to comply with the Program Plan, Attachment 3. During implemen-tation of the plan, the staff will confirm that the revision has been accomplished. O>. U O l I
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l J IV 2/3/86 SECTION 2.2.10 r, -- ; L . 2.2.10 ISAP VII.a.6. Exit Interviews , , 2.2.10.1 Introduction i the NRC's concerns This IAP addresses regarding the Exit Interview Program. 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 which seriously evaluates these concerns. 2.2.10.2 CPRT Approach The CPRT will determine that TUGC0 has an effective program in place by evaluation of the adequacy of the policies, procedures and activities of the CPSES Ombudsman and the CPSES SAFETEAM in identifying and resolving site personnel concerns which have l 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 the Ombudsman, the majority of review and evaluation will center upon the activities and program of the SAFETEAM as implemented through December 1985. The implementation of .this plan will develop a set of attributes derived from TUGC0 comitments and industry guidelines which will be utilized in the preparation of the checklists to be used in the review. of established policies / procedures in place governing the activities of the Ombudsman /SAFETEAM interviews of employees. Evaluations will then be made as to the effectivness of the Ombudsman /SAFETEAM's handling of employees' concerns including the CPRT's evaluations for potential j safety significance.
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Evaluations will then be made as to the I effectiveness of the Ombudsman /SAFETEAM's handling of the concerns including the evaluation for potential safety implications. l i e
.- - , , - , , . - - .-..m , , , . , . .-w,--,-c,,v-_---,
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IV 2/3/86 r; SECTION 2.2.10 . 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. The results of reviews and evaluations con-ducted in the implementation of this plan will provide a basis for determining whether the Ombudsman's interview program and implementation was adequate and effective in identifying 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 pro-gram being conducted by the QA/QC Review Team as well ' as providing reconynendations for improvement for future program implementation as required. [ 2.2.10.3 Staff Evaluation This evaluation finds that the plan is f-responsive to the NRC's concern, and that impelementation of the plan will evaluate past concerns, identify potential safety implications, and .f-d the I effectiveness # of ^ the ^ performance of ^ the j(. determine Implementation will also ensure that TUGC0 / I Ombudsman /SAFETEAM. fg management has now established an effective program which encourages employees to ' voice concerns regarding safety and which seriously evaluates these concerns. The plan, Section 4.1.2.5, states that reviews and evaluations shall be conducted of, and limited to, past items of concern brought before the Ombudsman g identified through employee interviews with the SAFETEAM. This statement can be inter-preted to mean that the CPRT will do evaluations of either the Ombudsman or the SAFETEAM. The staff. wishes to clarify its understanding that this paragraph means that the CPRT will evaluate both. During imple-mentation of the plan, the staff will confirm that the CPRT has done
IV 2/3/86 . . y SECTION 2.2.10 y . both evalutions. In addition, the staff finds that Section 4.4, Pro-cedufes, refers to the Program Plan and Issue Specific Action Plans
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instead of identifying the existing project, pro,c,duges e applicable to M- 5cciWh"a with the Program implementation of the plan. This a b'rs: varto#NY Plan, Attachment 3, ISAP format, which requires identification of exist-ing procedures. 2.2.10.4 Conclusion The staff notes that there is no regulatory position that requires the applicant t have a formal exit interview g s program; therefore, there is no st n d to enable a comparison of the g , c# exa/ieace w. applicants program for complian 7"'d7T:;;r n;--: 2
" a m ,5 , y re z. w ing :y.3.,...;.u.+.~,,.7.w,.m eee"4ence 2_ ::L t;;cn:tr=t';c, th . ;.i;w r by jd; :nt 'ind that I
implementation of this plan will establish adequate measures to address and resolve employees' concerns and to identify quality d safety [ implications. The staff c that this ISAP i acceptable. srsr.- r - ~ 2 .oncludes Program Plan, However, Section 4.4 netst be revised to comply with t Attachment 3. During implementation of the plan, the / taff will confirm that the revision has been accomplished. / 0Y$$$$k / [Y$ Y?kS$ $$$ b$f$$N $$ I 1 i 1
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IV 2/3/86 SECTION 2.2.11 .
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-- 2.2.11 ISAP VII.a.7. Cleanliness . .
2.2.11.1 Introduction This ISAP addresses the NRC's concern - per-taining to housekeeping and system cleanliness and will determine the validity of the current housekeeping system and system cleanliness pro-gram for Units 1 and 2. Results of other action plans, procedural requirements, surveys, etc., will be analyzed to determine any impact on hardware and programatic implications. 2.2.11.2 CPRT Approach The CPRT assesses the adequacy of the house-keeping and system cleanliness program at CPSES by implementatio.n of the g following tasks:
- Review the results of ISAPs II.c and VI.a
' for adverse trends ~related to housekeep-ing and system cleanliness.
- Review TUGC0 and Brown & Root procedures for ~ establishment of housekeeping and /
' - 7 cleanliness measures (including surveil-lance requirements). 4 m fm A2oetw16Y
- Evaluate implementation ofAb5-08 for P l
' Reactor Vessel cleanliness.
- Review and evaluate implementation of TlECO and Brown & Root Surveillance Pro- [
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IV 2/3/86 SECTION 2.2.11 1
$r. 7-kJm 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 sur- ;
veillance will also be reviewed. The TUGC0 flush procedures for verifying cleanliness of the Reactor Coolant Loops, including FP 55-08, as refer-enced in Item 9A of the NRC-TRT letter dated January 8,1985, will be reviewed to determine the adequqacy of swipe testing performed in accordance with the Westinghouse guidelines. 2.2.11.3 Staff Evaluation This evaluation finds that the NRC's con-Imple- - cerns are identified correctly and are adequgtely addressed.
<l mentation by the methodology described will det'rmine compliance with the requirements of 10CFR50, Appendix B, Criterion XIII, which is the FSAR comitment. The standards and acceptance criteria defined in the plan are appropriate for the evaluation to determine that compliance. There is concern, however, that Section 4.4, Procedures, contains a narrative i statement regarding the retention of checklists, guidelineg egcy instead of referencing existing procedures. This -
p;gjqy with the Program Plan, Attachment 3. ISAP format, which requires identi-fication of existing procedures. 2.2.11.4 Conclusion ryg NEC sr w Based on the evaluation finds that the 4 NRC's concern is adeqately addressed and that implementation.of the plan will evaluate and resolve the issue and determine compliance with the & However, FSAR, the staff concludes that this ISAP is acceptable. r-
4 2/3/86 m ' IV ) SECTION 2.2.11 g $ptRbe revised to comply with the Program Plan, Attach-Section 4.4 ettet , ment 5. _ During implementation of the plan, the staff will confirm that the revision has been accomplished.
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CTION 2.2.12 2.2.12 ISAP VII.a.8, Fuel Pool Liner
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2.2.12.1 Introduction This ISAP addresses the NRC's concern regard-ing the applicants' inability to maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and inspection. This issue which was reported in SSER 11 Appendix 0, pertains principally to operations travelers and related documentation. Reinspection of welds in the fuel pool liner will be performed under the self-initiated ISAP VII.c. 2.2.12.2 CPRT Approach Background information in the Plan states that SSER #10 (which reported on fuel pool welds and welding practices) states that 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 Progrm requirements). The fuel pool liners also are not required to be designed and erected to meet Seismic Category I cri-teria.
Additionally, the background states that the observations of SSER #16 notwithstanding, G&H Specification 2323-SS-18, Revision April 15, 1985, Paragraph 1.1 does identify the stainless steel liner systems (except the Unit 1 and Unit 2 Reactor Building Refueling Cavities) as Nuclear Safety Related. This includes the spent fuel storage pools, transfer canals, and cask loading pits. The CPRT will evaluate irregularities in the fuel pool liner travelers and related documentation by a review of liner specifications, drawings and procedures to determine the erection, inspec-tion and testing requirements. A sample of travelers will be randomly selected from a list of all the spent fuel pool, transfer canal, and cask
CTION 2.2.12 .. loading pit travelers used during erection of the liner and associated components. The sample will be selected to provide at least a 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 approach for the following reasons: No programmatic deficiencies have been identified in this population to date, and the population of travelers is homogeneous in that all the work was accomplished by the same crafts using the same procedures. The CPRT will review the sample 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 g
- g. authorized inspection sign-offs.
2.2.12.3 Staff Evaluation The staff's evaluation finds that this ISAP correctly identifies the issue as: the Applicant's inability to maintain an effective and controlled QC Inspection Program for fuel pool liner fabrication and installation. This ISAP addresses this issue based on the same premise that the TRT used for their assessment, namely, that the G&H specification imposed the requirement for a QA Program in accordance with 10CFR50 Appendix B, although this was not an FSAR comitment. Additionally, this evaluation finds that the plan adequately addresses the NRC's concern and that implementation of the methodology described in the plan will evaluate and resolve the issue. The plan describes that fuel pool liner inspection records shall~ be in com-pliance with the inspection record requirements of 10CFR50, Appendix B, Criterion X, " Inspection", and Criterion XVII, " Quality Assurance l
CTION 2.2.12 Records", and the associated commitments of CPSES/FSAR, paragraphs 17.1.10 and.17.1.17, respectively. The staff finds these criteria to be appro-priate. The staff has a concern that Section 4.4, Pro-cedures, contains a narrative pertaining to the development of matrices, checklists and data sheets instead of referencing existing procedures which are applicable to implementation of the plan. This is not in com-pliance with the Program Plan, Attachment 3, ISAP format, which requires referencing existing procedures. 2.2.12.4 Conclusion The staff concludes that this plan is accept-able, based on their evaluation that implementation of the plan will
,_ evaluate and resolve the issue and that appropriate criteria are used to ' ~) determine compliance with 10CFR50 Appendix B even though these criteria are not an FSAR comitment. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished.
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CTION 2.2.13 . 2.2.13 ONSITE FABRICATION (VII.b.1) . 2.2.13.1 Introduction This ISAP will assess and resolve the NRC's concern regarding the procedural and management control of the fabrication shop work activities at CPSES. 2.2.13.2 CPRT Approach The CPRT will implement this Plan in a two-step approach, the first of which will address concerns that may be-evaluated by review of safety related fabrication document packages. This evaluation will assess the proper completion of material requisitions, fabricated threads conformance and shop fabrication to memos and sketches g instead of operations traveller packages. Additionally, this step will (y identify populations of ASME and non-ASME safety related fabricated pieces, and evaluate 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, CPRT Sampling Approach, Applica-tions and Guidelines. If documentation discrepancies are identified, the CPRT will perform reinspections of items using checklists of appropriate attributes developed under this Plan and the self-initiated ISAP VII.c. The second step will address concerns which may be evaluated by review of procedures, survey, surveillance, and audit records to identify trends and corrective action effectiveness in: scrap and salvage control; safety, non-safety and bulk material segregation; and site surveillance of material storage. The data derived from the implementation of the two steps described above, will be analyzed to determine if the shop fabrication activities have met the requirements of 10CFR50, Appendix B, Criteria V, IX and X and the FSAR.
CTION 2.2.13 ; The Plan also describes its interaction with - ISAP II.a.1 which addresses material traceability, and also clarifies that a craft training concern, a part of the site fabrication issuc, is addressed in ISAP I.d.3. 2.2.13.3 Staff Evaluation This evaluation assessed that the Plan identi-
. fied the issue correctly and finds that the methodology when implemented will address the NRC's concern, and will determine compliance with the applicable criteria of 10CFR50, Appendix B.
Section 4.3 states in pa'rt: "All personnel associated with the analysis and evaluation of findings ... " Since the Program Plan, Appendix E, applies to the classification of diser pancies, ki. D the staff finds that the word findings is not an appropriate classifica-tion, and does not comply with Appendix E. Additionally, this evaluation finds that Sec-tions 4.4 procedures 'and 4.5 Standards / Acceptance criteria contain narra-tive descriptions of checklists, guidelines, etc., and a vague description of what the criteria will be based on, instead of identification of the procedures and criteria. The two sections do not comply with the Program Plan Attachment 3 ISAP format which requires identification of existing i procedures and the Standards / Acceptance criteria. 2.2.13.4 Conclusion The staff's evaluation found that implementa-tion of the plan will adequately address and resolve the issue and deter-mine FSAR compliance. The staff concludes that this ISAP is acceptable. However, Sections 4.3, 4.4 and 4.5 must be revised to comply with the Program Plan, Appendix E, and Attachment 3 respectively. During implemen-tation of the Plan the staff will confirm tha,t the revision has been accomplished.
CTION 2.2.14 ,, 2.2.14 Valve Disassembly (VII.b.2) 2.2.14.1 Introduction This ISAP addresses the NRC's concern regard-ing valve assembly / disassembly and evaluation of the adequacy of proce-dures that controlled the disassembly / reassembly process and determines 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. 2.2.14.2 CPRT Approach In implementing this Plan to evaluate and re-solve the issue, the CPRT will: EN Q - Identify all valves which have been disassembled and reassembled.
- Conduct a procedure review to determine adequacy of control of valve components during disassembly and reassembly.
Perform a safety consequence analysis to determine if valve 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 valves were properly reassembled.
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CTION 2.2.14 - Review applicable procedures, for both con- , struction 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. 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 re-sulting 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. 5% In addition, an evaluation will be made to N define potential Code violations which could result from improperly assembly valves. A reinspection of valves which have been dis-assembled 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 l and an additional sample of valves from the population comprised of the valves identified in the TRT issues will be reinspected. Both samples will be in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection is considered to be a reasonable approach for the following reasons: I l No programatic deficiencies have been identified in this population to date. i 1
- The population of valves which have been disassembled is homogeneous. Specifically, all the valves were l
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CTION 2.2.14 . *
- - disassembled by the same craft under the same proce-dures. Therefore, sampling in accordance with Appendix D will detect, with a high level of ac-curacy, programmatic errors associated with the pro-cess of disassembling and reassembling valves.
Manufacturers drawings and disassembly proce-dures will 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 a verification of internal parts. Probable improper reas-sembly will be indicated by an inconsistency in internal component serial numbers from one Operation Traveler to another for a particular . valve. Q 2.2.14.3 Staff Evaluation This evaluation finds that the concern is identified correctly and that implementation of the methodology will evaluate and resolve the issue. The staff is concerned however that the emphasis of the Plan appears to be directed towards valve internal parts. It is acknowledged that the tracking of valve internal parts is a critical essential element in the CPRT's evaluations. The staff wishes to further identify that the TRT's issue also identified the loss damage and inter-change of valve external parts, namely bonnets. This was particularly true in the case of the hand wheel operated diaphragm valves in the spent fuel cooling, boron recycle and chemical volume control systems. Section 4.1.5 states in part: " Probable improper assembly will be indicated by an inconsistency in internal component serial numbers." The CPRT's evalua-tions rust also consider inspection attributes that provide for a check of all valve parts that are traceable by physical part marking (not-limited to serial numbers), operations travellers, and in the case of Code class valves, the manufacturers Code Data Report Form NV-1.
CTION 2.2.14 .. Section 4.1 states in part: A safety conse- , quench analysis to determine if valve 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. The staff is concerned that the analysis may be limited only to those cases involving lower pressure / temperature ratings when in fact the same potential risks may ensue in cases of higher pressure / temperature ratings. The staff finds that the concern can be clarified by use of phraseology: " ... different pressure / temperature ... ".. Accordingly, the ISAP must be revised to so state. Additionally, Section 4.2 procedures does not identify existing procedures and therefore does not comply with the. Pro-gram Plan Attachment 3 which requires identification of existing proce-g dures. Also, in Section 4.6 the applicable Codes and Standards and FSAR @ comitments if any are not identified. 2.2.14.4 Conclusion The staff evaluation finds that implementa-tion of the Plan's methodology b 'll address and resolve the issues, how-ever, the Plan must contain provisions to inspect for.the interchange of critical valve external parts (e.g., bonnets) as well as internal parts. Additionally, Sections 4.2 and 4.6 must be revised to comply with the Program Plan Attachment 3. Based on the evaluation of the Plan's methodology the staff concludes that this ISAP is conditionally accept-able. Final acceptance is pending the staff's confirmation during imple-mentation, that Sections 4.2 and 4.6 have been revised to comply with the Program Plan Attachment 3 and that imspection checklist attributes provide I l 1
CTION 2.2.14 5 for the inspection of valve externals. Also, during implementation the - staff will confirm that Section 4.1 has been revised to~ state "different pressure / temperature ratings" and that the analysis does in fact address the differences in both cases. O
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A CTION 2.2.15 . 2.2.15 PIPE SUPPORT INSPECTIONS (VII.b.3)
- 2.2.15.1 Introduction This ISAP addresses the NRC's concern regard-ing the adequacy of QC as-built inspections of. pipe supports.
2.2.15.2 CPRT Approach The Plan scope and methodology describes that 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 6 the stated objective: k Reinspect the TRT sample to validate the TRT identi-fied discrepancies. Reinspect randomly selectef, 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 progrannatic concerns for any construction defi-ciencies and adverse trends.
Identify / develop procedures required to accomplish the tasks outlined above. L
IV SECTION 2.2.15 2/4/86 hf , ,- This action plan covers safety related Class . 1, 2 'and 3 pipe supports in Units 1, 2 and common areas. 4 The CPRT will review the documentation used by the TRT in their inspections (e.g., specifications, procedures, drawings etc.), prepare reinspection packages and perform reinspections of the items that the TRT initially inspected. The CPRT will compare their inspection results with the TRT's findings and identify the differences or results that cannot be reconciled. Under this ISAP, the CPRT will assure that the populations of supports to be random sample reinspected include the attributes and instructions required to verify the TRT identified discre-pancies in the Action Plan VII.c reinspection checklists and quality instructions for each population identified. (Note: The required inspections will be performed under Action Plan VII.c.) Review VII.c inspection results for pipe sup-port populations and identify valid discrepancies. In addition, the CPRT will evaluate all valid discrepancies for safety significance and perform trend analysis for all valid deviations. Both of these activities will be performed in accordance with the requirements of the Program Plan, Appendix E, Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Discrepancies Identified by CPRT. 2.2.15.3 Staff Evaluation The Staff's evaluation finds that the NRC's ! concern is identified correctly and complete identification of the TRT's findings are tabulated in the Plan. Implementation of the Plan's methodology, which addresses evaluation of the TRT issue combined with the defined interaction with ISAP VII.c, adequately addresses evaluation of
IV 2/4/86 SECTION 2.2.15 - f the issd_e. This evaluation finds that existing procedures applicable to - plan implementation are identified. However, Section 4.5 Acceptance Cri-teria describes activities performed by the CPRT instead of identifying the Codes / Standards and FSAR commitment. The section does not comply with the Program Plan, Attachment 3, ISAP format which requires identification of standards / acceptance criteria. 2.2.15.4 Conclusion The staff evaluation finds that the NRC's con-cern is correctly identified and that implementation of the Plan will adequately evaluate the issue. The staff finds however that although the Plan contains sufficient information to determine acceptability /nor.- acceptability of the items reinspected, the Plan lacks identification of the Codes / Standards and FSAR comitment which are used as comparisons to resolve the issue (e.g., inadequacy of QC inspections) and to determine compliance. Accordingly, the staff concludes that this ISAP is condi-tionally accepted. During implementation, the staff will confirm that the ISAP Section 4.5 has been revised to comply with the Program Plan Attach-ment 3 in the identification of Standards / Acceptance criteria. l
CTION 2.2.16 i 2.2.16 Hilti Anchor Bolt Inspections (VII.b.4) , 2.2.16.1 Introduction This ISAP addresses the NRC's concern regard-ing Hilti anchor bolt installation on pipe supports and electrical raceway supports. 2.2.16.2 CPRT Approach 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 reinspec-tion for safety-significant attributes of Hilti bolts. The following tasks will be implemented to {
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achieve these objectives: Review for safety-significant attributes.
- Insure inclusion of safety-significant attributes in Action Plan VII.c.
- Review for comonality in requirements among various project (discipline) documents.
- Evaluate sample size.
- 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 plan tasks to react to these implications.
IV 2/5/86 SECTION 2.2.16 . - { Under this Plan the CPRT will review specifi- ,
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cations and procedures and identify safety significant attributes that are in accordance with those attributes applicable to inspection performed under the self-initiated ISAP VII.c. The specification, procedures, QC inspec-tions, and training procedures and records for Craft ' installing Hilti bolts for various items, i.e., electrical raceway supports, pipe supports, 3 HVAC supports, conduit supports, equipment supports, etc., on Units 1, 2 l and comon will be reviewed to determine whether they are the same. If so,- i then the results of inspection of these items will be considered applicable to all Hilti bolt installations. If not, samples from other populations of i Hilti bolts in Units 1, 2 and comon will be inspected. Reinspections , shall be performed in-accordance with Action Plan VII.c and'shall include a) sample reinspection of Hilti bolt installations as a reinspection
,g attribute and b) documentation reviews to conclude that appropriate sur-4 g veillance attributes had been properly noted. This action plan for Hilti
- bolt installations will utilize the results of the above inspections as-well as additional inspections to resolve the Hilti bolt concerns.
i 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 program. This program will consist of torque checking i a number of Hilti bolts from Electrical Raceway Supports, pipe supports, and HVAC duct supports. Based on engineering evaluation of this program,- further pull-tests of questionable samples will be considered. Pull-tests, if required, will be based on determining the Hilti bolts resistance to the service load required of the bolt. J Programatic implications will be reported to the Manager - QA/QC - Programatic Issues, and those with potential impact' i 1
IV SECTION 2.2.16-2/5/86 T E on oth'erlaction plans will be provided to the affected Issue Plan Coordina-tor for any necessary action. 2.2.16.3 Staff Evaluation The staff's evaluation finds that the issue is identified correctly in the Plan, and the Plan is sufficient in scope and depth to adequately address 'the issue. This evaluation finds that the CPRT's review of applicable documentation will identify the inspection attributes. Evaluation of physical torque tests and pull tests performed under this Plan combined with evaluation of the results of inspections performed under ISAP VII.c will provide sufficient information to enable a conclusion regarding the Hilti-bolt installations. That staff is concerned that Section 4.6 Acceptance Criteria contains a narrative description of what the CPRT will do to establish the acceptance criteria instead of specific identification of the documents that yield the criteria. This does not comply with the Program Plan Attachment 3 ISAP Format which requires the identification of Standards / Acceptance criteria. Accordingly, Section 4.6 must be revised to comply with Attachment 3. l The staff notes that the torque verification program will be accomplished by reinspecting for nut rotation resistance I to a percentage of the original torque setting value defined by engineering l evaluation. Since the amount of torque used is critical to verification of
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proper seating of the Hilti'in the concrete, the staff will review this detail. 2.2.16.4 Conclusion In its evaluation of this ISAP, the staff found that the issue is identified correctly and the Plan's methodology is adequately descriptive of the activity that is essential to evaluation and l
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CTION 2.2.16 resoluti.on of the issue. The percentage of torque used in the torque . . verification program is an issue of concern that will be subject to staff review during implementation. Acccrdingly, the staff concludes that this ISAP is acceptable. Section 4.6 does accurately identify the type of document from which the acceptance criteria will be derived. Those specific documents, of necessity, were used to establish the inspection attributes. Therefore, discrete identification is known. Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 has been revised to comply with the Program Plan, Attachment 3. g3-
CTION 2.2.17 _1_ 2.2.17 Cable Tray Raceway Supports Inspection (VII.b.5) This ISAP was deleted from the CPRT Program Plan, Revi-sion 3, Appendix C. This ISAP was initially developed to respond to QA/QC issues that were identified in the NRC letter to the Applicant January 8, 1983. These were subsequently published in May 1985 in NUREG 0797 Safety Evaluation Report Supplement 11, Appendix 0, Reference Pages 0-295 through 0-298, and addressed electrical raceway support inspections. The areas of - concern were related to the following:
- 1. Undersized welds
- 2. Misplaced welds
- 3. Unauthorized configuration changes
.,_ 4. Hilti anchor bolt installation deficiencies Q 5. Undersize nuts These QA/QC issues arose from sources other than the CPRT, (in this case the SER Supplement 11), therefore are classified as external source issues.
The staff's evaluation of CPRT Program Documentation finds that the concern will be addressed in ISAPs I.c, VII.b.4, VII.c and DSAP XI. The staff has evaluated the CPRT's Program Plan method-ology that will ensure that all of the external source issues (including QA/QC issues) will be identified, evaluated and resolved. The staff found the Program Plan to be acceptable in this regard. The staff is confident that the issue of concern that was to be addressed in ISAP VII.b.5 (deleted) will be satisfactorily addressed by the CPRT under the Plan's l l \- - - . __ __. .
CTION 2.2.17 methodology for resolving the external source issues. During implementa- , tion of the Program Plan, the CPRT shall offer a reasonable explanation for the deletion of ISAP VII.b.5 and identify the action plan (s) that address this issue, and the staff will confirm the CRPT's action.
CTION 2.3 - 2.3 Civil / Structural Issues Six external source issues relating to construction adequacy in the civil / structural area were listed in NUREG-0797, Supplement No. 8 (Reference ). Under the Program Plan, Appendix C, Action Plans, the CPRT developed the following Issue Specific Action Plans (ISAP) to address and resolve the Civil / Structural issues relating to construction adequacy: Action Plan Title I.c Electrical Conduit Supports II.a Reinforcing Steel in the Reactor Cavity II.b Concrete Compression Strength 1 II.c Maintenance of Air Gap Between Concrete Structures Y :I.d Seismic Design of Control-Room Ceiling Elements II.e Rebar in Fuel-Handling Building 2.3.1 ISAP II.a, Reinforcina Steel in the Reactor Cavity 2.3.1.1 Introduction This ISAP addresses a documented occurrence in which reinforcing steel was omitted from a unit I reactor cavity con-crete placement between the 812-foot and 819-foot-1/2-inch elevations. Althougn the omission was documented, justification supporting the engineering conclusion to use as is was not available. 2.3.1.2 CPRT Approach The action plan is designed to assess the design adequacy of the existing as-built condition of the reactor cavity
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IV SECTION 2.3 1/29/86
%='1[ f wall and, other areas within Units 1 and 2 where rebars were omitted. ,
This assessment will include an evaluation of the engineering / field design-change interface. All documented instances of rebar omission will be reviewed to assure that proper engineering evaluation and doc-umentation exist in support of the disposition of each item. In addi-tion, a random sample of 60 concrete pour cards will be reviewed to verify that current design documents were used in construction. Procedures governing design changes will be reviewed to verify the adequacy of methods for controlling implementa . tion of design changes into construction. 2.3.1.3 Staff Evaluation N The staff has reviewed the CPRT Program Plan, ISAP II.a, Revision 2, and the CPRT cesponse of November 22, 1985, to the staff coments (dated Septemoer 30,1985). The staff has reviewed the standards and acceptance criteria delineated in the ISAP and has found that they are consistent with licensing comitments. The CPPT methodology in reviewing documenta-tion and evaluation of procedures governing the engineering / field design-change interface and the review of the evaluation of the imple-mentation of these procedures is consistent with current verification practices. 2.3.1.4 Conclusions The Program Plan, Revision 3 ISAP II.a, is responsive to the concerns raised by the staff in the September 30, 1985 letter and is therefore acceptable.
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% wame a o IV 1/29/86 id J SECTION 2.3 2.3.2 ISAP II.b, Concrete Compression Strength
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2.3.2.1 Introduction This ISAP addresses civil / structural allega-tions that some concrete strength tests were falsified. The applicant's position is that the uniformity of the concrete placed appears to min-imize the likelihood that low concrete strengths were obtained. The staff felt that additional action by the licensee was necessary to pro-vide confirmatory evidence that the reported concrete strength test results are indeed representative of the actual strength of the concrete installed. 2.3.2.2 CPRT Approach
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This action plan has been developed to verify N. the quality of the concrete in question. The Schmidt (Rebound) Hammer e* Test will be used to compare / correlate the relative strength of concrete poured during the period in question (Concrete at Issue, CAI) and con-crete poured outside this period (Control Concrete, CC). All testing will be in accordance with ASTI4 procedures. The area for testing will be limited to the exposed surface area where the Schmidt Hammer Test can be performed. Concrete-cylinder test data for the two populations will also be obtained, reviewed, and used for reference. If, after reviewing results of the Schmidt Hamer Test, the CAI population is found to have lower strength than the CC population, core tests, calibration of the Schmidt Hamer with known concrete strength or analysis will be performed. Any such actions will be documented as a revision to this action plan. I
"! 1/29/86 3E
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SECTION 2.3 0 W, J 2.3.2.3 Staff Evaluation The CPRT methodology for reviewing concrete-cylinder strength tests and for performing Schmidt Hantner tests on CAI and CC concrete pours is consistent with procedures / practices used in the concrete area. The statistical correlation for the CAI versus CC rebound tests is an appropriate approach, since the same or similar environment (age, strength, humidity) was used for the placements. 2.3.2.4 Conclusions The Program Plan, Revision 3, ISAP II.b, is responsive to the concerns raised by the staff in the September 30, 1985 c letter and is therefore acceptable. _1 2.3.3 ISAP II.C, Maintenance of Air Gap Between Concrete Structure 2.3.3.1 Introduction The TRT in NUREG-0797, Supplement 8, raised a concern that TUEC had not adeouately demonstrated compliance with FSAR Sections 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 interaction during an earth-quake. 2.3.3.2 CPRT Approach This ISAP will assess the current as-built ccr.dition to datermine the extent and cause of the condition. An evalu-ation will be performed to determine the design significance of the as-built condition. Any identified debris or rotofoam that impacts the design basis will be removed. -e=
2M6 Ay = SECTION 2.3 ' The final as-built condition of all separation , betwee6 Category I buildings and between Category I and non-Category I buildings will be determined as well as documentation of the design acceptability. Quality Control (QC) will document the final as-built conditions and a third party will overview this process. 2.3.3.3 Staff Evaluation The staff has reviewed the methodology to be used in addressing this specific issue. The approach is a complete reinspection of the as-built condition and the verification of design acceptability for compliance with FSAR comitments. In addition, the cause of the existing condition (s) and its applicability to other areas .g of the plant will be reviewed and evaluated. Qi 2.3.3.4 Conclusions The action plan is responsive and with proper implementation, including design acceptability for FSAR comitments, should resolve NRC concerns. 2.3.4 ISAP II.d, Seismic Design of Control-Room Ceiling Elements The seismic design of control-room ceiling elements issue reflected in ISAP II.d has been transferred to the CPRT Design Adequacy Program (DSAP VIII) due to potential design implications in the Civil / Structural discipline. This was done by TUGC0 to facilitate l resolution and to provide an improved focus on any generic implications and cc!!cc:1.c cignificance. The staff concurs with this approach. This item and the staff's review is contained in Section III, Subsection 2.3.2, of this SED.. 1
Ii 1/29/86 % [. g , sECTION 2.3 , g .g g j
. 2.3.5 ISAP II.e, Rebar in the Fuel-Handling Building ,
2.3.5.1 Introduction
- This issue-specific action plan addresses an alleged instance of unauthorized cutting of rebar in the Fuel-Handling Building due to depth of core drilling. .
2.3.5.2 CPRT Approach The CPRT action plan will address the as-built condition of the specific concrete mat in the Fuel-Handling Building, will assess the work of the construction crew'that could have cut addi-tional rebar without proper authorization, and will review controls governing rebar cutting. b Design calculations will be generated if required. All cases where rebar cutting was requested for installation of Hilti bolts will be reviewed and comparison made between rebar pattern and embedment depth of the installed bolts. The adequacy of the procedures and controls governing rebar cutting will be reviewed. 2.3.5.3 Staff Evaluation The staff has reviewed this specific action plan. The scope and methodology is acceptable for determining the adequacy of procedural controls and for locating areas where potential unauthorized rebar cutting was necessary. If redesign is required, the requirements of 1 ACI-318-71 and FSAR comitments will be consistent with original design criteria.
IV 1/29/86 SECTION 2.3 3g , p. , Wi% f; 2.3.5.4 Conclusions
- - The approach described in this ISAP is accept-able. Proper implementation will assure the acceptability of as-built conditions.
2.3.6 ISAP I.c, Electrical Conduit Supports 2.3.6.1 Introduction This issue-specific action plan addresses the installation of nonsafety-related conduit supports in seismic Category I areas of the plant. No evidence could be found that substantiated the adequacy of the installation, or in demonstrating that their failure would not aoversely affect the function of safety-related components or cause injury to plant personnel. 2.3.6.2 CPRT Approach This action plan will document the basis for the CPSES Damage Study assumption that Train C nonseismic conduit, two inches in diameter or less, would fall and have a potential for inter-a: ting with safety-related components. A seismic analysis will be performed that verifies stability and/or acceptable interaction during an earthquake. Two separate samples will be derived from the Unit 1 and comon areas. One will be randomly selected and the other will be derived on an engineering basis. The QA/QC Construction Adequacy for Train C conduit will be acdressed under CPRT Action Plans VII.a.1, " Quality Con-trol Inspection", and VII.b.4, "Hilti Bolts".
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IV 1/29/86 ' SECTION 2.3 DRAFT 2.3.6.3 Staff Evaluation . The staff has reviewed the scope and meth-odology used in addressing this specific issue. The sample size and selection is consistent with the overall approach used in the Construction Adequacy Program. The use of two samples, random and engineered, should provide a reason-able review of the entire population and a lower bound on seismic per-formance. The seismic analysis of both populations will determine whether the two-inch-and-under conduit supports meet the requirements of FSAR Section 3.78.2.8 and Regulatory Guide 1.29. g: Revision 3 of the plan is responsive to the Q concerns listed in the September 30, 1985 NRC letter to the applicant. I However, in clarifying the disposition of rejects identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Section 4.1.2.1 (page 7) and Sec-tion 4.1.2.5 (page 10). The intent of this statement relative to sample
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expansion and compliance with Appendix 0 of the Plan is unclear. 2.3.6.4 Conclusions The general scope and methodology contained in this ISAP is responsive and with proper implementation, including design acceptability for FSAR comitments, should resolve NRC concerns. However, before this ISAP can be accepted by the staff, clarification and/or justification of the statement in Sec- ! tion 4.1.2.1 ana 4.1.2.5 is needed, i
SECTION IV - STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN - Section 2.4 Disk: PLAN - section iv 2.4 Draft 4 - 2/6/86 2.4 Mechanical & Pipina Issues (votv/s f4 m The mechanical / piping issues dire the identified concerns whichh ssessment of allegations AultedfroDtheTRfM/PGr0UD pertainingto%echanical/ piping at CPSES. These issues were initially presented to the applicant by letter from the NRC dated November 29, 1984 and the detailed assessments were published in NUREG-0797 Safety Evaluation Report Supplement 10 issued in April 1985. Also included in this section are concerns identified as miscellaneous issues which arose from the TRT's investigations of allegations in the Civil / Structural area. These issues were
.:1 initially presented to the applicant by letter from the NRC dated i November 29, 1984, and the detailed assessments were published in NUREG-0797 Safety Evaluation Report Supplement 8 issued in February 1985.
Under the Program Plan, Appendix b, Quality of Construction and QA/QC Adequacy Program Plan, the CPRT developed ISAPs to address and resolve the mechanical / piping and miscellaneous issues related to construction adequacy. As detennined by the CPRT, the ISAPs may employ one or more of the following approaches: hardware reinspection, documentation review, walkdown inspections, engineering. review and analysis, and review and verification of TUGC0 corrective actions plans. The CPRT Program has also addressed the design-related aspects of two of the M/P ISAPs (V.b and V.c) in the Design Adequacy Plan. ISAP V.b is evaluated in Civil / Structural DSAP VIII, and ISAP V.c is addressed in Piping / Supports DSAP IX,
SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan The staff's evaluation of each of the action plans that address the M/P and miscellaneous issues related to the Construction Adequacy Program are presented in the following sections. 2.4.1 Inspection of Certain Types of Skewed Welds in NF Supports (V.a)2 2.4.1.1 Introduction During the CPSES ASLB hearings an allegation was made that Brown & Root (B&R) QC inspectors did not have adequate instructions or training to properly measure the size of skewed fillet welds during the inspection of pipe supports. NRC Region IV(reacto [ pspectors ingfiDinspection reports 50-445/82-14 and 50-445/84-06 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of its implementation. The TRT assessed the same allegation during its July-September 1984 Q onsite investigation and concluded that TUEC could not provide documentation that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., interfaces of curved sections). Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition. 2.4.1.2 CPRT Approach in response to the November 29, 1984 NRC letter, TUEC developed the CPRT Program Plan to include ISAP Va. This ISAP addressed the concerns of the TRT by establishing a scope and methodology, Sections 4.1.1 through 4.1.6, for the action plan that is responsive to the issue. The action plan included a review of a documented chronology of inspection methods involving skewed welds to correlate the period of time and specific procedure revisions for the inspection oI[s#kewed welds. Procedures QI-QAP-11.1-26, QI-QAP-11.1-28, and CP-QAP-12.1
r SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plcn , will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed weldg pm nsa m cse m e m s e ^^ * % m d " m d r-TUEC also committed to assess the adequacy of the implementation of the appropriate inspection procedures by establishing a random sample of Type 2 skewed welds to be reinspected. The sample plan is Lased on achieving a 95% confidence level that less than 5's of Type 2 skewed welds were not inspected properly and may result in a safety significant condition. The reinspections will be conducted by a third partyoswc- ruc Awsde /Ao M w?D - Finally, the results of the procedure review and physical reinspections will be evaluated to assess root cause and generic implications. Corrective action will be taken whenever modifications em n and procedural cans are required. A results report will be written to document the results of all procedure reviews, physical 4f- modifications, trend analysis and corrective actions. 2.4.1' 3
. Staff Evaluation NA9 The staff has reviewed the CPRT Program Plan, ISAP V.a. an@hD
[ plan generally to be responsive to the issue based on1the'fbing observations. The plan had identified chronology of inspection methods and its relationship to procedure revisions to be the proper starting point. The plan also addresses the adequacy of implementation of the appropriate inspection procedures by means of the proposed sampling plan. The staff believes that this aspect of the plan will [ g h identify the root cause of the skewed weld inspection problem. The staff expects the root cause and subsequent generic implications of this issue to be positively identified, since this issue had been previously identified in the ASLB hearings and addressed by TUEC. The fact that a procedure interpretation problem existed after action
SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan by TUEC is suggestive that there could be generic implications with respect to procedure revision and implementation in other areas of the plant. The staff also reviewed the CPRT response to the staff comments (dated September 30,1985) on ISAP Va. In Revision 3 of the Program Plan, the responses for Items 2-4 are acceptable since they are mainly clarifying in nature. However, the response to Item 1 requires additional explanation. The staff could not find where both Type 1 and Type 2 skewed welds were addressed by B&R procedure QI-QAP-11.1-28. If this were the case, then " stanchion welds" would have been inspected using the skewed weld inspection methods and marked as such on the QC checklist. 2.4.1.4 Conclusions The staf f conducted an evaluation of the CPRT Program Plan for ISAP
%. V.a and found the action plan to be generally responsive to the .' issues raised since the plan addressed inspection methods, procedure revisions, and reinspections. The staff, however, requires assurance that the ruot cause of the issue and its generic implications are properly addressed in the action. The CPRT-TRT issues manager should assure the staff that both items will be addressed in the results report. The staff perceives the root cause and generic implication aspect of this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC.
In addition, the response by the CPRT to Item 1 of the staff letter of September 30, 1985 concerning ISAP V.a is unacceptable. The stuff requires further explanation concerning the intent of procedure ' QI-QAP-11.1-28 with respect to skewed welds. (SG) 2.4.2 Improper Shortening of Anchor Bolts in Steam Generatorg Upper Lateral Supports (V.b).
SECTION IV - 2.4 - Staff Evaluation of Construction Ad;quacy Plan 2.4.2.1 Introduction During the July-Septem r 1984 investigation, the TRT was informed that some of the anchor bolts in the steam generator upper lateral support were shortened during installation without proper authorization to less than the length shown on the design drawings. Based on the results of its investigation, the TRT requested that TUEC provide evidence, such as ultrasonic measurement that would verify the actual installed bolt lengths. The TRT requested that should the bolts be determined to have been installed to engagements less than that shown of design drawings, TUEC shall: o Replace shortened bolts with bolts of the proper length or provide analysis to justify the adequacy of the installed bolts. o Provide justification or propose measures to ensure that no
> similar concern exists for other bolting.
TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations. This in accordance with 10 CFR deficiencywasreportedonJanuaryl17,1985 '
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- d to ensure that the steam generator upper lateral support meetg 4 design requirements and to review similar installations to determine if this issue pertains to other designs.
As stated in Section 4.1.1 of ISAP fb, thread engagement of the SG upper lateral restraint anchor bolts was detennined to be less than required by. design on the basis of inspections performed in Unit 1.
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u./ x d [nccc;;:9 Z l" X pM L h4 44 M g.",?f/," %"/ 2,"T. 't 72,' ' "" "' ~ '"'" 0 0 ry- i = L ign m i = d by-TEP^.. A similar inspection will be performed for Unit 2 and appropriate action taken. Section 4.1.2 provides for examination of the bolts and blind threaded holes during the bolt replacement to aid in the root cause assessment. This will include review of dimensional tolerance of assembly parts. ssue the Plan in Section 4.1.3 of As p> -artn-ofwthe.uCPRT,=effort:. .a. on c 1this ISAP V.bgi"p==& he t potentia / generic applicability of the bolt thread engagement issue for two other populations: o Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to determine that bolt engagement meets design requirements. If any cases of inadequate bolt engagement are identified, an assessment will be made to determine the p; ability of the component to carry its design load. If it is
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determined that the component cannot carry its design load increased sampling up to 1001 reinspection will be utilized. If it is determined that the component can still carry its design load 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. ,
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population and any cases of inadequate bolt engagement I [J :l'1. be.w, evaluated as described above for Richmond inserts. In Sections 4.1.4 and 4.1.5 of ISAP V.b, the CPRT commits to a third-party review of the process by which critical attributes of bolted connections were specified and the definition of their associated inspection criteria and documentation requirements. This
SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan will include an evaluation of the apparent lack of installation records for the SG upper lateral restraint. A third-party overview of all aspects of the Action Plan will also be completed. This will include the inspection plans for the UT of installed bolts as defined in 4.1.3, design calculations required for the evaluation of shortened bolts, and visual inspection of bolts and threaded holes during bolt replacement. Finally, based upon the methods described in Sections 4.1.2 through 4.1.5 and their results, the root cause and ener,1c implications pill be deteynined. c N zh f v o;- g/fi; J R S
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' steam genera anchor bolts will be addressed under ty (DSAP VIII) which s with the reanalysis Civil / Structural ac of the upper and lower stea, nera ateral supports. These supports are currently under ga lete reanalysis which may lead to a redesign o e support beam ancho 's tem. The adequacy of shortened" anchor bolts will be consi e art
[ of this an'alysis. 5 2.4.2.3 Staff Evaluation The staff, since it first identified this issue in its November 8, 1984 letter to TUEC, has been actively following the activities concerning this subject. The staff feels that the CPRT Program Plan has the ability to address all staff concerns relating to the specific issue based on the following observations. The Plan addresses possible generic implications by reviewing other designs that have the potential for similar thread engagement deviations. The Plan provides for performing random inspections of Richmond inserts and other blind bolt installations. The staff, however, still has a concern that when it is determined that a component can still carry its design load for all observed cases of less than adequate engagement, the need for additional inspection will be based on an evaluation of the trends in the inspection data. The staff must look at the basis for this evaluation case-by-case to detennine if the trends do or do not require additional inspections. ( . _-_ - _ - - _ _ __. _ - . . __ _. _ _ _ _ .
SECTION IV - 2.4 - Staff Evaluation of Construction Ad;quacy Plan The CPRT response to the three questions raised in the NRC Staff Evaluation dated September 30, 1985 havebeenrespondedtoina manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan. 2.4.2.4 Conclusions The staff concludes that if ISAP V.b is implemented as stated in the Plan the areas related to the original concern will be identified and resolved based on sound engineering practice, FSAR commitments and NRC guidelines. However, the staff has raised a concern that the use of trends of inspection data to determine the need for additional inspections must be reviewed on a case-by-case basis. 2.4.3 Design Consideration for Piping Systems Between Seismic Category I and Nonseismic Category I Buildings (V.c). @ 2.4.3.1 Introduction The TRT in reviewing the Comanche Peak Special Review Team Report determined that certain piping systems are routed from the Electrical Control Building (seismic Category I) to the Turbine Building (non-seismic Category I) without any isolation. Since the FSAR postulates Turbine Building failure during a safe shutdown earthquake (SSE) the effect of Turbine Building failures on any nonisolated piping routed from any seismic Category I building to the Turbine Building must be considered. ! In addition, for nonseismic Category I piping connected to seismic Category I piping, the dynamic effects of the nonseismic Category I piping must be considered in the seismic design of the seismic Category I piping and. supports, unless it can be shown that the dynamic effects of the nonseismic Category I piping are isolated by anchors or restraints designed to carry the combined loadings from both piping systems.
SECTION IV - 2.4 - Staff Evaluation of Construction Ad:;quacy Plan 2.4.3.2 CPRT Approach Since the Project Piping and Supports Program (PPSP) together with theDesignAdequacyProgram(DAP)includesprovisionsforsignificent piping reanalysis and associated support requalification, the CPRT will address the major concerns of this issue within the PPSP and DAP. The scope of this specific action plan will be limited to the following activities as outlined in Sections 4.1.1 through 4.1.3 of ISAP V.c: o IdentificationofallUnit1,2agd, common,pipingwhichhasa seismic /nonseismic interface /6 includer;
- Category I piping entering a non-Category I Building.
Piping with a c{ ass change frpm, Category I,to,non-Categ'y' I.
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2"dy:Cd iu pusiu'icic 'u n dC. g~; - Nh5 piping runs which have a portion which is seismically D analyzed to postulate breaks. o A review and dicussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based. o Recommendations to the PPSP and/or the DAP based on the results of the two items above. Any potential implications which should be considered during the PPSP and DAP implementation will be highlighted. 2.4.3.3 Staff Evaluation The staff has reviewed the action plan for ISAP Vc, and is satisfied l A I that the CPRT Plan understands the original concern and has the potential to identify items similar to the original concern. In addition, the NRC staff has perfonned an audit at Stone & Webster l
SECTION IV - 2.4 - Staff Evaluation of Construction Ad:quacy Plan Engineering Corporation (SWEC) offices. The purpose of this audit was to discuss with SWEC their scope and methodology for addressing this concern. The SWEC method has been determined by the staff to have the potential to identify and address this concern. The CPRT response to the four questions raised in the NRC Staff Evaluation dated September 30, 1965 have been responded to in a manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan. 2.4.3.4 Conclusions The staff concludes that if ISAP V.c is implemented as stated in the Plan all areas related to the original concern will be identified and resolved in a manner consistent with sound engineering practice, FSAR commitments and NRC guidelines. 2.4.4 Plug Welds (V.d). 2.4.4.1 Introduction The TRT investigated allegations that incorrectly located bolt holes in baseplates, pipe supports -and cable tray supports were " plug welded" without authorization, with undocumented wcid filler metal and without Quality Control inspection. The TRT concluded that the repair of misdrilled holes by welding was not prohibited by the appropriate editions of the applicable Codes. The TRT review of Brown & Root specifications established that misdrilled holes were Reevino regarded as base material defects and were SupposgD to be dispositioned by NCR action or engineering evaluation. The TRT concluded that the identification of undocumented " plug welds" and the difficulty in detecting them raised a generic concern as to the potential existence of-an unknown number of unauthorized
" plug welds" of questionable quality. Potentially defective welds in highly stressed areas could have safety significance.
SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan The TRT required that the Applicant modify a plan of action alreody proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocun,ented " plug welds" on the ability of pipe supports, cable [ ray supports, and baseplates to perform their intended function. 2.4.4.2 CPRT Approach g ySrugicuseweso m CNr % " M In Section 4.1 of ISAP V.jdhe CPRT has defined initiaDJbjectives: Co n so .a n o n 1.dheverificattogofthepresenceorabsenceofundocumented" plug welds" in ASME pipe supports and baseplates, - e SvosEwr mssss.*w as wris ssser y m wrw . Msms m r
- 2. (Veriticatiomof the quality of cable tray supports ?cntaining undocumented plug welds.
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~d baseplates representative of reactor Unit 1 and common components and a second sample of pipe supports and baseplates representative of reactor Unit 2. Each sample plan is to be based on identifying with 95% confidence level a rate of detectable plug welds of 5% or 5 greater. The minimum random sample size, which will achieve this M confidence level and rate of undocumented or unauthorized plug welds, -b is 60 with an acceptance number of zero.
As specified in Sections 4.1.1.2 ano 4.1.1.3 when a suspected " plug weld" is found, the paint will be removed from the support, the presence of a " plug weld" verified, visual inspection made, and comparison made to prior documentation to determine if the " plug weld" was or was not authorized. NCRs will be issued for , unauthorized " plug welds" and engineering evaluation performed to-evaluate structural integrity of the baseplate of support.
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SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan -- - t f In Sections 4.1.1.4 and 4.1.1.5 the CPRT commits that if any support or baseplate lacks structural integrity because of an unauthorized or undocumented " plug weld", the sample plan will be either expanded or increased to 100% inspection. If no unauthorized or undocumented
" plug welds" are found, it will be concluded that the structural integrity of ASME pipe supports and baseplates has not been degraded by the presence of such welds. If structural integrity is not
/ affected, the need for additional inspection will be based on i k t observed trends in the inspection results. ,
Finally, in Sections 4.1.1.6 through 4.1.1.8 the CPRT has stated that a review of existing QC inspection and documentation procedures will be made to identify necessary changes and also a third-party overview of the total effort will be made. To accomplish the second objective, as described in Sections 4.1.2 through 4.1.5, random samples of cable tray supports in both Units 1 & and 2 will be inspected and, if necessary, subjected to engineering evaluation. The investigative steps, in general, parallel those for ASME pipe supports and baseplates. Results will be used to assess the root cause and to determine generic implications. Finally, preceding either of the above objectives, Section 4.2 , describes the development of a viable inspection procedure to identify " plug welds", including criteria for paint by personnel / meeting the CPSES Quality Assurance Program or personnel / qualification requirements of the CPRT Program Plan. 2.4.4.3 Staff Evaluation Preliminary critique by the staff of the CPRT Program Plan raised 3 g 64 I > several concerns, some of which have been adequately resolved. The l h4 staff's concern about the following items remains unresolved. i 1
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cer ' a? inn of Com - 9. ion Adequacy Plan f 2,4.? Staff 4 valuation _(W members containing "plu s" made, surface prepared using methods available oCPgES on , and painted. The insp , detected i;.. r- .;;;, of the " plug welds." It .... h r d;* ;;;d ;;s 94*. Th T c+-" '2 4 - eng=+ad t2nah =^+ cc-- ;.. wiih a tppT ri - - - "'-- '-+ > 3 *- ' - ^=r A>--- ^# = '- ' ce -- The CPRT mu a ; onsistency and prop ea r lution. _ 14[ In March of 1985 at the CPRT action plan presentation at CPSES, the TRT stated it position that volumetric examination of any unauthorized )
" lug weld found should be made since the welder, who was trying to avoid QC cognizance, would be inclined to rush the job and may, therefore, have used poor welding techniques. The CPRT has not responded directly to this position.
% The sample plan (Section 4.1) and the definition of a reject were stated by the TRT as incompatible as currently wrj ten (P,R{s Q'
..f =^^' i responser J.J. references 3.4 ISAP V.a. Item 1 f
w mpwa%( Awdo p,.+s o. .. 2---+4. oh A. e sYnb o-f We*f *N. d -M;;'r.fr' # w k A ~ ." "'f- "4 . 5 W ' ltem V.e: .The staff review of ISAP V.e determined that the detail the s ific engineering evaluation and the generic study of ssible damage to er than the Unit 1, Loop 1, MS piping was sponsive to the actions requir of TUEC by the TRT. These acti are given in SSER No. 10, P. N-110, I s 1 through 8. Ac rison of items in the action plan and the act s required TUEC by the TRT found that ISAP V.e was sufficient to unbrel e actions required to resolve the issue, based on an engin ng ev uation by the staff. However, the s f has concerns that: l (1) e observation was noted in Section 3.2, " Pre inary ermination of Root Cause and Generic Implications" o SAP V.e, Revision ~ 3, that the phrase, "in construction practice, it not
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SECTION IV - 2.4 - Staff Evaluation of-Construction Ad:quacy Plan N (1) In 4.1.1.1, the second paragraph is confusing. The statement is made "The Sample Plan will be based on identifying with a 95 percent confidence a rate of detectable plug welds 5% or greater. The smallest random sample which will achieve this confidence level and rate of unauthorized or undocumented plug welds is 60, with an acceptance number of zero." These statements seem contradictory. It is not explained whether the Plan is establishing, with a confidence level of 95%, the rate of detectable plug welds or the rate of unauthorized or undocumented plug welds. Also, the Staff needs clarification to establish whether the rate is 5% greater or 5% less. (2) The Staff expressed concern that there is uncertainty as to the
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ability to detect a plug weld covered by paint and that this i uncertainty should be factored into the sample size. The CPRT in i Section 4.1 has reported the results of inspection of simulated cable l tray support members containing " plug welds" made, surface prepared using methods available to CPSES personnel, and painted. The g inspectors tested detected, on average, 82% of the " plug welds." The D maximum detected was 94%. The TRT notes that this reported ! capability is not consistent with the CPRT Program Plan stated intent of 95% confidence of a rate of 5% or more. The CPRT must address ; this inconsistency and propose a resolution. (3) In March of 1985 at the CPRT acti~.1 plan presentation at CPSES, the TRT stated its position that volume elc examination of any f unauthorized " plug welds" found should be made since the welder, who was trying to avoid QC cognizance, would be inclined to rush the job and may, therefore, have used poor welding techniques. The CPRT.has f not responded directly to this position. ! l l (4) The sample plan (Section 4.1) and the definition of a reject l were stated by the TRT as incompatible as currently written. CPRT's / response, which refer:nces 3.4 ISAP V.a Item 1, is confusing and needs further explanation. /
/ l
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1
SECTION IV - 2.4 - Staff Evaluation of Construction Adcquacy Plan 2.4.4 N
/ Conclusions qf k
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/ For the issue concerning plug welds, the staff concludes that there g, are important questions related to the CPRT Program Plan scope and methodology which must be satisfactorily answered prior to approvaV Q the Plan.
2.4.5 Repositioning of the Main Steam Line (V.e). 2.4.5.1 Introduction The TRT investigated an allegation that the 32-inch MS line was forced into position by the polar crane and 3-ton come-alongs and that " tension" induced in the line as a result of movement during the alleged incident was still present in the line. The TRT determined that repositioning of the Unit 1-luop 1 MS line 23 had been performed due to settlement of temporary supports. The TRT
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learned that the partially installed line had sagged due to settlement f temporary supports during flushing of the system and/or construction. The TRT also determined that the TUEC piping analysis performed 1 year after the alleged incident did not adequately address the full sequence of events involved in the incident. Accordingly, the TRT on November 29, 1984, informed TilEC that action was required to resolve this potentially safety-significant condition. 2.4.5.2 CPRT Approach The CPRT approach to resolve the TRT concerns resulting from the TRT investigation of the allegations regarding forced movement of the MS line and improper weldina of temporary supports is described in Section 4.0 ActionPlan,"ofISAPV.e[Rev.[Areviewof
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SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan Sections 4.1 and 4.2 of the CPRT plan indicates that specific engineering evaluations of the MS line incignt and a generic study of possible damage to other piping trIe o'roposeN[ The specific engineering evaluation includes: reviews of procedures for pipe erection and placement of temporary and permanent pipe supports; interviews of personnel involved in the MS line incident; evaluationsofproceduresangr,ac3iges nptical evaluations of full parametric variations ofj6nalysit> inputs for the MS line incident; significance of stresses and support loads resulting from the analytical evaluations; reviews of existing UT examinations and hydrostatic test data for the affected MS line; and a possible reinspection program. The generic study for possible damage in other piping, including the oF u snwiu no~s Unit 1, Loop 4, MS line includes: reviews g proceduresffor pipe. erection and placement of temporary and permanent pipe supports; Q reviews of Nonconformance Reports (NCRs) and Piping Deviation Request % Forms (PDRFs) for circumstances similar to the MS line incident; interviews of pipe installation personnel to determine piping subjected to adjustments during fitup; review of all other sources of residual stresses in piping systems; evaluations of the significance of residual stresses due to fitup; possible additional pipe fitup evaluations; and possible modifications to Gibbs & Hill (G&H) specifications and/or related procedures to ensure that piping and associated equipment are not adversely affected during flushing activities and/or by the use of temporary supports. Section 4.3, " Responsibilities," of ISAP V.e indicates that all activities are to be performed by third party (including a verification of previous work done by RLCA) except for th'e modification (if required) of procedures and specifications for the control of pipe erection, temporary supports and hydrostatic testing and flushing which was to be a Comanche Peak Project Engineering responsibility.
r SECTION.IV - 2.4 - Staff Evaluation of Construction Adequacy Plan 2.4.5.3 Staff Evaluation The staff review of ISAP V.e determined that the details of the specific engineering evaluation and the generic study of possible damage to other than the Unit 1, Loop 1, MS piping was responsive to the actions required of TUEC by the TRT. These actions are given in SSER No. 10, P. N-110, Items 1 through 8. A comparison of items in the action plan and the actioas required of TUEC by the TRT found that ISAP V.e was sufficient to unbrella the actions required to resolve the issue, based on an engineering evaluation by the staff. However, the staff has concerns that: (1)' The third party review of the RCLA work should not be limited to a verification only. Provisions for additional third party investigations should be provided,(Lf required /Adv wcdW F'd LC&A Aa dch nn es Ee n. fi . (2) Although the CPRT has indicated that its investigations performed as part of ISAP V.e, Revision 3, have concluded that the sequence of events described in SSER No.10 relating to MS line incident is not correct, the generic implications of settlements of supports and stresses due to hydrostatic testing and flushing activities will still be required to be evaluated by TUEC, since the sequence of events described by the TRT could have occurred elsewhere. 2.4.5.4 Conclusions For the issue concerning the repositioning of the main steam line, the specific engineering evaluation and generic study described in ISAP V.e, Revision 3, of the CPRT Program Plan provides an acceptable basis for resolution of the issues and concerns resulting from the- l TRT investigations of allegations regarding forced movement of the main steam line and improper welding of temporary supports. However, final acceptability by the staff is contingent upon verification by 1 l
SECTION IV - 2.4 - Staff Evaluation of Construction Adequacy Plan -17 . the CPRT of proper implementation of the details of the specific engineering evaluations of the main steam line incident and the
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generic study of possible damage to other piping.
IV 1/30/86 , SECTION 2.5 Q] 2,5 Testing Program Issues . Revision 3 of the Program Plan does not contain the ISAPs covering the testing area (the III series). The cover letter to Revi-sion 3 states that these ISAPs will be supplied on or before March 1, 1986. Therefore, this section cannot be reviewed and evaluated by the staff at this time and will be covered in a revision to this SER. 6
IV 2/6/86 h T SECTION 2.6 d E 2.6 Methodology for Resolving New External Source Issues 1 - At the present time it is uncertain how the new issues will be presented to the Applicant, or how the Applicant proposes to address them. Currently, the CPRT is charged with responding to and resolving the external source issues. Assuming that the issues will be evaluated and resolved under the present structure and methodology of the CPRT Program Plan, the staff's evaluations, of the adequacy and acceptability of the CPRT's capabilities to resolve.these issues, are presented in a number of. sections throughout this report. Part IV, Staff Evaluation of Construction Adequacy Plan, Section 2.0 and all Subsections 2.1.1 through 2.5.7 present the staff's evaluations of all of the ISAPs pertaining to these issues. In addition, Section 3.0 and Subsections 3.1 through 3.4 present the staff's' evaluation
^ of the self-initiated ISAP under which certain of these issues may be resolved, or, the results of which, when combined with the results of other ISAPs, may enable resolution of the issue.
Based on its evaluation of Revision 3 of the Program Plan the staff concludes that the Plan structure and methodology is adequate to address and resolve new-issues. This evaluation also considers that new action plan (s) may need to be developed and it;:lemented. The Program Plan in its current Revision 3 lists a number of sources that identified the existing issues, and may be the sources of new
-issues. The staff is concerned however: that new issues may emanate from sources other than those that are currently listed, and that the Program Plan does not address the manner of the CPRT's receipt of issues from new sources nor how the issues will be validated and entered into the CPRT tracking system for evaluation and resolution. Accordingly, the Program Plan must be amended to describe the CPRT's methodology that will ensure that concerns from new sources are identified and tracked and that the 1
i l.. -.
CTION 2.6 specific scurce is identified in the Plan. During implementation, the staff ,will confirm the adequacy of the CPRT's action implemented to resolve ~ this concern. This report, Part III, Subsection 2.6, presents the evaluation of new issues pertaining to design which will be addressed in the DAP and assesses the CPRT approach in finite aspects. 'l f _ . l 4
0 86 CTION 2.7 ,[, 2.7~ Evaluation of Closed External Source Issues The Staff's evaluation of the Program Plan, Revision 2, raised a concern that the Plan should be augmented to include information to meet the commitment of addressing the potential root cause and generic implica - tions associated with those issues which have been raised by an external source and subsequently closed by that source. The CPRT has responded to this concern by revision to Appendix B, " Quality of Construction /QA/QC Program". The revised Plan states that concerns which have been raised and subsecuently closed by the external source that raises the. issue will be considered for information when conducting root cause and generic implica-tion analyses. The Staff's evaluation of the Plan, Revision 3, finds that-the CPRT has responded to the NRC concern and that the CAP adequately addresses
, the root cause and generic implications analyses of the closed external source issues. Accordingly, the staff concludes that the response is acceptable. However, the Staff is concerned that, although the action plan results report format (Program Plan, Attachment 5) infers that closure of the issue will be reported, there is no clear statement in that format that requires reporting that each issue addressed in the action plan is closed.
Therefore, Attachment 5 .should be revised to include a requirement to identify each closed issue. During implementation of the Program Plan, the Staff will cor'irm that this action has been satisfactorily implemented.
, w ~ - -
i 3.0 Self-Initiated Evaluation l J.1 Scope . .
! 3.1.1. Introduction The construction adequacy program plan is described in ISAP VII.C.
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This action plan describgs e g o g d CPRT reinspection and documentation review ofdQC accepted safety related construction work activitiegegormed
, at Comanche Peak. The areas addressed by this d
program amp those which have not been identified as areas of concern by atter external sources. The objective of this effort is to provide additional confidence that there are no unidentified safety significant concerns related to the quality of construction of the hardware at Companche Peak in areas not addressed by external source issues. The CPRT's Plan consists of a sampled reinspection of Oc acceptedjsafety-related construction work jsupplemented by a review'of
. $. related documentation for nonrecreatable processes. The scope of the 5 Plan includes Units 1, 2, and the'r common areas ,w$Wr struction art-activities buts; organized into three disciplines A Hows:
o Civil / Structural o Electrical, and ' o Mechanical. The NRC staff has reviewed the scopej methodology,and process of this ISAP. This has been accomplished through document reviews and onsite audits. All aspects of this program have been examined from the categorization of installed safety-related hardware into population to the development of inspection lists from work process attributes. In ) addition to the presentation made by CPRT personnel at public i meetings, the staff and its consultants have perfomed M onsite
- audits of the construction reinspection and documentation review program. These audits have enabled the staff to understand and evaluate the framework and process for implementation of this plan.
I 3.1.2 CPRT Approach , i
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2-The methodology for CPRT construction adequacy review program consists of establishing reasonably homogeneous populations which are then - sampled, ev'aluated, and the results of these evaluations with conclusions drawn documented in an action plan results report. The , approach is to first categorize all installed safety-related hardware into populations made up of homogeneous work processes for which statistical samples can be drawn for evaluation. Population and work process descriptions are pr_epared for each construction category. The , population description describes the boundaries of the population i while the work process describes the activities required to install or construct a certain category of hardware. Attributes associated with each work process are developed from the _ installation and ingpection, { procedures and/or specifications used, /or /n.5/It //[r//an M y%e I subject hardware. For each population, two random samples will be l selected using established statist %al techniques. The first sample provides information about the total population while the second h sample, which is essentially an expansion of the first, provides D infonnation about that portion of the total population which is required to safely shut down the plant. In parallel with the sample selection, checklists and inspection procedures are developed from the l Both insmection ! attributesusedtocharacterizeeachworkprocess.Qd ar n Ms
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I and documentation review checklists argg eg -
- '::x.. t ;;':dhality Instructio[. Verification packages are then assembled for each sample item to facilitate an inspection or documentation review. Any deviations identified as a result of a.
reinspection or a documentation review are documented in a Deviation Report which will then be evaluated to determine the safety significance of the deviation. In addition, all deviations are collectively evaluated for adverse trends. Aa 2"i - r . . . . i w = u n.s r , renn-t deer :: tina the overall m:;lts J i.;ic s ii> ycu i vi.. fer ell- y pcpuhth St th: ';;ticle f;r d:: =:.tias ;.l.. ..sult; : d OY:h:thn; ' of this4 Sapr-The sample size for each population which is part of the construction ag y p gg y is targeted to meet a erfter k O' 95/5
- ::::._r:: -4t:- St. This is interpreted to a.ean that the sample size
_._.. . is sufficiently large such that one has 95 percent confidence that 95 .
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_ . ..7_ percent of the attributes in the work process do not have any safety significant deviations. The CPRT approach to sampling as described in Appendix 0 of the Program Plan identifies the sample size reqvired to . _ ~ achieve the targeted 95/5 assurance. For each work process of interest, a sample of size 60 is taken. If no safety significant deviations are found in the_ sample, the work process is accepted. If , a deviant is found, the sample is expanded. g f,4 y /g a ar,.shn(s) /ased on 7% nomher <dv/a dens nl dre. /k7ekJ/ed /h A,90H?cbk D k h W*rrs y lbr> - 7 n j& ,1,3an aDoye - > > i zu
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The 95/5 assurance1 3 evel was selected as a criterion to allow a quantification of the quality of the work process without having to pgach aesweenee level and is a every targeted,individual item in a work For r , g n gn exact.. process., y [, l assurance. most applications, the actual : .::; p g ff. L n /aga us = = =.
.s.t.3 SA #swLadm Mad The M staff amh eisse reviewed andnevaluated the aY*"c5 'C NI the CPRJ. QJQ Im .. : f/mch h+=^Y-& $ N '-Y 2:;th
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.to-permit audit- of this prose;5, .ii> impiemeni i.en, and auditaf the' coac-lesions upon completion e' t'! ? :;r=. ,
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, fom 4 %qpg pew The sampling procedure is, based on assumptions that characterize a binomial population,h$2ea :=;tta; include, - ^+k=: (1) homogeneity of items within a work process; (2) random selection of j sample items from a work process; (3) ability to classify an item as as acceptable or as af deviant with certainty; (4) the number of items in the work process is essentially infinite.
i lha h geneity of-the varS= ck pre;;;;;;, 7;; ired by asstanption P ), #' dct;.--in;f -' 5 tt'hd i;, ;;;;.. . ..; _0;;i':r d . If the rk l popuationoffn res; 's found to be on-homopeeou,the l pro ess bounda ies ari redrawn an .s ples are selected at random f
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i the respective work processes. e andom selection of the items int , the sample is made through r do ation proce' dure described i AppenWxtD. Since the bar of iteigs,in each whr) process is fi, nite.
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M / c a ,..; M L . / . ; e . ~ p h 3 - . - .. n j . Tpe 95/5 assur'ance level w selec by th )plic as a criterion lo allow a quan fica tio of the uality o th r wo k procefs - lyformance hout i ng to inspe ch aM every indi rn.- tene r terr,fik*re- Q,C Y' C 75 h 4*&/Y CCM-further enhance this assurance, even though no attempt is made to quantify this enhancement. Some of these factors are given below: Pur@hp tampling's'cheme often ass assumption that the sizelof the work rocess is infini . For mall procsses,thesg size conside ably I er than ne b and hence h associated a rance is und ted. d { /. The as u,rance increases with sample size, provided no additional D dekebNare found. c2eae = cre ct;r: it: : 'r= : = ::rk-p ::::; el;e b;1=; d te e rece9 ;;rk pr;;;;; already ===1=d l i Hence, the effect"?: ti:: Of th; ;;;er.d Orple has increer:d. , 7 [. The sampling assurance is increased when a deviant is identified and repaired. For small work processes this increase may be very significant.
) /. When a deviation is identified, it serves to identify a potential error path, which leads to further sampling. This activity increases the sample size, generally giving a still greater assurance.
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be complete and the development of the inspection checklists nam h-+=ti r :::::ht-d *^J 231,---{ :00 t te consistent for all populations. Th s te" '" : ' und tt.et ;; s Jm...s ,,i.ih . %
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.eva/ua knjllal k :.e-e d .fc.e yy:u?".:-AG gg g g j , The staff finds the CPRT approach to reinspection to be based on sound statistical principles. The staff believes that this program will provide a significant contribution tohoverall assessment of the design and construction adequacy of.the Comanche ,,
Peak steam electric station. Implementation of this program will be ^ -- 3
- d'u d/t audited by the staff. The CPRT's documentation of findings, m collective evaluatiod and the, documentation of thans results willabe
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I IV 1/29/86 1 SECTION 3.3 DRM7
- 3.3 Mechanical Populations The CPRT has divided the Mechanical Equipment Discipline into the following populations:
HVAC Ducts / Plenums HVAC Equipment Installation Large-Bore Piping Configuration Small-Bore Piping Configuration Pipe Welds / Material Piping System Bolted Joints / Material Mechanical Equipment Installation Field-Fabricated Tanks Instrumentation Tubing Welds / Material . g Within each copulation, work processes will be established. CPRTj defines each work process as a homogeneous activity and therefore j j must assure that similar installation procedures, craft, organization and QC inspection procedures were used in the ori inal construction. Random and engineered (safe-shutdown) sample # e will be selected for each population. 3.3.1 Staff Evaluation . ' The staff reviewed R1 vision 3 of the Program Plan and undertook audits of each of the Mechanical Populations. The7 audits # included reviews of procedures, documentation, work processes, and attributes. For each of the mechanical ' areas ERC has prepared a
" Population Description" addressing the contents and bounciary of each category of work. In addition to the Population Descriptions, a flow-chart describing the work processes and associated attributes for each l
[ It is the attributes that provide the l sample population was provided. ) I h
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IV 1/29/86 '
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SECTION 3.3 We y*l [ The work-process attributes were basis for the inspection checklists. reviewed in order to ver'ify that each work process would be adequately j reviewed. The Specific Staff Evaluation for each of the Mechanical Pop-ulations is provided in the subsequent paragraphs. 3.3.1.1 Field-Fabricated Tanks : l population contains eight field-(fabricated tanks. This All eight tanks will be reinspected. The procedures b O were reviewed and contained information for all attributes given in the Work-Process Description. a 3.3.1.2 Mechanical Ecuipurnt Installation The original governing construction document is Gibbs ~& Hill Mechanical Erection Specification 2323-MS-10Q d"# k fr$ implementation s accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. ,The orig-inal governing quality assurance procedure is Brown & Root QIpAJ11.1-39 titled " Mechanical Equipment Installation Inspection". Qualitative results of the sampling conducted so f ar indicate that 20 to 25 percent of the sample drawn is from Unit . The
- 2. The. remainder of the sample is from Unit 1 and comon areas.
work processes associated with mechanical equipment installation . are h setting, anchoring, welding and, for rotating equipment only, alignment. The attributes of each work process were reviewed in depth. ERC per-sonnel indicated that if a particular attribute of the work processes AM assessment was not addressghen _ the sampling activity was completed.g he sample needed to be expanded to would be madeg Qwhether include that attribute. If a decision was tr.rie not to specifically address that attribute, the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechanical equipment. Work-process homogeneity is evaluated
IV 1/29/86
-J- MD. D 4 pj m-.,
SECTION 3.3 l ggw/ w &w w w a r/ m by Gng to makehthat the same organizations are w involved som and 9 that the procedures have remainedfominally constanjl g Sampling is per-
- d at tM us_k-process 1=u=1 T M 7yaluation ofmccessequipment is made i
at the work-proceglevel, each sample will Fexpanded such that) sixty evaluations [will3made for each work process. e~ W M## # '" S/N'of Y The ERC reinspection procedures were reviewed and compared to the original construction specifications and procedures for homogeneity of work processes and choice of generic attributes., o f Rf V'f"' 3.3.1.3 Piping System Bolted Joints / Materials Two . work processes comprise the piping-system bolted-joint categor . e installation preparation and final bolt p ThNe
, fit-up_. There arei bolt d joints at the Comanche Peak Power Sta-
- tion.. The work processes and their attributes appear to adequately h@ f represent the bolting of piping joints. A flowchart and population 4 . description have been prepared to provide the basis for the sampling of bolted joints. Several of the attributes ginn in this population will -
j pequirebothinspectionanddocumentationreview. pfh ' 3.3.1.4 Large-Bore Piping Configuration /Small-Bore d Piping Configuration , The large- and small-bore piping configuration g f construction adequacy reviews are addressed using @ Brown & Root jM Sometric drawings. The scope of this adivity is inten:ed to assess the work process of piping installation through evaluation of attributes 9 /// f 'h' suth as location, size, and orientation of piping and pipe components.
#906 The Brown & Root isometric drawings provide the basis for sampling both
(/* / large- and small-bore piping. Large-bore piping includes that piping which is 2-1/2 inches and larger in diameter; small-bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing con-( taining both large- and small-bore piping were to be drawn as part of a i l (
IV SECTION 3.3 OP* W kh* j ( sample, it would be- used in both the large- and the small-bore work-process review. The in'stallation work process and its attributes are the same for both large- and small-bore piping. The piping considered .! h in this review includes alllASME Code Class piping, ERC reported that f
'all piping of large and small bore is installed to one procedure and by 9 Some attributes such as piping valves would ! ~
[/ one craft, pipe fitters.obviously be included in any sample drawn bore piping. There are other attributes such a expansion joints, screw joints, and strainers which, because there are very few in the system, might not be included in any selected sample. ERC reported that, fol-lowing the sampling process, a review to assess the adequacy of the sample for adeauate representation of attributes would be made. How-ever, a specific component, 'because it was not included in a sample, . o would not necesssarily be examined only for that reason. 3.3.1.5 HVAC Equipment Installation l t 9 The CPRT has divided the safety-related HVAC systems into two mechanical populations. One population is HVAC Equip- . ment Installation (active components), and the other is HVAC Ducts and
- Plenums (inactive components). Both the active (equipment) and inactive (ducts, plenums and appurtenances) components in these populations have
.' been installed by Bahnson Services Company with the exception of the pad .
~
or structural-steel-mounted equipment. This equipment was installed by g
. Brown & Root and is not included in either of the populations. The installation of this equipment will be inspected as part of the Mechan-ical Equipment Inst'allation population.
The HVAC Equipment Installation population l includes: fans, filters, fan-coil units, air conditioners, dampers I (fire, gravity and modulating) and airflow monitoring stations. There are two Work Processes associated with the population, which are: ,
- 1) equipment setting and 2) equipment connection. The setting Work
( Process includes those activities required to position / orient the equip-l f I l ._ .
1/29/86 5 CTION 3.3 h p,. b N, f ( ment in the proper location. The connection Work Process includes those activities necessary to' connect equipment flanges to supporting duct flanges. There are over 60 samples (items) in this population. 5 p#f' The staff undertook audits of this population. g6 The audits reviewed documentation, work processes, attributes and homogeneity. "' W " O " 3.3.1.6 HVAC Ducts / Plenums . The HVAC Ducts and Plenums population includes fabricated sheet-metal duct sections, plenums, flexible connections, fittings (elbows, transitions, tees and wyes) and appurtenances. - The appurtenances include: turning vanes, access doors and volume dampers. There are three Work Processes associated with the population, which are: 1) fabricating, 2). installing and 3) welding. The. number of e. samples (items) in this population is ove O W M # N " The random and engineered (safe-shutdown) . sample set will be selected for each population such that each Work Process will be inspected to the 95/5 confidence level. The staff undertook audits of this population. . These audits reviewed documentation, Work Processes, attributes and homogeneity. The Work Proccess attributes were reviewed in order to j verify that each would be adequtely inspected. This entailed reviewing the installation procedures referred to in the Description Memorandum for Reinspection and Quality Instruction documents for each population. A comparison of the distribution of component types in the sample sets (random and engineered) to the distribution in ,j the total population set was made. This revealed that 'all component f types were represented in the sample sets, and the distribution closely
- i. resembled that of the total population set.
ll i
IV 1/29/86 SECTION 3.3 [
- 3.3.1.7 Pipe Welds / Material Based upon the fact that both large-bore and small-bore pipe welds were fabricated to the same procedure and by the same craft, it was decided by ERC to combine these populations The staff reviewed the (LBWM and SBWM) popuation basis, description mem-orandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Weld--
ing. Apparently, regardless of the possible differences in the welds (configuration, material type, or process), each work process involves: (1) comon erection specification requirements; (2) comon installation procedure requirements; (3) comon craft labor performing the same basic types of operations, (4) comon inspection procedure; and (Si a common inspection organization. Since basically only two Welding methods were Q used at CPSES, Gas Tungsten ARC Welding (GTAW) and Shielded Metal Arc
$ Welding (SMAW), ERC has comitted to two random samples of 60 welds for each welding method. The staff expressed a concern for the lack of separation of carbon- and stainless-steel welding. ERC pointed out that welder qualification is in compliance with B&R Specification WES-031, which qualifies a welder to both carbon- and stainless-steel welding.
The staff reviewed WES-031 and B&R Procedure CP-CPM-6.9D, " Welding and . Related Processes", and found very few areas where the procedures or specifications differed with regard to carbon- and stainless-steel weld- ' ing. Differences were associated with the two welding methods, GTAW and SMAW. ERC said that of the 120 samples already established approx-imately 50% were stainless-steel welds. Ingdition, an engineered sample of 60 welds for each method was h to account for safe-shutdown systems. 'In both cases, GTAW and SMAW, the original sample of 60 and the engineered sample overlapped. This necessitated increasing In , the original sample to achieve the engineered sample of 60 welds. l I all, a total number of approximately 180 samples will be inspected. l t l 9
~.__...__,.,,_,..-,.,-..,,-_,..,-__rm.m- _ . . . -
- _ _ _ _ . _ _ - , _ . . _ _, _-m , . _ . ,
.v 1/29/86 dECTION 3.3 -
hk ( ' - Under the work process identified as " Weld-ing", 24 attributes were identified,18 of which are comon to both welding methods and to all welds. The remaining six attributes will be inspected as the sample dictates. Additional samples for these six attributes will be chosen as deemed necessary, or a justification for not increasing the sample will be given at that time. 3.3.2 Conclusions SW In reviewing Revision of the Program Plan, several concerns were raised by the NRC staff in the August 9 and September 30, 1985 evaluation letters to TUGCO. These concerns can be sumarized as follows: ff
$ / A- Inspector Certification Program.
Basis and rationale for establishing homogeneous
//
[ - hardware populations. qr p pp Y f - Attribute and criterion determination. O d) p - Sample expansion criteria. . Yf - The staff's evaluation and conclusions on the CPRT l
~
response to the concern on spector Certification Program is dis-
# of this SER..
cussed in Section . V The NRC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.c), when evaluated collectively with the assemblage of procedures and check-lists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogeneous hardware populations and the method used in determining attributes / criteria. Based on the results of the audits, the Staff has con-cluded the following relative to the Mechanical Equipment Populations: [
--,p..y _%-, ,y,_, ,.-
, l gy 1/29/86 ; g j g
=emesse SECTION 3.3 jg g l
~
- 1. A documented auditable trail of the background j exists.
- 2. The samples selected for the inspections are repre-sentative of the type and distribution of the com-ponents within each population.
- 3. The attributes and associated checklists adequately describe the work processes.
- p&
4 The Verification (inspection) packages demonstrated that the CAP inspection will produce an auditable
/
results trail. The concern raised by the Staff on sample expansion
- f. The criteria has not been resolved to the satisfaction of 7 of Q details of the concerns are given in Section this SER.
u A specific concern on sample selection in the Pipe Welds / Material population is as follows. The original breakdown bsosrs a sample of of60 LB and . 50 SB welds as part of two separate populations. The two populations i nave been combined to account for the similarity in the welding attri-i butes and the welding methods. The staff questions whether the original two 60 sample sets that are now combined into a sample of 120 will be ! This judged as (1) a single sample of 120 or (2) two samples of 60. i discrepancy must be clarified statistically. ,
!/
i I l
IV 1/31/86 SECTION 4.0 4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW DRAFT ' 4.1 Introduction During the construction of CPSES, there were a number of con-tractor and hardware suppliers. Since it is an objective of the Program Plan to assure the quality of construction in addition to the quality of the installed hardware, it is imperative that the Program Plan does not exclude edda;; N the work performed by all contractors unless there is adequate justification. 4.2 CPRT Approach (Justification) The Program Plan, Appendix C, ISAP VII.C, " Construction Reinspection / Documentation Review Plan", Section 4.2, states n L? D, "The scope of this action plan includes all safety-related construction work which has been inspected and accepted by CPSES QC." This scope, in conjunction with the scope and methodology described in Appendix B, " Quality of Construction and QA/QC Adequacy Program Plan", for External Source Issues and self-initiated evaluation, defines and describes the mechanism to identify and evaluate construction deficiencies or weaknesses and, if required, to expand the scope beyond that specified in the plan. The only reference to exclusion of vendors from the CPRT Review is contained in a footnote on page 49 of Appendix A (Design Adequacy Program) of the plan. This exclusion applie:; to the NSS design (Westinghouse design responsibility) and the individual design of equip-ment supplied by vendors. i
I ' i IV 1/31/86 i SECTION 4.0 l DRAFT l 1 4.3 Staff Evaluation
- - The Quality and Construction and QA/QC Adequacy Program Plan (QOC) does not exclude the review of any safety-related construction work which has been accepted by CPSES QC from its scope.
The plan does contain the scope and methodology for expansion of hardware inspections and evaluation. This is described in the Appen-dix B, Introduction, pages 2 and 3. 4.4 Conclusions The staff concludes that the QOC plan adequately defines the scope and methodology for the inclusion of all safety-related construc-tion activites.
Yt? 2-
. 29
- R. Masterson 1/1(/86 Appendix B Staff Evaluation of the CPRT Construction Adequacy Program Plan Section 4.4 4.4 Mechanical & Pioina Issues 4.4.1 Introduction Item V.a: Inspection of Certain Types of Skewed Welds .
in NF Supports. 7 n During the CPSES ASLB hearings an allegation)concerni the imp ~ roper inspection of skewed fillet weldsfwas madegrE - e allegation stipulatetfthat Brown & Root (B & R) QC l inspectors did not have adequate instructions or training to properly measure the size of skewed fillet welds during the inspection of pipe supports. The NRC Region IV reactor inspectors in their inspection reports 50-445/82-14 and 50-445/84-08 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of its implementation. The TRT assessed the same allegation during its July-Sept 1984 on-site investigation and concluded that there was no documentation that certain types of skewed fillet welds were reinspected correctlpC The TRT discovere at during the Vendor Certified Drawing (VCD) reinspection program for ASME supports, certain elds that exhibited a skewed condition, i.e. interfaces of
~
curved sections) [were not properly inspect h Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition.
- 8'/
R. Masterson 1/}(/86 Appendix B , Section 4.4 4.4.1 Introduction (Continued) Item V.b: Improper Shortening of Anchor Bolts in Steam i Generator Upper Lateral Supports. p gp ty 7/4f > tni>*MM / 9tywv4 MMe % JteTRTwasinformedthatsomeoftheanchorboltsin j the steam generator upper lateral support were shortened
- during installation to less than the length shown on the
! design drawings without proper authorization ,fThe 3 TRT g'was unable to verify the length of these inst'alled bolt since TUEC was unable to produce any installation becords.[Jfe'TRUrkueYt'edthatidECproYidNvidence, such as ultrasonic measurement that would verify the-actual installed bolt' lengths. The TRT requested that should the bolts be determined.to have been installed to engagement less than that shown j of design drawings, TUEC shall: o Replace shortened bolts with bolts of the proper length or provide analysis to justify the adequacy of I the installed bolts. I i o Provide justification or propose measures to ensure } that no similar concern. exists for other bolting. TUEC performed reinspection of'the anchor bolts and determined that insufficient thread engagement existed '- in specific locations. This deficiency was reported on January 17, 1985 in accordance with 10CFR50.55(e).. Item V.c: Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings. l ({(This Item should be moved to Appendix A Section 4.3)])-tL- l 4 L - , , _ - - _ - - - - . . --.- - - .-. - _ _ _ . - - - - - - .- . - - - -. - _ . . - _ . . - -
4 g 4 R. Masterson 1/M /86 Appendix B Section 4.4 1 4.4.1 Introduction (Continued) The TRT in reviewing the Comanche Peak Special Review l N/q tr~ Team find 7determined ((in the that areacertain of piping pipng desig systems @ derations are routed from the Electrical Control Building (seismic s Category I) to the Turbine Building (non-seismic l Category I) without any isolationg If isolation by - separation, barrier or constraint is not feasible, then , I f the effect on the seismic piping of the failure in the ! non-seismic piping must be considered (CPSES FSAR 3.7 3-13.1).JTherefore.)gince-theFSARpostulatesTurbine l
- Building f ailure during a safe shutdown carthquake (SSE) the effect of Turbine Building failures on any non-isolated piping routed from any seismic Category I l building to the Turbine 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 i supports, unless it can be shown that the dynamic effects of the non-seismic Category I piping are i isolatedbyanchorsorrestraints.JTheanchorsoh j estraints used for isolation must be designed to ( withstand the combined loadings imposed by both.the seismic Category I and non-seismic Category I piping. Item V.d: Plug Welds
- Q fg wdensarA1AnEdrw"*
gt was allegep that incorrectly located bolt holes in t 1 ! baseplates, pipe' supports, and cable tray supports were
" plug welded" without authorization, with undocumented weld filler metal and without Quality control f inspectio p RC Region IV had substantiated the '
allegation, in part, with the identification of r ppp4 undocumented " plug welds" in cable tray supports. l Further details on the allegation were obtained by the C tnt from a review of ASLB testimony. _b
89 R. Masterson 1/)1f/86 Appendix B Section 4.4 4.4.1 Introduction (Continued) The TRT determined that the ASME B&PV Code, Section III, Subsection NF was applicable to Class 1, 2, and 3' pipe hangers and supports, that ANSI B31.1 Power Piping Code was applicable to Class 5 and 6 pipe hangers and supports, and that AISC Specification for Design, Fabrication and Erection of Structural Steel for Buildings, were applicable to cable tray supports. The first two codes both reference Section IX of the ASME B&PV Code for welding procedure and welder performance qualifications. The last one references AWS Dl.1 Structural Welding Code. T TRT reviewed the appropriate editions of the applicable codes in detail and established that none of them set forth explicit requirements authorizing,
, prohibiting, or governing the repair by welding of fabrication errors such as misdrilled holes. (The TRT noted that a later edition of AWS Dl.1 specifically addresses the repair of misdrilled holes by welding.)
ve,y jL Consequently,h e TRT concluded that the repair of m a h,illed no es by welding was not prohibited 4 f M# fb/goss ofM MHessM Cse ss . y [ The TRT review of Brown and Root Specifications established that misdrilled holes were reoarded as base material def For Class 1, 2, 3, 5, and 6 sup NC (such defectspre supposed to be dispositioned 04 byass+R nw. action. Q cable tray supports engineering dir :timr-W requir % O(
/7 The TRT concluded that the identification of undocumented " plug welds" and the difficulty in detecting them raised a generic concern as to the potential existence of an unknown number of unauthorized
" plug welds" of questionable quality. Potentially defective welds in highly stressed areas could have safety significance.
7_ If R. Masterson 1/)/f786 Appendix B Section 4.4 4.4.1 Introduction (Continued)
//q M /A The TRT dirccted-that the Applicant modify a plan of action already proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocumented " plug welds" on the ability of pipe supports, cable, tray supports, and baseplates to perform their intended function.
Item V.e: Repositioning of the Main Steam Line The TRT investigated an alle relating to
% nstruction deficiencies during installation M a Unit
( 1 Main Steam (MS) line. It was alle at the 32-inch MAvr/ MS line was forced into position by the polar crane and 3-ton come-alongs and that " tension" induced in the line as a result of movement during the alleged incident was still present in the line. The TRT investication substantiated the alle _artdTheTRT N. N $at repositioning of the Unit 1 loop 1 MS line had been performed due to settlement of ww temporary supports. The TRT dctemaa&Oned that the partially installed line had sagged due to settlement of a e nw > ysn erer temporary support 5during flushing,;and/or construction. ; A*ws l The TRT also determined that the TUECjanalysis performed 1 year after the alleged incident did not adequately address the full sequence of events involved in the incident. l Details of the TRT investigation of the allegation are % documented in CPSES SSER No. 10, pp N-99 through N-ll2. Details of related TRT investigations regarding improper welding of temporary supports are also documented in SSER No. 10, pp N-37 through N-42. L l 7 fU Y' A Y fff . lW Y k 7pgg. W M/rsw owsG & drys ~d .i :0 r slesdsw ree& AC ~ 7"& nm e.y fM&y S/6 efscA-+-r~ Cd"A5 &.
f9 R. Masterson 1/J6786 Appendix B Section 4.4 4.4.2 CPRT Acoroach 4.4.2 CPRT ADoroach Item V.a: In response to the November 29, 1984 NRC letter TUEC developed the CPRT Program Plan to include ISAP Va. This ISAP addressed the concerns of the TRT by siccaow q.t.i nMe.sw v r e> establishing a scope and methodology,jfor the Program Plan that is responsive to the issue.. The Program Plan inclu . a) cfreviewofadocumentedchronologyofinspection methods involving skewed welds to correlate the period of time and specific procedure revisions for the inspection of skewed welds. -) b) CProcedures QI-QAP-11.1-26, QI-QAP-ll.1-28, and CP-QAP-12.1 will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed welds. Wg;, Ar,gp cen.es}-re 70 MMes c) jyheadequacyoftheimplementationofthe E appropriate' inspection procedures (will be assessed:T ' by establishing a random sample of Type 2 skewed welds to be reinspected. The sample plan is based on achieving a 95% confidence level that less than 5% of Type 2 skewed welds were not inspected properly and may result in a safety significant j condition. The reinspections will be conducted by
, ao rvm third party.
y, f) d jyheresultsoftheprocedurereviewandphysical reinspections will be evaluated to assess root 9 / change and generic implications. Corrective action will be taken whenever modifications and procedural cause are required." ) e) 4GL results report will be written to document the results of all procedure reviews, physical modifications, trend analysis and corrective actions.
i [V : R. Masterson 1/) 4/86 Appendix B Section 4.4 4.4.2 CPRT Acoroach (Continued) Item V.b: The CPRT glan addresses the measures which are required to be taken to ensure that the steam generator upper lateral support meets design requirements and to review similar installations to determine if this issue pertains to other designs. i asMi~ Sectro u 4' /, (o h h h portio) of the CPRT response dealing with the shortening of the steam generator anchor bolts will be addressed under a Civil / Structural activity (DSAP VIII) which deals with the reanalysis of the upper and lower steam generator lateral supports. These supports are currently undergoing a complete reanalysis which may lead to a redesign of the support beam anchoring system. The adequacy of the " shortened" anchor bolts will be considered as part of this analysis, f# V g fw iySt&neA/WId'Q As part of the CPRT effort on this issue ill assess the potential generic appiteabil'ity of the bolt thread engagement issue for two other populations: o Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to determine that bolt engagement meets design requirements. If any cases of inadequate bolt engagement are identified, an assessment will be made to determine the ability of the component to carry its design load. If it is determined that the component cannot carry its design load increased sampling up to 100% reinspection will be utilized. If it is determined that the component can still carry its design load 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. o Bolted Connections - Bolted connections using blind holes will be identified by an engineering review of L structural / mechanical drawings. __
-g- gy R. Masterson 1/y/86 Appendix B Section 4.4 4.4.2 CPRT Acoroach-(Continued)
- The blind holes identified will form a second population jg and any cases of inadequate bolt engagement will be fa rar 1 ' l_ Evaluated as described above for Richmond inserts.
ItemV.c:h(fbeProjectPipingandSupportsProgram < (PPSP) together with the Design Adequacy Program (DAP) includes provisions for significant piping reanalysis andassociatedsupportrequalificatioq[~Therefore'7fthe CPRT will address the major concerns of this issue within the PPSP and DAP. The scope of this specific action plan will be limited to the following activities 4 5 dere w s o w 5 d e>r M '/. A/ rA+ts v 64 e x 3p /J c. ? o Identification of all Unit 1, 2 and common, piping which has a seismic /non-seismic interface which will include:
- Category I piping entering a non-Category I Building.
- Piping with a class change from Category I to non-Category I.
- Piping runs which have a portion which is seismically
/#N# analyzed to postulate breaks.
- NNS piping runs which have a portion which is seismically analyzed to postulate breaks.
o A review and discussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based. o Recommendations to the PPSP and/or the DAP based on the results of the two items above. Any potential implications which should be considered during the PPSP and DAP implementation will be highlighted, i i i
49 R. Masterson 1/p/86
- Appendix B
- - Section 4.4 i 4.4.2 CPRT Anoroach (Continued)
Item V.d: Plug Welds Wg, fy S/crise y;e i.s# Vd g The CPRT Sction plarp hag initial objectives: (1) the verification of the presence or absence of undocumented " plug welds" in ASME pipe supports and l baseplates. l (2) verification of the quality of cable tray supports l containing undocumented plu eldg gf, g,g g,,,rr=s;o & To accomplish the first k ec g b ,e,ga sample of pipe j supports and baseplates representative of reactor Unit 1 and common components and a second sample of. pipe j supports and baseplates representative of reactor Unit 2 1 g li bptselect s for examinatio [ Each sample plan is to be based n identifying with 95% confidence level M - At as 6 M**At - "*tw " m e d M we &sn e w & i o F 8 # n N M f w t, w r u u W .srateg mum ghe random mi sample sizg of undocumented or fd l
- unauthorized plug welds is 60 with an acceptance number of zero.
g guptsnis ex 'de're"S W4 ZA" 4' 4 / 3 jGthen a suspected " plug weld" is found, the paint will be i. 4 removed from the support, the presence of a " plug weld" verified, visual inspection made, and comparison made to 4 prior documentation to determine if the " plug weld" was or was not authorized. .NCRs will be issued for i unauthorized " plug welds" and engineering evaluation i performed to evaluate structural integrity of the baseplate of supportj If structural integrity is not affected, the need for additional inspection will be l l based on observed trends in the inspection results.
/* g' ,g,w:;
W W O /t/~Ce*** wr3 nW l f an. y support / / .1 m or (su.baseplate
- f. lacks structural integrity because of.an unauthorized or undocumented " plug weld",
) '
the sample plan will be either expanded or increased to
- 100% inspection. If no unauthorized or undocumented
! " plug welds" are found, it will be concluded that the 1 l structural integrity of ASME pipe supports and ! baseplates has not been deg'raded by the presence of such welds. c i
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S'ection$.4 f.4.2 CPRT Acoroach (Continued) # M "* W ' Z.- g g ficcepus 9'N & 7pd4M V /' l U N
/ Cc;;110: 7 &n t- h i c: imrartigation .;ill b9 a review of * * * * * '
- existing QC inspection and documentation proce6u'"re's'fon-j fas,.,r e
necessary changes @ d'6(/ V /WrA4 WAfLrf d er&;e virw ces 17h6 torns- sf//p ses" wn dd AMtE.y p4CNsedo w s O rm 9'x5 To accomplish the second objective,grandom samples of rev ae w
*Ai cable tray supports in both p its 1 and 2 will be inspected and, if necessary, subjected to engineering evtluation. The investigative steps, in general, parallel those for ASME pipe supports and baseplates.
Results will be used to assess the root cause and to determine generic implications, s gfj,,,y eg g.,4 n <A<4 C jQ&M% j Preceding either of the above objectivesgic the fut development of a viable inspection procedure to identify
" plug welds", including criteria for paint by personnel meeting the CPSES Quality Assurance Program or personnel qualification requirements of the CPRT Program Plan.
Item V.e: (epositioningoftheMainSteamLi The CPRT approach to resolve the TRT concerns resulting from the TRT investigation of the allegations regarding forced movement of the MS line and improper welding of temporary supports is described e J in Section 4.0, "CPRT Y l-Action Plan" of ISAP V.3, Rev. K. A reviewj$fcinw 4/*** ofjthp CPRT plan indicates that specific engineering evaluations of the MS line incident and a generic study of possible damage to other piping are proposed.
89 R. Mrsterson 1/)1f/86 Ap;:ndh ; ' Sectiontf.4
/.4.2 CPRT Aporoach (Continued)
Z. The specific engineering evaluation includes: reviews
-of procedures for pipe erection and placement of temporary and permanent pipe supports; interviews of j personnel involved in the MS line incident; evaluations l of procedures and practices; analytical evaluations of full parametric variations of analysis inputs for the MS line incident; significance of stresses and support l
loads resulting from the analytical evaluations; reviews of existing UT examinations and hydrostatic test data for the affected MS line; and a possible reinspection
- l program.
l The generic study for possible damage in other piping, i including the Unit 1, Loop 4, MS line includes: reviews and procedures for pipe erection and placement of I temporary and permanent pipe supports; reviews of Nonconformance Reports (NCR's) and Piping Deviation ! Request Forms (PDRF's) for circumstances similar to the { MS line incident; interv'iews of pipe installation i ~ personnel to determine piping subjected to adjustments during fitup; review of all other sources of residual stresses in piping systems; evaluations of the [ ] significance of residual stresses due to fitup; possible
- additional pipe fitup evaluations; and possible
! modifications to Gibbs & Hill (GEH) specifications 1 and/or related procedures to ensure that piping and 4 j associated equipment are not adversely affected during j flushing activities and/or by the use of temporary ; supports. l Section4.3," Responsibilities",ofISAPV.e[Rev.1 indicates that all activities w N to be performed by
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third party (including a verification of previous work done by RLCA) except for the modification (if required) of procedures and specifications for the control of pipe f
- erection, temporary supports'and hydrostatic testing and l flushing which was to be a Comanche Peak Project l
Engineering responsibility.
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?sesudia B" Section4(.4 f,f.d.3 ftpff Evp] pat ion 2,./.4.3- Staff., Evaluation Item V.a: The staff has reviewed the CPRT Program Plan, ISAP Va,3xa 1 sn x ro,ww odhamans.and found the plan cenerally to be responsive to the issuef The plan had identified chronology of inspection methods and its relationship to procedure revisions to be the proper starting point. The plan also addresses the adequacy of imp'lementation of the appropriate inspection procedures w Yeproposed sampling plan. The staff believes'that this aspect of the plan will most-likely identify the root cause of the skewed weld inspection problem. The staff expects the root cause and subsequent generic implication of this issue to be positively identified, since this issue had been previously identified in the ASLB hearings and addressed by TUEC. The fact that a procedure interpretation problem existed after action by TUEC is suggestive that there could be generic implications with respect to procedure revision and implementation /p orh# 44Qt-s r# W /N The staff also reviewed the CPRT response $f Novembe N
,1985])to the staff comments (dated tember 30 ffMww.2 as nm ?Sep%m Nm rp>6-1985) on ISAP Va. In thir rerpen:: 07. 2 3co 5^ 01 thc-responses for Items 2-4 are acceptable since they are mainly clarifying in nature. However, the response to Item 1 requires additional explanation. The staff could not find where both Type 1 and Type 2 skewed welds were addressed by B & R procedure QI-QAP-ll.1-28. If this were the case, then " stanchion welds" would have been inspected using the skewed weld inspection methods and marked as such on the QC checklist.
I M 1/J8/86 R. Mestorcon App-udi, L
. Section 4.4 f.4.3 Etaff Evaluation (Continued) 4 Item V.b: The staff, since it first identified this issue in its November 8, 1984 letter to TUEC, has been actively following the activities concerning this subject. The staff feels that the CPRT Program Plan has the ability to address all staff concerns relating to 6aus sw nc mue ads amas-the specific issueg The Plan addresses possible generic implications by reviewing other designs that have the potential for similar thread engagement deviations. The Plan provides for performing random inspections of Richmond inse'rts and other blind bolt installations.
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to thir irru ir-when it is determined that a component can still carry its design load for all observed cases of less than adequate engagement, the need for additional inspection will be based on an evaluation of the trends in the inspection data. The staff must look AA ra s Avs. dw w at the basigfcase by case to determine if the trends do or do not require additional inspections. l l The CPRT response to the three questions raised in the l NRC Staff Evaluation dated September 30, 1985 have been l responded to in a manner acceptable to the NRC Staff /#
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Item V.c: The staffA has As w -.d_.._ reviewed theAlou P W p- plan __&_- - m-
^c ~ w/> J..~4erffty -that the CPRT ipp rwob uses cwcfk Plan understandsj and has the potential to identify 2
items similar to the (item causing th3 o. *r iginal concern.
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In addition, the NRC staff has performed an audit at Stone & Webster Engineering Corporation (SWEC) offices. The purpose of this audit was to discuss with SWEC their scope and methodology for addressing this concern. The SWEC method has been determined by the staff to have the potential to identify and address this concern. I The CPRT response to the four questions raised in the NRC Staff Evaluation dated September 30, 1985 have been responded to in a manner acceptable to the NRC staff /#
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F R. Masterson 1/)8/86 ann.nM +
. Sictiontf.4 / 4.3 Staff Evaluation (Continued)
Item V.d: Plug Welds Preliminary critique by the staff of the CPRT Program Plan raised several concerns, some of which have been adequately resolved. The staff's concern about the j following items remains unresolved: l (1) In 4.1.1.1, the second paragraph is confusing. The statement is made "The Sample Plan will be based on identifying with a 95 percent confidence a rate of- 1 detectable plug welds 5% or greater. The smallest random sample which will achieve this confidence level and rate of unauthorized or undocumented plug welds is 60,withanacceptancenumberogzero." ghge, wm 7g &,3 l I statements seem contradictory.j ace-we establishing, with a confidence level of 95%, the rate of detectable plug welds or the rate of unauthorized or undocumented plug weld . Also,pr Sarpthe ratxmst cusv.moe rrssmesu eswrW , greate 4 or Q 5% hesp (2) The Staff expressed concern that there is uncertainty as to the ability to detect a plug weld covered by paint and that this uncertai t should be a _ we / factored into the sample size. The CPRTg has reported ! the results of inspection of simulated cable tray I support members containing " plug welds" made, surface i prepared using methods available to CPSES personnel, and painted. The inspectors tested detected, on average, 82% of the " plug welds". The maximum detected was 94%.
/.s or nGer ewrW The TRT notes that this reported capabilityg e the l
CPRT Program Plan stated intent of 95% confidence of a rate of 5% or more. pry og c/Ar_qnr:Ap uv== Ave ,m m= ursu ysvev== + mm,nc[ NtNN.9Wu [Ye b (3) In March of 1985 at the CPRT action plan presentation b CPSES, the TRT stated its posit' ion that volumetric examination of any unauthorized " plug welds" found should be made since the welder, who was trying to avoid QC cognizance, would be' to rush the job l and may, therefore, have used poor welding techniques. l 1 The.CPRT has not responded directly to this position. l l
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U R. Masterson 1/%/86
, syycuula B SectionZE.4 g.4.3 Staff Evaluation (Continued)
Z (4) The sample plan (Section 4.1) and the definition of a reject were stated by the TRT as incompatible as currently written. CPRT's response, which references 3.4 ISAP V.a, Item 1, is confusing and needs fvN#4 explanation. Item V.e: hpositioning of the Main Steam The staff revfeh' @ t E IhT N $ ails of the specific engineering evaluation and the generic study of possible damage to other than the Unit 1, Loop 1, MS piping was responsive to the actions required of TUEC by the TRT. s {aresultofitsinvestigationoftheMSlineallegation. These actions are given in SSER No. 10, P. N-110, Items 1 through 8. A comparison of items in the h getion [lanandtheactionsrequiredofTUECbytheTRTfound that ^ !bNT .htier"lnwassufficienttoumbrellathe actions required cf T"EC by th " " " ' M O## '
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However, t c e N: (1) Theobservation)otedinSection3.2, " Preliminary Determination of Ro t ag e and Generic Implications" of ISAP V.e, Rev. , thap "in construction practice, it is not at all uncommon to perform adjustments in pipe position prior to final welding, particularly when permanent supports are installed subsequent to final fitup" could predisposition the implementation of the CPRT evaluations and studies. (2) The third party review of the RLCA work should not be limited to a verification only. Provisions for additional third party investigations should be provided, if required.
g R. Masterson 1/MI/86
. f.ppe. dix B -
Section//.4 4.4.3 Staff Evaluation (Continued) (3) Although the CPRT has indicated that its investigations performed as part of ISAP V.e, Rev. , have concluded that the sequence of events described in SSER No. 10 relating to MS line incident is not correct, the generic implications of settlements of supports and stresses due to hydrostatic testing and flushing activities will still be required to be evaluated by TUEC, S/.+t-6 7456 Sd&V4 rcd fp .e'~rd'ts ddJcAV.<f fo
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fly /7%S 772f~C&c/c-d /Ms rf dc.-d'V44 4 4 f'"'*'" f.4.4 Conclusions Item V.a: The staff conducted an evaluation of the CPRT g/ . atr/ Sim rurProgram Plan for ISAP Va and found the action Ass ~ Aaacsro nuness mem .sorsemd ws,w plan t a ms
- a. m g jg responsive to the issues raisedj The staff, however, requires assurance that the root cause of the issue and %
its generic implications are properly addressed in the action plan. The CPRT TRT issues manager should assure f the staff that both items will be addressed goor cAuss in the { results report. The staff perceives theg generic implication aspect of this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC. y p CR2/ & p5 & M'
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3o In addition, the response to Item 1 -in=th Nc't:-2 : 22, . 19 8 5 W^'.,Y. . '"'_.*'
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Sectiontg.4 f.4.4 Conclusions (Continued) 'W NY Y 2- y g y cou w s&S Item V.c: ,/7f the CPRT Program PlaO is implemented as stated in the Plan all areas related to the original Msowde concern will be identified and di pered ef-in a manner consistent with sound engineering practice, FSAR D cbSI.N and NRC guidelines. Item V.d: For the issue concerning plug welds, the Staff concludes that there are important questions Swd w usesoso 4 y related to the CPRT Program Plan which f must be satisfactorily answered prior to approval of the Plan. Item V e: For the issue concerning the repositioning of the main steam line, the specific engineering evaluation and generic study described in ISAP V.e, Rev. , of the CPRT Program Plan provides an acceptable basis for resolution of the issues and concerns resulting from the TRT investigations of allegations regarding forced movement of the main t,e,am pj line and impro g wp g g of temporary supports. Ax nwe Final acceptability! is contingent ad-upoli verificationgo proper implementation of the details of the specific engineering evaluations of the main steam line incident and the generic study of possible damage to other piping. I l l l l
gg g.t +45 W g/ 7 a .' ///fA p P 20 gy rit e SECTION IV - STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN - Draft l - 1/30/86 APPENDIXpM L nev W 4I4 Mechanical & Piping Issues WI.4.1
, Introduction Item V.a: Inspection of Certain Types of Skewed Welds in NF Supports.
During the CPSES ASLB hearings an allegation was made that Brown & Root (B&R) (C inspectors did not have adequate instructions or training to properly measure the size of skewed fillet welds during the inspection of pipe supports. The NRC Region IV reactor inspectors in their inspection reports 50-445/82-It and 50-445/84-08 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of its implementation. The TRT assessed the same allegation during its July-September 1984 7WC. twse ese ses,e.s onsite investigation and concluded that,fsnere was nm documentation - that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., interfaces of curved sections). Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition. Item V.b: Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports. During the July-Septembver 1984 investigation, the TRT was informed that some of the anchor bolts in the steam generator upper lateral support were shortened during installationpto less than the length shown on the design drawingg/W1tnout proper authorization) Based on the results of its investigation, the TRT requested that TUEC provide evidence, such as ultrasonic measurement that would verify the actual installed bolt lengths.
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21 4/ 4 y wno s enwf connav <'sJ The TRT requested that should the bolts be determined to have been installed to engagement >1ess than that shown of design drawings, TUEC shall: o Replace shortened bolts with bolts of the proper length or provide analysis to justify the adequacy of the installed bolts. o Provide justification or propose measures to ensure that no similar concern exists for other bolting. TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations. This deficiency was reported on January 17, 1985 in accordance with 10 CFR 50.55(e). Item V.c: Design Consideration for Piping Systems Between Seismic Category I and Nonseismic Category I Buildings. The TRT in reviewing the Comanche Peak Special Review Team Report determined that certain piping systems are routed from the Electrical Control building (seismic Category I) to the Turbine Building (nonseismic Category I) without any isolation. Since the FSAR , postulates Turbine Building failure during a safe shutdown earthquake (SSE) the effect of Turbine Building failures on any nonisolated piping routed from any seismic Category I building to the Turbine Building must be considered. In addition, for nonseismic Category I piping connected to seismic Category I piping, the dynamic effects of the nonseismic Category I piping must be considered in the seismic design of the seismic Category I piping and supports, unless it can be shown that the dynamic effects of the nonseismic Category I piping are isolated by , I anchors or restraints b< iw.a to c.<xsy y co s.,siva ww"* 1
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Item V.d: Plug Welds The TRT investigated allegations that incorrectly located bolt holes in baseplates, pipe supports, and cable tray supports were " plug welded" without authorization, with undocumented weld filler metal and without Quality Control . inspection. The TRT concluded that the repair of misdrilled holes by welding was not prohibited by the appropriate editions of the applicable Codes. The TRT review of Brown & Root specifications established that misdrilled holes were regarded as base material defects and were supposed to be dispositioned by NCR action or engineering evaluation. The TRT concluded that the identification of undocumented " plug welds" and the difficulty in detecting them raised a generic concern as to the potential existence of an unknown number of unauthorized " plug welds" of questionable quality. Potentially defective welds in highly stressed areas could have safety significance. The TRT required that the Applicant modify a plan of action already proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocumented " plug welds" on the ability of pipe supports, cable, tray supports, and baseplates to perfonn their intended function. Item V.e: Repositioning of the Main Steam Line. The TRT investigated an allegation that the 32-inch MS line was forced into position by the polar crane and 3-ton come-alongs and that
" tension" induced in the line as a result of movement during the alleged incident was still present in the line.
The TRT determined that repositioning of the Unit I loop 1 MS line had been performed due to settlement of temporary supports. The TRT learned that the partially installed line had sagged due to settlement of temporary supports during flushing of the system and/or
I V
&/ / winy n ns a f cnema) construction. The TRT also determined that the TUEC piping analysis-performed 1 year af ter the alleged incident did not adequately address the full sequence of events involved in the incident.
According'y, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety-significant condition.
.y A.4.2 CPRT Approach Item V.a: In response to the November 29, 1984 NRC letter, TUEC developed the CPRT Program Plan to include ISAP Va. This ISAP addressed the concerns of the TRT by establishing a scope and methodology, Sections 4.1.1 through 4.1.6, for the NEN Y that is responsive to the issue. The 9I((U included a review of a documented chronology of inspection methods involving skewed welds to correlate the period of time and specific procedure revisions for the inspection of skewed welds. Procedures QI-QAP-11.1-26, QI-QAP-11.1-28, and CP-QAP-12.1 will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed welds.
TUEC also committed to assess the adequacy of the implementation of the appropriate inspection procedures by establishing a random sample
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of Type 2 skewed welds to be reinspected. The sample plan is based on achieving a 95% confidence level that less than 5% of Type 2 skewed welds were not inspected properly and may result in a safety significant condition. The reinspections will be conducted by a third party. Finally, the results of the procedure review and physical reinspections will be evaluated to assess root c k and generic-implications. Corrective action will be taken whenever modifications and procedural cause are required. A results report will be written to-document the results of all procedure reviews, physical modifications, trend analysis and corrective actions.
.. [ ' _24 (pp r-AN'/hM &?W*& Item V.b: The CPRT Plan addresses the measures (wffich a3 required to takenJensure that the steam generator upper lateral support meets design requirements and to review similar installations to determine if this issue pertains to other designs. As sated in Section 4.1.1 cf ISAP Vb, thread engagement of the SG upper lateral restraint anchor bolts was determined to be less than required by design on the basis of inspections performed in Unit 1. Gibbs & Hill has determined by an engineering assessment that the design engagement should be provided and rework will be prescribed as-necessary. This has been design reviewed by TERA. A similar inspection will be performed for Unit 2 and appropriate action taken. Section 4.1.2 provides for examination of the bolts and blind threaded holes during the bolt replacement to aid in the root cause assessment. This will include review of dimensional tolerance of assembly parts. As part of the CPRT effort on this issue the Plan in Section 4.1.3 of ISAP V.b will assess the potential generic applicability of the bolt thread engagement issue for two other populations: o Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to determine that bolt engagement me.ets design requirements. If any cases of inadequate bolt engagement are identified, an assessment will be made to determine the ability of the component to carry its design' load. If it is determined that the component cannot carry its design load increased sampling up to 100% reinspection will be utilized. If it is determined that the component can still carry its design load 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 l inspection data. j l o Bolted Connections - Bolted connections using blind holes will be identified by an engineering review of structural / mechanical drawings. p x4cr Qv s Wr/**C l
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hy g (P/2r AA*AbMa %r;rwde) m g gA ' e blind holes identified will form a second population and any cases uf inadequate bolt engagertent will be evaluated as described above for kichmond inserts. s [ In Sections 4.1.4 and 4. p ( of ISAP V,b, the CPRT commits to a third-party review of the process by which critical attributes of bolted connections were specified and the definition of their associated inspection criteria and documentation requirements. This will include an evaluation of the apparent lack of installation records for the SG upper lateral restraint. A third-party overview of all aspects of the Action Plan will also be completed. This will include the inspection plans for the UT of installed bolts as defined in 4.1.3, design calculations required for the evaluation of shortened bolts, and visual inspection of bolts and threaded holes during bolt repl acement . Finally, based upon the methods described in Sections 4.1.2 through 4.1.5 and their results, the root cause and generic implications will be determined. Section 4.1.6 of the CPRT response dealing with the shortening of the steam generator anchor bolts will be addressed under a Civil / Structural activity (DSAP VIII) which deals with the reanalysis of the upper and lower steam generator lateral supports. These supports are currently undergoing a complete reanalysis which may lead to a redesign of the support beam anchoring system. The adequacy of the " shortened" anchor bolts will be considered as part of this analysis. Item V. : Since the Project Piping and Supports Program (PPSP) together with the Design Adequacy Program (DAP) includes provisions for significant piping reanalysis and associated support requalification, the CPRT will address the major concerns of this issue. within the PPSP and DAP. The scope of this specific. action plan will be limited to the-following activities as outlined in Sections 4.1.1 through 4.1.3 of ISAP V.c:
I -
.. 3 g,.s.cr of Ao *wl@<m w.e:o) o Identification of all Unit 1, 2 and common, piping which has a seismic /nonseismic interface which whill include:
- Category I piping entering a non-Category I Building.
- Piping with a class change from Category I to non-Category I.
- Piping runs which have a portion which is seismically analyzed to postulate breaks.
- NNS piping runs which have a portion which is seismically analyzed to postulate breaks.
o A review and sicussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based. o Recomendations to the PPSP and/or the DAP based on the results of
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the two items above. Any potential implications which should be considered during the PPSP and DAP implementation will be highlighted. Item V.d: Plug Welds In Section 4.1 of ISAP V.d the CPRT has defined ini.ial objectives:
- 1. The verification of the presence or absence of undocumented " plug welds" in ASME pipe supports and baseplates.
- 2. Verification of the quality of cable tray supports containing undocumented plug welds.
To accomplish the first objective, the CPRT in Section 4.1.1.1 has comitted to select for examination a sample of pipe supports and baseplates representative of reactor Unit I and common components and a second sample of pipe supports and baseplates representative of reactor. Unit 2. Each sample plan is to be based on identifying with 95% confidence level a rate of detectable plug welds of 5% or greater. The minimum random sample size, which will achieve this confidence level and rate of undocumented or unauthorized plug welds, is 60 with an acceptance number of zero.
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As specified in Sections 4.1.1.2 and 4.1.1.3 when a suspected ' plug weld' is found, the paint will be removed from the support, the presence of a ' plug weld' verified, visual inspection made, and comparison made to prior documentation to determine if the ' plug weld' was or was not authorized. NCRs will be issued for unauthorized " plug welds" and engineering evaluation performed to evaluate structural integrity of the baseplate of support. In Sections 4.1.1.4 and 4.1.1.5 the CPRT commits that if any support or baseplate lacks structural integrity because of an unauthorized or undocumented " plug weld", the sample plan will be either expanded or increased to 100% inspection. If no unauthorized or undocumented
" plug welds" are found, it will be concluded that the structural integrity of ASME pipe supports and baseplates has not been degraded by the presence of such welds. If structural integrity is not affected, the need for additional inspection will be based on observed trends in the inspection results.
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Item 'a Inspection of Certain Types of Skewed Welds in NF Supports During the CPSES ASLB hearings an allegation concerning the improper inspection of skewed fillet welds was made. The allegation stipulates that Brown & Root (B & R) QC inspectors did not have adequate instructions or train-ing to properly measure the size of skewed fillet welds during the inspection of pipe supports. The NRC Region IV reactor inspectors in'their inspection reports 50-445/82-14 and 50-445/84-08 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of its implementation. The TRT assessed the same allegation during its July-Sept 1984 on-site investigation and concluded that there was no documentation that certain types of skewed fillet welds were reinspected correctly. The TRT discovered that during the Vendor Certified Drawing (VCD) reinspection program for ASME supports, certain welds that exhibited a skewed condition, i.e. interfaces of curved sections, were not properly inspected. Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition. l 1 e /
I PP 6 MISC 11 - 4.4 VM QL Draft 1 - 1/2/86 N Q f .
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[ hik4 'l N 4.4 Mechanical and Piping Issues y { gpg ( 4.4.1 Introduction _ yy,i&rgsosnw(u">J j Item V b: Improper Shortening of Anchor Bolts in $ team Generator ! Upper Lateral Supports. The TRT was informed that some of the anchor bolts in the steam generator upper lateral support were shortened during installation to less than the length shown on the design drawings without proper
, authorization. The TRT was unable to verify the length of these installed bolts since TUEC was unable to produce any installation records. The TRT requested that TUEC provide evidence, such as
- ultrasonic measurement that would verify the actual insta11eo bolt lengths.
The TRT requested that should the bolts be determined to have been installed to engagement less than that shown of design drawings, TUEC shall: Replace shortened bolts with bolts of the proper length or provide
. . analysis to justify the adequacy of the installed bolts.
Provide justification or propose measures to ensure that no similar concern exists for other bolting. TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations. This deficiency was reported on January 17, 1985 in accordance with 10 CFR j 50.55(e). Item Vc: Design Consideration for Piping Systems Between Seismic
% j~ , Category I and Non-Seismic Category I Buildings.
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PP 6 9 l y g ff/A A AMl dings in g t/,f p(c ovW h Peak Special Review Team i ns determined that certain pip n ig fin The TRT in reviewing the Comanc (seismic eofny pipin ( the area systems are routed-from the Electrical Control constraint Buildingild is not ier or in the ; Category isolation. I) to the Turbine BuIf isolation by h feasible, then the effect ' W o R :i:ri fa$hn m on t e FSAR i
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non-seismic piping d tha 3-13.1). Therefore, since the rthquake
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d piping considered (CPSES failure FSARduring 3.78 a sat'e shut ; l I g postulates Turbine Building (SSE) the . routed from any seismic Catego [ ismic , (E , be considered, ory I piping connected to seCatego f In addition, for non-seismic Categeffects of the non-i ffects
; Category I piping, the dynam c the seismic designor of thec !
{ [ piping must be considered inI ust bepiping /
/
of the non-seismic Category traints used for isolation mh t ' h5
._ restraints. The anchors or rescombined loadings im designed to withstand ismicthe Category I piping.
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appendix b, 4.4 MISC 10 ' 12/26/85-Draft 2 Appendix B Staff Evaluation of the CPRT Construction Adequacy Program - Plan
- 4. External Source Issues 4.4 Mechanical and Piping Issues I 4.4.1 Introduction M 17f?Vd, ptub wfca5 It was alleged that incorrectly located bolt holes in baseplates, pipe supports, and cable tray supports were " plug welded" without authorization, I with undocumented weld filler metal and without Quality Control inspection.
NRC Region IV had substantiated the allegation, in part, with the j Further identification of undocumented " plug welds" in cable tray supports. I details on the allegation were obtained by the TRT from a review of ASLB' testimony. The TRT determined that the ASME B&PV Code Section III, Subsection NF was applicable to Class 1, 2, and 3 pipe hangers and supports, that ANSI B31.1 Power Piping Code was applicable to Class 5 and 6 pipe hangers and supports, and that AISC Specification for Design. Fabrication and The Erection of Structural Steel for Buildings, were applicable to cable tray supports. first two codes both reference Section IX of the ASME B&PV Code for welding The last one references .AWS procedure and welder perfomance qualifications. D1.1 Structural Welding Code. The TRT reviewed the appropriate editions of the applicable codes in detail and established that none of them set forth explicit requirements authorizing, prohibiting, or governing the repair by welding of fabrication errors such as misdrilled holes. (The TRT noted that a later editionConsequently, of AWS D1.1 specifically the TRT addresses the repair of misdrilled holes by welding.) concluded that the repair of misdrilled holes by welding was not prohibited. The TRT review of Brown and Root Specifications established that misdrilled For Class 1, 2, 3, 5, and 6 holes were regarded as base material defects. For supports, such defects were supposed to be dispositioned by NCR action. cable tray supports, engineering direction was required.
l h ' M '/./ /uM40Me "(_Cw'r) The TRT concluded that the identification of undocumented " plug welds" and the f difficulty in detecting them raised a generic concern as to the potential existence of an unknown number of unauthorized " plug welds" of questionable quaiity. Potentially defective welds in highly stressed areas could have safety significance. The TRT directed that the Applicant modify a plan of action already proposed to NRC Region IV with respect to specific items or perfom a bounding aaalysis to assess the generic effects of undocumented " plug welds" on the ability of pipe supports, cable, tray supports, and baseplates to f perfom their intended function. gre % Repositioning of the Main Steam Line The TRT investigated an allegation relating to construction deficiencies during installation of a Unit 1 Main Steam (MS) line. It was alleged that the 32-inch MS.line was forced into position by the polar crane and 3-ton come-alongs and
. that " tension", induced in the line as a result of movement during the alleged incident was still present in the line.
The TRT investigation substantiated the allegation in part. The TRT found that l repositioning of the Unit 1 loop 1 MS line had been perfomed due to settlement of temporary supports. The TRT detemined that the partially installed MS line l had been used in flushing operations and that the partially installed line had sagged due to settlement of temporary support during flushing and/or
- construction. The TRT also detemined that the TUEC analysis perfomed 1 year after the alleged, incident did not adequately address the full sequence of events involved in the incident. ~
Details of the TRT investigation of the allegation are documented in CPSES SSER No.10, pp N-99 through N-112. Details of related TRT investigations regarding improper welding of temporary supports are also documented in SSER No.10, pp N-37 through N-42. p I e
/'R Masterson (To be inserted in section 4.4.2 of Teledyne's draf i Appendix B C A/2 r 4 4 " W Ilem Va In response to the November 29, 1984 NRC letter TUEC developed the CPRT Program Plan to include ISAP Va.
This ISAP addressed the concerns of the TRT by establishing a scope and methodology for the Program Plan that is responsive to the issue. The Program Plan included: a) A review of a documented chronology of inspection methods involving skewed welds to correlate the period of time and specific procedure revisions for the inspection of skewed welds. b) Procedures QI-QAP-ll.1-26, QI-QAP-ll.1-28, and CP-QAP-12.1 will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed welds. c) The adequacy of the implementation of the appropriate inspection procedures will be assessed by establishing a random sample of Type 2 skewed welds to be reinspected. The sample plan is based on achieving a 95% confidence level that less than 5% of Type 2 skewed welds were not inspected properly and may result in a safety significant condition. The reinspections will be conducted by a third party. d) The results of the procedure-review and physical reinspections will be evaluated to assess root change and generic implications. Corrective action will be taken whenever modifications and procedural cause are required. e) A results report will be written to document the results of all procedure reviews, physical modifications, trend analysis and corrective actions. cu
l gL cA/27- J/94WLcs !r) Item V.b The CPRT plan addresses the measures which are required to be taken to ensure that the steam generator apper lateral support meets design requirements and to review similar installations to detemine if this issue pertains to other designs.
~
I ' This portion of the CPRT response dealing with the shortening of the steam generator anchor bolts will be addressed under a Civil / Structural activity (DSAP VIII) which deals with the reanalysis of the upper and lower steam generator lateral supports. These supports are currently > undergoing a complete reanalysis which may lead to a redesign of the support beam anchoring system. The adequacy of the " shortened" anchor bolts will be considered as part of this analysis. As part of the CPRT effort on this issue they will assess the potential generic applicability of the bolt thread engagement issue for two other populations: o Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to detemine that bolt engagement meets design requirements. If any cases of inadequate bolt engagement are identified, an assessment will be made to detemine the ability of the component to carry its design load. If it is detemined that the component cannot carry its design load increased sampling up to 100% reinspection will be utilized. If it is detemined that - i the component can still carry its design load for all observed cases of less than design thread engagement, the need for i additional inspection will be based on an evaluation of trends in 7 the inspection data. l l l 1 1 o Bolted Connections - Bolted connections using blind holes will be identified by an engineering review of structural / mechanical drawings. The blind holes identified will fom a second population and any cases of inadequate bolt engagement will be evaluated as described above for Richmond inserts.
.= . . - - -- - . _ ._ _ - --
tj' f. 2 CA47*WNNh"W Item V.c The Project Piping and Supports Program (PPSP) together with the Design Adequacy Program (DAP) includes provisions for significant piping reanalysis and associated support requalification. Therefore, the CPRT will address the major concerns of this issue within the PPSP and DAP. The scope of this specific action plan will be limited to the following activities i o Identification of all Unit 1, 2 and common, piping which has a seismic /non-seismic interface which will include:
- Category I piping entering a non-Category I Building.
- Piping with a class change from Category I to non-Category I.
- Piping runs with attached piping (i.e., small branch lines) which have a class change. ,
NNS piping runs which have a portion which is seismically ! analyzed to postulate breaks. o A review and discussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based. o Recommendations to the PPSP and/or the DAP based on the results of the two items above. Any potential implications which should be considered during the PPSP and DAP implementation will be highlighted. I i
7------------- g 7 f* d * ,P lug Welds The CPRT action plan has an initial objectives: the verification of the presence or absence of undocumented " plug welds" (1) in ASME pipe supports and baseplates. (2) verification of the quality of cable tray supports containing undocumented plug welds. To accomplish the first objective, a sample of pipe supports and baseplates representative of reactor Unit 1 and coninon components and a second sample of l pipe supports and baseplates representative of reactor Unit 2 will be selected for examination. Each sample plan is to be based on identifying with 95% I confidence a rate of detectable plug welds of 5% or greater. For this confidence level and rate, the minimum random sample size of undocumented or unauthorized plug welds is 60 with an acceptance number of zero. When a suspected " plug weld" is found, the paint will be removed from the support, the presence of a " plug weld" verified, visual inspection made, and ( comparison made to prior documentation to determine if the " plug weld" was or was not authorized. NCRs will be issued for unauthorized " plug welds" and engineering esaluation perfomed to evaluate structural integrity of the
,l baseplate of support. If structural integrity is not affected, the need for
. additional inspection will be based on observed trends in the inspection results.
1 4 If any support or baseplate lacks structural integrity because of an unauthorized or undocumented " plug weld," the sample plan will be either expanded or increased to 100% inspection. If no unauthorized or undocumented
" plug welds" are found, it will be concluded that the structural integrity of ASME pipe supports and baseplates has not been degraded by the presence of such -
w ids.
= - _ _ _ _
--- \ _.
Corollary to this investigation will be a review of existing QC inspection and documentation procedures for necessary changes. To' accomplish the second objective, random samples of cable tray supports in l both units 1 and 2 will be inspected and, if necessary, subjected to _/
. engineering evaluation. The investigative steps, in general, parallel those 1
for ASME pipe supports and baseplates. Results will be used to assess the root cause and to detemine generic implications. l Preceding either of the above objectives is the development of a viable inspection procedure to identify " plug welds," including criteria for paint by personnel meeting the CPSES Quality Assurance Program or personnel
-_Mion requirements of the CPRT Program Plan.
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' r* Ve: Repositioning of the Mein Steam Line The CPRT approach to resolve the TRT concerns resulting from the TRT investigation of the allegations regarding forced movement of the MS line and improper welding of temporary supports is described in Section 4.0, "CPRT Action Plan" of ISAP V.e., Rev. 1. A review of this CPRT plan indicates that-specific engineering evaluations of the M5 line incident and a generic study of possible damage to other piping are proposed.
The specific engineering evaluation includes: reviews of procedures for pipe erection and ' placement of temporary and pemanent pipe supports; interviews of personnel involved in the MS line incident; evaluations of procedures and
~
practices; analytical evaluations of full parametric variations of analysis inputs for the MS line incident; significance of stresses and support loads _resu1 ting from the analytical evaluations; reviews of existing UT examinations
~
and hydrostatic test data for the affected MS line; and a possible reinspection program.
~ )\ '
The generic study for possible damage in other piping, including the Unit 1 Loop 4, MS line includes: reviews' and procedures for pipe erection and placement of temporary and pemanent pipe supports; reviews of Nonconfomance Reports (NCR's) and Piping Deviation Request Foms (PDRF's) for circumstances similar to the MS line incident; interviews of pipe installation personnel to
- .detemine piping subjected to adjustments during fitup; review of all other
' sources of residual stresses in piping systems; evaluations of.the significance I
of' residual stresses due' to fitup; possible additional pipe fitup evaluations; l and possible modifications to Gibbs & Hill (G&H) specifications and/or related
~
l procedures to ensure that piping and associated equipment are not adversely ) affected during flushing activities and/or ty he use of temporary supports. Section 4.3, " Responsibilities," of ISAP V.e., Rev. 1, indicates that all
)
activities were to be perfomed by third party (including a verification of previousworkdonebyRLCA)exceptforthemodification(ifrequired)of procedures and specifications for the control of pipe erection, temporary supports and hydrostatic testing and flushing which was to be a Comanche Peak Project Engineering responsibility. l I . . _ ,. -- -. t - .-
7 _ - W b astersS Appendix B (To be inserted in section 4.4.3 of Teledyne's draft Item 4.4 3 End/f deak-&senw Item _Ea The staff has reviewed the CPRT Program Plan, ISAP Va, and found the plan generally to be responsive to the issue. The plaa had identified chronology of inspection methods and its relationship to procedure revisions to be the proper starting point. The plan also addresses the adequacy of implementation of the appropriate in-spection procedures with the proposed sampling plan. The staff believes that this aspect.of the plan.will most likely identify the root cause of the skewed weld inspection problem. The staff expects the root cause and subsequent generic implications, if any, of this issue to be positively identified, since this issue had been previously identified in the ASLB hearings and addressed by TUEC. The fact that a procedure inter-pretation problem existed after action by TUEC is sug-gestive that there could be generic implications with respect to procedure revision and implementation. The staff also reviewed the CPRT response of November
'22, 1985, to the staff comments (dated September 30, 1985) on ISAP Va. In this response on Pages 59-61 the responses for Items 2-4 are acceptable since they are mainly'claritying in nature. However, the response to Item 1 requires additional explanation. The staff could not find where both Type 1 and Type 2 skewed welds were addressed by B & R procedure QI-QAP-11.1-28. If this were the case, then " stanchion welds" would have been inspected using the skewed weld inspection methods and i
- marked as such on the QC checklist.
i
+
SCf- } .5 F M E w!4. M us.u en <H Item V.b - The staff since it first identified this issue in its November 8,1984-letter to TUEC has been actively following the activities concerning ' this subject. The staff feels that the CPRT Program Plan has the ability to address all staff concerns relating to the specific issue. The Plan addresses possible generic implications by reviewing other designs that have the potential for similar thread engagement deviations. The Plan provides for perfoming random inspections of Richmond inserts and other blind bolt installations. The only area of concern that the staff has in relation to this issue is when it is determined that a component can still carry its design load for all observed cases of less than adequate engagement, the need for additional inspection will be based on an evaluation of the trends in the inspection data. The staff must look at the basis case by case to determine if the trends do or do not require additional inspections. I
& /A/56tT l
. Item V.c '
The staff has reviewed the Plan and the plan implementation. The staff has verified that the CPRT Plan understands and has the potential to In identify all items similar to the item causing the original concern. addition, the NRC staff has perfomed an audit at Stone & Webster of this audit was up EngineeringCorporation(SWEC offic g The for addressing thiFconcern. The SWEC to discuss with SWEC their
- method has been determined by the staff to have the potential to identify and address this concern.
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# "' @ Pgo_(elds, Preliminary critique by the staff of the CPRT Program Plan raised several -
concerns, some of which have been adequately resolved. The staff's concern about the following items remains unresolved:
)
(1) In 4.1.1.1, the second paragraph is confusing. The statement is made "The j Sample Plan will be based on identifying with a 95 percent confidence a j rate of detectable plug welds of 5% or greater. The smallest random l l sample which will achieve this confidence level and rate of unauthorized or undocumented plug welds is 60, with an acceptance number of zero." " These statements seem contradictory. Are we establishing, with a
' confidence level of 95%, the rate of detectable plug welds or the rate of unauthorized or undocumented plug welds? Also, is the rate 5% or greater, or is it really 5% or less?
(2) The' Staff expressed concern that there is uncertainty as to the ability to detect a plug weld covered by paint and that this uncertainty should be ' factored into the sample size. The CPRT has reported the results of inspection of simulated cable tray support members containing " plug welds"
- l. made, surface prepared using methods available to CPSES personnel, and painted. The inspectors tested detected, on average, 82% of the " plug wel ds ." The maximum detected was 94%. The TRT notes that this reported capability negates the CPRT Program Plan stated intent of 95% confidence How does the CPRT propose to reattain 95% of a of a rate of 5% or more.
5% rate? (3) In March of 1985-at the CPRT action plan presentation at CPSES, the TRT stated its position that volumetric examination of any unauthorized " plug welds" found should be made since the welder, who was trying to avoid QC cognizance, would be included to rush the job and may, therefore, have used poor welding techniques. The CPRT has not responded directly to this position. (4) The sample plan (Section 4.1) and the definition of a reject were stated by the TRT as incompatible as currently written. CPRT's response, which references 3.4 ISAP V.a. Item 1, is confusing and needs explanation. , % g, . Repositioning of the Main Steam Line The staff review found that the details of the specific engineering evaluation l and the generic study of possible damage to other than the Unit 1, Loop 1. MS
.. .1
3 gy g:yrss vs$ r7sw ( Cohls piping was responsive to the actions required of TUEC by the TRT as a result of its investigation of the MS line allegation. These actions are given in SSER No. 10. P. N-110. Items 1 through 8. A comparison of items in the CPRT Action Plan and the actions required of TUEC by the TRT found that the CPRT Action Plan was sufficient to umbrella the actions required of TUEC by the TRT. However, there are concerns that:
- 1) The observation noted in Section 3.2 " Preliminary Detemination of Root Cause and Generic Implications" of ISAP V.e., Rev.1, that "in construction practice, it is not at all uncomon to perform adjustments in pipe position prior to final welding, particularly when permanent supports are installed subsequent to final fitup" could predisposition the implementation of the CPRT evaluations and studies.
- 2) The third party review of the RLCA work should not be limited to a verification only. Provisions for additional third party investigations should be provided, if required.
- 3) Although the CPRT has indicated that its investigations perfomed as part of ISAP V.e., Rev.1 have concluded that the sequence of events described in SSER No.10 relating to MS line incident is not correct, the generic implications of settlements of supports and stresses due to hydrostatic ,
testing and flushing activities will still be required to be evaluated by TUEC. . .
I
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l 1 Ite The staff conducted an evaluation of the CPRT Program a Plan for ISAP Va and found the action plan to be respon-sive'to the-issues raised. The staff, however, requires assurance that the root cause of the issue and its generic implications are properly addressed in the action plan. The CPRT TRT issues manager should assure the staff that both items will be addressed in the results report. The staff perceives the generic impli-cation aspect of this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC.
- In addition the response to Item 1 in the November 22, 1985 CPRT response to the staff evaluation of the CPRT Program Plan needs further explanation. #
Item V.b The staff feels that if the CPRT Program Plan for this issue 4e /f completed as stated would yield a~ solution to the identified problem that would be considered adequate. Item V.c
- If the CPRT Program Plan is implemented as stated in the Plan all areas related to the original concern will be identified and disposed of in a
' manner consistent with soukd engineering practice. FSAR coments and NRC guildelines. 173?m Vd r For the issue concerning plug welds, the Staff concludes that there are important questions related to the CPRT Program Plan which must be
- satisfactorily answered prior to approval of the Plan.
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_ -i SSER ON COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN APPENDIX I B. F. Saffell
1.0 INTRODUCTION
m The U.S. Nuclear Regulatory Comission's (NRC's) Executive l Director for Operations established on March 12, 1984, a program to assure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be addressed in a coordinated and integrated manner by the NRC staff. As a means of executing its programatic respcnsibilities, the NRC's Comanche Peak Project formed five Technical Review Teams (TRTs) representing the following disciplines. e Electrical / Instrumentation e Civil / Mechanical e QA/QC e Protective Coatings e Testing Programs The TRTs initiated a series of on-site inspections and evaluations in July,1984, and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report. In response to the concerns and issues identified by the TRTs, Texas Utilities Electric company (TUEC) formed the Comanche Peak Response Team (CPRT) for the purpose of addressing all TRT concerns. The CPRT, in response _to TUEC direction, submitted in October, 1984, its initial Program Plan which included Issue-Specific Action Plans (ISAPs). TUEC, in Revision 2 to the Program Plan, has expanded the CPRT scope to address all issues identified by external sources and has also comitted to perform self-initiated evaluations of design adequacy and quality of construction. Specifically, Revision 2 of the CPRT Program Plan is intended to address all NRC concerns and
C ,~. ,e. ,. , g demonstrate the quality of design and construction. The Program Plan, as revised, has the following principal objectives: e Evaluate and recommend solutions for all issues raised by the TRT, ASLB, SSERs, CAT, SRT g SIT,RgionIV.Intervenors, Applicant and g , o Detemine root cause and generic implications of each safety-significant deficiency found. e Perfom self-initiated evaluations for the purpose of assuring that there are no undetected and uncorrected safety significant deficiencies at CPSES. The CPRT's role through this Program Plan is to. resolve issues and determine root cause and generic implications of each safety signi-ficant deficiency. The NRC staff has reviewed the Comanche Peak Response Team Program Plan, Revision 2, with programmatic and detailed concerns provided re Texas Utilities Generating Company (TUGCO) in August and September of 1985, respectively. TUGC0 responded to the staff's concerns in November, 1985. Since the staff completed its review of the CPRT Program Plan document, it has continued its evaluation with numerous audits and inspectio,,s This SSER describes the staff's evaluation of the CPRT Program Plan. It addresses the scope, process, and evaluation i aspects of the Plan and not its implementation. Region IV will inspect a w .ers. , e t av av as rn* e r 6 -s and audit the implementation of the 4 Plan and reflect any finding it may have in periodic inspection reports. 8 Y Fac.tr (N bE v ' ' t- s t u > F e c r w o % e , r- -r are i mincuero r *re u a in r'# A b G i ffesa h o or & LA W tLAug? A *J V ";* "**T? L 9 0 er ur y =r \ 7 cre ,te s a e o ' 2.0 CPRT PROGRAM PLAN DESCRIPTION ew assac,y3eserauM ster pet.rs . ' N'~ The CPRT Program Plan is the document which describes the 7 9"" scope and mode of operation of the Comanche Peak Response Team. The 9 it
- Acronyms are defined on page of this report. !
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<m responsibilitiesoftheComanchePeakResponseTeamincludetheresolub tion of all open issues, the identification of the root cause of each \
found safety significant deficiency and the perfomance of 'a self initiat(d evaluation of the design adequacy and construction quality of the CPSES. '(j A$ The Program Plan itself includes the CPRT charter, program principles. 'I structure, methodology, process and organization. Three appendices yr ' c ~ _ fom the nucleus of the Program Plan. Appendix A addresses the design f <C,%.> adequacy aspects of the Program Plan. Construction adequacy is addressed r- - in Appendix B. And all individual issue and discipline specific plans are included in Appendix C. All evaluations are perfomed in accordance with a similar process regardless of whether it is a design construction or a very focused issue evaluation. This process'is initiated by defining the scope and methodology for the topic or issue to be evaluated. Procedures l and checklists are then developed as guidance for the reinspection and document review. All relevant standards and applicable acceptance criteria are reflected in the development of the checklist. Any deviations i identified during the reinspection reevaluation or document review l process are evaluated for their safety significance. Further, root cause evaluations are performed and a determination regarding potential generic implications is made for each identified deviation. Finally, corrective actions are identified as are actions designed to preclude 1 recurrence in the future. While the process for evaluation is identified in each issue specific or discipline specific action plan, the output from this effort will be documented in individual results reports. Each results report will identify any found deficiencies along with the evaluation of these deficiencies. The results of individual issue specific evaluations are [o'11ectively evaluated within the construction quality and design adequacy programs. A Sumary Report for each discipline area will be prepared summarizing the results of the effort and fulfillment with the objectives of the CPRT Program. t l L - _ _ . _ _ _ . - - . _ _ . . ---- _ - - . ~ - -- -.- - ---
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,,. W b ' W*"L 3 2.1 CPRT DESIGN ADEQUACY PROGRAM PLAN - W')
The Design Adequacy Program Plan (DAP) has been developed by the CPRT to evaluate and resolve a number of concerns regarding the adequacy of this CPSES Design and Design Process. The DAP is comprised of the following three components.
- a. Evaluation of. specific design and programatic designs process issues raised by external sources.
- b. Investigation of the root cause of each found safety significant deficiency.
- c. Performance of a self initiated evaluation of selected additional design areas.
Implementation of the DAP is by execution of discipline specific action plans (DSAP's) and by the preparation and issuance of results reports and a final design adequacy program report. The DSAP's are organized by the following design disciplines:
- a. Civil / Structural
{.
- b. Piping / Supports J-]
- c. Mechanical Systems and Components . . f
- d. Electrical / Instrumentation Control Systems and Components. /
The piping and pipe support program is different from others in that reanalysis will r,bex performed forrutepen the CPSES \ a significant level of(Sr.ae g urts.t t= m ein er Srojects nuo &MKo by as outside organizationgwho had no responsibility for the original m eb (f piping design. The work of th/st.outside organizationgwill be reviewed rf) by the CPRT. Each identified design issue will be reviewed and evaluated with the results being documented in a results report. evaluatign' [ j, - of the overall adequacy of the CPSES design and design proces5 will be made-by integrat results of the individual discipi ne specific action plans. This evaluation'will be reported in the final design adequacyprogramreht. ~ bid /Y.$
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2.2 CPRT CONSTRUCTION ADEQUACY PROGRAM PLAN The construction reinspection / documentation review program is designed to collect infomation on the adequacy of construction I l l
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t work activities at the Comanche Peak Steam Electric Station. Construction N}Q748 s, l activities are divided into the following three areas: g' . C.
- a. Civil / Structural N
- b. Electrical g
- c. Mechanical. ! l This program consists'of a sample einspection of QC-accepted safety i-)o.a ,
related construction work supplemented by review of related quality
~
' h5*y' Gj goTurifentation' forionrecr[afta r3 cess ~ inspect 1ons_/ Both units '
h h' and the common areas are being addressed by this program. / The methodology used for construction evaluation is to first W fj(&gs$o v n i categorize the installed safety related hardware into populations made .Ojg e , up of homogeneous work activities. Samples will be selected from th,ese gN homogeneous work activities and evaluated for the quality of constructigrth , T*c samples will be selected from each population for evaluation. b{N l Prit, a purely random selection will be made from the complete popui j t lettan. Then, engineered samples will be selected at random by expandingj the fMtt,al sample to ensure evaluation of a like number of items locatfd {& , l ( '- in systerrr.3 required for safe rhutdown. Items will be evaluated using ) checklists and inspection procedures developed from the original instal- {y k l lation documents. All deviations will be identified and evaluated t to determine their safety significance. The totality of the infomation will be evaluated for adverse trends. Results will be documented in [ )e A results reports which will d'ocument the inspections of individual popu-lations and well as the overall results of the construction adequacy (k Ed um n $1>pws s nw [$ k('s It~n. *mr0 ru te^ W '"*U (evaluationeffort. M 00 t% Tw ars e Ks a fs w m L. o I V t. + W n vw $ w 9 L G~
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IW*3 PN'*) 3.0 NRC REVIEW AND EVALUATION @ cry Do y>pu A<t/ The NRC staff has evaluated the prograrunatic aspects of the
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. Applicant's Program Plan and find it to be comprehensive in scope and
- )
l 0 structured to address all existing issues and any future issues which ' [ may be identified by external sources. The program plan also contains '
/ o the applicants commitment to a set of self-initiated programs intended - -.
k todemonstratetheadequacyofdesignandconstructionoftheComanchef
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,,. .3 A 'T mW b %%f l Peak project. Finally, the CPRT Program Plan provides a consnitment F 'g , , g s on the part of the applicant to resolve staff concerns and demonstrate b' overall plant safety.
The staff as part of its review of the program plan has perfonned O d (t [tensivereviewsandauditsoftheself-initiatedprogramsintended p f to evaluate design and the design adequacy and construction of the . a CPSES. The staff finds these self-initiated programs to be appropr l1 c , . F mechanisms for eyaiuating design and construction quaisty. rurtner, i the implementation and results of these programs are being documented , in sufficient detail to pennit future more in-depth review should this Implementationoftheseprogramshasbeenandwillcontinuej gegy i be necessary. to be audited until completion of these activities. Staff acceptance '\ gf ' of the self initiated programs is intended to indicate that an acceptable \, , process has been proposed, an acceptable framework provided for its j implementation, and consnitment made to document this process, its results e and conclusions in a manner amenable to future audits. i The staff's evaluaticn finds the issue-specific and discipline- l I ( i specific action plans to be responsive to external source issues identified
,, D at this time. { s The applicant has indicated that sampling as used in the M '
CPRT program is intended to ensure that a systematic approach is used in the resolution of specific issues and in the execution of the self initiated evaluation. The staff finds that the applicants general \ sampling approach is acceptable. Specific application of sampling will continue to be reviewed and audited by the staff during the imple- g mentation of the program. Finally, the staff notes that some areas have already been identified for 100 percent reevaluation. [ 9
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1 DRAFT 4.1 QA/0C of CPRT Activities 4.1.1 Introduction - The requirement for the development and implementation of a Quality Assurance program is covered by 10CFR50, Appendix B. Third-party review and audit activities are not specifically required to be covered by a QA Program. The Staff noted that Revision 2 of the Plan did not include any QA Program for CPRT activities. In the interim period between Revi-sions 2 and 3 the CPRT investigated a number of approaches to providing QA coverage of CPRT activities. The original CPRT Policy on Quality Assurance adopted the following position:
"The CPRT will not perform inspections, calculations, or designs of record. _
CPRT activities and results will not form any of the bases for the design or con-struction of the plant nor will the CPRT activities have a direct impact on the plant as 'it physically exists. For this reason, the CPRT does not fall under the normal Comanche Peak QA Program established by TUGC0 as specified in the FSAR. The CPRT has been set up to consist of independent, third-party axperts who will advise TUGC0 management of existing plant condi-tions, and who will make recomendations for the resolution of any probluns which may exist." However, the CPRT intends to resolve external source issues, some of which are currently categorized as violations of the TUGC0 QA Program. Resolu-tion of these issues may result in CPRT defining, recomending and review-ing corrective action which, when implemented by others, do. form the bases for design or construction and would have an impact on the plant as it physically exists. Although the corrective action is performed by others, there is the potential that the CPRT activities could be considered to go beyond review and audit. Once the CPRT determined that recomended cor-rective' action was one of the CPRT functions, it became clear that a QA Program for CPRT activities would be beneficial.
DRAFT 4.1.2 CPRT Approach Revision 3 of the Plan includes Appendix G entitled "CPRT - Third Party Quality Assurance Program." This program was developed in response to direction from the CPRT, SRT and is based on the importance and scope of the third-party review. The CPRT QAP is structured in line with the three categories of CPRT activities. A separate program is provided for each activity. (1) Overall Responsibility Overall responsibility for the quality of CPRT activities resides with the SRT. This is accomplished in the following manner. SRT will receive the results of all audits of CPRT activities, SRT will receive corrective action response to audit findings, SRT will perform, or have performed for them, special audits or reviews of CPRT activities as deemed necessary and documentation adequacy will be determined by reviews performed by the File Review Com-mittee. (2) Issue-Specific Actions Plans - 0A Elements It is the position of the SRT that the principles of the CPRT Program Plan, the CPRT Policies and Guidelines and the implementation requirements specified in each ISAP generally provide the QA elements necessary for ISAP sctivities. Supplemental instructions were prepared and issued in the civil / structural and mechanical /miscellaneods areas be-cause of the extent of third-party activities related to engineering evaluations and calculations in these areas. The CPRT Program documents address the following criteria of 10CFR50, Appendix B, in sufficient
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3 DRAFT . l detail to satisfy the SRT that activities performed by the third party responding to ISAPs will have adequate QA coverage. t o c. r:rt. So k H G"O*k 6 l Criteria No. Description CPRT Program Guidance 1 Organization CPRT Program Plant Section VIII 2 QA Program CPRT Program Plan Section III.k 5 Instructions, CPRT General Policy for Conduct of Action Procedures and Plants Section 5.3 and each ISAP Drawings 6 Document Control CPRT Program Plan Section III.j and Guide on Central and Working Files { 10 Inspection CPRT Program Plan Section III.k and Policy on Inspection Personnel 15 Non-conforming CPRT Program Plan Section III.k and General . Conditions Policy for Conduct of Action Plac- (Section 5.5) 16 Corrective Action CPRT Program Plan St.etion III.k 3r.d General Policy for Conduct of Act.f on Pips Section 5.5 17 QA Records CPRT Program Plan Section III.j and Guide on Central and Working Files 18 Audits Checks of the activities performed under TRT ISAPs are accomplished by Review Team Leader overview of activities (CPRT Prograrh Plan Sec-tion VIII.b.3); the reviews and audits con- 3 ducted by the CPRT Results Report and File I
DRAFT Review Comittee (Attachment 4 to CPRT Third-Party QA Program); and SRT review and approval of Results Reports (CPRT Program Plan Section VIII.b.1) In addition to the generically applicable guidance listed above, the direction provided by specific ISAPs implement measures of other QA ele-ments (e.g., test control) as they are appropriate to the specific issue. (3) Quality of Construction Program A Quality Assurance Program has been developed for the QOC activities and addresses the following 10CFR50, Appendix B Criteria: Criteria Title { 1 2 Organization Quality Assurance Program 4 Procurement Document' Control 5 Instructions, Procedures and Drawings 6 Document Control 7 Control of Purchased Material, Equipment and Services 10 Inspection 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 QA Records 18 Audits Overall responsibility for QA activities rests with the ERC Division Manager of Quality Assurance who has the authority to issue Corrective Action Requests or Stop Work Orders. The Procedures and Project Assurance Group are the on-site representatives of the ERC Division Manager of Quality Ass,urance and are responsible for identifying and reporting on the status of the quality program by conducting surveillances of the 00C activities. The results of these surveillances are documented and Ts w s Seawd ref n. s rs rthr Ftrw"r #pt ro ca m nhr kot e Pitr 6L 4 Pise a<irr i u.tri ree r w c- #~l p w 7ta w p u a cra w .7,c rw & es c on r w i ri err uS
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.s. CRAFT reported to the Manager of Quality Assurance and the Review Team Leader.
In addition, the Manager of Quality Assurance conducts audits of QOC activities in accordance with ERC QA requirements. The Division Manager of ' Quality Assurance is organizationally independent from the CPRT. (4) Design' Adequacy Program A Quality Assurance Program has been developed for the DAP activities and addresses the following 10CFR50, Appendix B Criteria: i Criteria Title 1 Organization 2 Quality Assurance Program , I 3 Design Control 4 Procurement Document Control { 5 6 Instructions, Procedures and Drawings Document Control 7 Control of Purchased Material, Equipment and Services 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 QA Records 18 Audits In addition, should activities in the areas of Inspection, Testing or Measuring, and Test Equipment be required appropriate Quality Assurance requirements will be established or subcontractors with applicable Quality Assurance Programs will perform the activity. Responsibility for ensuring effective implementation of the DAP QA Program resides with the DAP Quality Assurance Manager who reports directly to the DAP Review Team Leader. Audits will be performed, or led, by individuals qualified to the requirements of ANSI N45.2.23, Sections 2.3.1 through 2.3.4 for Lead Auditors.
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DRAFT 4.1.3 Staff Evaluation - The Quality Assurance Program provided by Revision 3 of the Plan is a significant improvement over the original CPRT Policy on Quality Assurance and establishes a level of program quality comensurate with the activities of the CPRT. (1) Overall Responsibility Overall responsibility for the quality of CPRT activities resides with the SRT. Results of audits and corrective action in each category are provided to the SRT. The program is not sufficiently detailed with respect to the QA audits that will be performed by (or for) the SRT. These audits are important to assure SRT QA involvement and control that is' comensurate with their responsibility. Sufficient experience in Quality Assurance requirements is available in the SRT to understand the magnitude { of audit findings, to determine the impact on program quality and to properly administer their responsibility for quality. (2) Issue-Specific Action Plans Although a formal QA Program is not provided for ISAPs, 10CFR50, Appendix B Criteria applicable to all ISAPs are provided in the various sections of the Program Plan and Policies. In addition, individual ISAPs implement measures of other QA criteria as they are appropriate to the issue of concern. The one criterion that appears to be missing is Criterion 12, Control of Measuring and Test Equipment. Some of the ISAPs require field measurement and the use of tools, gages and instruments, and Criterion 12 provides assurance that instruments are properly calibrated and controlled. Since formal QA audits are not being performed within the ISAP organization it is important that the SRT assure that its audit activities sample ISAP efforts.
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rwep Wdkg9[] (3). Quality of Construction Program A formal QA Program is provided for the QOC activities. l Eleven criteria of 10CFR50, Appendix B, are addressed in the QOC QA Pro-gram. However, Criterion 12, Control of Measuring and Test Equipment is not a part of the QOC QA Program. QOC personnel will be performing inspections which include measurement, therefore it is important that the l tools, gages and instruments used are properly calibrated and controlled. Adoption of Criterion 12 by QOC will assure that this occurs. l
! QA. activities are the responsibility of the ERC Division
{~ Manager of Quality Assurance who is independent of the CPRT organization. J Ongoing QA surveillances of QOC activities are performed by the Procedures and Project Assurance Group. This group has two reporting responsibili-ties; (1) to the ERC QA Manager for QA surveillance activities and (2) to the Review Team Leader for non-QA activities. This dual reporting re 1 sponsibility could appear to create conflicts. However, since the ERC QA Manager performs independent audits and is organizationally removed from all CPRT activities, and the Project Assurance Group non-QA activities are essentially Engineering Inspection Assurance activities, QA activities ar_e I y sufficiently removed from day-to-day inspection and evaluation actvities. Since SRT retains overall responsibility for quality imple-mentation of the CPRT activities, the_QOCrorganizatiortchartjFigure 2.1) should indicate that the LdC Division Manaaer of QA has reporting obliga-tions to the SRT. i 1 1 (4) Design Adequacy Program i A formal QA Program is provided for DAP activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the DAP QA Program. Should inspection activitie_s be required' appropriate QA requirements wil_1 be established or subcontractors with applicable QA Programs will oerform \ this activity. If '- -" ""[ncoection activities, if required, bY be covered by formal adoption _ of criteria 10 and 12 of 10CFR50, Appendix __B. j
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E g DAP QA responsibility resides with the DAP QA Manager who Although this J h}I reporting D) reports directly to the Design Adequacy R chain is not as separate as that used in the QOC Program, it is k accept'able under Criterion 1 guidelines. In addition, the DAP QA Manager E has reporting responsibilities to the SRT.
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This responsibility to SRT g should be clearly indicated on Figure 1 of the DAP QA Program.
) t, Since the DAP has the responsibility of reviewing and t
- 4 kk { accepting activities being performed by the Comanche Peak project it is 1 important that the DAP QA Progran be structured to assure audit of these
'g 4 project activities. Extensive reanalyses of piping, supports and cable v trays are being performed by the Comanche Peak [roject. Since the organi- .
'b zations performing the reanalysis activities are implementing their own QA 3 Programs, subject to TUGC0 audits, it is important that the DAP sample 2 d
)g these QA activities. For example, an important input to this effort is the h as-built configuration of hardware. In the piping and pipe support area, [
SWEC has performed sample walkdowns to determine the adequacy of current ( as-built data for elements they consider to be critical to design. In g D k addition, SWEC will be relying on any deficiencies in piping and support as-built data reported by QOC. Based on this, it is critical that DAP [ ' p h assure that sufficient data is obtained and that the quality of the data is k 0 D acceptable. In the area of cable trays and supports, a complete walkdown % g _ J is being performed by b i lmpell to develop as-built geometry prior to ('A{ analysis. It is critical that DAP assure that the quality of this as-buil_t [I t. data is acceptable. A I
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. ki t 1 N es584 The CPRT QA Program prov ed ,in,. Revision 3 of the Plan,is- ,
'V-(J( acceptable for the current CPRT activities W t'& u rw7t'If %5cHede '+6+r nc n oov v ru mr c PW&& pu
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[ Staff review of Revision 2 of the CPRT Plan indicated concern with the acceptance criteria contained therein. This concern had aa Ik two focuses. The first was that the acceptance criteria, as defined, did gf U '4 not assure that licensing commitments would be complied with. The second
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f was that sample size increase was primarily a result of the " safety fb$g significance" of a discrepancy. Deviations trigger scope expansion only 9 g% , when they would be a deficiency (i.e., " safety significant") if occurring
) , elsewhere. However, the criteria for determination of whether a deviation % ( would be a deficiency can vary from component to component or system to system depending upon the plant event and the component or system function g 9)D* under consideration in the evaluation of the deviation. Guidelines in-9 dicating how this evaluation would be accomplished were not provided.
W J 4.2.2 CPRT Approach - fbh 5 I Revision 3 of the Program Plan includes Appendix E, "CPRT Procedure for the Classiication, Evaluation and Tracking of Specific f Design or Construction Discrepancies Identified by the CPRT." Appendix E
, provides requirements for the classification of items, the evaluation i p process ta be used, discussion of a tracking system and roles and responsi-t bilities for CPRT personnel. The classification and evaluation process sections of Appendix E provide separate guidance for Design, Construction and Testing adequacy, including more detail definitions and the evaluation f
jj.h p process used for individual and programmatic discrepancies. The approach to adverse trending of related observations, deviations or deficiencies indicative of a pattern exhibiting a discernible t rmnonality are providad-g g) s, a . u m ~ ,. - ~ , - ,e, ~ , r r . ..- ... a .4 : S u i e. r e etr* As:4mt rv >> n, L.OC, EB'HICu / ["f det-ht trent m w -q n w ne.e rmr w#tx n tw Tu oom ! n!. Sure.7. +..... Luer twLua ste vtm 7tre D A P nc.- % m. a en W$WWb $ # ett Nc#5LM /)(d (A f fB t? ( tv *v -ryur A 64 9 e qa 4%
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T DJ w.sN J Root cause and generic implications will be evaluated for all deficiencies and adverse trends. In addition, Appendix E provides root cause and generic implication evaluation for special cases. For example, when a deviation results in a substantial loss of design margin a root cause y add- generic implication evaluation will be performed.
Identification of special cases will be situation-specific and cannot be generically defined. 4.2.3 Staff Evaluation p /2,o G cm 5 wir tr iM F rwu (htM G n o+9W C . R s- t T' 4 vv o, The approach to Acceptance Criteria defined in Revision 3 2 of the Plan, particularly Appendix E,.is a significant improvement over the information contained in Revision 2 and is partially responsive to prior Staff concerns. .The classification of discrepancies into separate Design, Construction and Testing adequacy categories will provide a more consis-tent and readily auditable set of records. { The evaluation process defined in appendix E, though more definitive than Revision 2 of the Plan, still does not orovida c"fficient detail on safety-significant evaluation. This concern is primarily related to the fact that safety-significant evaluations of discrepancies are currently underway using information, in some cases- that is being revised by the CPSES Projec [o areas of major concern are piping and cable trays and their supportsg), Until this revised information becomes available as " plant record documentation" then the safety-significance evaluation process cannot be completed. Any evaluations made using exist-ing documentation must be revisited when the new documentation becomes available. The major reason for this is that TUGC0 has elected to perform extensive reanalysis of piping, cable trays and their supports which could result- in hardware modification related to optimization or deficiencies or, different design documents and values which form the has o,rghg
- safety-significant evaluation. Based on this, the staff heh that safety-significant evaluation and the potential for scope expansion must be based on final plant configuration and documentation. This position l does not preclude the fact that existing issues which led to the current l l
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reanalysis of piping and cable trays must be evaluated for root cause and g generic implication to assure that programatic deficiencies do not extend } beyond the boundaries covered by the reanalysis efforts. A second concern is related to the f act that safety- & significant evaluations must be performed using Ccde or Regulatory ap- ' proaches. This does not mean that Code or Regulatory margins must be the criteria for safety significance, rather the techniques used and the ext; tdt _of the evaluation must address each criteria which forme _d._th.e basis for the original design. For example, the use of actual material proper- s ties versus Code defined material properties could be acceptable but does 3 U I not preclude the fact that all evaluations comitted to in the FSAR must be N I l addressed in order to establish margins on all segments of the acceptance y criteria. Actual material properties (if higher than Code minimums) may be I of value in evaluating primary stresses and functionality but do little to I. change the fatigue margin. This concern is not limited to Design discre-pancies but includes Construction discrepancies for which safety- signifi-f Q cance is determined through the use of Design evaluations. . F j The staff has conducted audits of the QOC activitTsr ad 3 l
,{ reviewed the safety-significant determination process during one of those b
J" p o M audits. The staff ha,s a concern with the orocess being_ usti_As it ad-dresses safety-significant determination and subsequent sample expansion. ~~
&g ,J 8 6 , The QOC has developed a number of populations for review. In some cases a
, M tiven population may include hardware that is covered by another popula-
{ pd 1 ion or is not considered appropriate for individual population develop- g 30 n ent. In the review of the given population, any hardware covered by
< a other population that is considered to be a deviation will be evaluated' %
iD w ph respect to its safety-significance on the given population within w ich it is included. The fact that the piece of hardware, if considered [1 i the framework of its own population, may have been safety-significant is
&C # g ot a consideration. Further, since the piece of hardware ,is.already a g N, part of another population it would never be included in its own popula-I f g tion. For example, a valve within a piping population may have a deviation h h ich does not effect ,t.ha efety @ WW f the piping. However, if o aJ A u I9v% tu T. NTL M M otLt2, m 4 ypowseo
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safety-significant. The Staff is concerned that evaluations are a func-tion of population and can change depending on the piece of hardware under [g A consideration and the population in which it is being evaluated. l h{ v
} Another area of Staff concern is related to the " Adverse' y td Trend" section of the Evaluation Process in Appendix E. This concern is TV T- I h
\ related as much to wording as it is to the process defined. In discussing if trends, the CPRT uses the expression " discernable comonality." Although c, 4 fsomeexamplesareprovided,thestafffeelsthesewordsaddlittleto_the r f3 A u44 2' discussion and can lead to confusion _. TheexamplesgivenareappropriatefI for a set of items creating a pattern for concern and therefore should -
to g ;'% U d result in a trend that is considered "potentially adverse." However, since g the examples discuss a process, there is some concern that " Homogeneous f 4 % Design Activities" (HDAs), which do not necessarily address a specific D process, will provide the appropriate information for trending. / Fou N D IT a y)z . $ tt I ( Y $ 4.2.4 Conclusiony f rtw Crvrf t* M&r 45 6 A G&c r W N Q v5
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g 'S < A 4.3.1 Introduction (d) ferre s a s a rs c= . e += r e-u et v.t +-r rm., iev 1 A4 A ers t i > c si.c r), w c.r r f rters e D G* 1 I (r J r,t. Co u2ruAst.Mt N 1% 0 twr P vervT o rt-t. (C4A. C C# t.P err P-w A ut i J d Q N The NRC Staff coments on Revision 2 of the Plan ex ts
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e 4 M pressed concern with the failure to provide criteria and guidelines to be rW W rt e yt
? used by the CPRT in defining corrective action and judging implementationF Fiwrt
' t. ,wr g of the corrective action by TUGCO. Revision 2 only addressed corrective *~Fic.u vt. +rW p r w e t1 **
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-=J7 action related to ext'ernal source issues and did not provide a process for addressing corrective action resulting from self-initiated activities.
Further, the TUGC0 corrective action system was an item of concern to the Staff which increased the necessity for CPRT involvement in implementation activities. 4.3.2 CPRT Approach Revision 3 of the Plan includes Appendix H, "CPRT Proce-dure and Policy for the Development, Approval and Confirmation of Imple-mentation of Corrective Action" which describes:
- the process through which corrective action will be defined for deviations or deficiencies identified by the CPRT, the process through which the CPRT third-party will review and approve the definition of corrective actions for all deficienci.'s and for certain categories of devia-
-tions identified by the CPRT, and
- the nature and extent of CPRT third-party confirmatory overviews of the implementation of defined corrective actions.
l (1) Corrective Action Definition Once the individual CPRT RTL classifies a discrepancy as a deviation (failure to meet a design consnitment or specification) or a l deficiency (a deviation determined to be safety-significant) the CPSES Project is responsible for: 1 performing 10CFR50.55(e) reportability evaluations, defining appropriate corrective action, l l l
- obtaining CPRT RTL concurrence in the defined corrective action for a safety-significant deficiency; program-matic deviation or deficiency; design deviation involv-ing failure to meet FSAR, licensing or regulatory cri-teria or comitments; and a deviation reportable under 10CFR50.55(e).
The CPRT RTL is responsible for determining the adequacy of the corrective actions submitted by the CPSES Project for review. In the event that the RTL determines the proposed corrective action is inadequate and cannot resolve the situation with the Project, the SRT is responsible for resolv-ing the concern. The Executive Vice President of TUGC0 is responsible for responding to the SRT with the TUGC0~ position.
; In addition, the CPRT RTL may recommend proposed. corrective action to the CPSES Project. SRT approval is required for CPRT recommenda--
tions for corrective actions: i that are programatic in nature, l to res'olve safety-significant deficiencies, and to resolve design deviations that could involve a change to existing licensing or FSAR commitments. (2) Overview of Implementation The CPRT must be satisfied that, when implemented as defined, the CPSES Project corrective action will correct the nonconform-ing condition identified and, if applicable, will preclude the recurrence of similar conditions in the future. The CPRT RTL will be responsible for performing confirmatory overviews of the implementation of corrective ' action for which they were responsible for reviewing and approving. These-confirmatory overviews are intended to ensure that the corrective actions have been effectively implemented for each:
..- ~ ,
programmatic deviation or deficiency, safety-significant deficiency, design deviation involving a failure to meet FSAR and licensing commitments, and specific deviation that meets reportability criteria of 10CFR50.55(e). In general, the overview involves a review of documenta-tion. In addition, where reinspection is required for corrective actions related to QOC activities, the CPRT will either witness the reinspection performed by the CPSES Project or perform independent reinspection. 4.3.3 Staff Evaluation Revision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirma-tion o( implementation and responsibilities of the CPRT and the CPSES ; Project. The only major consnent the staff has 1s rela _ted to _the_ timing i of SRT approval of C_PRT _ RTL determination of the adequacy of corrective actions defined by the CPSES Project. Appendix H provides two alterna-tives, ! approval on an ongoing basis as corrective actions are developed, or
- approval as part of the Action Plan Results Report approval process.
The Staff feels that the SRT should approve (or disapprove) corrective 1 actions on an onaoina basis as they are develooed. This approval should follow that of the CPRT RTL. It is felt that this would keep the SRT more I in line with CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES Project involved in lengthy discussions when the RTL does not agree with the proposed corrective action. ,
i i iN --a- i 4.3.4 Conclusions W MM The CPRT Procedure and Policy for the documentation, approval and confirmation of implementation of corrective actions as defined in Appendix H of Revision 3 of the Plan is comprehensive and is responsive to staff coments on Revision 2. It !! r a c a="a n d a d +%t SRT f / apnrau=1 af carractiva action adecuarv fe"- i.l,o . ;;;x:dt f ear 0"+11ned h*Y g +5e "Ste<< rualnation.t/in ord to a sure that the rogram is b ing % implemented i accordanc with R ision g(performingrviewsand of the Plan, he Staff wi be udits of the CP and the CPSE Project acti ities
, a) \rJt lated t corrective action. _ _ __ ..- -- - - --
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i DD 5 %^QT APPEO!" '- 2 -- SECTION 4.0 1 4.0 EXTERNAL SOURCE ISSUES 4.1 Introduction yd External Source Issues are defined in the Program Plan as being those issues identified by the following: NRC Staff (TRT, CAT, SIT, SRT, Region Inspection Reports and SSER's), ASLB Proceedings, CYGNA IAP, Intervenors and Applicant. The Extenal Source Issues are being addressed in'ISAP's and DSAP's. The evaluation of all specific External Source Issues is one of the main objectives of the Program Plan. It is the intent of the Program Plan to identify any safety-significant deficiencies, to determine root cause and evaluate potential generic implication, and to determine appropriate corrective actions. The goal of the plan is to provide " reasonable assurance" that there are no undetected or uncorrected safety-significant deficiencies associated with the External Source Issues.
/ The Program Plan has an adequate mechanism in place to assure that ESI's are identified, tracked, evaluated and closed out by the L CPRT. This mechanism has a six-part scope to deal ith ESI's:
Identification of Issues Definition of Issues Development of Action Plan Implementation of Action Plan Corrective Action Results Report The Program Plan requires the review of all External Source documentation in order that all External Source Issues are identified. The Program Plan notes that the review " warrants a degree of selectivity in determining which documents should undergo detailed reviews..." due to the volume of External Source documentation (response to NRC e Evaluation dated August 9,1985). (The staff feels that this" degre M-r& f
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. ~-
I (selectivity in determining the detailed review requires auditing by the ) (staff]. The results of implementation of this CPRT Action Plan will be I [documentedinfutureresultsreports. New issues identified during the l implementation phase of the Plan will be pursued, and the results of the staff evaluation will be contained in future reports.
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O D A 7"""" L/iN M,f"; - APPENDIX A SECTION 4.4 4.4 Civil / Structural ~ Issues 4.4.1 Introduction Gtrvr> , The Program Plan identifies External Source Issues in the Civil / Structural Design Area. External Source Issues in this area have been evaluated in ISAP's and the Cable Tray / Conduit Supports (CTCS) Program. These ISAP's and the CTCS Program are intended to meet one of the main objectives of the Program Plan, that being that there is f reasonable assurance that there are no undetected and uncorrected
. safety-significant design deficiencies associated with any of the External Source Issues.
Tt4 sf 4.4.2 CPRT' Approach pM p
- The methodology employed to respond to the External dU,.ludz.
Source Issues has a six-step approach to identify, define, develop and implement action plans, determine corrective action and report results. J ct-p C. c ra . J The two ISAP's in the Civil / Structural Design Area deal b I with the Seismic Design of the Control Room Ceiling and the Steam Gen-erator Upper Lateral Supports. In addition to these ISAP's, the CTCS Program is currently in progress. This is a comprehensive reanalysis and construction as-built review of the cable tray and conduit supports.
?
4.4.3 Staff Evaluation . The staff's evaluation of the External Source Issues in the Civil / Structural Design Activities is based on a review of Revi-sion 3 of CPRT Program Plan and audits of the Comanche Peak DAP scope validation process. The staff also notes that ISAP's reflect the methodology outlined in the Program Plan. T SGu Eve ~ TW w 6, am nCo '7t> D 1 C W G3 WN ffT 7% 7t n Japaps tg D oj <sg. w r ry tk /~1Df*VW *C.
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the_4TCS "regram. Thoro hac hoon nopponse by CFKI otner than thp-{ y 3 Revision 3 of the Program Plan will address these concerns. 0
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_1 k M.i **l'j l APPENDIX A STAFF EVALUATION OF THE CPRT DESIGN ADEQUACY PROGRAM PLAN (DAPP) EXTERNAL S0t5tCE ISSUES 4.6 QA/0C Issues 4.6.1 Introduction yd The NRC Staff performed a comprehensive evaluation of the Revision of the Program Plan and by letters dated August 9 and September 30, 1985 provided to TUEC the Staff's evalution of the Plan. C By letter dated November 22, 1985 TUE[ submitted its C' responses to the Staff's evaluation. These responses and Revision 3 of the Program Plan provided the basis for evaluation of the QA/QC issues related to the Design Adequacy Program Plan. 4.6.2 CPRT Approach Appendix A does not specifically address QA/QC issues related to design, however the Plan does address the scope and methodology to identify and resolve External Source Issues. . Resolution of the issues is accomplished through a review of External Source Documents which are listed in the Plan (e.g., SSERs, RIV Inspection Reports, etc.) to identify the issue, and the
~
~ implementation of ISAPs and DSAPs which evaluate and close the issue. The CPRT approach also relies on a coded cross reference, prepared by the DAP, ,
which identifies the issue and the source document (SSERs, etc.) and issue tracking matrices prepared by the CAPP which identify the issue, the source
- document and action plan that addresses the issue. he required rogramatic
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L: e errm -2 .= canarT fgg(fg.T,i> tw fn+ w ov+us e n J interface between the DAP and the QA/QC CAP is a significant influence in the resolution of QA/QC issues related to design. ve,vf 4.6.3 Staff Evaluation y c/- The Staff has reviewed Revision 3 of the Plan to assure that the concerns expressed in the NRC's letters of August 9, and September 30, 1985 have been responded to. This evaluation pertains prin-cipally to the QA/QC issues regarding the DAPP (CPRT Program Plan, Appendix A). Revision 3 describes the approach and methodology being used to review documentation to identify the issue, prepare a coded cross reference, maintain an ongoing document review to identify new issues and develop new action plans as required. Additionally, the Plan details the _ DAP approach to resolution of: design issues raised and closed outside the CPRT, external source design issues not closed outside the CPRT, and external source issues closed outside CPRT but also evaluated in the DAP. The response also describes the detail of the interface between the DAP and the' CAP QA/QC Review Team to ensure the identification, tracking and resolution of issues. The Staff finds the CPRTs response establishes confidence j that QA/QC issues (external source issues) related to design will be identified and resolved in the DAP. This is based on a parallel evaluation of the QA/QC review team (CPRT Program Plan, Appendix B) methodology for I identifying and tracking the issues by use of tracking matrices (Reference this report, Appendix B, Sections 4.6.2 and 4.6.3) and the defined inter-face between the DAP and the~ CAP. Meeugh e response adequately address the,NRC's con-cern regarding design related QA/QC issues (external source issues) Me-GPRT did e p epeta a ravMan +a tt CAPI (CPRT P , em Fian, Appenau A) i
3 DRAFT GV p.yr uG-te 4 ace perate the rc;p = 0 but r;'ici on the coded cross reference, the issue tracking matrices (CAPP, Appendix B) and the interface between the QA/QC CAP and the DAP. 4.6.3 Conclusions Based on the evaluation of the response and the revised CAPP Appendix B, the Staff is confident that the QA/QC issues related to design will be identified, and resolved. Accordingly, the Program Plan Revision 3, as it addresses the design related QA/QC issues is acceptable. However, final acceptance of the Plan will be predicated on the Statt eview of the coded cross reference and the tracking matrices.
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DRAFT APPENDIX A STAFF EVALUATION OF THE CPRT DESIGN ADEQUACY PROGRAM PLAN 4.7 Closed External Source Issues d The CPRT Program Plan states that those external source design issues that have not yet been resolved will be resolved and closed in the course of the DAP and identifies the source documentation (e.g., CYGNA IAP/SSERs,INPO,etc.)thatidentifiestheissues. The document review is an ongoing activity from which a coded cross reference is developed between DSAP topics and the external source documents for issues related to design. Any new source documents that become available will be similarly reviewed and new action plans developed as required to address the ide'ntified issues. The action plan results reports will report the path that each issue took in the DAP and will be documented in appropriate cross reference tables. In parallel with the DAP activity the QA/QC review team is per-forming a similar document review which results in the development of issues tracking matrices that identify the issue, the source document, and the action plan (ISAP/DSAP) that addresses and resolves it. The Staff's evaluation establishes a level of confidence that the DAP will identify, address and resolve the external source design issues. However, the Staff isconcernedthatalthoughtheactionplanresultsreportformat(Program Plan, Attachment 5) infers that closures of the issue will be reported, there is no clear statement in that format that requires reporting that m each issue addressed in the actiglan is closed. Accordingly, send w CN f nYr 1 t $mant$nbea.t e c$:Yi$$. _ n isc w o.r s <wa. - ~, ra , e n rw y ever cea n a wa. & cr>r,-w w u-
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DRA?/ . APPENDlX A SECTION 5.4 (F 7[ x r 5.4 Civil and Structural Design Activities
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tt' fy)h-o_ t- 4' 5.4.1 Introduction 0
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[ The Self/ Initiated Evaluation of the Civil / Structural 7$ DSAP was develo ed to increase the confi ence in the verall CPSES \ Civil /Structur Des ' n Area. \ The purpos'e of these eval htions is to; verify the ality of the design, to Issure compliance ith licensing connitment and to ident'ify pot ential design eviations pbd deficien es. f deviations or defAciencies are identif'ed, the Program s
~
lan prqvide the methodology for evaluating generic implications. j f This Civil /5tructural Self-Initiated Evaluation will ( { help enhance one of the main objectives of the Program Plan, that being i that there is " reasonable assurance" that there are no undetected d deficiencies at CPSES. 4 c - - _3 The topics addressed in the Civil / Structural Self-Initiated Evaluation are Concrete Design, Structural Steel Design, HVAC V f ' Supports and Other Supports. Examples of the Other Supports include the crane support, equipment supports, penetration sleeve anchors, missile- ' resistant doors and hatches, and various seismic restraints.
)t) 5.4.2 CPRT Approach w w
[' The scope of the, Self-Initiated Evaluation of the
! Civil / Structural esign Activityj6nsists of four phas .
phase is intenped to define theAreadth of the revie based on past VP The initia ( I
) and other r/ views. The next phaseidentifies sign attribute and charactert[ tics. Phase 'ree is intended to alidate the DSA scope [
based homogeneous d ign activities. Th fourth and fin phas[, scope determination, identifies final sco e, findings, trends and / 9eneric implications. -
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b D .7 7 . APPENDIX A kJ\ *[ d SECTION 5.4 A This DSA program consists of a " vertical" slice review of the design activity. Phase three of thi program is based on the 'g l Homogeneous Design Actipity (HDA) validation The HDA's were identified based on the following'Iattributes: ' I
/ . I
! fw f ps ~, d friteria j g
/ Design Approach and Msthodology f ,
Organization /Discip ne Design Control Pro _ss ' [
/-
/- Design Interface I i s ! It is the intent o theprogramplanthatdheimplemen-tation of th s four-phase scope wi 1 achieve the program's reasonable Qurance objective.
5.4.3 Staff Evaluation - C The staff's evaluation of the Self-Initiated Civil / Structural Design Activities is based on CPRT's response to the NRC's staff evaluation of the CPRT Program Plan dated November 22, 1985, Revi-sion 3, to the Program Plan, and audits of the Comanche Peak DAP scope validation process. 7 The staff had noted a number of specific concerns in W ik the Civil / Structural Design Activity to which TERA has issued responses ( \ (CPRT-13). A concern whicti was generic to al the Self-Initiated Design
)
Activities area was tpt TERA was unabl to provide G&H documentation covering design considerations, approa_ and methodology, and design control procedures which were to be [the basis for determining the homogeneous design activities. This ,6&H documentation is now available to TERA for review in the Civil /Strdctural Design Area to assure that the design activities identified i phase three of the DAP are indeed homogeneous.
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APPENDIX A
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e o J / m/D W pe% r p/ gM WW A* e*7 rY pt-f 4% M~4 9'e 77fLVWh$$ / C C'en There were additional concerns raised by the NRC staff cwff. with the selection of concrete and steel structures to be reviewed, the D 'f f'#ce 4
, adequate representation of CPSES Category I structures, inadequate C sample sizes and inadequate DSAP scope for embedments. It is the posi-('
. tion of the staff that Revision 3 of the Program P'lan adequately
\ addresses the concerns. [T M (rt.~ dffm R d d, N - -
5.4.4 Conclusion 7, The staff concludes that the CPRT evaluation plan the Self-Initiated Civil / Structural Design Activity is acceptable. The staff will audit the implementation of the CPRT Action Plan. k __ . . _ . _ . . - - ~ [ a ~ s,,, n ru a e nr ( 77+e.f & oir w 44~A 4-75 erv c 7w 'r _f
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J '- ., APPENDIX A Page 1 of 13
- 5. Self-Initiated Evaluation
..g % ,*ss 5.5 Piping and Supports Design Activities ,3 %)
5.5.1 Introduction A number of external source issues have been raised in the area of piping analysis and pipe support design. These external source issues have resulted from several sources; the primary sources being the Cygna Independent Assessment Program, the ASLB hearings, and j the NRC -staff reviews. As a result, the applicant has initiated a special piping and pipe support requalification ' program which will result in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. Stone & Webster Engineering Cor-poration (SWEC) has been contracted by the applicant to perform this re-qualification program. In addition, a third-party overview of this I effort is being conducted by TERA Corporation (TERA) to provide assur-ance that the objectives of the Design Adequacy Program in the piping and pipe support area are being achieved. The CPRT Program Plan descri-bes the piping and pipe support program and overview in DSAP IX. l In this section of the SER, we will discuss the staff
~
review and evaluation of the SWEC piping and pipe support requalifica-tion program. The staff review and evaluation of the TERA effort is provided in Appendix B. Section 4.5 of this SER. 7 ' ' The staff has reviewed the CPRT Program Plan DSAP IX f
~
Attachment 2 and Appendix F Section II.F which describe the SWEC piping and support effort and the SWEC interface with otner organizations, re-( go spectively. In addition, the staff has performed several audits at the
+\ t SWEC offices and at the CPSES site to further understand the depth and i breadth of the effort. Our review focussed on the adequacy of the scope I
and the completeness of action plan details .in addressing the, technical concerns associated with piping and pipe support design which have been 1 raised in external sources as well as in self-initiated reviews.
-- - - - . =--: .-- -
APPENDfX A V Pag 2 of 5.5.2 CPRT Approach , M. A, -4 3 The scope of the SWEC program for the requalification of piping and pipe supports include: 100% of all ASME Code Class 2 and 3 piping larger than 2 inches (large bore) excluding portions within the boundary of Westinghouse Class 1 auxil-iary branch line stress problems. 100% of all ASME Code Class 1, 2, and 3 large bore pipe supports, small bore piping and pipe supports on a sampling basis, all Class 5 piping and pipe supports within ASME Code Class 2 and 3 stress analysis problem boun-dary, and C all Class 5 supports within the ASME Code Class I stress problems. The CPRT Program Plan in DSAP IX Attachment 2 describes the outline of the SWEC Action Plan. The SWEC Action Plan consists of the following six elements:
- 1) Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria p gmm DP 't-* WMfdW_ , wom ..e:,s - ry
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fhe Design criteria and procedures to be used for [ the pipe,, stress _and support requalification effgr1, cous,.-f, by SWECE 2._4W U__ "'Y. . '.U. ~" ' . . ,,~___d_"_-=_e listed
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APPENDIX A Page 3 of 13 Proceaura Title Issue Date CPPP-1 Management Plan for Project Quality, Rev. 2 12/02/85 CPPP-2 Project Organization Charts, Rev. 0 12/02/85 , CPPP-3 Do ument Control Procedure, Rev. 2 11/25/85 CPPP-4 Proj t Records Management Procedure, Rev. I 11/25/85 CPPP-5 Field W ik Procedure, Rev. I 10/18/85 CPPP-6 Pipe Stres / Support Requalification 10/31/85 Procedure Unit No. 1, Rev. 1 CPPP-7 Design Criter' for Pipe Stress and Pipe fil/04/85 Supports, Rev.1 CPPP-8 Support System Verification Walkdown 10/28/85 Procedure, Rev. 0 / CPPP-9 Pipe Stress / Support -Built Procedure # 11/01/85 Unit No. 2 Rev. 1 CPPP-10 Power Division Procedure for Documented 10/31/85 Review of Plant Operating Mode Canditions. Rev. 0 / CPPP-11 Administrative Control of Cale ations, Rev. 0 11/27/85 { \ CPPP-12 Cost and Schedule Control P oce, dure, Rev. 0 10/11/85 CPPP-13 Site Construction Suppo Activi es, Rev. 0 10/11/85 CPPP-14 Procedure for the Prep 4 ration and Control 11/05/85 of Project Procedures, Rev. 1 \ .
/ \
CPPP-15 Small Bore Stress / upport Requalification Procedure \
\
PM's Project Memora da \ PM-001 Pipe Suppor ' Computer Program Usage 11/01/85 PM-002 Design Cr/teria for Pipe Stress and Pipe \ 11/04/85 Suppor s PM-003 Desig Information Request Procedure 11/18/85 PM-004 EmVedment Plate Evaluation 1 02/85 PM-005 alve Modeling - 12/03/85 PM-006 Use of Code Case N-411 for CPSES Stress - 12/13/85 Requalification
\
\ l l
l
, APPINDIX A ,e
- o f 13 The ma- details, however, ar ont;'ned
\
in pr> \ cedure CPPP , PP-6, CPPP-7 and CPPP-8. N f Thev will he M: d t; th; "",C ;;aff iv, review. A I ^t thu ;L= nune no.e L;;n ceincet These pro-h* cedures will reflect all CPSES FSAR comitments and the ASME Section III Code of Record (with NRC approval changes). In the process of the requali-fication effort, it is expected some changes to this FSAR and ASME Section III Code of Record will be requested by TUGCO. These changes (some pre-viously approved by the NRC for use on previous s ee SWEC-designed plants) might include pe eyY)rw .:::Sn vtoc.r-use the following documents: NUREG=0484 Code Case N-392 Code Case N-411
, Code Case N-413 In addition, Procedures CPPP-6 and -7 will include any specific methods required for the proper treatment of all external source issues which are ;
not covered by the standard SWEC procedures and j
, which are unique to the CPSES plant. At this $###
time, Procedures CPPP-6 and -7 do not include all hccF of the methods required for the resolutinne of p f I f'
- these issues. ~
[/## y /W When all work is completed, revisions to these W gg rocedures will be incorpora ted. It is not ggi
/ts## # intended that all of the backup detail or suppor-
- 7. f J f ting SWEC calculations will be included in the p[q g
*g
' p , M[1 4) P!
4 procedures. This detail will be available for ro !
, ( review at the SWEC offices. ,
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APPENDIX A Pag,e 5 of 13 TUGC0 has requested (W.G. Counsil letter dated p , u p 11/18/85 to V. Noonan) approval for the use of I Code Case N-411 from the NRC. This reonest _i s ped w t "* presently under consideration at the NRC. O
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- 2) Verification of As-Built Infomation 07 AN g:2 $(heu, tt c *t r Since the as-built data will be used as input for n pt-the SWEC requalification e f fo rt , it ..i.s. important I" * #
y tn develoo confidence in its accuracy. ppg m Sup p e - The process being used to develop this confidence I' ' # tru involves walkdowns performed by SWEC, a reliance werwr-of previous work by TUGCO, and other work by the MN O CPRT. & '4:- p
~
)MC The walkdowns by SWEC include: 8" N#
twff - W c2 a) CPPP-5 Field Walkdown p @fft , b) CPPP-8 Walkdown c) SWEC " Stress Reconciliation Walkdown" Previous work by TUGC0 includes their 1) " General Program for As-Built Piping Verification" and 2)
" Penetration Schedule".
The activities by CPRT to be considered here include the QA/QC Construction Adequacy Walkdown, specifically those for samples related to piping and supports. CPPP-5 Walkdawn_ - the purpose of this walkdown by SWEC was to establish confidence in the adequacy of dimensions and functions shown on the as-built drawing to support the initiation of the piping analysis effort. This walkdown is discribed in SWEC procedure CPPP-5 and the results will be
APPENDIX A Page 6 of 13 g p [ ublished in a c ; <down report. W =;i k ur-- 2 [G i te de-4 a'; + ' ^ - - - ' - l (# -per# = ad ?t th ( f!M The walkdown consisted of the field verification f' f ggfM of random samples of four attributes selected by The attributes selected included valve lo-f SWEC. [ cation, pipe support location, pipe support func- / '/ [ ^ $. f tion and support orientation. J;* Mlkdown repari ve ave +ad to 5a 4"una en Q Preliminary results indicated the need for a
,_/ 100% walkdown of the support and valve orientation attribute. This 100% attribute walkdown has now been completed by TUGCO.
CPPP-8 Walkdown - This is a Piping and Support System Engineering Walkdown. The objectives of the walkdown are: (1) To detennine whether there are technical con-figuration issues, other than existing tech-nical findings from previous reviews, that should be evaluated relative to the functional behavior of the system, and (2) for experienced SWEC personnel to become familiar with the physical aspects of the design and determine whether additional, or refinements of, design inputs, guidelines, or procedures are necessary for the pipe stress and supports requalification effort. r, The walkdown was performed on a total of 70 stress
/ / problems out of the approximately 360 which are within the scope of the SWEC requalification v.
/L effort.
M The walkdown was performed by teams of SWEC pipe fT p stress analysts and pipe support designs h
- a=
.as
. APPENDIX A Page 7 of 13
./ h, . The data is presently being evaluated and additional verification walkdowns 7 W
', Ah will be performed at the site as needed.
d f M ccpert for tMr a "a - + M c pui.cu w oe in late Anuary, 1^"C. (imenad SWEC Stress Reconciliation Walkdown - This, as in other nuclear plants, will be performed by pipe stress analysts with the completed piping stress analyses. The item of most concern here (with respect to as-built information) is gaps and interferences. TUGC0 General Program for As-Built Piping Verifi-cation - These represent the walkdowns performed by TUGC0 to satisfy the general intent of NRC IE Bulletin 79-14. The TU000 ;-arad" ras esedy b;hdad CP-QP-11.3, "e . 6, QI-QF-il.13-1, Rev. S._C" EI-4.5-1, Rev_ Q and TME 4 ?4-1, Rc.. O. C... Penetration Schedule - The penetration schedule is a detailed computer listing describing all of the penetrations in the plant. The schedule lists the type of sealant, type of penetration, openings and a number of other parameters. The stress analyst can obtain all required info relative to clear-ances etc. at penetrations having this available. QA/QC Construction Adequacy Walkdowns - The piping configuration and pipe supports sample walkdowns (See Appendix B, Paragraphs 5.3.3 and 5.4.4 of this report) along with all of the above will also provide verification of the as-built information . (r0cc C""" 0, "cv. O. " r:3r:P5 1.0) .--
APPENDIX A Page 8 of 13 Review and Verification of Systems Design Input, 3) Seismic Acceleration and Fluid Transients S'WEC will review all drawings and specifications for systems within this scope. The specifications will be reviewed to assure compliance with
/
licensing commitments and that all operating modes and conditions are identified appropriately. Existing fluid transient loads will be reviewed and new loadings generated, if required. SWEC Procedure CPPP-10 describing the operating condi-tions for the plant has been prepared and includes some of the above data. A third party review of this activity will also be performed. A procedure review will be performed to verify that the SWEC procedures are adequate to perform their intended purpose. This procedure review will focus on, among other things, the definition and verification of design input. 4 Verification of Existing Pipe Support Design Docu-ments The CPRT Program Plan in 05AP IX Attactnent 2 states that the existing pipe support calculations will be reviewed to detennine their technical ade-quacy. SWEC originally intended to review existing large bore support calculations on a sampling basis to determine their acceptability by using a load comparison method. However, in the M e~mber 22, 1985 lety, the approach changed to pg.m 7, evaluating all large bore pipe supports TV individually. SWEC Project Procedures CPPP-6 and CPPP-7 describe 'the approach to be used, the design criteria to be satisfied, and the extent of the review required for the pipe support requali-fication ef fort. Thus, this Action Plan
, ..APPENDfX A Page 9 of 13 element has been incorporated into Action Plan Element #1.
5 Resolutior of Special Technical Concerns (By Dave Terao) C 6\ Reanalysis of Pipine Systems and Reevaluation of I Pipe Support Designs (By Dave Terao)
TPENDIX A Pag,e 10 of 13 5.5.3 Staff Evaluation
- 1) Development of Comanche Peak Pipt. Stress and Pipe Support Design Criteria Due to the fact that the major detr.ils of the SWEC requalification effort are contained in the SWEC project procedures CPPP-5, CPPP-6, CPPP-7, and CPPP-8 and since these have not yet been made available to the staff for thorough review, the task of evaluation has been and continues to be very difficult. The primary method of evaluation has been through audits which have been performed both at the try SWEC offices and at the CPSES site. During these audits, draft copies go g gf the procedures were available for review.
d y/ T is i m is n pen con T o"% FM tem [ The staff will od this ri a sup ement is . [h i l' " N O
,p d(e$g &- [, 2) Verification of As-Builtmation Infor&rso dprco d / g' "/ g r$
s g( "O rja r pu r u r LeW, (l*
'frCf44 p 0 </'(*7 (/ During' staff audits at the WEC offices and at the ( W sis' Itu Ti t l u te U9 9/ *
'hpdCPSES site, CPPP-5, the CPPP-5 walkdown report, CPPP-8, the TUGC0 as-built procedures, the penetration schedule and the QA/QC piping and pipe e h48 d
r Mg A, supports samples were discussed and partially reviewed. In addition, o f the staff and its consultants performed verification bf h -5 a -8 -
- g alkdowns. i f
^I
,f g/
Ff g The following questions and/or comments remain as open tt f iy: g ./ t p D /* a) For the CPPP-5 walkdown - the valve and support C i location tolerances used by SWEC range from +/- 3" to +/- 12" depending on the dimension used on the L / W, f / g drawing. Typically, a tolerance for such a dimen-sion is a function of the diameter of the piping syrtem. In this case, there is no relationship. p l's i n g this CPPP-5 approach, a valve or support fp could be mislocated more on a 3" line F fr
... , " APPENDIX A Page 11 cf 13 than on a 30" line and is within the limits established in CPPP-5.
ega it4 This dees act m ke IS cr o oJ e e%~c r ,- sese--from a pipe stress point of view. Th_e _1_2," tolerance shouli bdus.t_ified_ by_.SWEC_ for_ small p .r diameter piping as a minimum. M Cso m e n 4 ir 'l j b) For the CPPP-8 walkdown, until the final walkdown /et. c.c, report is issued, the evaluation of this task can- WM rY g not be completed. However, a preliminary review k&e4 e of a portion of' the data indicates several dis- # g& i crepancies with snubber / strut installations such
' g g p,' 888 as improper alignment and interferences with the g t" (/ 1/ M rear bracket. It was also noted that there were A
dc T1W ptM %8 improper clearances between the pipe and support pf member at some locations. M I eN g f.^ c) SWEC Stress Reconciliation Walkdown Procedure N ' 5 g Ar M CPPP-6 indicates that a final field walkdown will p be perfomed at the completion of the requalifi- .r v ti-cation effort. The purpose of this walkdown is to v Ps F '- pv F
- verify that sufficient clearance exists between VJ 0 F C
p p(9 T the piping systems and nearby structures. Based ,_ at on the preliminary conclusions from the CPPP-8 mm fb i f walkdown data, the scope of the stress reconcilia- r . f. '5 tion walkdow[should be expanded to reconcile con- ru yig H1 ppri ' cerns such as are noted above in b.
.ne, a r-
)M TW d) TUGC0 Penetration Schedule - During an audit at p f rt o a)
/
[7 the CPSES site, the content of this schedule was discussed with TUGC0 employees. It appears that P'*"' O L /* the information required by the pipe stress anal-
. ysis is available in this schedule. The apparent '
/ lack of reference of this penetration schedule, pid d; - however, in the SWEC Procedure CPPP-7, is of con- p4 yr [ cern to the staff. In addition, the staff plans a e.v M f o j u r -
walkdown to verify the accuracy of the data in the a, a f f penetration schedule in the near future. Due to k f go the above, the staff considers this to be an open Avgic 4 M item and will consider it in a supplement to this Gt6 SER.
, .. APPENDIX A ,Page 12 of 13 e) QA/QC Construction Adequacy Walkdown -
During audits at the site, it was determined that there is a difference of toleran:es used within this walkdown versus those "ured :.by SWEC in the CPPP-5 walkdown. In adcition, it is not clear to the
\ staff that the tolerances used here for gaps
,f (e.g., on box frame supports) would be acceptable g/
I) # 6 for the SWEC pit.e stress requalification e f fo rt . It is recommended that all tolerances here be re-f I viewed by SWEC and their acceptance documented. ( d i Until this is available for review by the staff, g/ [ this remains an open itt:m and the staff will con-fg [ ider it in a supplement to this SER. S/ - Since, as described above, the total verification of the as-built drawings is a function of a compilation of a number of M' walkdowns and work by at least three organizations, iQ recommended \ that one document be prepared to_ Compile and integrat_e_ all of, _th_is @ f f
.. famition. Without such a document, it is not clear to the staff if all of this information is compatible and it is not clear that it will lead p c to the proper conclusions, f/w Cit (is.
- O In addition, since the need for the 100t walkdown d' g
r offailure valve and strut orientation came about in CPPP-5 as a result of the i
/
v of one of the four attributes chosen by SWEC, and since this ' #1 t,. i failure effects any conclusion relative to the accuracy of the as-built [/ data, it is recommended that a statement regarding this failure and its effect on the accuracy of the as-built data be included in this docu-ment. The comparison of the 100t TUGC0 re-walkdown with the existing as-built data would be helpful in reaching a conclusion. t Until all of the documents noted above are avail-able for thorough review by the staff, all of the concerns noted above 1 f# are satisfactorily resolved, the verification of as-built data remains as an open item.
- 1
APPENDIX A P, age 13 of 13 5.5.4 (This will be very brief and presented in general tenns with reference to the detail provided in 5.5.3.) These words have been written by Dave Terao.
/
C
Appendix A p Page 1 of I DRArT Paragraph 6 - Exclusion of Vendors and Other Organization Activities ex. (Note: This paragraph deals only with the piping and should be incorporated into a more comprehensive section of this topic). The Class 1 piping is not within the SWEC scope but is the responsibility of Westinghouse. The loads from the SWEC analysis of the Class 2 and 3 ' piping imposed on the Class 1 piping as well as the requalification results of Class 1 supports (including pipe support stiffness) will be transmitted to Westinghouse. These interfaces are described in procedure CPPP-6 and are considered to be satisfactory by the staff. O e
a s= w.
.) A.;
s-APPENDIX B Dm2%% se - SECTION 4 t 4.0 EXTERNAL SOURCE ISSUES (ESI's) 4.1 Introduction The CPRT has developed a Program Plan which defines the scope, structure and methodology to be used in demonstrating that all concerns relating to construction adequacy identified by the NRC staff (i.e., TRT, CAT, SIT, Region IV), CYGNA Independent Assessment Program (IAP),
- Collectively, ASLB Proceedings, Intervenors, etc., have been addressed.
these concerns are sometircas referred to as " External Source Issues" or
- ESI's.
In order to adequately address all ESI's, including root cause and generic implications, and correcting any deficiencies resulting from this review, the applicant must demonstrate that there is reasonable assurance that the construction of Comanche Peak Steam Electric Station { (CPSES) complies with the requirements embodied by the regulations, and that it can be operated without undue risk to the public. ( t.f CJ 2T WIL M To accomplish the resolution of the construction-related external source issues, the CPRT has developed ISAP's in two categories: l
~
- 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 as issues by the External Sources. This includes any addi- l j tional construction QA/QC concerns identified by the CPRT through its evaluation of those issues.
As CPRT determines it appropriate to the specific - issues being considered, each of the Category 1 ISAPs will employ approaches: one or more of the following evaluative reinspection of hardware, review of hardware, documentation walkdown inspections, data collected from other CPRT Review Team Action Plans engineering analysis and evaluation, and review and verification of TUGC0 Corrective Action Plans.
DD $'y - APPENDIX B W Nku SECTION 4
- The Category 2 ISAP (VII.c) implements the CPRT's self-initiated hardware reinspection / documentation review program that addresses all safety-related construction work activities at CPSES. The implementation of this ISAP will include consideration of specific QA/QC issues and the results of implementation of this ISAP may contribute to the resolution of QA/QC issues in other CPRT Action Plans; e.g., I.d.1, QC Inspector Qualifications, VII.a.1, Material Traceability, VII.b.3 Pipe Sapport Inspections, etc.
The Introduction to Appendix B, Quality of Construction and QA/QC Adequacy Program Plan, Revision 3, was revised as follows to address ESI's:
"To assure that all issues / concerns for external sources are addressed, a matrix is being 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 presents information such.that each valid concern can be tracked to the appropriate Criteria of 10CFR50 Appendix B and/or hardware area and to the ISAP or DSAP covering the problem. During this development phase, personnel from the QA/QC review team assigned to develop this matrix will work with ISAP/DSAP !ssue Coordinators and others. to determine which ISAP/DSAPs need to be mod-ified or supplemented in order to cover all concerns. The team is reviewing source documents in detail to ensure that all identified problems with any substance are included in the matrix. The external sources are the following: SSERs (particularly SSER 11, Appendix P) NRC January 8 letter S w M o rt.,t v o'c* W i P NRC SIT Report, February 15, 1983 "fM[, ' NRC CAT Report April 11, 1983 CYGNA Report l
- , ses
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" - ~' -* -
APPENDIX B SECTION 4 ' Contention 5 NRC HITS Docket - 'v Im /8 7*'5 MAC Report Lobbin Report Teledyne Report NRC - SRT Report Region IV Inspection Reports During the course of the CPRT activities the matrix will be kept current to incorporate status of ISAP/D' SAP results and to ensure that all con-cerns have been satisfactorily closed. WD M t! "M
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DRAFT ( APPENDIX B STAFF EVALUATION OF THE CPRT CONSTRUCTION ADEQUACY PROGRAM PLAN > 4.3 Test Programs
'T 4.3.1 Introduction .
,Er put? 3 The NRC Staff performed a comprehensive evaluation of the g Revision 2 of the CPRT Plan and provided concerns that arose from that ye 0 l evaluation to TUEC. fs~(,. l Revision 3 of the Program Plan responds to the Staff's #pr 7 l concerns and provides the basis of this evaluation of action plans that K,Q' ,' )
( address the resolution of concerns related to test programs. pp 4 - ; 17 i W rt r* r 4.3.2 CPRT Approach k pg gu 4 DetW The CPRT prepared issue specific action plans to evaluate ' jest and resolve the test program issues. The plans are identified as: 'Mptgg ff,eI #m I' . R-3 III.a.1 Hot Functional Testing (HFT) Data Packages R-2 III.a.2 JTG Approval of Test Data R-2 III.a.3 Technical Specification for Deferred Tests R-3 III.a.4 Traceability of Test Equipment R-3 III.b Conduct of the CILRT R-3 III.c Prerequisite Testing R-3 III.d Preoperational Testing 4.3.3 Staff Evaluation ( The Staff's evaluation of the Program Plan Revision 2 did not present any concerns for the ISAPs III.a.2 through III.2.4, and III.b, III.c and III.d. However, concerns were identified for I3AF III.a.1.
l 2 DRA===l I t i Evaluation of the responses for the concerns about ISAP III.a.1 finds that the CPRT has satisfactorily justified or clarified the concerns and where applicable has incorporated the response in the revised action plan. 4.3.4 Conclusion
- Based on the staff's evaluation of Revision 2 of the.
Program Plan which did not present any concerns for six of the ISAPs for the test programs issues, and evaluation of the CPRT responses to concerns i related to ISAP III.a.1 the TRT concludes that the test program ISAPs as i presented in the CPRT program plan Revision 3 are acceptable,peevided-that the e4r ftaps III.a.? thenenh a and III.b _!!!. 1 Land _IILd_have not been
- i
- ;;d ;&-nuent in +he 4=="e of tha Program 4-lan4edsfen4. If such is
" e est , :::epte ce e' th; Plan Revi=ica 3-it ;:nding N"C-5 rwin of f +haee -evised !<Aps- ,
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APPENDIX B SECTION 4.5 4.5 Civil and Structural Issues 4.5.1 Introduction fe f Attachme 1 to Appendix B lists the Category I ISAP's f related to issues identified xternal Sources in the Quality of Con-struction and QA/QC area. Prog atic and hardware-related Issue k Specific Action Plans are contained in th isting. 4.5.2 CPRT Approach , i g The generic elements for the ISAP's evaluation approach I p' t are given in Appen ix B. The specific issues being considered may g employ one or more of the following approaches:
*s ,
Reinspe ion of Hardware ( 2, Review of cumentation e' q g[
\
Correlation With Data Collected From Other CPRT Action
& Plans dg I N NA EngineeringAnalysis\andCvaluation C,'
l
\
j Review and Verification 'of TUGC0 Corrective Action Pro-grams
! \
All valid hardware deviatiohs will be evaluated for safety significance. This evaluation is performed by a Safety Evalu-1 ation Groco. Aspartoftheevaluation,theCPRYwillseektodetermine l the root cause of all safety-significant deficiencies. Where a root cause can be estabished, generic implic'ations will be tvaluated.
\ -
I \ Interrelationships between external Nource issues ISAP's and the self-initiated ISAP VII.C have been estabibshed as well
^
.< ,[D Mi .k [' "
APPENDIX B SECTION 4.5 as relationships with ot CPRT Program Plan elements. This - will be accomplished through the CPRT A/QC Review Team. In order to ident and keep current, the CPRT is reviewing External Source Documents nd developing Issue Tracking Matrices that will provide a cross-referen between each Issue / Concern and the Action Plan that addresses it.
"'t.
4.5.3 Staff Evaluation s d The Staff as reviewed the CPRT responses to the NRC (l l , etters of August 8 and Septe er 30, 1985, and the proposed revisions y$ g' t t the CPRT Program Plan (Revisio 3). g, f Mdcgi d The revised Appendi B states that Issue Tracking 3('p atrices will be developed which identi all External Source Issues, cluding classification, identification o ISAP that covers issue an a status report. i
/ The revised Appendix B is acceptable, pending NRC f Mewofthe Issue Tracking Matrices. This review is needed to ensure l r (hat all ESI's have been identified and that a tracking mechanism is in
'# ( .(placeforcurrentandfutureESI's.
/
,/ ! The Staf evaluated the CPRT responses contained in the
/ November 22, 1985 letter per ining to the issues related to the Quality )
of Construction and QA/QC Adeq cy Program Plan. The responses provided + . clarification and, where appropri e, were incorporated in Revision 3 to the Program Plan. The detailed Staff coment evaluation and conclusions for the External Source Issue ISAP's are given in Section 4.6.3 of this l SER.
- l
-y -- -
m 7 -,---
D h, .g i APPENDIX B STAFF EVALUATION OF TH CONSTRUCTION ADEQUACY PROGRAM PLAN . 4.6 QA/QC ISSUES l 4.6.1 Introduction The NRC f performed a comprehensive aluation of N! ' Revision 2 of the C TIan and by letters to TUEC ed August 9 and September 30, provided the Staff's concerns at resulted from the gy o gYc. tf ) evaluatio gr , g&P d Novenber 22, 1985 th RT submitted its Jo6 g By letter d responses to the Staff's aluation. These respons (, of the CPRT Progra lan. Revision 3 of t resulted in Revision Program Plan provides the uj basis of the S f's evaluation of the /QC issues related to the CPRT Constructi Adequacy Program Plan, j fig fpgne 4.6.2 CPRT Approach M Fr* M / The PRT has been arged with respo ing to and resolving the TRT nd ASLB issues a remaining open SSER , CAT SIT RIV and IAP issues. ollectively, t e concerns are som mes referred to as external urce issues. Wi n those external 50 ce issues are the QA e issue hich are the subject of the evaluati in this section. Program Plan, Appendix B, Quality of ~ Under the Construction and QA/QC Adequacy Program Plan, the CPRT developed issue i specific action plans to address and resolve the QA/QC issues related to construction adequacy. (Reference Appendix B Attachment 1). As the CPRT l determines it appropriate to the specific. issue being considered, each nf the listed ISAPS will employ one or more of the following eyaluative I approaches: re-inspection of hardware, review of hardware documentation,
i
- c. 'o DRAFT walkdown inspections, data collected from other CPRT review team action i plans, engineering review and analysis, and review and verification of j TUGC0 corrective action plans.
ISAPs Related to Issue Identified by External Sources A. QA/QC Progrannatic Issue-Specific Action Plans-4 1.d.1 QC Inspector Qualifications 1.d.2 Guidelines for Administration of QC Inspector Tests VII.a.1 Material Traceability j VII.a.2 Non-conformance and Corrective Action Systems VII.a.3 Document Control VII.1.4 Audit Program and Auditor Qualification VII.a.5 Management Assessment
~
- VII.a.6 Exit Interviews l VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation i
B. QA/QC Hardware Related Issue-Specific Action Plans I i 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 Electrical Raceway Support Inspections i In addition to the above, also under Appendix B, the CPRT issued a self initiated ISAP VII.C, construction reinspection and documentation review plan. The Program Plan defines the interaction of the results of the implementation of this Plan (VII.C) to assist "in the ~ l resolution of QA/QC issues addressed in other action plans. i
....,._,._. .-_ - . . . . - _ . . . _ , . _ _ _ . . . , , . . _ . , . _ _ _ _ _ _ . , - , , , _ , . _ , . _ . _ _ _ _ . . , . _ _ , _ _ _ _ , _ _ . _ . ~ , , . _ . , _ . . - _-
'8 DRAFT Design related QA/QC issues will be resolved within the Design Adequacy Program Plan.
To ensure that all issues are identified including these .l 'f tf listed in SSER-ll Appendix P, the CPRT in an ongoing activity is reviewing, , ($ Qf external source documents and developing issues tracking matrices thatl gf.,y provide a cross reference between each issue / concern and the action plan (s)( 4. /. / that address it. 4.6.3 Staff Evaluation pd T.ha-Ertsif iras evaiuoi.ed the CPRT responses-(CPRT Pregi ero I R1an Revkien 3) +n ensure that the concerns Expressed _in_thfLNRCis letters-Aupst-iHnTd-Septermer-30,-1985-have-been-responded to or are-addressed in-Revision 3 ef-the Dregra- D hn This evaluation pertains principally to (. QA/QC issues regarding the Construction Adequacy Program Plan
- o. _ . y . .u . .... . ,_ m er,. Q-
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- 1. Appendix B, Section I The Staff raised a concern regarding Appendix B, Section I, Page 4 which stated that the results of the 1RT SSER-ll have not yet been incorporated into the Plan (particularly Appendix P) and requested that the applicant indicate how the QA/QC concerns in Appendix P will be reflected in the appropriate ISAP and DSAP.
The revised Appendix B states that matrices are being developed to identify the issue and cross reference to the action plan that resolves it. , The Staff finds that the revised Appendix B which f gg#V ^E pertains to tracking and resolving the issues is acceptable pending NRC w i&Dp ftY D # Aa.. w, . m-m., YfW G A. d w
' >- fn P> r P W A / M 6-em "kkm.
.A '
DRAFT review of the matrices to assure that the issues listed in SSER-11, Appendix P are identified and listed in the matrices. This NRC review will establish a level of confidence that all QA/QC issues will be resolved. The Staff evaluated the CPRT's responses to the NRC's concerns pertaining to the QA/QC issues related to the Construction Adequacy Program Plan. The responses provided clarification of the concern and where applicable were incorporated in revision to the Plans. The action plans evaluated are listed in the previous section, 4.6.2 (CPRT Approach). The Staff coments as follows: 2 The evaluation of issue specific action plans I.d.1; VII.a.3; VII.a.4; VII.a.6; VII.b.1; VII.b.2; VII.b.3; and VII.b.4, found that the CPRT responses adequately addressed the NRC's concerns and that h the responses have been incorporated in the revised action plans. Accordingly, the revised ISAPs, identified above, as presented in the CPRT Program Plan, Revision 3 are acceptable. The Staff did not present any concerns resulting from its previous evaluation of ISAP VII.a.1 Revision 0, and ISAP VII.a.8 Revision
- 0. The Staff finds that these plans Revision 0 are acceptable as presented in the CPRT Program Plan, Revision 3.
4
- 2. ISAP I.d.2 l The Staff's concern was that there was an incorrect inte 1 rf ace between the Special Evaluation Team (SET) and TUGC0 defined in the action plan. The CPRT responded that the interface activity was performed in accordance with the Plan and will be documented in- the action plan results report. The Staff's evaluation finds that the departure from interface requirements is minor with no effect on plan implementation or issue resolution. Accordingly, this ISAP as presented in the CPRT Program Plan Revision 3 is acceptable.
DRAFT
- 3. ISAP VII.a.2 The Staff's concern was that the Plan is written (in part) to address the detail findings listed by the TRT, however, the detail findings were not identified in the Plan. The CPRT responded that the TRT issues identified in SSERs 7, 8, 9,10 and 11 will be identified in issues tracking matrices which identify the issue and the action plan that will resolve it. The evaluation of each TRT issue will be reported in the Action Plan Results Report. The Staff evaluation finds that the revised Appendix B which pertains to tracking and resolving the issues is g r' acceptable pending NRC review of the matrices to assure that the issues f listed in SSER-11 Appendix P are identified and listed in_ the matrices. .- g er This NRC review will establish a level of confidence that all QA/QC issues /v6 will be identified and resolved. Other. NRC concerns regarding this plan
{ have been incorporated in the revised plan.
- 4. VII.2.5 i
The Staff's concern was that the plan was not responsive ; to the NRC's request (in part) that the plan's evaluations consider the implication of the TRT's finding on construction quality and an examination of the potential safety significance. The CPRT responded that this ISAP was not intended to perform evaluations which would result in conclusions regarding the installed hardware but rather to rely on other action plans to assess the quality of hardware and any potential safety significance. The Staff evaluation finds this response acceptable and also that the action plan has been revised to incorporate the response to other concerns. Accordingly, this revised plan as presented in the CPRT Program Plan Revision 3 is acceptable.
~
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~'-
DRMT r
- 5. ISAP VII.2.7 The Staff's concern was that terminology "recent TUGC0 b
information" as used in the plan was vague and the Staff requested that the plan be amended to delete the word "recent" and define the time span that The CPRT responded that the encompasses the information to be reviewed. time interval to be reviewed was dependent on the nature of the site activity but in some cases, especially audit reports, the reviews go back to 1979. The word "recent" was deleted. ~ This evaluation finds the response to be acceptable based on the Program Plan requirement that the action plan files will identify the documents reviewed (the dates should be shown thereon). Accordingly this revised plan as it is presented in the CPRT Program Plan Revision 3 is acceptable.
- 6. ISAP VII.b.5 The Staff presented a concern that the plan, Section 4.7, does not describe the standards (e.g., FSAR, IEEE, Regulatory Guides, etc.) against which the reviews are performed, and also stated that Section 4.7 of the plan was not in compliance with the Program Plan attachment 3,
- ISAP format. In its' response to this concernfthe CPRT revised this plan (VII.b.5) stating that the list of documents (Standards) is contained in the ISAP VII.C record file. The revision also added a list of inspection attributes. This evaluation finds that the response is not acceptable because it does not adequately address the noncompliance stated in the NRC's concern. Accordingly, although the response to the concern regarding sampling plan definition is acceptable, this revised plan ble as oresented in the CPRT Program Plan Revision 3.
(VII.b.5) is not acce r>T1*=r RrA. u "' c' ' r' W Accordingly,Ytw the CPRT /pta shall take appropriate corrective action to prepare Section 4.7 in accordance with the CPRT Program Plan attachment 3.
- o. 'o
+
DRAFT 4.6.4 Conclusion In its evaluation of the QA/QC issues the Staff reviewed the CPRT Program Plan Revision 3. to assess the accuracy validity and acceptability of the CPRT responses to the NRC's concerns which were derived from a previous staff evaluation of the plan revision 2 and presented to TUGC0 by the NRC in enclosures to letters dated August 9 and September 30, 1985. The Staff's evaluation of these QA/QC issues regarding the ya.- Construction Adequacy Program Plan as detailed in Section 4.6.3 found that fut i r' * # the CPRT method of identifying and tracking individual issues (particularly #f , ,,e y SSER 11, Appendix P) remains an open item pending NRC review of the iupMy matrices and any new action plans that result from development of the e,r
' S""
matrices. l 4 .c
)
{- This evaluation also found that the revised ISAP VII.b.5 f
,Z # '
does not comply with the Program Plan. ' K$,,a Ytt>tT Accordingly th Staff con es that except for SAP b w_ VII. 5 whichihuires ,cofr ti e action , the CPRT Rev 3 . the [g f ; Program n adequately ad ess s t ^~ " D
/
T' t ficat
, resoufnof e Ptvt<~saw-QA/QC is tes pe , 'ining t ,tru/ction ad quacy' howe er, final ac p c g of the plan is dependen on 'resubmissio f'ISAP V .5 and the Staf s review of the matrices which identify the individual issues.
A e e a rt a i n ,e. y , , a w crm=, e. ,eeuoer r,w rtbr Cf g7, rdevoga w 5 , .n g pu 4 y w pu a t,w suArrty if-o o fte r C e rs ot-ec. G r> r a r. r p ot e 9 ' ( @m W v er hrr e s Fort vt-e 1 e t. u r t e a en.- rt err M L o '~' 's-4 do weDL*/3 : .
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DRAFT APPENDIX B STAFF EVALUATION OF THE CPRT C0hSTRUCTION ADEQUACY PROGRAM PLAN 4.7 Miscellaneous Issues 4.7.1 Introduction Initial Staff's concerns regarding miscellaneous issues arose from the TRT's investigations of allegations in the civil / structural area.
' omprehens aluation ision 2 e P1 as g periorned b the S ff d concern forwarde e CPRT. .
O e PrograpH'lan wh T
- EC r spondedftFR vision 3 provides of the isce aneo q ,issuas.
asis of th @ f's evalu
\\ s 4.7.2 CPRT Approach ' rtF $
/
[ i.s
- The CPRT formulated ~ issue specific action plans which p sM will evaluate and resolve the 1,ssiles. The CPRT on an ng basis is p,w W (N reviewing external source docunients (e.g., SSERs, RIV Anspection Re
[ etc.) to identify issues wbf(h must be resolved. The reviews result in the [ preparation of: acode[crossreferencewhichidentifythesourcedocu- pcr 0 elatedtodesign(DAP);'andissuestrackingmatrices b# 4 ments and the issu , which identify e issue, the source doc,ument, and the action plan (ISAP pv , The ongoing I and/or DSAP) hat evaluates and reso)ves the issue (CAP . view team and the source do ment review and interface'between the QA/QC are identified a addressed, and if DAP w
- ensure that all iss ired, new action plans are prepared and implemented.
re :
DRAFT 4.7.3 Staff Evaluation This evaluation finds that CPRT Program Plan addresses the methodology th g j g identify and resolve the miscellaneous issues. Qrx up vg wittett &M A > c uu e! ir s.r nge-u ef gr pw MA.4<mr 4.7.4 Conclusion Based on evaluation of the CPRT response and the methodology described in the Program Plan the Staff is confident that the CPRT will resolve concerns regarding miscellaneous issues. Accordingly, the Staff concludes that the CPRT Program Plan, Revision 3, as it addresses the resolution of miscellaneous issues is acceptable pending the Staff's f review of the DAP's coded cross reference and the QA/QC review team'5 issues tracking matrices. m w % 4, C on w cy a s . e f
/
===
- e. 'b '
Ib APPENDIX B STAFF EVALUATION OF THE CPRT CONSTRUCTION ADEQUACY PROGRAM PLAN 4.8 Closed External Source Issues The revised CPRT Program Plan Appendix B describes the use of issues tracking matrices that ar6 prepared by the QA/QC review team as a result of their review of all external source documents. These matrices provide a cross reference between each issue / concern and the action plan (s)th.ataddressit. The action plans submitted as part of the Program Plan Revision 3 have been revised to describe the criteria for closing out the issue. Although the action plan results report format (Program Plan Attachment 5) infers that closure of the issue will be reported, there is no clear statement in that format that requires reporting that each issue ( addressed in the action plan is closed. Therefore, Attachment 5 should be revised to include a requirement to identify each closed issue. little*r r f ri t T r w 7% K fAJ !a jnr 47 & 4r Arseusw 4.
- , , -- -,-..-.m-, _
=
r% M .g
,, t APPENDIX B-2kM[ ] '
SECTION 5.0 5.0 SELF-INITIATED EVALUATION 7-5.3 Mechanical Equipment Population . 5.3.1 Introduction In Appendix B, Quality of Conjtruction and QA/QC, Pro-j# Agram Plan, the CPRT has addr ed External ,Sdurce Issues and the meth-
/ t t odology used to assure tha 11 issues / concerns from External Sources are addressed. For additional confidence, the CPRT has established a self-initiated Issue Specific Action Plan. This self-initiated hardware reinspection /documentp[ ion review program addresses all safety-related construction work a ivities at CPSfS.
- h y1' j f p,4 The Category II, Issue Specific Action Plan, related to ggf the Self-ini ated Reinspection / Documentation Review Program, is ISAP 5I VII.c. [ ,
""p J
/ // /
j .The pon truction adequacy review program J's being per-formed within the pu@few of the Coman he Peak Responsedeam with ERC, In responsible for performing the revi m ! 5.3.2 CPRT Approach . / ([ $ The self-initia d plan consists of p sam le reinspec-1 g tion, based pon statistical ech ques, of QC-acce6ted afety-related constructio work supplemep ed by a document review for nonrecreatable el d g@ and/orin-processinspecIons. Tt e sample includes area of Units 1, 2 fo and comon areas. Construction activi v been categ by Disci-pline:
- 1. Electrical frW7Lr w rit W / w7?t-cpu e ra r >sy PM WW M LM '~ "
ht)r!-<rt.f tA/g wc(Wt cst-z
wa 4 mv ' " [ J h APPENDIX B SECTION 5.0
)
i 2f M hanij:ah F StMural{ scipline (conhruction a'cfvity)',' pula-Within eat tions ha t's The Mechanical Discipline Populations are: HVAC Ducts / Plenums HVAC Equipment Installation large-Bore Piping Configuration Small-Bore Piping Configuration Pipe Welds / Material Piping System Bolted Joints / Material Mechanical Equipment Installation Field-Fabricated Tanks Instrumentation Tubing Welds / Material The methodology established is similar for each popula-tion. Checklists, procedures and i structions will b} developed. For Within each population, work discip)1nus have been established. each population, two stmples will/ be randomly selected. The first The second sample will provide information about tle total population.
. sample will be from the safe shutdown s stems only, I
f The ke activities of he Plan are: i f ' l
- Establish Populatilon (M
# i - Select Samples f l
p
- Develop Checklist ;andInspectionProcepures l
v If f, - Prepare Verificatjion Packages
. f -PerformReinspectionsandDocumentationReview EvalgateValidityofDeviationReportsl(DRs)
I [/A t/ -
'- Adverse Trending i
[I g/'[L Present Results i
<%g%@
DkN APPENDIX B SECTION 5.0 5.3.3 Staff Evaluation (Generic) ' The Staff as reviewed the CPRT Program Plan for the self-initiated ISAP (VII.c on Construction Reinshtion/ Documentation
, Review. In addition, th Staff has performed several audits at the CPSES site. Through thes audits, the Staff has reviewed the basis for g the establishment of pop lation, work processes and attributes associ-ated with each discipl ne. The following is an overview of these
[ j$ audits. ; C f
>O The ke] activities required to formulate the plan were ,I Areviewed. The audits did not include the implementation activities of d D the action plan (last four key activities given in paragraph 5.3.2 of NE7 Appendix B of this SER. k
( i I , The CF'R T , under the direction of ERC, will establish procedures and checkli sts Some pro-( for each population id ntified. C cedures and checklists; for specific populations are not complete /or in t place at this time. The format and methodology applied in the develop-I l ment of these documen s is generic and therefore \ consistent with the [g, j. J quality of the documen s currently in place. For hach population the f t0 i following procedures a e prepared prior to the implementation of the sinspection/ document r view. \
\
W \ A)
- Popu'ation Description j Work rocess Definitions
- Popul tion Items List \
- Qualit'y Instruction (QI's) for Reinspeqtion QualitkInstruction(QI's)forDocument'tionReview l
Evaluation %esearch Corporation has develop d Project Procedures which define the neric requirements and methodolo ( to be
\ysed in establishing and implementing the above checklists and pro-cedures.
u A ' clt - APPENDIX B SECTION 5.0- ( The Population Description Procedure defines the bound-I aries of the population i cuding specific interf aces and the systems, components and structures ithin those boundaries. l I The Work Process Definitions Procedure efines the work processes applicable to t 1e specific population. If al work process has been excluded from the p3pulation, justification for f.he exclusion is given in this procedure as well as ERC Description Memorandums for the population. The source land choice) of attributes and acceptance cri- , teria to be used in the 7 inspection / documentation review are also given in this procedure. I The sourice of attributes and acceptpnce criteria was developed from the (original) construction specification and procedures utilized during the cons ruction of CPSES. The specific specifictions and procedures are referenced. l' (. l
\
The attriqutes for each work process are listed and the method of verification is hoted. Those attributes not, applicable for allsampleitemsarelistedyndthejustificationgiven. \ , The Population Item List for a population defines the source and specific items of k population as well as the ERC basis for accepting the list. \
\
\
Quality Instrucjion (QI's) procedures for Reinspection and QI's for Documentation Review are developed in accordance with ERC CPP-007. These procedures describe the methods and contain the check-
\
lists to be used by the QA/QC Revi Team personnel to perform and doc- ) ument their reviews. Accept / reject criterion for the review ist efined d for each attribute within the work pro ess. \
\
ERC Project Procedure C -008, Preparation o'f Verif.ica-tion Package defines the procedure and con nts of verification packages 1 i
.- - _ _ ~ . - , ___ ___
APPENDIX B D/ .4-d. SECTION 5.0 ; which will be used in the performance and documen ation of the reviews ! required by ISAP VII.c. [ j For each s; ample a separate Verification Package will be prepared and issued to the .QA/QC inspection gro p. These packages pro-vide all of the informatial necessary to conddet the reviews and doc-ument the results. The Ny documents containbd in each Verification I ,' Package are i I Content List Form Checkli t(s) {
- Suppl tal Inspection Instruction (if required) l
- Drawings k j
- Equipmen Specificationsandhocuments
- Database eport(s) {
Any Exis ng NRC's, DCA's, etc ERC Project Wocedure CPP-009, Performance of Reinspec-i tions and Documentation Review , describes the methods to be used by the QA/QC Review Team personnel to', perform and document! reviews as required , by ISAP VII.c.
\
, \
Reinspections and documentation reviews are perfor.ned utilizing the checklists and instructions contained in the Verification Packages. The method for initia ing a Deviation Report'.,(DR) when a con-dition on an item being reinspected / reviewed appears to.be inconsistent withthespecificQIcriterionisbefinedinthisprocedure.
\
\
ERC Project Procedure CPP-016, Safety' Significance Evaluations of Deviation Reports hstablishes the method to perform
\
reviews of valid Deviation Reports f r Safety Significance. The Safety Significance Evaluation Group (SSEG) shas _ the responsibility \,to review and evaluate valid deviations. Guidel nes are given for performing the l documented evaluation. Based on the re ults of the Safety Significance , evaluation, an expansion of the sample un r review may be required.
\
l
; .. .s yS g-,-a .
APPENDIX B ~~' A J 3 SECTION 5.0 5.3.4 Conclusions (Generic) Several concerns were raised by' the NRC Staff in the , 1 August 9 and September!30, 1985 evaluation letter's to TUGCO. These con-cerns can be sumarized as foll.ows: ,/ fp / - Inspector Certification Program.
# ,3* -
Basis and rationale for establishing tomogeneous ( p 8[ - hardware populations. ,,. Attribukeandcriterton, determination. ,
. Sample expansion criteria. .
/
The Staf"'s evaluation and' conclusions on the CPRT response to the concern on the Inspector Certification Program is discussed in Section 4.6 o ' Appendix B 'of this SER. i ) {; .- l The NRC Staff concludes ;that Revision 3 of the CPRT Program Plan for the selfeinitiated construction program (ISAP VII.c), whenevaluatedcEllectivelywiththeassemblageofproceduresandcheck-lists for the populations, adequately addresses the concerns raised on the basis / rationale for es ablishing homogeneous hardware populations and the method used in determining attributes / criteria.
\ N \
The concern raised by the'. Staff on sample expansion
\
criteria has not be\g resolved to the satisfaction of the Staff. The details of the concerns are given in Section .2 of Appendix i of this SER. l
- 1. l 5.4 Structural Populations e
/ 7 '
5.4.1 Introduction .
~
In Append B, Quali of Construc tion and A/QC Pro
,,_ Plan. th. C, T h.s p.ss.d ,xt.,_.,s..s nal and .. m.tv
., g ,
, - .2 L &Qf" )
i - APPENDIX B SECTION 5.0 . odology used to assure that'all issues / concerns from External Sources are addressed. For additional confidence, the CPRT has established I self-initiated Issue Specific Action Plan. This s if-initiated hardelare reinspection / documentation review program addresses all safety-related construction work activities at CPSES. <
/
The Category II, Issue Specific' Action Plan, related to the Self-initiated Reinspection / Documentation Review Program, is ISAP VII.c. [ '
/
The construction adequacy r9 view program is being per-formed within the purview of the Comanche Pdak Reshonse Team with ERC,
/ ,
Inc.,responsibleforperfojingthereview. 5.4.2 CPRT Approach
}f 4' The self-initi d plan consists of ample reinspec-p tion, based n statistica techni ues, of QC-a epted safety-related '
construction ork supple )nted byocument a r view for onrecreatabls ( , and/or in-proc ss insp tions. The s le cludes areas f Unity 1', 2 {I and common area The Structural discipline populations are: Concrete Placement Structural Steel Liners Fuel Pool Liner Fill and Backfill Placement Grout-Cement Grout-Epoxy Large-Bore Pipe Supports - Rigid . Large-Bore Pipe Supports - Nonrigid Small-Bore Pipe Supports
d
,..,=g D% . .
APPENDIX B
~
Es- A b["" SECTION 5.0 .g. Pipe Whip Restraints Instrument Pipe / Tube Supports Category 1 Conduit Supports HVAC Duct Supports Equipment Supports [ The CPRT ppr ch for met olo , samplingy ,efa uation and /eporting is he s e as th se desc bed in S ction 5 .2 of Appen-dii B of this SER.
/ 5.4.3 Staff Evaluation
.j T The , s performed by-17ie Staff at the and
/ described if 5.3.3/ above, included the Struc ral populations for -the f I (VII.c) on C nstruction - R inspe,cf. ion / Documentation i
self-initiatedh. SAP Review. 5.4.4 Conclusions The er'c conclusi[cr the Structural populations
/ i -
e the same s tho e given 'n 5.3 for thegbaffical discipline. fgr fpf & W L%r N '
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nucn<ien wpem a.uh w Me,s. W m%% W W m %M h-e n ;(* , W& pg a wu e rw n ice Wit-cb o i g e>e~ w n;
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, APPENDIX 8 SECTION 6.0 6.0 EXCLUSION OF VENDORS AND OTHER ORGANIZATION ACTIVITIE5 6.1 Introduction
%d During the construction of CPSES, there were a number of con- t tractor and hardware suppliers. Since it is an objective of the Program Plan to assure the quality of construction in addition to the quality of the installed hardware, it' is imperative that the Program Plan does not exclude addressing the work performed by all contractors unless there is adequate justific ation.
6.2 CPRT Approach It is the intent of the Program Plan, as outlined in ISAP VII.c, not to exclude any contractors, vendors or other organizations who conducted construction activities at CPSES. The Program Plan has a mechanism to identify and evaluate construction deficiencies or weaknesses and, if required, to expand the scope beyond that specified in the ISAP. If required, the expansion of the Plan will include review of g ity_assuranc_e__ programs of off-site suppliers. 4 h( Ym
@4
\
6.3 Staff Evaluation M Mcr 1 ( eu r w .t 2. The staff's evaluation of this issue is based on a review of Revision 3 of the CPSES Program Plan. ISAP VII.c, Construction Reinspection / Documentation Review Plan, includes the methodology to address this issue. Ad e,yt, a tw , %e *rths p at a c, y ps-L ! Mf NW &O .fr>ii e- f 7th*' 6.4 Conclusion Wff wo R-otr/*w n L=~ W mmge,f pm ,, w c_,e ,,, , c .
- 72/>ff 77W M M so &,p t f ste W A' -
7"?t73 t d'. The staff concludes that the CPRT Program Plan adequately-addresses this issue. Tt; irsic;entetien Will t: :;tj::t ' t: St af f. Teaen and eedit m p A 7- .y ff y nw ~ ~ n n N#c A/# / )c .
~
i a
SECTION IV - STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN - Draft 1 - 1/28/86 1 l 1.0 Introduction I The adequacy of construction QA/QC program and the quality of construction performed within , scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC'with responding to and resolving these concerns. This section of the SSER documents the staff evalua-tion of the CPRT formulated program to evaluate questions concerning construc-tion QA/QC and the adequacy of installed hardware. The CPRT's objectives for the construction adequacy program are to fully resolve
.; all of the external source issues, assess in an integrated fashion all identified 2: safety significant d'eficiencies and to make a statement about both the adequacy r and quality of construction at CPSES. The CPRT's program has the following three components:
~ - a. Evaluation of external source issues,
- b. Root cause evaluation and generic implication assessment for each identi-fied safety significant. deficiency or trend of nonsafety significant deviations, and
- c. Self-initiated reinspection of a sample of the balance of the hardware within the scope of the QA/QC program.
The objective of the staff's evaluation is to ascertain if the CPRT Program Plan describes the framework and process for performing a meaningful reinspection of the QA/QC and the construction acti'vities performed within the scope of that program. The staff's evaluation has consisted of document reviews and audits; the scope of'the review has ranged from a review of the Program Plan to the docu- - mentation characteristic of the evaluation prepared for assessment of specific I hardware populations. Subsequent sections of this SSER section address both the CPRT proposed process and the staff's evaluation of this process. The staff's 03/10/86 IV-1 NUO797 SEC IV
- - - - _--,,.,-----m>----m ,y----.--.- n,p - - - - - . - - , - - - - e -M--- --
evaluation addresses both the CPRT's plan for addressing external source issues as well as their self-initiated evaluation. Issue-specific action plans (ISAP) are key elements in the CPRT's process for evaluating construction adequacy. The ISAPs document the CPRT plan for resolving external issues. All construc-tion QA/QC issues whether'of a hardware nature or a QA/QC programmatic concern, will be the subject of an issue-specific action plan. A single ISAP describes the process and methodology for the CPRT's self-initiated hardware reinspection and documentation review. A matrix is then developed to provide a cross refer- ) ence between each issue or concern and the respective action plan which addresses i t. This matrix provides assurance that all external source issues have been addressed by the CPRT. i The ISAPs, which are prepared to address specific external source issues, l describe the process for evaluation of these issues. This process may include
~
reinspection of hardware, documentation review, engineering analysis and evalua-l f tion, assessm,ent of .TUEC corrective action programs and an evaluation of data 4 -collected from other CPRT review team action plans. The results report prepared
.4 for.each ISAP documents each individual issue evaluation.
f . r. The self-initiated hardware reinspection and documentation review program
- c. addresses all safety related construction work activities at CPSES. This prograa
; will ensure that areas not addressed by the external source evaluation are evaluated. The self-initiated program also provides additional confidence that l any currently unidentified concerns related to construction quality are identi-fied, evaluated, and resolved. The process for accomplishing this self-initiated program is to evaluate the work activities required to construct the Comanche Peak plants. This evaluation will be performed on a sampling basis primarily l
l through reinspections of safety-significant attributes. Documentation reviews will be used to assess inaccessible or nonrecreatable attributes. As with other l ISAPs, a results report will be prepared documenting the results of the total self-initiated evaluation program. CPRT proposes to integrate and collectively evaluate the findings from their j external source issue evaluations with the results of the self-initiated program in order to make a statement about construction quality at the Comanche Peak Steam Electric Station. Three reports will be prepared in addition to the in-I dividual action plans results reports to document the results of the integrated 03/10/86 IV-2 NUO797 SEC IV _ - _ _ _ _ _ _ . ___ _ _ _ , _ _ . ~ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - , _ _ _ . _ _
evaluation. Two collective evaluation reports'will be prepared to addres's the adequacy of the construction QA/QC program and the quality of installed hardware. Finally, a summary report which integrates the results of the two collective evaluation reports, and state the CPRT's conclusions regarding the quality of construction and the QA/QC program at Comanche Peak plant. The staff's review of the Program Plan has included a review of each individual I ISAP including the ISAP describing the self-initiated evaluation program. In ad-dition to the review of each individual ISAP, a number of onsite audits of the l documentation being prepared in support of the self-initiated evaluation have been performed. The purpose of these audits was for the staff to develop an in-depth understanding of the CPRT process for resolution of external issues and the 4 scope of its self-initiated evaluation program. These audits also served to es-tablish that the Applicant was documenting construction adequacy evaluation ac-tivities in sufficient detail to permit audit now or in the future. The staff's e evaluation addressed not only the framework and process of the construction ade-
.+ quacy review program but the degree of documentation to be 'provided by the
- applicant.
n Review of the construction adequacy program plan has been accomplished by teams
-c of NRC staff and consultants. External source issue review teams have been organized in a manner similar to the technical review teams and include the following disciplines:
- a. Electrical and instrumentation issues
- b. Test program issues
- c. Mechanical and piping issues
- d. Civil and structural issues
- e. QA/QC issues
- f. Miscellaneous issues Many of the individuals responsible for reviewing the scope methodology and implementation of the external source ISAPs were members of NRC's Technical Review Team. Review of the self-initiated evaluation program is accomplished by multidisciplinary team compassing most of the disciplines addressing external source issues. This team has reviewed the methodology for the self-initiated program and performed an audit of each of the categories of safety related hardware.
03/10/86 - IV-3 NUO797 SEC IV
l l l In summary, the staff's review and evaluation of the program plan has included I an assessment of the scope, methodology, and process for resolution of ex'ternal ! source issues and a self-initiated evaluation of the construction adequacy and quality at Comanche Peak. This review has been broad in scope in that it has encompassed all disciplines being addressed by the CPRT program plan. In addi- f tion, it has been deep inasmuch as the staff has audited a number of the pro-cesses down to level of inspection checklist preparation. In addition, the fI* staff required the CPRT to document the scope, n.ethodology, implementation, results, and evaluation of each ISAP in sufficient detail to permit audit now and in the future. ' I l i
)
l 03/10/86 IV-4 NUO797 SEC IV
2.0 EXTERNAL SOURCE ISSUES t Concerns regarding the adequacy of the CPSES construction QA/QC program and the adequacy of the constructed safety-related hardware have been raised by a number of sources external to Texas Utilities. These sources are the NRC Staff Tech-nical Review Team reports ("TRT"), the NRC ASLB proceedings on the CPSES operat-ing license ("ASLB"), the NRC Staff's Supplemental Safety Evaluation Reports ! ("SSER's"), the NRC Staff's Construction Assessment Team (" CAT") and Special Investigation Team (" SIT") reports, certain Inspection Reports issued by NRC's I Region IV staff ("RIV"), and the Cygna Independent Assessment Program ("IAP"). Collectively, these concerns are referred to as the " External Source Issues ] (ESI). i The Quality of Construction and QA/QC Adequacy Program (QOC) was formulated by ] CPRT to respond to and resolve the External Source Issues. The QOC has two i # components to resolve and bound the safety-significant implications of any ESI m identified or found deficiency in either the hardware or the CPSES construction
& QA/QC program. These components are: First, the CPRT will evaluate each of the y specific hardware and programmatic concerns raised by the External Source issues.
x It will determine the nature of any safety-significant hardware deficiencies a and the corrective actions necessary to resolve them. Second, the CPRT will 4
. cMtermine the root cause of each discovered safety-significant deficiency (or l trend of nonsafety-significant hardware deviations) and will analyze the generic i
implications at each root cause in order to determine the extent of any addi-tional hardware that might be deficient for the same programmatic reasons and i i to determine if changes need to be made in ongoing programs to prevent recurrence in the future. , 6 Implementation of the QOC program is by execution of Issue-Specific Action Plans (ISAPs). Toassurethatal.1 issues /concernsfromExter[1alSourcesareaddressed,CPRT will develop a matrix that provides a cross reference between each issue / concern i and the action plan (s) that addresses it. This matrix will also serve as an aid 1 in the collective evaluation process. The matrix format will present information 03/10/86 IV-5 -NUO797 SEC IV i i
such that valid concern can be tracked to the appropriate criteria of 10CFR50, Appendix B, and/or hardware area, and tracked to the ISAP or DSAP governing tne concern. 2.1 ElectricaI Instrumentation, and Control Systems and Comoonent Issues l The following External Source Issue items have been identified in the Electrical ! and Instrumentation and Control area: i 1.A.1 Class 1E Heat Shrinkable Cable Insulation Sleeves ' 1.A.2 Inspection Reports on Butt Splices
- 1. A'. 3 AMP Butt Splice Qualification 1.A.4 Agreement Between Drawings and Class 1E Field Terminations 1.A.5 Nonconformance Reports on Vendor Installed AMP Terminal Lugs 1.B.1 Flexible Conduit to Flexible Conduit Separation !
.: 1.B.2 Flexible Conduit to Cable Separation
.d_ 1.B.3 Conduit to Cable Tray Separation -
! S 1.B.4 Separation Barrier Material Removal l ,c The CPRT Program Plan states that a portion of the External Source Issues are ' l 5 currently identified by ISAPs and DSAPs, and that the Plan must include a com-2 plete listing of all External Source Issues to assure that the CPRT properly i addresses each item [1]. -In addition, an interface has been established between the design and construction QA/QC adequacy programs to assure that the construc-l tion issues are identified in the design adequacy program document review pro-cess [2]. To assure that all External Source Issues are captured, a cross-reference matrix will link each issue with a specific action plan. These CPRT Program Plan commitments appear sufficient to assure that each Exter-nal Source Issue will be identified, tracked, and evaluated. The staff will monitor the implementation phase to assure that each External Source Issue has been captured by the program. Other issues that may be identified during the implementation phases of the program plan will be pursued, and the results of the staff evaluation will be l reported in a future report. Similarly, the results of implementation of the i 03/10/86 IV-6 NUO797 SEC IV i
=
CPRT Action Plan for the listed items will be documented in a future results report. The staff will evaluate the implementation results as they become available. The CPRT Program Plan commitments should provide for the identification and disposition of each External Source Issue during the implementation phase of the program. 2.1.1 Class 1E Heat Shrinkable Cable Insulation Sleeves (I.a.1) 2.1.1.1 Introduction
- Heat-shrinkable insulation sleeves are required for uninsulated butt splices, j 480 volt and 6.9kv motor terminations, at cable reduction splices, and at elec-trical penetration assembly cable connections. The NRC concern centered on the
~
# -lack of awareness by craft and inspection personnel as to where the sleeves
- o should be installed and the high percentage of missed or improperly documented w inspections requiring witnessing. One specific action recommended was addi-
- u. tional QC inspector training to ensure that heat shrinkable sleeves were in-
! stalled where required. 2.1.1.2 CPRT Approach ISAP 1.A.1 revision 4 was issued on January 24, 1986 to address this concern,
- and the evaluation process will use quality instruction procedure QI-003. Two activities have been committed; namely, (1) retraining of TUGC0 craft and QC inspectors after revisions have been made to construction installation procedure .
EEI-8 and inspection procedure QI-QP-11.3-28, and (2) initiation of a records review sampling program to provide reasonable assurance that heat shrinkable sleeves are installed where required. This records review sampling program will include systems important to safety. Each hardware installation requiring the installation of a heat shrinkable sleeve will be visually. inspected if the records review does not indicate that it was installed. In plant areas where cable reduction splices were not required but may nevertheless have been used for electrical terminations, 7 cables and i 03/10/86 IV-7 NUO797 SEC IV I
'O o i 26 equipment components will be visually inspected to confirm that reduction splices were not used. Should any cable splices be detected from this examina-l tion, the corresponding records will be reviewed to confirm the adequacy of installation documentation. Decision criteria regarding expansion of the records review sample size are described in the Action Plan. 2.1.1.3 Staff Evaluation Based on the two activities committed in the Action Plan to provide retraining after the applicable procedures are revised and to review a sample o'f heat , shrinkable sleeve installations, the staff believes that the Action Plan is l adequate to resolve this External Source issue insofar as applies to construc-- l tion complete items. The Action Plan does not, however, address the adequacy l l
- of the revised procedures and additional training as it relates to future con- '
struction. The Action Plan should include provisions for continued inspection l 4 e of completed items to ensure the adequacy of the revised procedures and additional i training. NRC personnel will' review the implementation of the Action Plan and s procedure QI-003 to assure their adequacy. , ) 2.1.1.4 Conclusions J
- . The proposed Action Plan is adequate to establish the accuracy and completeness of documentation records for the heat shrinkable sleeve External Source issue with respect to completed construction items. However, since the cause of the 4
concern has been identified as inadequate personnel training, additional train-ing along with revised procedures must be provided and the Action Plan should be expanded to include provisions for inspecting future electrical construction to ensure the effectiveness of the additional training and procedure revision. 2.1.2.1 Inspection Reports on Butt Splice Inspection Reports (I.a.2) QC inspection reports for 12 butt splicas were found to be deficient in one or more respects. Nine rsperts used a post-installation inspection form instead of a witnessing-type inspection form. Six of these nine reports did indicate that installation of the heat shrinkable sleeves had been witnessed, but did ' not indicate that such witnessing was required. The other. three of these nine 4 l 03/10/86 IV-8 NUO797 SEC IV i ) _ __ _ , . _ __ . a
. .._. . _ _ . - _ ._~ _ _ _ - - ___ .. _. _. __ ___
! l
- forms did not indicate that installation of the splices had been witnessed.
f The remaining three reports using the correct form indicated that witnessing of the installations of heat shrinkable sleeves was not applicable (or required). t The NRC recommendation was that all QC inspections requiring witnessing for splices be performed and properly documented, and that all butt splices be iden-tified on design drawings and physically identified within the appropriate panels. 2.1.2.2 CPRT Approach 1 ISAP 1.A.2 revision 4 was issued on January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-002. A TUGC0 phase 1 program _ confirmed the validity of the documentation problems noted
, by the NRC. The Action Plan provides a second phase commitment to determine whether the installed butt splices are technically acceptable, and if not, a third phase commitment will expand the inspection to all Class 1E and associated circuits.
- j n In the second phase, a review of all drawings and design change documents in-
% volving butt splices will be performed to assure that the splices are shown in c design documents. From this document review,.each affected cable will be-in-
- 2. spected for cable splices relative to the FSAR Amendment 44 commitment and the-requirements of the Safety Evaluation Report. Pullout tests will'be performgi on those butt splices rejected and replaced during the phase 2 evaluation. Y - D' assure completeness, the population of Class IE control room cabinets will be inspected on a sample basis for the absence of butt splices.
If two or more butt splices from the phase 2 inspection are found to be improp-erly installed, a phase 3 program will be initiated to identify and inspect all other essential circuits where AMP insulated butt splices may have been used. i 4 2.1.2.3 Staff Evaluation l The proposed Action Plan fails to make the connection between the phase 1 con- l
; firmation of documentation report deficiencies and the phase 2 review of design l ! documentation in conjunction with an inspection of a sample of butt splices.
The Action Plan implicitly suggests that: l 03/10/86 IV-9 NUO797 SEC IV l
-,----n-- . , .-.,.---r_,.-. - . - - - - - -- .- - - - , , , . , - - . - , , - , . . - - - - - - - - , - - - - - - - - - , . - - . - - . - , . . , _ ,, . - - -----m--- . ~
.e o (1) if none of the inspected butt splices are rejected, pullout tests , will not be performed, and the population of butt splices will be , i
-presumed to be satisfactory. The documentation records will not be corrected for installation and witnessing aspects; (2) if one butt splice is rejected, it will be subjected to a pullout test. If this test is satisfactory, the population will be presumed to be acceptable. The documentation records will not be corrected for installation and witnessing, and (3) if more than one butt splice is rejected, each will be subjected to l pullout testing, but the documentation records will not be corrected for installation and witnessing.
In addition, the Action Plan does not commit to physically identify butt splices
- within the panels. !
r The staff's preference.is that butt splices not be used in Class IE or asso- i
, ciated circuits except where absolutely necessary. If butt splices are used, '
e the documented procedures and installation records should be correct and suffi-
~
< ciently detailed to permit any independent review to confirm the technical ade-
]
nquacy of their use. Since the existing documentation records have been unable ' l to confirm their adequacy, the staff's position is that the acceptability of butt splices must be demonstrated by other means. A sufficient amount of addi-tional inspection and testing must be performed to clearly demonstrate the tech-j nical adequacy of the butt splices in ordes to overcome the present inadequacy I of.the documentation records. The proposed Action Plan does not'take this approach; rather, it presumes that
! the butt splices are satisfactory regardless of the state of the documentation records. The Action Plan simply does not contain sufficient rigor to clearly i demonstrate the adequacy of installed butt splices. To overcome this weakness, the Action Plan should be revised to explicitly state how many butt splices will be inspected and. pullout tested, and how the documentation deficiencies ,
will be corrected. In addition, the physical identification of butt splices must be addressed.
- 03/10/86 IV-10. NUO797 SEC IV
1 2.1.2.4 Conclusions The proposed Action Plan for this External Source Issue is unsatisfactory both in its approach and in the lack of quantitative commitments for inspection and pullout testing of existing butt splices. 2.1.3 ButtSpliceQualificationTI.a.3)~ -- 2.1.3.1 Introduction On a limited basis as described in FSAR Amendment 44, the practice of butt splic-ing cable conductors in panels has been permitted subject to: (1) adequate pro-visions in . installation procedures to verify the operability of circuits using i butt splices; (2) qualification of the wire splices for anticipated service conditions, and (3) staggering of the splices so that they are not adjacent to _:ror pressing against one another in the same wire bundle. In addition, reinspec-
~
e:S tion of all existing butt splices was to b'e accomplished using adequate instal-
<d'lation and inspection procedures. . Circuits containing butt splices were to be c tested, and ratested if reworked, during plant preoperational and startup tests
. to assure their operability. .
f.1.3.2 CPRT Approach ISAP 1.A.3 hksion4EwasissuedJanuary 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-002. In revi-sion 3 of the CPRT Program Plan, the ISAP was to be revised to reflect.construc-tion and inspection procedures, a craft training lesson plan, and formal class-room training. 4 Construction procedure EEI-8 will be. revised to require a continuity check of all circuits containing butt splices and an inspection of butt splices to assure that they are staggered or separated. Inspection procedure QI-QP-11.3-28 will be revised to require that the circuit continuity checks be made and that the splices be inspected for adequate separation. Inspection of adjacent butt splices within panels is included as a part of ISAP 1. A.2. The acceptance criteria requires that no splice touch another splice, and the configuration of wire l I 03/10/86 'IV-11 NUO797 SEC IV
bundles will be corrected where splices are pressing on one another. A qualifi-cation data package will be assembled, reviewed, and approved for the butt splices used in the panels. 2.1.3.3 Staff Evaluation The Program Plan commitment to inspect all butt splices in various panels to assure that no butt splice touches another one within a wire bundle, and to rework splices in nonconforming wire bundles is responsive to the butt splice separation concern. Preparation and issue of a qualification data package for the butt splices for their service conditions is deemed to be adequate. Except for its proposed method of testing butt splice circuits, the plan to revise construction and inspection procedures and conduct training sessions for craft and inspection personnel is appropriate. ! I Circuit continuity checks proposed in the Action Plan to test butt splice cir- ,
- cuits use a very small current value that is unlikely to be representative o'f
- actual circuit current values when system functional tests are performed. Hence, the Action Plan should either justify the use of circuit continuity tests in lieu of actual circuit current values or should be modified to use actual cir-cuit values that would be present during preoperational and startup tests.
2.1.3.4 Conclusions The proposed Action Plan for butt splice qualification is adequate to address this External Source Issue provided that functional operability of those circuits containing butt splices can be demonstrated by the proposed use of circuit con-tinuity checks. l 2.1.4 Agreement Between Drawings and Field Terminations (I.a.4) 2.1.4.1 Introduction Detailed inspection was performed of 380 selected cables within various panels l for correct conductor terminations. Five safety-related cables and one non- l safety-related cable were found to be not terminated in accordance with current t 03/10/86 IV-12 NUO797 SEC IV
-. . a
=
design drawings. NRC requested that a reinspection be performed of all safety-related and associated terminations in the control room and in the cable spread-ing room termination cabinets to verify that their locations agree with current design documents. If this reinspection revealed an unacceptable level of nonconformance, the scope was to be expanded to all safety-related and associated terminations'in the plant. 2.1.4.1 CPRT Approach ISAP 1.A.4 revision 4 was issued January 14, 1986 to address this concern, and the evaluation process will use quality-instruction procedure QI-001. The six cables identified by NRC were reinspected with.the following results: (1) three cables were correctly terminated, but the drawings were in error regarding conductor color code details. All three drawing errors
- were subsequently corrected; ,
ft (2) one cable had two conductars interchanged, but this would not affect
- - proper circuit operation. The conductors have now been changed to y conform to the current drawing; (3) one cable was designated as a spare, but the design change authoriza-tion was found to be incomplete. This cable was subsequently deleted from the interconnection drawing, and (4) one cable had spare conductors terminated even though wiring on the vendor side of the terminal blocks had been removed. These spare conductors have been removed from the terminal blocks.
The Action Plan states that a sampling inspection will be developed to reinspect cable terminations versus current drawing requirements in Class 1E safe shutdown circuits that interface with the alternate shutdown panel in the Unit 1 control room and cable spreading room. Safe shutdown circuits comprise approximately 27% of all Class 1E terminations in these rooms, and a random sample of 300 ter-minations will be reinspected to an acceptance criteria of zero errors. Expan-sion of the sample size up to a maximum of 3812 terminations will result if one 03/10/86 IV-13 NUO797 SEC IV
or more termination errors are identified. Should more than fourteen errors be detected, all Class 1E and associated terminations in Unit 1, Unit 2, and common will be reinspected. 2.1.4.3 Staff Evaluation TUGC0 has provided reinspection results of the conductor termination errors for six cables identified by the NRC staff. The proposed Action Plan for a reinspection sample of 300 terminations in Class 1E circuits with an acceptance criteria of no errors is responsive to the NRC concern. Expansion o'f the sample to all safe shutdown terminations, and to all Class IE terminations at the Comanche Peak Station is also provided by this plan. 2.1.4.4 Conclusions
- The TUGC0 reinspection results of conductor termination errors for six cables T identified by the NRC staff are. satisfactory. The proposed Action Plan to rein-a spect a minimum of 300 terminations for conformance to current drawing require-
+ ments is adequate for this External Source Issue. The proposed acceptance criteria for sample size expansion appear satisfactory for this concern.
2.1.5 Nonconformance Reports on Vendor Installed AMP Terminal Lugs (I.a.5) 2.1.5.1 Introduction Sixteen nonconformance reports issued in early April-1984 documented a condition described by allegation AQE-36 involving vendor installed AMP terminal lugs in ITT Gould-Brown Boveri 6.9 Kv switchgear. Terminal lugs described by these non-conformance reports were bent in the area between the ring and barrel either in excess of 60 degrees or were twisted. d The initial acceptance criteria for bending of the terminal lugs was 60 degrees, and was modified by the terminal lug manufacturer to permit a one time bend up to 90 degrees and that lugs bent.to 120 degrees might be acceptable depending on an end user engineering evaluation. These acceptance criteria were subse-quently changed by the manufacturer to be two bends up to 45 degrees, one bend - 03/10/86 IV-14 NUO797 SEC IV
o . suitability of twisted terminal lugs had not been addressed. A reevaluation and redisposition of each nonconformance report was requested taking into account both bent and twisted terminal lugs and the documentation of engineering analyses to justify any "as-is" dispositions. 2.1.5.2 CPRT Approach ISAP 1. . revision 4 was issued on January 24, 1986 to address this concern. An examinati was made of the terminal lugs identified in the nonconformance reports, and it w determined that the bend angle ranged between 60'and 90 de-grees. These nonconfo nce reports were dispositioned relative to the manufac-turer's revised criteria, a did not require an engineering evaluation. The proposed Action Plan makes a commitme at the nonconformance reports will be redispositioned to more clearly state the actu inal lug bend and
.. twist condition and will provide an engineering justification for "use-as-is"
- dispositions. In addition, AMP will be requested to provide a documen d anhlysis a to support the change from the initial 60 degree bend to the present 90 grees ,
e bend a:ceptance criteria, and will include an evaluation of twisted termin a lugs. Any lugs that cannot be justified based on AMP criteria will be repla ed. The action plan also identifies Mil. Spec MIL-T-79286 as a source of acceptan criteria for both bent and twisted terminal lugs. , 2.1.5.3 Staff Evaluation . The proposed action plan commits to a final reevaluation and redisposition of the nonconformance reports for the previously identified terminal lugs using acceptance criteria for bending and twisting to be developed by the manufacturer. Improved detail regarding the condition of each terminal lug and justification for "use as-is" dispositions will be provided. The manufacturer's analysis of acceptable bend and twist values will be reviewed and approved by the Electrical Review Team. The action plan acceptance criteria states that conformance with
~
an applicable Military Specification will also be accomplished. Any terminal lugs not in conformance with these criteria will be replaced. The NRC concerns centered on the "use-as-is" disposition of the nonconformance reports in that engineering evaluations had not been performed and the 03/10/86 IV-15 NUO797 SEC IV
l l Plan includes a review of Gibbs and Hill separation criteria and inspection procedures for conduit installation. Physical tests will be conducted on the SERVICAIR flexible conduit used in the panels to evaluate its adequacy as a barrier under design basis short circuit or overload conditions. A detailed separation analysis will be performed of the main control room panels and vertical panels, and will include cables.to control switch modules, instrument controllers, meters, indicators, recorders, cathode ray tubes, indicating lights, and the annunciator. Inspections of these panels will be performed to ensure that required separation distances have been . attained, and that barriers have been installed where required. If the tests , and analysis results do not qualify SERVICAIR conduit as a barrier,' the cable installation within the panels will be modified either to achieve acceptable separation distances or to install appropriate barriers, and the affected draw-ings will be revised to reflect the final configuration. re The proposed Action Plan contains acceptance criteria for the qualification
- w tests on SERVICAIR conduit and for the inspection of installed conduit relative e to the final separation criteria to be developed by Gibbs and Hill.
i
- 2.1.6 Flexible Conduit Separation (I.b.1) 2.1.6.1 Introduction i
Industry criteria, such as IEEE Std. 384-1974, have established minimum separa-tion distances to be maintained between redundant safety-related cables and between safety-related and non-safety-related cables within control room panels L and cable spreading room termination cabinets. Lesser separation distances may i be justified if supported with engineering analyses of the involved circuits and components. The Technical Review Team observed that flexible conduits con-I taining safety and non-safety cables within these panels were in direct physical contact, and could not find evidence that analyses had been performed to justify this deviation from requirements in the industry standards. Within main control room panels, for example, flexible conduit identified with l one separation division (orange color) has been bundled together with flexible 03/10/86 IV-16 NUO797 SEC IV
+ -v ---+-mm*-'--'wW^'"
r--W W -r-+--$ -v g f-1'*--my3-
%.-- -,w ,- --m _____-e-.- - ..9,ew. mmco e M-ee-s w%i*+wPy-my'ww-wy-'syww g- w wy>-wwr-pw-%w+---ey
s conduit identified with the redundant separation division (green color). In this ' instance, a technical justification for the ~ lack of one inch separation distance between redundant conduits containing safety-related circuits has not been provided. A reinspection of all panels containing redundant safety-related conduits or both
, safety-related and non-safety-related conduits was required to either correct each violation of the separation criteria or to demonstrate by analysis the l acceptability of the conduit as a barrier.
2.1.6.2 CPRT Approach ISAP 1.B.1 revision 4 was issued June 4, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-004 [8]. The Action 3 2.1.6.3 Staff Evaluation 9 The proposed Actjon Plan requires conformance of internal panel cables and con-
> duits to applicable industry separation criteria by achieveme'nt of minimum 4 separation distances, installed barriers, or by appropriate engineering analyses e of the actual installation to justify lesser separation distances.
Qualification testing of SERVICAIR flexible metal conduit as a suitable barrier for redundant safety-related cables and for safety to non-safety cables will be performed. Detailed analysis of the separation provisions installed in main control room and vertical panels, and inspection of installed SERVICAIR. conduits relative to final separation criteria is committed. -If the installed conduits do not satisfy the final separation criteria, the installed cables and conduits will be modified to assure the achievement of minimum separation distances or the installation of barriers. Drawings will be revised to reflect the final ; configuration. 2.1.6.4 Conclusions The proposed Action Plan is responsive to the External Source Issue of adequate
, separation of flexible conduits in main control room panels and vertical panels.
03/10/86 IV-17 NUO797 SEC IV i
s However, the Action Plan does not specifically address the issue of SERVICAIR flex in areas outside the main control room. In Sections 3.0'and 4.1.5 of the Action Plan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installa- ' tions outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be det. ermined on a case by case basis. The staff will find this acceptable and re's'ponsive to the actions items stated in SSER 7 on confirmation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc. containing two or more Class 1E circuits *, or Class IE and non-Class 1E circuits. 2.1.7 Flexible Conduit to Cable Separation (I.b.2) 2.1.7.1 Introduction
. This particular NRC concern is similar in many respects to External Source e Issue 1.B.1 regarding the accomplishment of minimum separation distances bet' ween e flexible conduits within main control room panels and vertical panels. In Ex-
- c. ternal Source Issue 1.B.2, the Technical Review Team identified twenty-one cables within four panels where the minimum separation distance of 6 inches specified in industry standards had not been maintained relative to SERVICAIR flexible i metal conduits containing safety related cables.
NRC required that a reinspection be performed of main control room panels, other panels located in the control room, and panels located in other areas of the plant where cables and flexible conduit had been used. TUGC0 was requested to either correct any separation criteria violations in these panels or demonstrate that the flexible metal conduit was an adequate barrier in accordance with IEEE Std. 384-1974. If the flexible conduit could not be shown to be a suitable barrier, a minimum separation distance of 6 inches was to be maintained between cables and flexible conduit within the panels. In addition, drawings and related documents were to be revised to indicate the revised minimum separation distances. 03/10/86 IV-18 NUO797 SEC IV
1
~
c 2.1.7.2 CPRT Approach i 4 ISAP 1.B.2 revision 4 was issued January 24, 1986 to address'this concern, and the evaluation process will use quality instruction procedure QI-004. The Action Plan states that SERVICAIR flexible metal conduit will be qualified as a barrier by test and analysis and that Unit 1 separation deficiencies will be corrected through inspection nonconformance reports. Unit 2 installation procedures and the post construction inspection program will ensure that separation requirements are met for this plant. The Action Plan provides acceptance criteria for-the 1 qualification tests on SERVICAIR flex conduit and for the inspection of installed . conduit relative to the final separation criteria to be developed by Gibbs and Hill. 2.1.7.3 Staff Evaluation 8 The proposed Action Plan requires conformance of internal panel cables and ron-v duits to applicable industry separation criteria by achievement of minimum e separation distances, installed barriers, or by appropriate engineering analyses 4 of the actual installation to justify lesser separation distances. Qualification testing of SERVICAIR flexible metal conduit as a suitable barrier will be performed. Detailed analysis of the separation provisions installed in i main control room and vertical panels, and inspection of installed SERVICAIR conduits relative to final separation criteria is committed. If the installed l conduits do not satisfy the final separation criteria, the installed cables and conduits will be modified to assure the achievement of minimum separation dis-tances or the installation of barriers. Drawings will be revised to reflect the final configuration. - 2.1.7.4 Conclusions The proposed Action Plan is adequate for assuring compliance with minimum separation requirements for main control room panels and vertical panels. ) This Action Plan, however, does not explicitly address the issue of SERVICAIR flex in areas outside the main control room. In Sections 3.0 and 4.1.5 of the
.03/10/86 IV-19 NUO797 SEC IV
I - Action Plan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installa-tions outside the control room the appifcability of the separation criteria i developed for the control boards and vertical panels will be determined on a case by case basis. The staff will find this acceptable and responsive to the Action items stated in SSER 7 on confirmation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc. containing two or more Class 1E circuits, or Class 1E and non-Class 1E circuits. Also, in Sec- l tion 4.5.1 of the Action Plan, the acceptance criteria is stated as ',' testing ) and/or analysis." This is inconsistent with the other sections of the plan l which describe testing and analysis, combined, as the means of demonstrating the adequacy of SERVICAIR flex as a barrier, and is therefore not acceptable, i i, 2.1.8 Conduit to Cable Tray Separation (I.b.3)
. 2.1.8.1 Introduction t
4 A minimum separation distance of one inch between an enclosed rigid conduit
- e and open ladder type cable trays was established by Gibbs and Hill in specifica-tion 2323-ES-100; however, the Gibbs and Hill analysis supporting this separation criterion was neither referenced in the FSAR nor reviewed by the NRC for accept-ability. IEEE Std. 384-1974 requires the installation of a barrier between a conduit and an open cable tray unless greater minimum separation distances are maintained or are otherwise justified by an engineering analysis. The Technical Review Team requested that the Gibbs and Hill analysis supporting the one inch separation distance be submitted for NRC review in sufficient detail to permit
- an independent evaluation of the establishment of this criterion.
2.1.8.2 CPRT Approach ISAP 1.B.3 revision 4 was issued January 24, 1986 to address this concern. The proposed Action Plan commits to a review of the Gibbs and Hill analysis of this separation criterion in conjunction with a supporting Sandia report on Cable l , Tray Fire Tests (SAND _ 77-1125C), and its submittal to NRC following approval by ) the Review Team Leader and a third party consultant. In addition, the Electrical Review Team will review nonconformance reports and inspection reports applicable 03/10/86 IV-20 NUO797 SEC IV J
.----~c,.,,..w._,..-..., . - - e -,_n--- ,..--m.__. ,. -,,.-_.._._--n.-.,,__- , , - - , , - ._ .-..-,..n.m, ,-.,.v.--,,-v,m_,-.-
=
s to this External Source Issue. If compliance with IEEE Std. 384-1974 cannot be. demonstrated, conduits and cable trays.will be modified to assure compliance , with the standard. i 2.1.8.3 Staff Evaluation The proposed Action Plan commits to compilation, review, and approval of the applicable documentation to support the one inch minimum separation distance between rigid conduits and open cable trays, and submittal of this material for NRC independent review. Compliance with the separation requirements of IEEE Std. 384-1974 is committed either by this engineering justification analy-sis or by physical modification of the conduit and cable tray installations. ' 2.1.8.4 Conclusions The proposed Action Plan is responsive to this External Source Issue and the e action item stated in SSER 7. The plan is therefore acceptable. Final reso'lu-A tion of this issue, however, is contingent on the staff review and acceptance e of the engineering justification analysis. In the event the justification is a found not acceptable, the Action Plan will have to be expanded to cover conduit 1 and cable tray modifications committed to in Section 4.6 of this plan. 2.1.9 Barrier Removal (I.b.4) 2.1.9.1 Introduction During the Technical Review Team inspection of auxiliary feedwater panel CP1-EC-PRCB-09, two barriers used to separate redundant devices and cables were found to be missing. Within panel CP1-EC-PRCB-03, field wiring was not separated 1 by the minimum separation distance of 6 inches.
- p. -
N g quired,that a barrier be installed in panel CB-09 to separate redundant i flow and pr' essure instruments, and that field wiring in panel CB-03 be separated by the minimum distance or by an installed barrier. 03/10/86 IV-21 NUO797 SEC IV
. - - - - - .-.-,.--.--.,----.-.,.,,.-my~,,,--,-y-----,ywwsmw._ w, w-,w,-.-m ---,me mve e - ww,------.v-,m-,.=-.,ec%-,--y --~.
2.1.9.2 CPRT Approach 1 ISAP 1.B.4 revision 4 was issued January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-004. The Action Plan commits to the re-installation of the barrier material in the auxiliary I feedwater panel and the reworking of field cables in the other panel to resolve
- the identified separation violations. Nonconformance reports will be issued '-
for these violations, and maintenance procedures wil1 be revised to ensure that reparation requirements are met following modification or maintenance activities. ! As a part of Action Plan 1[, physical inspecticn of other main coiltrol room panels and vertical panels will be performed to identify any other undetected separation violations. 2.1.9.3 Staff Evaluation
. The proposed Action Plan commits to correction of two identified separation vio-lations, revision of maintenance procedures to ensure compliance with separation j >. requirements, and the physical inspection of other control room panels for undetected separation violations. The Action Plan states that compliance with
, applicable industry separation criteria will be achieved.
2.1.9.4 Conclusions p..
. The proposed Action Plan is responsive to thfs#Exterid1' Source Issue for main control room panels. To assure that existing separation violations have been detected in a timely manner, the physical inspection portion of the Action Plan
- should be expanded to include the cable spreading room termination cabinets and i
safety-related instrument racks located throughout the plant. In addition, Section 4.5 of the plan is not acceptable. The applicant should explain what is meant by meeting "the intent" of IEEE-384 and Regulatory Guide 1.75 require-ments, and why this is acceptable. In the absence of an adequate explanation, the applicant should commit to " meet" the requirements of the above documents. 03/10/86 IV-22 NUO797 SEC IV i
l 2.2 QA/QC Issues The QA/QC issues are the identified concerns which resulted from the TRT QA/QC group's assessments of allegations pertaining to the QA/QC Program at Comanche j Peak. These issues were initially presented to the Applicant by letter from the NRC dated January 8, 1985 and the detailed assessments were' published in NUREG 0797 Safety Evaluation Report Suppl'ement (SSER) 11 that was issued in May 1985 (reference Appendix 0. Pages 0-277 through 0-303). 4 Additionally SSER 11 contains an Appendix P (reference Pages P-1 through P-56) which presents the result of the TRT QA/QC Group's integrated evaluation of the ! QA/QC issues identified in Appendix 0, together with those QA/QC issues which were either; specifically referred to the QA/QC Group by other TRT groups or, implied in each of the assessments presented in the Appendices to the SSER Supplements 7, 8, 9 and 10. 1 [ ] l a. Since the QA/QC issues arose from sources other than the CPRT (e.g., SSERs,' j st CAT, SIT, R IV inspection reports, etc.) it has become common terminology to l ! : refer to them as external source issues. i l 1 Under the Program Plan, Appendix B, Quality of Construction and QA/QC Adequacy l Program Plan, the CPRT developed issue specific action plans to address and '. resolve the QA/QC issues related to construction adequacy. (Reference Appendix ) i 8 Attachment 1). As the CPRT determines it appropriate to the specific issue i being considered, each of the listed ISAPS will empicy one or more of the fol-lowing evaluative approaches: re-inspection of hardware, review of hardware i documentation, walkdown inspections, data collected from other CPRT review team j action plans, engineering review and analysis, and review and verification of l TUGC0 corrective action plans. f l Also under Appendix B, the CPRT issued a self initiated Issue Specific Action j Plan (ISAP)VII.c,gonstructiongeinspectionandgocumentationgeviewylan. j The Program Plan defines the interaction of the results of the implementation l of this Plan (VII.c) to assist in the resolution of QA/QC issues addressed in other action plans. The Program Plan further states that to ensure that all issues are identified including these listed in SSER-11 Appendix P, the CPRT, [ { 03/10/86 IV-23 NUO797 SEC IV
'y-m+',.w,-m-es7a-4 ywe +'--y--r' -- %- r-p==='Pr-" WW"4 --myr--pa w g--'-Mu1-em ee + '-eige w=- w'Fw- -'t--+--w-w-w Wy- =-w- - - r--'-'- "i- " *- -'--
9 g in an ongoing activity, is reviewing external source documents and developing
- issues tracking matrices that provide a cross reference between each issue /
concern and the action plan (s) that address it. During implementation of the Program Plan, the Staff will review these matrices to ensure compliance with the Plan, that any required interfaces have been performed, and that the issues identified in SSER-11, Appendix P, are identified and listed in the matrices.
~-The staff's evaluations of each of the action plans that address the QA/QC issues related to the construction adequacy program are presented in the fol-lowing sections of this report. *
! 2.2.1 QC Inspector Qualification (I.d.1) iI 2.2.1.1 Introduction
~
1 l i
.,- This ISAP addresses the validity of the training, qualification, certification y and recertification in accordance with project procedure and FSAR commitments i
c for all electrical QA inspectors, all current ASME inspectors and current j non-ASME inspectors. l 2.2.1.2 CPRT Approach i The Program Plan defines a three phased approach which will review inspector i 4 qualification documentation for compliance with project documents, Codes, and l
- standards which were in place at the time of the inspector's certification.
j This review will be conducted by an audit group using prepared checklists and i the results overviewed by a special evaluation team. The Plan provides for l reinspection of a. sample of work completed by those inspectors whose qualifi- ! cations could not be verified. The Plan identifies implementing procedures, j standards and abceptance criteria and describes its interface with ISAP I.d.2 4
" Guidelines for Administration.of QC Inspector Tests" and ISAP VII.c "Construc- l l
tion Reinspection / Documentation Review Plan." The action plan results report l
- will contain a conclusion regarding the impact of the remaining work on Unit 2 j and the operations QA/QC program.
} . l 03/10/86 IV-24 NUO797 SEC IV i 1
2.2.1.3 Staff Evaluation The staff has evaluated the Plan methodology, reviewed the checklists to be l , used in its implementation and verified the accuracy of the interface require-ments with other identified action plans. The Plan addresses a review of the l qualifications 'of all current inspectors and by its interface with the results ] of ISAP VII.c will provide a conclusion regarding the impact of the quality of { construction which may have resulted from the work of inspectors whose quali-j fications were found to be questionable. 1 This evaluation finds that the Plan will determine the acceptability of QC inspector qualifications in compliance with standards and acceptance criteria
; in place at the time of certification of the inspectur. The FSAR commitment includes: CPSES QA Program Requirements, Regulatory Guide 1.58, Rev. 1, ANSI N45.2.6-1978 and ASME/ ANSI Code requirements.
2.2.1.4 Conclusion
- l e The Plan adequately addresses the NRC's concern pertaining to QC inspector
> qualifications and adequately describes the evaluation process that will
- r resolve the issue and enable a conclusion regarding inspector qualifications in compliance with the. stated FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable.
4 l 2.2.2 QC Inspector Test Administration (I.d.2) l 2.2.2.1 Introduction i This ISAP addresses guidelines and procedural requirements for the testing and certifying of electrical QC inspectors. 2.2.2.2 CPRT Approach Although the specific issue primarily addressed the training and certification of electrical inspectors, the CPRT increased the scope of this Plan to include f i all QC inspectors. The Plan describes a three-step approach as follows: i 1 03/10/86 IV-25 NUO797 SEC IV
...,.-w,-=,e,.wm,,.-%-~ . - - ~ . ,,_ew_._v.. --,m. . , - ,--.v--O. , _ _ , ,,, , , , , , . , . . . , , - - _ ~ _ _ . - - . . , . _ - - - - . - - , .
(a) Step 1: A Special Evaluation Team (SET) will evaluate the adequacy and acceptability of the project procedures that control the structuring and administration of tests and provide recommendations for improvement of the procedures. (b) Step 2: The CPRT will forward the SET's findings to TUEC for pro-cedure revisions ~in accordance with the SET recommendations. All inspector certification exams currently in use will be reviewed and revised, as appropriate, to comply with the revised procedures. (c) Step 3: The CPRT will conduct a review to determine whether other improvements should be made to the training program. Utilizing the results of implementation of this Plan, ISAP I.d.1 and VII.c will enable ,the QA/QC Review Team Leader (RTL) to reach a conclusion regarding QC inspector testing practices. 2.2.2.3 Staff Evaluation
- 1 i .
This evaluation finds that the Plan methodology describes the process whereby
- e. the CPRT will assure that TUGC0 has provided adequate procedures to implement e and control the training and testing program for QC inspectors. Additionally, this evaluation verified the existence of an interface with ISAPs I.d.1 and VII.c.
2.2.2.4 Conclusion The Plan methodology adequately describes the evaluation process that will ensure that the QC inspector testing program is in compliance with project procedures, regulatory requirements and FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable. 2.2.3 Craft Personnel Training (I.d.3) 2.2.3.1 Introduction , T The objective of this ISAP is to evaluate the Craft Training Program to deter-mine if it was adequate in the past, and also to evaluate the current program. 03/10/86 IV-26 NUO797 SEC IV
l 2.2.3.2 CPRT Approach The requirements of ANSI N45.2-1971, set forth in part, that personnel perform-ing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. To determine that these require- { ments are implemented, this ISAP has formulated a Special Evaluation Team (SET), comprised of individuals with no direct responsibility to CPSES, who will per-I form 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: 4 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.
j r - How craft personnel classifications are established for crew loading.
- i i'
How craft personnel become aware of changes in design and construction require-ments and how retraining occurs. How craft personnel are informed and become knowledgeable of QA/QC require- ! ments/ criteria and changes to those requirements / criteria. l How management is assured that the craft personnel selection, training, f assignment and retraining program complies with project requirements. How supervisory personnel are selected and trained. l How background of education and experience of craft personnel is verified j and documented. The SET evaluation will be accomplished through reviewing those craft procedures l that were in existence, interviewing craft personnel, and observing training l and field activities. 03/10/86 IV-27 NUO797 SEC IV
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 f were selected and trained. ' ! Training and field activities will be observed to determine if adequate training l is provided and to evaluate how well the craft personnel performed in the field , j after training has taken place. - 1 Based on this review, conclusions will be drawn by the QA/CC Review Team Leader j as to the adequacy of both past and current practices used for craft selection { and training. If current procedures are determined to be inadequate, recommenda-l tions for improvement will be provided to TUGC0 prior to the closure of this ) action plan. i
/ r The decision criteria detailed in the Plan provide that the results of inspect-m ' ions conducted during the implementation ISAP VII.c will provide.an indication
.n of the adequacy of hardware construction. This information will be categorized f r by. major discipline, e.g, civil, mechanical, electrical and structural. This information can then be compared to the results of this ISAP during the collective evaluation phase.
i 1 If craft training was determined to be a root cause, recommendation will be i provided to TUGCO. 2.2.3.'3 5taff Evaluation This evaluation finds that the CPRT approach will provide a broad-scope in-depth evaluation of the essential elements of the training program and will determine the effectivness of both past and current training and its impact on the con-l struction of the physical plant, and compliance with ANSI N45.2.6 and 10CFR50, j Appendix B, Criterion II, as committed to in the FSAR. The staff finds, however, that Section 4.4, Procedures, does not comply with the Program Plan, Attachment 3, ISAP format, which requires that existing proca-dures be referenced. t 03/10/86 IV-28 NUO797 SEC IV
- - - - - --. L _ - - - - _ -
j ! 2.2.3.4 Conclusion i The staff's evaluation finds that the ISAP adequately addresses the NRC's con-
- i. cern pertaining to craft training, and implementation of the plan will determine compliance with FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will i
confirm that the revision has been accomplished.
- 2.2.4 Material Traceability (VII.a.1) -
2.2.4.1 Introduction l l This ISAP assesses the adequacy of the material traceability control systems implemented during construction. It also evaluates-all NRC, TRT and SSER find-l ings relating to material traceability that are not covered in other action
~
plans. . f
~
j 2.2.4.2 CPRT Approach i l The Plan methodology describes a seven step approach to resolution of the issue { as follows: I
-(a) Interface with ISAP VII.c to ensure that reinspections verify material traceability.
(b) Review material control procedures to determine if requirements of
- 10 CFR 50 Appendix 8, criterion VIII and the FSAR are met. ,
(c) Evaluate the TRT's findings regarding failure to maintain material traceability as identified in the October 1981 ASME Code survey.
- (d) Review and identify all SSER findings (including Appendix P) relating
- to material traceability and verify that action is bei,ng taken to resolve the finding. Develop action plans if necessary.
03/10/86 IV-29 NUO797 SEC IV
(e) Review the results of ISAPs VII.b.3 and VII.b.1 to verify that material traceability concerns for pipe supports and site fabrication shop activities have been addressed. (f) Review the results of Action Plan VII.c as they apply to material traceability and review the results of the remainder of the action plans for any impact on the overall evaluation. (g) Collectively evaluate the results of the above to identify program-matic deviations which require correction of procedures fo'r Unit 2 and operations and areas of hardware which require further evaluation because of programmatic weakness. Prepare an Action Plan Results Report which addresses the overall adequacy of current and
~
historical material traceability controls. 2.2.4.3 Staff Evaluation at The staff's evaluation finds that the descriptive methodology will adequately
- t. address the resolution of concerns regarding material traceability. In addition, e to assure the identification of all issues, Appendix B of the Program Plan e,
describes the development and utilization of issue tracking matrices that identify the issue, the source of the issue and the action plan that addresses it. 2.2.4.4 Conclusion A review of the Plan's methodology that describes the evaluation process and the interface with other action plans finds that the implementation of this Plan adequately addresses resolution of the NRC's concerns wit' material traceability. Therefore the staff concludes that this ISAP is acceptable. 03/10/86 IV-30 NUO797 SEC IV
2.2.5 Corrective Action System (VII.a.2) l 2.2.5.1 Introduction . 7 This ISAP evaluates individual NRC, TRT and SSER findings and provides a com-prehensiveevaluationoftheCPSESconstructionsitegonconformancegorrective j getionand10CFR50.55(e)reportingsystem?Becauseofthecloseinterrelation-ship of TRT concerns involving the nonconformance systems, the corrective action systems, and the 10 CFR 50.50(e) reportability system, all identified issues will be addressed under this one Issue-Specific Action Plan, 2.2.5.2 CPRT Approach Because of the differing complexity of the three systems being evaluated, the methodology for the evaluation of each will vary somewhat. For the nonconfor-
-- mance systems, all the various methods (populations) of documenting nonconfor-
- mances will be identified. Populations will be reviewed to determine if non'-
.e conformances were properly processed and resolved. In. addition, the procedures e, applicable to the selected nonconformance will be reviewed for compliance with
- 10 CFR 50, Appendix B and PSAR/FSAR requirements.
For ,q,orrective action systems, applicable site procedures will be reviewed for adequacy. This procedural review will be followed by a review of the implemen-l tation of the site 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 10 CFR 50.55(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 10 CFR 50.55(e) reportability system. The results of the evaluation of the gonconformance system shall be utilized in the evaluations of the corrective action and 10 CFR 50.55(e) systems. The results of the evaluation of the corrective system will be considered in the ! evaluation of the 10CFR50.55(e) system.
.. l 03/10/86 IV-31 NUO797 SEC IV
2.2.5.3 Staff Evaluation The staff has evaluated the Plan methodology with respect to the standards and acceptance criteria applicable to the issues addressed. These criteria are containedin10CFR50AppendixBgriteriaXVandXVI,10CFR50.55(e)andthe FSAR. Additionally, Appendix B of the Program Plan describes the development and utilization of issues tracking matrices to ensure that all issues are identified and resolved. - 2.2.5.4 Conclusion , The staff's evaluation finds that the Plan adequately addresses the NRC's con-cerns and proper implementation of the Plan will resolve the issues in com-pliance with the FSAR commitments. Accordingly, the staff conicudes that this ISAP is acceptable. 2.2.6 Document Control (VII.a.3) 2.2.6.1 Introduction Problems were identified over a period of time in the implementation of the Document Control Program during the construction phase of CPSES. The scope of this Action Plan is to provide confidence that Document Control Program problems did not impact the installation and testing of hardware and that current design requirement are satisfied. q , , pp* l 2.2.6.2 CPRT Approach 4,N l The concerns identified in this Plan are addressed by review and evaluation of theresultsoftheimplementationofISAgIII.d"PreoperationalTesting"and ISAP VII.c " Construction Reinspection / Documentation Review Plan" to determir.e if deficiencies identified under those plans are attributable to Document Control problems. Implementation of the action plans requires verification that the latest design information (e.g., drawings, design change authoriza-tions and component' modification cards) is used in the preparation of checklists 03/10/86 IV-32 NUO797 SEC IV
l used in the reinspections and documentation reviews. Programs and procedures will be evaluated for adequacy against the applicable sections of the FSAR and l 10 CFR 50 Appendix B Criterion VI. i
; 2.2.6.3 Staff Evaluation i
The staff's evaluation finds that implementation will determine the adequacy of the document control system in compliance with 10 CFR 50, Appendix B, Criterion VI, and will identify the impact of Document Control problems in the physical plant. However, the staff finds that Section 4.4 procedures refers to Program Plan and Issue Specific Action Plans instead of identifying the existing project
! procedures applicable to implementation of the Plan. This does not comply with the Program Plan Attachment 3 ISAP format which requires identification of l existing procedures.
!' 2.2.6.4 Conclusion i - s This evaluation finds that the methodology and interface with other action plans a adequately addresses the NRC's concerns regarding document control. However, s Section 4.4 must be revised to comply with the Program Plan Attachment 3. During i e implementation of the Plan the staff will confirm that .the revision has been
- accomplished.
1 2.2.7 ISAP VII.a.4, Audit Program and Auditor Qualification - D' i 2.2.7.1 Introduction '
- This ISAP addresses the NRC's concern regarding the adequacy of the TUGC0 Audit j Program from its inception to the present and will evaluate the program to j datermine the effect of any identified inadequacies on the Quality Assurance l
Program and/or the physical plant, and to recommend appropriate corrections' l and/or improvements to the current program. This evaluation will be accom- '
- plished through a review which will address audit planning and scheduling, j preparation, performance, reporting, follow-up and closecut, and audit per- )
i .sonnel qualification. I ! l i )
- 03/10/86 IV-33 NUO797 SEC IV
]* . 2.2.7.2 CPRT Approach i l All revisions of the progr.am and procedures pertaining to the QA-Audit Program i 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. J Included in this evaluation will be the CPSES PSAR/FSAR (Appendices lA(N) and 1A(B), Chapter 17.1), and NRC QA branch questions and answers); TUGC0 Corporate Quality Assurance Program; CPSES Project Quality Assurance Plan (Design and 1 Construction); Dallas Quality Procedures / Instructions Manual. 1 ! Reports, documentation, and data generated during the implementation of the l program will be reviewed on a selective basis to evaluate the effectiveness of implementation. The selection of specific items to be reviewed will be based j 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 1 l Audit Plans and Checklists Audit Reports Audit Deficiency. Follow-up Audit Team Members, Including Qualifications and Staffing Levels Organizations Performing Audit Activities 1 Application of Audit Activities to Hardware versus Program Procedures s
- 03/10/86 IV-34 NUO797 SEC IV
The object of this evaluation is to reach a conclusion concerning the adequacy of program assessment provided by the Audit Program. This information will be , used as an input for recommendations for revision of the current program, as appropriate. ! Should audit program deficiencies or weaknesses related to construction i activities be identified, they will be evaluated to determine whether action j beyond that specified in ISAP VII.c is required to identify potential areas of concern regarding construction quality. 2.2.7.3 Staff Ev.11uation l The staff evaluation has considered that the source documents (e.g., SSERs, ! R IV Inspection Reports, CAT, etc.) that identified the issue have reported the j ineffectiveness of the TUGC0 QA Audit Program for a time frame that covers the j, ; period from 1978 through 1984. Since this period covered almost all of the j u construction activity, the staff wishes to emphasize its understanding of the j A. ISAP that the CPRT's evaluations will include the PSAR/FSAR and all revisions, f t and the TUGC0 QA Audit Program and Procedures and all revisions thereto; and
' that the CPRT's evaluations will determine and report compliance / noncompliance
- with each of the documents as applicable from inception of the TUGC0 QA Audit
! Program to the present period of activity covered by this ISAP. During l implementati,gtof the Plan the staff will confirm-the CPRT's documented j objectiveevMnceindthisregard. l The staff finds that the FSAR commitments are identified in this plan and.that i the plan methodology is of adequate scope and depth to determine compliance l with those commitments. This evaluation also finds that this plan's interac-l tion with ISAP VII.c will assist in the identification and the determination of
- the impact of audit program deficiencies on construction quality. However, the i staff finds that Section 4.4 Procedures; refers to Program Plan and Issue Specific Action Plans instead of identifying the existing project procedures
! applicable to implementation of the plan. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires ientification of existing procedures.
I 03/10/86 IV-35 - NU0797 SEC IV 1
2.2.7.4 Conclusion Based on the staff evaluation that FSAR commitments are identified in the plan, and that implementation of the plan will cover sufficient scope and depth to determine compliance with those commitments and any resultant impact on con-struction quality, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished, and the staff will also confirm that the CPRT's evalua-tions have considered all revisions of the PSAR/FSAR and the TUGC0 QA Audit Program and Procedures. 2.2.8 ISAP VII.a.5, Management Assessment 2.2.8.1 Introduction t This plan addresses the NRC's concern regarding the TUGC0 management assessm'ent t of the effectiveness of implementation of their QA Program during construction e of CPSES. The issue arose because of TUGCO's failure to implement periodic c management review of QA Programs in compliance with 10 CFR 50, Appendix B, c Criterion II, QA Program, which states in part: The applicant shall regularly review the status and adequacy of the Quality Assurance Program. - 2.2.8.2 CPRT Approach The purpose of this action plan is to assess the adequacy of the current CPSES Periodic Review of the QA Program against criteria to be developed as part of this plan. The Review Team will review in place Periodic Review of QA Programs in other organizations and will consult with INPO to define criteria for an adequate and an effective Periodic Review of the QA Program. The Review Team will then evaluate the current CPSES Periodic Review of the QA Program against the criteria developed above and will recommend appropriate revisions to the CPSES Program. 03/10/86 IV-36 NUO797 SEC IV
Utilizing the information gathered, a set of criteria will be developed to define an effective Periodic Review of the QA Program for CPSES which addresses, among others, the following: Scheduling and performance of reviews at least annually. Reports directed to, and responses received from, a sufficiently high level of management to ensure effective correction action. Ongoing contact by management with program status. Identification of corrective action. 4 Tracking and follow-up. The current TUGC0 program will be evaluated against the criteria developed
; above, and, if appropriate, revisions to the TUGC0 written program will be pro-
- - posed to assure that an effective Periodic Review of the QA Program is in 4 effect for the remaining construction phase of Unit 2 and for the operations phase.
Copies of the Results Report for this ISAP will be provided to TUGC0 for their i consideration in responding to the NRC Notice of Violation (445/8432-02; 446/8411-02) (detailed below). Background information detailed in this plan states: 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 the 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.
l l I 03/10/86 IV-37 NUO797 SEC IV
l* t
- This ISAP is not intended to perform evaluations which would result 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.-
j - In addition to the TRT issue, the NRC issued a notice of violation l (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 con-struction quality assurance program.
i I 2.2.8.3 Staff Evaluation i i j The staff's evaluation of the CPRT's stated intent finds that this plan is l- 4 responsive to the action identified by the NRC, which requested that the appli-v cant propose an action ' plan that will ensure that such problems (lack of a * ] j ri management assessmeint program) do not occur in the future. The plan methodology ! r adequately describes a viable approach to establishing a management review j program. I i . j With regard to additional action identified by the NRC that the applicant j evaluate the TRT's findings and address potential safety significance, root [ cause, generic implications and collective significance, this plan states that j these factors are addressed in other hardware and programmatic ISADs and the j self-initiated ISAP VII.c. The staff finds that this is a satisfactory response
- to the action identified.
i l The staff finds that Section 4.4.1 procedures refers to the Program Plan and j Issue Specific Action Plans in' stead of identifying the existing project procedures l applicable to implementation of the plan. This does not comply with the Program j Plan, Attachment 3, ISAP format, which requires identification of existing pro-i cedures. i i 03/10/86 IV-38 NUO797 SEC IV
i D t 2.2.8.4 Conclusion Based on the ev'aluation, and the plan's determination of compliance with l 10 CFR 50, Appendix B, Criterion II, the staff concludes that this ISAP is acceptable. However, Section 4.4.1 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished. 2.2.9 ISAP VII.a.6, Exit Interviews 2.2.9.1 Introduction This ISAP addresses the NRC's concerns regarding the Exit Interview Program. i The purpose of this action plan is to determine if TUGC0 management has now established an effective program which encourages employees to v'o ice concerns y regarding safety and which seriously evaluates these concerns. l .
., 2.2.9.2 CPRT Approach j g The CPRT will determine if TUGC0 has an effective program in place by evalua-t , tion of the adequacy of the policies, procedures and activities of the CPSES i
Ombudsman and the CPSES SAFETEAM in identifying and resolving site personnel j concerns which have potential safety implications. The scope includes the l evaluation of the Ombudsman's activities associated with employee concerns l brought before him, including those uncompleted actions transferred by him to j TUGCO. However, due to the time frame within which this plan will be conducted
- related to the time of transfer of responsibilities from the Ombudsman, the j majority of review and evaluation will center upon the activities and program l of the SAFETEAM as implemented through December 1985. The implementation of this plan will develop a set of attributes derived from TUGC0 commitments and industry guidelines which will be utilized in the preparation of the checklists
; to be used in the review of established policies / procedures in place governing the activities of the Ombudsman /SAFETEAM interviews of employees. Evaluations will then be made as to the effectivness of the Ombudsman /SAFETEAM's handling of employees' concerns includf ag the evaluation for potential safety implications.
03/10/86 IV-39 NUO797 SEC IV i --
l 1 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. The results of reviews and evaluations conducted in the implementation of this plan will provide a basis for determining whether the Ombudsman's interview l program and implementation was adequate and effective in identifying employee l concerns, as well as determining whether the existing SAFETEAM program as implemented is effective in identifying and evaluating employee concerns regard- ; ing potential safet'y implications. The results of this action plan will provide ; input for the overall evaluation of the adequacy of the QA program being con-ducted by the QA/QC Review Team as well as providing recommendations for improve-ment for future program implementation as required. 2.2.9.3 Staff Evaluation y This evaluation finds that the plan is responsive to the NRC's concern, and*
- t that implementation of the plan will evaluate past concerns, identify potential t safety implications, and determine the effectiveness of the performance of the
.3 Ombudsman /SAFETEAM. Implementation will also ensure that TUGC0 management has
- v. now established an effective program which encourages employees to voice concerns !
regarding safety and which seriously evaluates these concerns. The plan, Section 4.1.2.5, states that revinws and evaluations shall be con-ducted of, and limited to, past items of concern brought before the Ombudsman of identified through employee interviews with the SAFETEAM. This statement can be interpreted to mean that the CPRT will do evaluations of either the Ombudsman or the SAFETEAM. The staff wishes to clarify its understanding that this paragraph means that the CPRT will evaluate both. During implementation i of the plan, the staff will confirm that the CPRT has done both evalutions. In addition, the staff finds that Section 4.4, Procedures, refers to the Program Plan and Issue Specific Action Plans instead of identifying the existing project procedures applicable to implementation of the plan. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires identification of existing procedures.
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03/10/86 IV-40 NUO797 SEC IV
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I 2.2.9.4 Conclusion The staff notes that there is no regulatory position that requires the applicant to have a formal exit interview program; therefore, there is no standard to enable a comparison of the applicants program f'or compliance. However, the staff has determined that implementation of this plan will establish adequate measures to address and resolve employees' concerns and to identify quality and safety implications. The staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished. 2.2.10 ISAP VII.a.7, Cleanliness 2.2.10.1 Introduction c This ISAP addresses the NRC's concern pertaining to housekeeping and system - e cleanliness and will determine the validity of the current housekeeping system
~
i and system cleanliness program for Units 1 and 2. Results of other action
- r. plans, procedural requirements, surveys, etc., will be analyzed to determine a any impact on hardware and programmatic implications.
2.2.10.2 CPRT Approach The CPRT assesses the adequacy of the housekeeping and system cleanliness pro-gram at CPSES by implementation of the following tasks: Review the results of ISAPs II.c and VI.a for adverse trends related to housekeeping and system cleanliness. Review TUGC0 and Brown & Root procedures for establishment of housekeeping j and cleanliness measures (including surveillance requirements). Evaluate implementation of Flush Procedure (FP) 55-08 for Reactor Vessel cleanliness. 03/10/86 IV-41 NUO797 SEC IV
Review and evaluate implementation of TUGC0 and Brown & Root Surveillance Programs. The procedural controls that are in effect for housekeeping and system cleanli-ness 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 also be reviewed. -
The TUGC0 flush procedures for verifying cleanliness of the Reactor Coolant i Loops, including FP 55-08, as referenced in Item 9A of the NRC-TRT letter dated January 8,1985, will be reviewed to determine the adequqacy of swipe testing performed in accordance with the Westinghouse guidelines. 2.2.10.3 Staff Evaluation
-f This evaluation finds that the NRC's concerns are identified correctly and ire s adequately addressed. Implementation by the methodology described will deter-
.i mine compliance with the' requirements of 10CFR50, Appendix B, Criterion XIII, 7 which is the FSAR commitment. The standards and acceptance criteria defined in the plan are appropriate for the evaluation to determine that compliance.
There is concern, howner, that Section 4.4, Procedures, contains a narrative statement regarding the retention of checklists, guidelines... , etc. , instead of referencing existing procedures. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires identification of existing procedures. 2.2.10.4 Conclusion Based on the evaluation the NRC staff finds the NRC's concern is adequately addressed and that implementation of the plan will evaluate and resolve the issue and determine compliance with the FSAR, the staff concludes that this
.ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will
, confirm that the revision has been accomplished. 1 1 j j 03/10/86 IV-42 NUO797 SEC IV
2.2.11 ISAP VII.a.8, Fuel Pool Liner 2.2.11.1 Introduction This ISAP addresses the NRC's concern regarding the applicants' inability to maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and inspection. This issue which was reported in SSER 11 Appendix 0, pertains principally to operations travelers and related documentation. Reinspection of welds in the fuel pool liner will be performed under the self-initiated ISAP VII.c. ' 2.2.11.2 CPRT Approach Background information in the Plan states that SSER #10 (which reported on fuel pool welds and welding practices) states that the fuel pool liners are not re-9 quired by FSAR to meet 10CFR50 or ASME B&PV Code requirements (although G&H Speci-4 fication 2323-SS-18 does impose 10 CFR 50 Appendix B QA Progrm requirements). z The fuel pool liners also are not required to be designed and erected to meet Seismic Category I criteria. s Additionally, the background states that the observations of SSER #10 notwith-n standing, G&H Specification 2323-SS-18, Revision April 15, 1985, Paragraph 1.1 does identify the stainless steel liner systems (except the Unit 1 and Unit 2 Reactor Building Refueling Cavities) as Nuclear Safety Related. This includes the spent fuel storage pools, transfer canals, and cask loading pits. The CPRT will evaluate irregularities in the fuel pool liner travelers and re-lated documentation by a review of liner specifications, drawings and procedures to determine the erection, inspection and testing requirements. A sample of travelers will be randomly selected from a list of all the spent fuel pool, trans-fer canal, and cask loading pit travelers used during erection of the liner and associated components. The sample will be selected to provide at least a 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. 03/10/86 IV-43 NUO797 SEC IV
A sample review is considered a reasonable approach for the following reasons: No. programmatic deficiencies have been identified in this population to date, and the population of travelers is homogeneous in that all the work was accom-plished by the same crafts using the same procedures. The CPRT will review the sample' 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, veri-fication of date entries and authorized inspection sign-offs.
2.2.11.3 Staff Evaluation The staff's evaluation finds that this ISAP correctly identifies the issue as: the Applicant's inability to maintain an effective and controlled QC Inspection c Program for fuel pool liner fabrication and installation. This ISAP addresses
- n this issue based on the same premise that the TRT used for their assessment,'
u namely, that the G&H specification imposed the requirement for a QA Program in
, accordance with 10CFR50 Appendix B, although this was not an FSAR commitment.
- . Additionally, this evaluation finds that the plan adequately addresses the .
- NRC's concern and that implementation of the methodology described in the plan will evaluate and resolve the issue. The plan describes that fuel pool liner
, inspection records shall be in compliance with the inspection record require-ments 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. The staff finds these criteria to be appropriate.
The staff has a concern that S'ection 4.4, Procedures, contains a narrative pertaining to the development of matrices, checklists and data sheets instead of referencing existing procedures which are applicable to implementation of j the plan. This is not in co pliance with the Program Plan, Attachment 3, ISAP format, which requires referencing existing procedures. i I i , 03/10/86 IV-44 NUO797 SEC IV l
2.2.11.4 Conclusion The staff concludes that this plan is acceptable, based on their evaluation that implementation of the plan will evaluate and resolve the issue and that appropriate criteria are used to determine compliance with 10CFR50 Appendix 8 even though these criteria are not an FSAR commitment. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During imple-mentation of.the plan, the staff will confirm that the revision has been accom-plished. 2.2.12 Onsite Fabrication (VII.b.1) 2.2.12.1 Introduction This ISAP will assess and resolve the NRC's concern regarding the procedural
-- and management control of the fabrication shop work activities at CPSES.
2.2.12.2 CPRT Approach ,
- The CPRT will implement this Plan in a two-step approach, the fir:;t of which t will address concerns that may be evaluated by review of safety related fabrica-tion document packages. This evaluation will assess the proper completion of material requisitions, fabricated threads conformance and shop fabrication to memos and sketches. Additionally, this step will identify populations of ASME and non-ASME safety related fabricated pieces, and evaluate 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 0, CPRT Sampling Approach, Applications and Guidelines. If documentation discrepancies cre identified, the CPRT will perform reinspections of items using checklists of appropriate attributes developed under this Plan and the self-initiated ISAP VII.c.
The second step will address concerns which may be evaluated by review of pro-cedures, survey, surveillance, and audit records to identify trends and correc-tive action effectiveness in: scrap and salvage control; safety, non-safety and bulk material segregation; and site surveillance of material storage. 03/10/86 IV-45 NUO797 SEC IV
The data derived from the implementation of the.two steps described above, will be analyzed to determine if the shop fabrication activities have met the re-quirements of 10CFR50, Appendix B, Criteria V, IX and X and the FSAR. The Plan also describes its interaction with ISAP VII.a.1 which addresses material traceability, and also clarifies that a craft training concern, a part of the site fabrication issue, is addressed in ISAP I.d.3. - 2.2.12.3 Staff Evaluation This evaluation assessed that the Plan identified the issue correctly and finds that the methodology when implemented will address the NRC's concern, and will determine compliance with the applicable criteria of 10CFR50, Appendix B. Section 4.3 states in part: "All personnel associated with the analysis and
- - evaluation of findings ... " Since the Program Plan, Appendix E, applies to a the classification of discrepancies, the staff finds that the word findings is not an appropriate classification, and does not comply with Appendix E.
o Additionally, this evaluation finds that Sections 4.4 procedures and 4.5
.r Standards / Acceptance criteria contain nar.rative descri'ptions of checklists, guidelines, etc., and a vague description of what the criteria will be based on, instead of identification of the procedu g .,and criteria. The two sections
,donotcomplywiththeProgramPlanAttachmehth.ISAR2f6rmatwhichrequires identification of existing procedures and the Standards / Acceptance criteria.
2.2.12.4 Conclusion l The staff's evaluation found that implementation of the plan will adequately address and resolve the issue and determine FSAR compliance. The staff concludes that this ISAP is acceptable. However, Sections 4.3, 4.4 and 4.5 must be revised l to comply with the Program Plan, Appendix E, and Attachment a respectively. During implementation of the Plan the staff will confirm that the revision has been accomplished. 03/10/86 IV-46 NUO797,SEC IV 1
2.2.13 Valve Disassembly (VII.b.2)
, 2.2.13.1 Introduction This ISAP addresses the NRC's concern regarding valve assembly / disassembly and evaluation of the adequacy of procedures that controlled the disassembly /
reassembly process and determines if valves that required disassembly were pro-perly reassembled; and, if not, whether an improperly reassembled valve could result in a Code violation or have a safety consequence. 2.2.13.2 CPRT Approach In implementing this Plan to evaluate and resolve the issue, the CPRT will: Identify all valves which have been disassembled and reassembled. e - Conduct a procedure review to determine adequacy of control of valve com-
+ ponents during disassembly and reassembly.
ex - Perform a safety consequence analysis to determine if valve component e 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 valves were properly reassembled. Review applicable procedures, for both construction and QC, to determine if they provided adequate controls of materials during valve disassembly and re-assembly. In addition to prop'er matching of components, the procedures will be reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process. In parallel with the procedure review, an analysis will be made to determine p the safety consequences of improperly assembled valves. The analysis will include potential failure modes resulting from improper reassembly of the generic 03/10/86 IV-47 NUO797 SEC IV _m ___. ,-___.---.7-_m.__, -. _
o a 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. l In addition, an evaluation will be made to define potential Code violations which could result from improperly assembly valves. ! 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 additional sample of valves from the population comprised of the valves identified in the TRT issues will be reinspected. Both samples will be in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection is considered to be a reasonable approach for the following reasons: No programmatic deficiencies have been identified in this population to date. g - The population of valves which have been disassembled is homogeneous. Speci-a fically, 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 errors associated with the pro-cess of disassembling and reassembling valves.
Manufacturers drawings and disassembly procedures will be reviewed and docu-mentation 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 a verification of internal parts. Pro-
- bable improper reassembly will be indicated by an inconsistency in internal component serial numbers from one Operation Traveler to another for a particular valve.
03/10/86 IV-48 NUO797 SEC IV
2.2.13.3 Staff Evaluation This evaluation finds that the concern is identified correctly and that imple- l mentation of the methodology will evaluate and resolve the issue. The staff is concerned however that the emphasis of the Plan appears to be directed towards valve internal parts. It is acknowledged that the tracking of valve internal parts is a critical essential element in the CPRT's evaluations. The staff wishes to further identify that the TRT's issue also identified the loss damage and interchange of valve external parts, namely bonnets. This was particularly true in the case of the hand wheel operated diaphragm valves in the spent fuel cooling, baron recycle and chemical volume control systems. Section 4.1.5 states in part: " Probable improper assembly will be indicated by an inconsistency in internal component serial numbers." The CPRT's evaluations must also consider inspection attributes that provide for a check of all valve parts that are traceable by physical part marking (not limited to serial numbers), operations travellers, and in the case of Code class valves, the manufacturers Code Data Report Form NV-1. ~
- Section 4.1 states in part: A safety consequence analysis to determine if valve componcnt 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. The staff is concerned that the analysis may be limited only to those cases involving lower pressure / temperature ratings when in fact the same potential risks may ensue in cases of higher pressure / temperature ratings. The staff finds that the concern can be clarified by use of phraseology: " .. different pressure /
temperature ... ". Accordingly, the ISAP must be revised to so state. Additionally, Section 4.2 procedures does not identify existing procedures and therefore does not comply with the Program Plan Attachment 3 which requires identification of existing procedures. Also, in Section 4.6 the applicable Codes and Standards and FSAR commitments if any are not identified. l l l
<03/10/86 IV-49 NUO797 SEC IV
. . , - - - , , , y--- -
-,y
= 2.2.13.4 Conclusion The staff evaluation finds that implementation of the Plan's methodology will address and resolve the issues, however, the Plan must contain provisions to inspect for the interchange of critical valve external parts (e.g. , bonnets) as well as internal parts. Additionally, Sections 4.2 and 4.6 must be revised to comply with the Program Plan Attachment 3. Based on the evaluation of the Plan's methodology the staff concludes that this ISAP is conditionally acceptable. Final acceptance is pending the staff's confirmation during implementation, that Sections 4.2 and 4.6 have been revised to comply with the Program Plan Attachment 3 and that imspection checklist attributes provide for the inspection of. valve externals. Also, during imple-centation the staff will confirm that Section 4.1 has been revised to state "different pressure / temperature ratings" and that the analysis does in fact address the di,fferences in both cases. i 2.2.14 Pipe Support Inspections (VII.b.3) 2.2.14.1 Introduction This ISAP addresses the NRC's concern regarding the adequacy of QC as-built inspections of pipe supports. 2.2.14.2 CPRT Approach The Plan scope and methodology describes that 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: Reinspect the TRT sample to validate the TRT identified discrepancies. Reinspect randomly selected samples of pipe supports. (Note: this rein-spection is performed under the ISAP VII.c program. )
.03/10/86 IV-50 NUO797 SEC IV
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 tasks outlined above. This action plan covers safety related Class 1, 2 and 3 pipe supports in Units 1, 2 and common areas. The CPRT will review the documentation used by the TRT in their inspections (e.g., specifications, procedures, drawings etc.), prepare reinspection packages and perform reinspections of the items that the TRT initially inspected. The CPRT will compare their inspection results with the TRT's findings and identify
- the differences or results that cannot be reconciled.
d Under this ISAP, the CPRT will assure that the populations of supports to be
~
\
a- random sample reinspected include the attributes and instructions required to j
. verify the TRT identified discrepancies in the Action Plan VII.c reinspection
~. checklists and quality instructions for each population identified. (Note:
i The required inspections-will be performed under Action Plan VII.c.) Review VII.c inspection results for pipe support populations and identify valid discrepancies. In addition, the CPRT will evaluate all valid discrepancies for safety signi-ficance and perform trend analysis for all valid deviations. Both of these activities will be performed in accordance with the requirements of the Program Plan, Appendix E, Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Discrepancies Identified by CPRT. 2.2.14.3 Staff Evaluation The Staff's evaluation finds that the NRC's concern is identified correctly and complete identification of the TRT's findings are tabulated in the Plan. Imple-mentation of the Plan's methodology, which addresses evaluation of the TRT 03/10/86 IV-51 NUO797 SEC IV
]
l l issue combined with the defined interaction with ISAP VII.c, adequately addresses evaluation of the issue. This evaluation finds that existing procedures appli-cable to plan implementation are identified. However, Section 4.5 Acceptance Criteria describes activities performed by the CPRT instead of identifying the , Codes / Standards and FSAR commitment. The section does not comply with the Program Plan, Attachment 3, ISAP format which requires identification of stand-ards/ acceptance criteria. . 2.2.14.4 Conclusion The staff evaluation finds that the NRC's concern is correctly identified and that implementation of the Plan will adequately evaluate the issue. The staff finds however that although the Plan contains sufficient information to deter-mine acceptability /non-acceptability of the items reinspected, the Plan lacks identification of the Codes / Standards and FSAR commitment which are used as a comparisons to resolve the issue (e.g., inadequacy of QC inspections) and to e determine compliance. Accordingly, the staff concludes that this ISAP is co'n- i s ditionally accepted. During implementation, the , staff will confirm that the l a ISAP Section 4.5 has been revised to comply with the Program Plan Attachment 3
. in the identification of Standards / Acceptance criteria.
2.2.15 Hilti Anchor Bolt Inspections (VII.b.4) 2.2.15.1 Introduction i This ISAP addresses the NRC's concern regarding Hilti anchor bolt installation j on pipe supports and electrical raceway supports. 2.2.15.2 CPRT Approach 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. 03/10/86 IV-52 NUO797 SEC IV
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 comonality in requirements among various project (discipline) documents. . Evaluate sample size. ' 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 plan tasks to
- c. react to these implications. ~
Under this Plan the CPRT will review specifications and procedures and identify a safety significant attributes that are ,in accordance with those attributes 4 applicable to inspection performed under the self-initiated ISAP VII.c. 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 items will be considered applicable to all Hilti bolt installations. If not, samples from other populations of Hilti bolts in Units 1, 2 and common will be inspected. Reinspections shall be performed in accordance with Action Plan VII.c and shall include a) sample reinspection of Hilti bolt installations as a reinspection attribute and b) documentation reviews to conclude that appropriate surveillance attributes had been properly noted. This action plan for Hilti bolt installations will utilize the results of the above inspections as well as additional inspec- l tions to resolve the Hilti bolt concerns.
)
03/10/86 IV-53 NUO797 SEC IV
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 program. This program will consist of, torque checking a number of Hilti bolts from Electrical Raceway Supports, pipe supports, and HVAC duct supports. Based on engineering evaluation of' this program, further pull-tests of questionable samples will be considered. Pull-tests, if required, will be based on determining the Hilti bolts resistance to the service load required of the bolt. - Programmatic implications will be reported to the Manager - QA/QC - Programmatic Issues, and those with potential impact on other action plans will be provided to the affected Issue Plan Coordinator for any necessary action. 2.2.15.3 Staff Evaluation r The staff's evaluation finds that the issue is identified correctly in the Plan, and the Plan is sufficient in scope and depth to adequately address th'e
% issue. This evaluation finds that the CPRT's review of applicable documentation a will identify the inspection attributes. Evaluation of physical torque tests r and pull tests performed under this Plan combined with evaluation of the results e
of inspections performed under ISAP VII.c will provide sufficient information to enable a conclusion regarding the Hilti-bolt installations. That staff is~ concerned that Section 4.6 Acceptance Criteria contains a narrative description of what the CPRT will do to establish the acceptance criteria instead of specific identification of the documents that yield the criteria. This does not comply with the Program Plan Attachment 3 ISAP Format which requires the identification of Standards / Acceptance criteria. Accordingly, Section 4.6 must be revised to comply with Attachment 3. The staff notes that the torque verification program will be accomplished by reinspecting for nut rotation resistance to a percentage of the original torque setting value defined by engineering evaluation. Since the amount of torque used is critical to verification of proper seating of the Hilti in the concrete, i the staff will review this detail. 03/10/86 IV-54 NUO797 SEC IV
a 2.2.15.4 Conclusion In its evaluation of this ISAP, the staff found that the issue is identified correctly and the Plan's methodology is adequately descriptive of the activity that is essential to evaluation and resolution of the issue. The percentage of torque used in the torque verification program is an issue of concern that will be subject to staff review during implementation. Accordingly, the staff con-cludes that this ISAP is acceptable. Section 4.6 does accurately identify the type of document from which the: acceptance criteria will be derived. Those specific documents, of necessity, were used to establish the inspection attributes. Therefore, discrete identification is known. Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 has been revised to comply with the Program Plan, Attachment 3.
~
2.2.16 Cable Tray Raceway Supports Inspection (VII.b.5) i
~
T This ISAP was deleted frem the CPRT Program Plan, Revision 3, Appendix C. 2 This ISAP was initially developed to respond to QA/QC issues that were identified A in the NRC letter to the Applicant January 8,1983. These were subsequently 4 published in May 1985 in NUREG 0797 Safety Evaluation Report Supplement 11, e Appendix 0, Reference Pages 0-295 through 0-298, and addressed electrical raceway support inspections. The areas of concern were related to the following:
- 1. Undersized welds
- 2. Misplaced welds 1 3. Unauthorized configuration changes -
- 4. Hilti anchor bolt installation deficiencies 5'. Undersize nuts These QA/QC issues arose from sources other than the CPRT, (in this case the SER Supplement 11), therefore are classified as external source issues.
The staff's evaluation of CPRT Program Documentation finds that the concern will be addressed in ISAPs I.c, VII.b.4, VII.c and DSAP XI. 03/10/86 IV-55 NUO797 SEC IV
2 The staff has evaluated the CPRT's Program Plan methodology that will ensure that all of the external source issues (including QA/QC issues) will be identi-fled, evaluated and resolved. The staff found the Program Plan to be acceptable in this regard. The staff is confident that the issue of concern that was to be addressed in ISAP VII.b.5 (deleted) will be satisfactorily addressed by the CPRT under the Plan's methodology for resolving the external source issues. During implementation of the Program Plan, the CPRT shall offer a reasonable explanation for the deletion of ISAP VII.b.5 and identify the action plan (s) that address this issue, and the staff will confirm the CRPT's action. 2.3 Civil / Structural Issues Five external source issues relating to construction adequacy in the civil / structural area were identified in NUREG-0797, Supplement No. 8 O'&-- re ). One additional external source issue (I.c) was identified in NUREG-0797, Supple-
- ment No. 7, which is now included as part of the civil / structural issues.
Under the Program Plan, Appendix C, Action Plans, the CPRT developed the following
+ Issue Specific Action Plans (ISAP) to address and resolve the Civil / Structural issues relating to construction adequacy:
(ActionPlan gg Title d CI..c Electrical Conduit Suppor D pt II.a Reinforcing Steel in the Reactor Cavity fII.b Concrete Compression Strength II.c Maintenance of Air Gap Between Concrete Structures II.d Seismic Design of Control-Room Ceiling Elements II.e Rebar in Fuel-Handling Building 2.3.1 ISAP II forcing Steel in the Reactor C 2.3.1.1 Introduction , This ISAP addresses.a documented occurrence in which reinforcing steel was or.itted from a unit I reactor cavity concrete placement between the 812-foot and 819-foot-1/2-inch elevations. Although the omission was documented, justifi-cation supporting the engineering conclusion to use as is was not available. 03/10/86 IV-56 NUO797 SEC IV
4 2.3.1.2 CPRT Approach The action plan is designed to assess the design adequacy of the existing as-built condition of the reactor cavity wall and other areas within Units 1 and 2 where rebars were omitted. This assessment will include an evaluation of the engineering / field design-change interface. All documented instances of rebar omission will be reviewed to assure that proper engineering evaluation and documentation exist in support of the dispo-sition of each item. In addition, a random sample of 60 concrete pour cards will.be reviewed to verify that current design documents were used in construction. Procedures governing design changes will be reviewed to verify the adequacy of methods for controlling implementation of design changes into construction. 2.3.1.3 Staff Evaluation e The staff has reviewed the CPRT Program Plan, ISAP II.a Revision 2, and the
- . CPRT response of November 22, 1985, to the staff comments (dated September 30, 1985).
The staff has reviewed the standards and acceptance criteria delineated in the ISAP and has found that they are consistent with licensing commitments. ..
* -E . @'
The CPRT methodology in reviewing documentation and evaluation of procedures governing the engineering / field design-change interface and the review of the evaluation of the implementation of these procedures is consistent with current verification practices. ' l l However, the plan should recognize the possibility that some structural members may be deficient when reinforcing steel was emitted. Furthermore, the logic diagram in the attachment to the ISAP is incorrect. The seccnd vertical branch l at the left and the s-shaped branch near the upper right hand corner should be deleted. 03/10/86 IV-57 NU'0797 SEC IV , l
2.'3.1.4 Conclusions The Program Plan, Revision 3, ISAP II.a. is responsive to the concerns raised by the staff in the September 30, 1985 letter and is therefore acceptable, with the qualification that deficient structural members needs to be addressed for-mally in the plan and the logic diagram corrected. 2.3.2 ISAP II.b, Concrete Compression Strength 2.3.2.1 Introduction ' This ISAP addresses civil / structural allegations that some concrete strength tests were falsified. The applicant's position is that the uniformity of the concrete placed appears to minimize the likelihood that low concrete strengths
.:: were obtained. The staff felt that additional action by the licensee was neces-e: sary to provide confirmatory evidence that the reported concrete strength te'st
- c results are indeed representative of the actual strength of the concrete installed.
2.3.2.2 CPRT Approach This action plan has been developed to verify the quality of the concrete in question. The Schmidt (Rebound) Hammer Test will be used to compare / correlate the relative strength of concrete poured during the period in question (Con-crete at Issue, CAI) and concrete poured outside this period (Control Concrete, CC). All testing will be in accordance with ASTM procedures. The area for testing will be limited to the exposed surface area where the Schmidt Hammer Test can be performed. Concrete-cylinder test data for the two populations will also be obtained, reviewed, and used for reference. If, after reviewing results of the Schmidt Hammer Test, the CAI population is i found to have lower strength than the CC population, core tests, calibration of the Schmidt Hammer with known concrete strength or analysis will be performed. Any such actions will be documented as a revision to this action. plan. 03/10/86 IV-58 NUO797 SEC IV
a 2.3.2.3 Staff Evaluation The CPRT methodology for reviewing concrete-cylinder strength tests and for performing Schmidt Hammer tests on CAI and CC concrete pours is consistent with procedures / practices used in the concrete area. The statistical correlation for"the CAI versus-CC rebound tests is an appropriate approach, since the same or similar environment (age, strength, humidity) was used for the placements. . 2.3.2.4 Conclusion The Program Plan, Revision 3, ISAP II.b, is responsive to the concerns raised by the staff in the September.30,1985 letter and is therefore acceptable.
# 2.3.2 ISAP.II.C, Maintenance of Air Gap Between Concrete Structure
/ .
2.3.3.1 Introduction - r The TRT in NUREG-0797, Supplement 8, raised a concern that TUEC had not ade-t quately demonstrated compliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which require separation of Seismic Category I buil, dings to prevent l interaction during an earthquake. l N-3: . 4n-1 2.3.3.2 CPRT Approach This ISAP will assess the current as-built condition to determine the extent i and cause of the condition. An evaluation will be performed to determine the design significance of the as-built condition. Any identified debris or roto-foam that impacts the design basis will be removed. The final as-built condition of all separation between Category I buildings and between Category I and non-Category I buildings will be determined as well as documentation of the design acceptability. i 03/10/86 IV-59 - NUO797 SEC IV
Quality Control (QC) will document the final as-built conditions and a third party will overview this process. 2.3.3.3 Staff Evaluation The staff has reviewed the methodology to be used in addres' sing this specific issue. The approach is a complete reinspection of the as-built condition and the verification of design acceptability for compliance with FSAR commitments. In addition, the cause of the existing condition (s) and its applicability to other areas of the plant will be reviewed and evaluated. However, the flow diagram given in the ISAP is not correct. There is no indication where item A is generated and item C serves no purpose. 2.3.3.4 Conclusions The action plan is responsive and with proper implementation, including design acceptability for FSAR commitments, should resolve NRC concerns with the qua'lifi-cation that the flow diagram be corrected. 2.3.4 ISAP II.d Seismic Design of Control Room Ceiling Elements 2.3.4.1 Introduction This review of the design of Seismic Category II items is a result of the allega-tion tnat the field run conduit, the drywall ceiling and the lighting installed in the area above the control room were classified nonseismic and may fail , during a seismic event. This review is to assure that proper consideration was given to governing design criteria in the design of Seismic Category II items. CPSES General Design Criteria No. 19 requires that safe occupancy of the control room during abnormal conditions be provided for in the design. The Comanche Peak Steam Electric Station (CPSES) control room is in a seismic Category I structure, with certain seismic Category II and nonseismic components located in the ceiling. Seismic Category I refers to those systems or components which cust remain functional in the event of an earthquake. Seismic Category II refers to those systems or components whose continued functioning is not required, but whose failure could reduce the functioning of any seismic Category I system 03/10/86 IV-60 NUO797 SEC IV _ ,_,.__. _ . ~ , , , _ _ - , _ - , ...e. . , , c _,.m,, ---,__ , ., -----, .-we -
l* I l i l or component (as defined in Regulatory Guide 1.29) to an unacceptable level or could result in an incapacitating injury to occupants of the control room. Seismic Category II systems or components are, therefore, designed and constructed so that a Safe Shutdown Earthquake (SSE) will not cause such failure or injury. 2.3.4.2 CPRT Approach In assessing this allegation, the TRT reviewed the CPSES nonsafety-related conduit, lighting fixtures, and the suspended ceiling's installed in the control room. Three types of suspended ceiling exist in the control room; drywall, louvered and acoustical. Item II.d, of Appendix C (Civil / Structural ISAPs) of the CPRT Program Plan contains a complete description of the actions taken to assess this allegation, along' with assessing the design adequacy of Seis'nic Category II items, in general, to assure that the conditions identified by the allegation are not applicable to other Category II and nonseismic structure systems and components at CPSES. , e The significance of Category II and nonseismic items is identified in Regulatory r, Guide 1.29, which states that portions of structures, systems, or components
- whose continued function is not required but whose failure could reduce the e functioning of any plant feature to an unacceptable safety level should be designed and constructed so that the SSE would not cause such failure. It is therefore the intent of the CPRT Program to assure that, in fact, the failure 1 of non-Category I items will not cause damage to safety-related systems. To achieve this, the CPRT is to conduct a third party design verification of the Unit.I Damage Study Program to address generic implications.
The review and verification of the damage study includes a project review of. i all architectural features to determine if there is a potential for seismic interaction with safety-related items. Any architectural features in Units 1 and 2 which have potential seismic interaction will~be either modified or sub-jected to a damage study assessment. This includes a review of all resolutions of unacceptable interactions. The third party will review procedures, methods for conducting the seismic damage review, along with interfaces between the damage study group and other disciplines. The populations oi' all non-Category I systems, structures and components which are considered for seismic interaction with safety-related items, including selection criteria, will be identifed. l 03/10/86 IV-61 NUO797 SEC IV
The third party will review the criteria for evaluation of the consequences of
, interactions and methods for performing the damage study and will perform a
~ comparative damage assessment in selected rooms to assess the consistency with which interactions are identified. The rooms will be chosen based on functional and physical aspects, importance of components, and balance of types of non-seismic items. 2.3.4.3 Staff Evaluation - The staff's evaluation of this section of the Program Plan is based on a review of Revision 3 of the CPRT Program Plan and Supplement 8 of NUREG-0797, which address the specific concern that Seismic Category II items were not properly designed in the area above the control room. The Program Plan goes beyond the ; resolution'of the specific issue to review the CPSES Unit 1 damage study to
~
assure that the FSAR commitments are met.
.i However, the flow charts in Figures II.d-1 and II.d-2 do not reflect the in-
; tended use of third party review. In Fig. II.d-1 it is indicated that the new s ceiling will be installed without regard to the results of the third party review. The installation should be made contingent on a successful third party v review and the arrowhead between " Design New Ceiling" and "A" should be revised.
- 2. In Fig II.d.2 implementation of$esign % should also be made contingent on a successful third party review. 6 7 2.3.4.4 Conclusion The staff concludes that the Program Plan appropriately addresses the staff concerns and is acceptable with the qualification that Figures IId-1 and II.d-2 be corrected. ,
2.3.5 ISAP II.e, Rebar in the Fuel-Handling Building 2.3.5.1 Introduction This issue-specific action plan addresses an alleged instance of unauthorized i cutting of rebar in the Fuel-Handling Building due to depth of core drilling.
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03/10/86 IV-62 NUO797 SEC IV s _
2.3.5.2 CPRT Approach The CPRT action plan will address the as-built condition of the specific concrete mat in the Fuel-Handling Building, will assess the work of the construction crew that could hve cut additional rebar without proper authorization, and will review controls governing rebar cutting. Design calculations will be generated if required. - All caes where rebar cutting was requested for installation of Hilti bolts will be reviewed and comparison made between rebar pattern and embedment depth of the intalled bolts. The adequacy of the procedures and controls governing rebar cutting will be reviewed. 2.3.5.3 Staff Evaluation
- The staff has reviewed this specific action plan. The scope and methodology is acceptable for determining the adequacy of procedural controls and for locating areas where potential unauthorized rebar cutting was necessary.
If reanalysis is required, the requitments of ACI-318-71 and FSAR commitments will be consistent with original design criteria. However, the plan does not mention corrective actions to be undertaken if cut rebar produce an unacceptable ; structural member. Furthermore, the logic diagram given in the ISAP is incorrect, in that there are no arrows connected to the lower right-hand box. 2.3.5.4 Conclusions The approach described in this ISAP is acceptable. Proper implementation will assure the acceptability of as-built conditions with the qualification that th'e possibility of structural deficiencies must be addressed and the logic diagram corrected. 03/10/86 IV-63 NUO797 SEC IV i
2.3.6 ISAP I.c, Electrical Conduit Supports 2.3.6.1 Introduction This issue-specific action plan addresses the installation of nonsafhty-related conduit supports for conduit two inches in dianeter or less in seismic Category I areas of the plant. No evidence could be found that substantiated the adequacy of the installation, or in demonstrating.that their failure would not adversely affect the function of safety-related components or cause injury to plant personnel. 2.3.6.2 CPRT Approach This action plan will document the basis for the CPSES Damage Study assumption that Train C nonseismic conduit, two inches in diameter or less, would fall and have a potential for interacting with safety-' elated r components.' A seismic analysis will- be performed that verifies stability and/or acceptable ;
, interaction during an earthquake. Two separate samples will be derived from the Unit 1 and common areas. One will be randomly selected and the other will be derived on an engineering basis.
TheQA/QCConstructionAdequacyforTrainCconduitwillbeaddressedunder CPRT Action Plans VII.a.1, " Quality Control Inspection", and VII.b.4, "Hilti Bolts". 2.3.6.3 Staff Evaluation l The staff has reviewed the scope and methodology used in addressing this specific issue. The sample size and selection is consistent.with the overall approach used in l the Construction Adequacy Program. The use of two samples, random and engineered, should provide a reasonable review of the entire population and a lower bound on seismic performance. O
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03/10/86 -IV-64 NUO797 SEC IV
--. - . . . - . -. -. _- -- . - , - . . , - . ._ . . . _ _ _ , . - , __,,n. . . , , . - , . . , n-- , ,,- u,..__-
o . The seismic analysis of both populations ~will determine whether the two-inch-and-under conduit supports meet the requirements of FSAR Section 3.78.2.8 and Regula-tory Guide 1.29. - Revision 3 of the plan is responsive to the concerns listed in the September 30,'1985 NRC letter to the applicant. However, in clarifying the disposition of rejects identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Section 4.1.2.1 (page 7) j and Section 4.1.2.5 (page 10). The intent of this statement relative to sample expansion and compliance with Appendix D of the Plan is unclear. 2.3.6.4 Conclusions The general scope and methodology contained in this ISAP is responsive and with l proper implementation, including design acceptability for FSAR commitments, I should resolve NRC concerns.
,e However, before this ISAP can be accepted by the staff, clarification and/or s justification of the statement in Section 4.1.2.1 and 4.1.2.5 is needed.
- 2. 4 Mechanical & Piping Issues The mechanical / piping issues evolved from the TRT's assessment of allegations pertaining to the mechanical / piping area at CPSES. These issues were initially presented to the applicant by letter from the NRC dated November 29, 1984 and the detailed assessments were published in NUREG-0797 Safety Evaluation Report Supplement 10 issued in April 1985.
Also included in this section are concerns identified as miscellaneous issues which arose from the TRT's investigations of allegations in the Civil / Structural area. These issues were initially presented to the applicant by letter from the NRC dated November 29, 1984, and the detailed assessments were published in
' NUREG-0797 Safety Evaluation Report Supplement 8 issued in February 1985.
Under the Program Plan, Appendix B, Quality of Construction and QA/QC Adequacy Program' Plan, the CPRT developed ISAPs to address and resolve the mechanical / 03/10/86 IV-65 NUO797 SEC IV
piping and miscellaneous issues related to construction adequacy. As determined by the CPRT, the ISAPs may employ one or more of the following' approaches: hardware reinspection, documentation review, walkdown inspections, engineering review and analysis, and review and verification of TUGC0 corrective actions plans. The CPRT Program has also addressed the design-related aspects of two of the - M/P ISAPs (V.b and V.c) in the Design Adequacy Plan.. ISAP V.b is evaluated in Civil / Structural DSAP VIII, and ISAP V.c is addressed in Piping / Supports DSAP IX. The staff's evaluation of each of the action plans that address the M/P and miscellaneous issues related to the Construction Adequacy Program are presented in the following sections. 2.4.1 Inspection of Certain Types of Skewed Welds in NF Supports (V.a). l 2.4.1.1 Introduction
- l
;; During the CPSES ASLB hearings an allegation was made that Brown & Root (B&R) c QC inspectors did not have adequate instructions or training to properly measure x the size of skewed fillet welds during the inspection of pipe supports. NRC
- Region IV inspection reports 50-445/82-14 and 50-445/84-08 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of !
its implementation. The TRT assessed the same allegation during its July-September 1984 onsite investigation and concluded that TUEC could not provide documentation that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., interfaces of curved sections). Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition. 2.4.1.2 CPRT Approach # In response to the November 29, 19 NRC letter, TUEC developed the CPRT Program Plan to include ISAP Va. This IS addressed the concerns of the TRT by
- i l
03/10/86 IV-66 NUO797 SEC IV
establishing a scope and methodology, Sections 4.1.1 through 4.1.6,.for the action plan that is responsive to the issue. The action plan included a review of a documented chronology of inspection methods involving skewed welds to cor-relate the period of time and specific procedure revisions for the inspection of Type 2 skewed welds. Procedures QI-QAP-11.1-26, QI-QAP-11.1-28, and CP-QAP-12.1 will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed weld dimen-sional configurations and revised if necessary. - TUEC also committed to assess the adequacy of the implementation of t.he appro- , priate inspection procedures by establishing a random sample of Type 2 skewed welds to be reinspected. The sample plan is based on achieving a 95% confidence level that less than 5% of Type 2 skewed welds were not inspected properly and may result in a safety significant condition. The reinspections will be con-ducted by a third party using the revised procedures.
.y Finally, the results of the procedure review and physical reinspections will be ^
y evaluated to assess rooli cause and generic implications. Corrective action s.will be taken whenever modifications and procedural changes are required. A 2,results report will be written to document the results of all procedure reviews, uphysical modifications, trend analysis and corrective actions. 2.4.1.3 Staff Evaluation The staff has reviewed the CPRT Program Plan, ISAP V.a, and has the following observations. The plan had identified chronology of inspection methods and its relationship
~
to procedure revisions to be the proper starting point. The plan also addresses the adequacy of implementation of the appropriate inspection procedures by c:ans of the proposed sampling plan. The staff believes that this aspect of the plan will identify the root cause of the skewed weld inspection problem. The staff expects the root cause and subsequent generic implications of this issue to be positively identified, since this issue had been previously identi-fied in the' ASLB hearings and addressed by TUEC. Tlie fact that a procedure interpretation problem existed after action by TUSC is suggestive that there 03/10/86 IV-67 'NUO797 SEC IV
o could be generic implications with respect to procedure revision and implementat-ion in other areas of the plant. I The staff also reviewed the CPRT response to the staff comments (dated Septem- ; ber 30, 1985) on ISAP Va. In Revision 3 of the Program Plan,.the responses for j
. Items 2-4 are acceptable since they are mainly clarifying in nature. However, i
' he response to Item 1 requires additional explanation. The staff could not t I
- find where both Type'l and Type 2 skewed welds were addressed by B&R procedure
,QI-QAP-11.1-28. If this were the case, then " stanchion welds" would have been inspected using the skewed weld inspection methods and marked as such on the QC l checklist.
2.4.1.4 Conclusions l The staff conducted an evaluation of the CPRT Program Plan for ISAP V.a and l
. found the action plan to be generally responsive to the issues raised since the
{ plan addressed inspection methods, procedure revisions, and reinspections. 'The l
+ staff, however, requires assurance that the root cause of the issue and its generic implications are properly addressed in the action. The CPRT TRT issues manager should assure the staff that both items will be addressed in the results
- - report. The staff perceives the root cause and generic implication aspect of .
this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC. i In addition, the response by the CPRT to Item 1 of the staff letter of Septem-ber 30, 1985 concerning ISAP V.a is unacceptable. The staff requires further explanation concerning the intent of procedure QI-QAP-11.1-28 with respect to i
- skewed welds.
2.4.2 Improper Shortening of Anchor Bolts in Steam Generator (SG) Upper Lateral Supports (V.b). i 2.4.2.1 Introduction During the July-September 1984 investigation, the TRT was informed that some of the anchor bolts in the steam generator upper lateral support were shortened during installation without proper authorization to less than the length shown 03/10/86 IV-68 NUO797 SEC IV
- - . , . - - . - . . . _ . , , , _ _ , ..n._,.,-----.c-,-.,_s
on the design drawings. Based on the results of its investigation, the TRT requested that TUEC provide evidence, such as ultrasonic measurement that would verify the actual installed bolt lengths. The TRT requested that should the bolts be determined to have been installed to engagements less than that shown of design drawings, TUEC shall: Replace shortened bolts with bolts of the proper length or provide analysis to justify the adequacy of the installed bolts. Provide justification or propose measures to ensure that no similar concern exists for other bolting. TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement exicted in specific locations. This deficiency was reported on January 17, 1985 in accordance with 10 CFR 50.55(e). In addition, an evalua-
- tion of the design of the connection by the third party determined that the m cxisting design is not adequate for the specified loading conditions.
2.4.2.2 CPRT Approach The CPRT Plan describes the measures that will be used to ensure that the steam generator upper lateral support beams meet design requirements and to review similar installations to determine if this issue pertains to other designs. As stated in Section 4.1.1 of ISAP V.b, thread engagement of the SG upper lateral restraint anchor bolts was determined to be less than required by design on the b: sis of inspections performed in Unit 1. A reevaluation of the current design and loading conditions will be performed. i R: visions to the design or analysis will be reviewed by the third party and will provide the basis for reinspection and rework. A similar inspection will bs performed for Unit 2 and appropriate action taken. Section 4.1.2 provides ! for examination of the bolts and blind threaded holes during the bolt replace-ment to aid in the root cause assessment. This will include review of dimensional tolerance of assembly parts. 03/10/86 IV-69 NUO797 SEC IV n-
As part of the CPRT effort on this issue the Plan in'Section 4.1.3 of ISAP V.b provides for the assessment of the potential generic applicability of the bolt ; thread engagement issue for two other populations: Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to determine that bolt engagement meets design requirements. If any cases of inadequate bolt engagement are identified, an assessment ' will be made to determine the ability of the component to ' carry its design load. If it is determined that the component cannot carry its design load increased sampling up to 100% reinspection will be utilized. I'f it is 4 determined that the component can still carry its design load 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. Bolted Connections - Blind hole bolted connections where th' read engagement is important will be identified by an engineering review of structural / 2 mechanical 2.4.2 drawings. The blind . holes identified will form a sec'ond
' sample population and any cases of inadequate bolt engagement in the in- ;
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spected sample will be evaluated as described above for Richmond inserts. u In Sections 4.1.4 and 4.1.5 of ISAP V.b, the CPRT commits to a third party review of the process by which critical attributes of bolted connections were specified and the definition of their associated inspection criteria and docu-cmentation requirements. This will include an w l ev'aluath, .n of the apparent lack of installation records for the SG upper lateral restraint. A third party overview of all aspects of the Action Plan will also be completed. This will include the inspection plans for the UT of installed bolts as defined in 4.1.3, design calculations required for the evaluation of shortened bolts, and visual inspection of bolts and threaded holes during bolt replacement. Finally, based ! upon the methods described in Sections 4.1.2 through 4.1.5 and their results, the root cause and generic implications will'be determined. The adequacy of the design of the upper lateral support itself will be addressed separately under DSAP VIII. i 03/10/86 1V-70 NUO797 SEC IV
. - . . , _ - - - - . - - - .-,--.--.v,., , . _ - - .,-,.w,
2.4.2.3 Staff Evaluation The staff, since it first identified this issue in its November 8,1984 letter to TUEC, has been actively following the activities concerning this subject. The staff feels that the CPRT Program Plan has the ability to address a'11 staf f concerns relating to the specific issue based on the following observations. The Plan addresses possibl.e generic implic~ations by reviewing other designs that have the potential for similar thread engagement deviations. The Plan provides for performing random inspections of Richmond inserts and other blind bolt installations. The staff, however, still has a concern that when it is determined that a component can still carry its design load for all observed cases of less than adequate engagement, the need for additional inspection.will be based on an evaluation of the trends in the inspection data. The staff must look at the basis for this evaluation case-by-case to determine if the trends do or do not require additional inspections.
- 7
# (0 The CPRT response to the three questions raised in the NRC Staff Evaluation e
dated September 30, 1985 have been responded to in a manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan. 2.4.2.4 Conclusions The staff concludes that if ISAP V.b is implemented as stated in the Plan the areas related to the original concern will be identified and resolved based on sound engineering practice, FSAR commitments and NRC guidelines.. However, the i staff has raised a concern that the use of trends of inspection data to deter-cine the need for additional inspections must be reviewed on a case-by case basis. 2.4.3 ~ Design Consideration for Piping Systems Between Seismic Category I 4 and Nonseismic Category I Buildings (V.c). 2.4.3.1 Introduction The TRT in reviewing the Comanche Peak Special Review Team Report determined that certain piping systems are routed from the Electrical Control Building (seismic Category I) to the Turbine Building (nonseismic Category I) without 03/10/86 IV-71 t NUO797 SEC IV !
.. 7
kny isolation. Since the FSAR postulates Turbine Building failure during a safe shutdown earthquake (SSE) the effect of Turbine Building failures on any nonisolated piping routed from any seismic Category I building to the Turbine Building must be considered. In addition, for nonseismic Category I piping connected to seismic Category I piping, the dynTmic effects of the nonseismic Category I piping must be considered
'in 'the seismic design of the seismic Category I piping and supports, unless it can be shown that the dynamic effects of the nonseismic Category I piping are isolated by anchors or restraints designed to carry the combined loadings from both piping systems.
2.4.3.2 CPRT Approach Since the Project Piping and Supports Program (PPSP) together with the Design c,- Adequacy Program (DAP) includes provisions for significant piping reanalysis . c*
. and associated support requalification, the CPRT will address the major conc' erns ,7 of this issue within the PPSP and DAP.
The scope of this specific action plan 2 will be limited to the following activities as outlined in Sections 4.1.1 through 4.1.3 of ISAP V.c: Identification of all Unit 1, 2 and common, piping which has a seismic / , nonseismic interface. This includes: r Category I piping entering a non-Category I Building. ' Piping with a class change from Category I to non-Category I. Piping runs with attached piping which have a class change. NNS piping runs which have a portion which is seismically analyzed to postulate breaks. A review and dicussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based. Recommendations to the PPSP and/or the DAP based on the results of the two items above. Any potential implications which should be considered dur.ing the PPSP and DAP implementation will be highlighted. , 03/10/86 IV-72 NUO797 SEC IV
2.4.3.3 Staff Evaluation The staff has reviewed the action plan for ISAP V.g, and~ is satisfied that-the CPRT Plan NW$$ the original concern and has the potential to identify l items similar to the original concern. In addition, the NRC staff has performed an audit at Stone & Webster Engineering Corporation (SWEC) offices. The purpose of this audit was to discuss ~with SWEC their scope and methodology for addressing this concern. The SWEC method has been determined by the staff to have the potential to identify and address this concern. e CPRT response to the four questions raised in the NRC Staff Evaluat dated September 30, 1985 have been responded to in a manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan.
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2.4.3.4 Conclusions
~
4 The staff concludes that if ISAP V.c is implemented as stated in the Plan all L areas related to the original concern will be identified and resolved in a manner s consistdnt with sound engineering practice, FSAR commitments and NRC guidelines.
. 2.4.4 Plug Welds (V.d).
2.4.4.1 Introduction The TRT investigated allegations that incorrectly located bolt holes in base-plates, pipe supports, and cable tray-supports were " plug welded" without authori-zation, with undocumented weld filler metal and without Quality Control inspect-ion. The TRT concluded that the repair of misdrilled holes by welding was not j prohibited by the' appropriate editions of the applicable Codes. The TRT review of Brown & Roct specifications established that misdrilled holes were regarded ! as base material defects and were required to be dispositioned by NCR action or engineering evaluation. ' The TRT concluded that the identification of undocumented " plug welds" and the difficulty in detecting them raised a generic concern as to the potential exist-ence of an unknown number of unauthorized " plug welds" of questionable quality. Potentially defective welds in highly stressed areas could have safety significance. 03/10/86 IV-73 NUO797 SEC IV
-,--,-,__-,,.--_-----_-_-.-_,----,-,-.-.y,-. y, _., y . - , -, , -- , , . , .-._ -~,
The TRT required that the Applicant modify.a plan of action already proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocumented " plug welds" on the ability of pipe-supports, cable tray supports, and baseplates to perform their intended function. 2.4.4.2 CPRT Approach Section 4.1 of ISAP V.d defines the following two CPRT Action Plan objectives: i
- 1. Confirmation of the presence or absence of undocumented " plug welds" in ASME pipe supports and baseplate, and the subsequent assessment of their l safety significance.
- 2. Assessment of the quality of cable tray supports containing undocumented plug welds.
. . cfy( r These objectives were to be accomplished by a combination of third party (Edgi- ' s neering Research Corp. [ERC]) sample inspections and third party overview of 8 e TUEC engineering evaluations. The sample inspections were to be used to charac-4 ' a terize the frequency of occurrence and location of plug welds to be evaluated; l l 3 and the engineering evaluations were to be used to assess the significance of incontro11ed plug welds identified during the inspections. l l Relative to the first of the above stated objectives, two random samples of l ASME Code pipe supports and baseplates were to be inspected. One of these j samples was to be drawn from the Unit 1 and Common Areas population, and the second from the Unit 2 population. The use of two samples was stated to be I based not on any expected difference between the two populations but on the i
- intent to increase the inspection coverage in anticipation of a low frequency l
' -l of occurrence of unauthorized or undocumented plug welds. Sampling was to be I consistent with Appendix 0 of the Program Plan with a minimum sample size of 60 and a detection number of zero. However, the confidence level achievable by this sampling inspection was stated to be less than that described in Appendix D. The Action Plan recognize,d that, based on the results of test inspections of painted mockup supports containing plug welds, the inspection technique would only detect about 85% of unauthorized or undocumented plug welds.
- 03/10/86 IV-74 NUO797 SEC IV -
, _ . - - . - - - - _ _ . _ _ _ . _ _ _ . . . . _ - . _ _ . _ .- _ - , . _ ~ _ _ . . _ . , _ - , - - _ _ . , , . , , . . _ . _ . . _ . _ _ - . - _ , . . . .
i ERC field inspectors to be utilized in the sampling inspections were to be selected based on their performance in detecting plug welds in the mockups. Unauthorized plug welds identified in ASME Code pipe supports and baseplates were to be identified in nonconformance reports (NCRs) and engineering evalu-ations performed to determine the effects of these welds on the structural integrity of the affected supports and baseplates. If no undocumented plug welds were found in the samples inspected, it would be concluded that there is reasonable assurance that the structural integrity of the pipe supports and baseplates had not been degraded by the presence of un-authorized plug welds. Further, if all unauthorized or undocumented welds found were determined by inspection or engineering evaluation not to affect the quality of the affected pipe supports or baseplates, it was proposed that the need for additional inspection be based on the observed trends in the sampling inspection. However, if one or more supports or baseplates were found to lack l e structural integrity due to unauthorized or undocumented plug welds, it was
- l
.~.4 proposed that the sample size be expanded, stratified sampling be utilized or a
- 100% inspection be performed. l 1
- n. Additionally, a third party review of t.he existing QC inspection and documen- l
,;tation procedures was to be conducted and changes recommended as necessary.
i With respect to the second of the above stated objectives, two random samples of cable tray supports were to be inspected. The populations for these samples were to be similar to those for the pipe support and baseplate samples. Addi-tionally, the steps involved in the Action Plan to achieve this second objective pertaining to cable tray supports were to parallel those previously described ' relating to pipe supports and baseplates. Third party reviews were to be conducted of: (1) Design Change Authorization (DCA) 5347; and (2) the history of the programmatic procedures for QC documentation relating to plug welds. These reviews were stated to be intended to: (1) ascertain if a sufficient basis for the DCA existed at the time of issuance; and (2) assess compliance of the docu-mentation with the QA program and FSAR licensing commitments, respectively. Furthermore, third party reviews of the results of the sample inspections were
- to be conducted to assess the root cause and possible generic implications of I
_ unauthorized and undocumented plug welds in cable tray supports.
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03/10/86 ^ IV-75 NUO797 SEC IV l i
2.4.4.3 Staff Evaluation Based on its review of the CPRT Action Plan relating to unauthorized and un- , documented plug welds in ASME pipe supports and baseplates and AISC cable tray l supports, the staff found that the plan as currently proposed was unacceptable ' for the following reasons: (1) The confidence level achievable.by the proposed. sampling plan was less l than that described in Appendix D of the Program Plan. The obtainable l confidence level was not quantified and not justified. "
)
- (2) As currently proposed, the Action Plan will provide as a minimum assessments l of the effects of unauthorized and undocumented plug welds identified in
- the samples. Additionally, in view of the lack of a fully effective in-spection method for plug welds, it appeared that even a 100% reinspection s program would still not provide reasonable assurance that the structural l "r integrity of ASME Code pipe supports and baseplates and AISC cable tray' l m supports have not been compromised by the presence of unauthorized and undocumented plug welds.
2 (3) Based on the previous two reasons, it further appears that the first alter-2 - native offered by the staff in its assessment of unauthorized and undocu-mented plug welds is not achievable. Consequently, it appears that only ' the second of the two staff alternatives is currently available to TUEC. ; This second alternative required that bounding analyses be performed to l assess the generic effects of uncontrolled plug welds on the ability of I pipe supports, cable tray supports and baseplates to serve their intended l function. (4) Details of the third party overview of TUEC engineering evaluations of uncontrolled plug welds identified during the sampling inspections were not provided in the Action Plan. (5) Criteria to determine if the structural integrity of ASME Code pipe supports
- and baseplates had been degraded by the presence of unauthorized plug welds were not provided in the Action Plan. ,
03/10/86 IV-76 -NUO797 SEC IV
.-~,,#. ..-..r_,.,..___-,.---~._,--..--,w- - - -
,__,r___, -. , y ------~._ ----,...m.,.,_,. . . . . .-. ,,m_... ,_~.-,,,___,,----_..---..r-e....--,-v---e-
l l (6) -Criteria to determine if: (a) the samples of ASME Code pipe supports and baseplates were to be expanded, (b) stratified sampling be utilized, or (c) a 100% reinspection be performed were not provided in the Action Plan. (7) In March of 1985 at the CPRT action plan presentation at CPSES, the TRT stated its position that volumetric examination of any unauthorized plug
, welds found should be made since the welder, who was trying to avoid QC cognizance, would be inclined to rush the job and may, therefore, have ,
- used poor welding techniques. The CPRT has not responded directly to this request. .
l l (8) The sample plan (Paragraph 4.1) and the definition of a reject were stated by the TRT as incompatible'as currently written. CPRT's response references paragraph of 3.4 ISAP V.a, Item 1. This reference was reviewed but does not appear to address the incompatibility noted. Further explanation is required.
& (9) In NRC Staff Evaluation of the Comanche Peak Response Team Program Plan -
4 Detailed Comments (Board Notification No. 85-087), identification was
- r. requested of the procedure referred to in paragraph 4.1.4. In TUGC0 letter ;
e CPRT-113 (previously referenced) responding to the above document, the , m procedure was identified as QI-QP-11.10-2. However, the procedure identity was not added to paragraph 4.1.4. 2.4.4 Conclusions Based on its evaluation of ISAP V.d the staff concluded that the CPRT Action Plan was unacceptable. The staff found that the proposed combination of third-party sampling inspections and third party overview of TUEC engineering evalu-ation of uncontrolled plug welds identified during the inspections would not provide reasonable assurance that the structural adequacy of CPSES pipe supports, baseplates and cable tray supports would not be compromised by uncontrolled plug welds since: (1) the proposed inspect!on technique was not fully effective and consequently, (2) the confidence level achievable by the Action Plan was less than the designed 95/5 level. 4 03/10/86 IV-77 NUO797 SEC IV
i It appears that the first alternative offered by the staff in its assessment of
- the significance of uncontrolled plug welds is not achievable and that only the second alternative is currently available. This second alternative required that bounding analyses be performed to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, baseplates and cable tray supports to serve their intended function.
I 2.4.5 Repositioning of the Main Steam Line (V.e). , l 2.4.5.1 Introduction i 1 , t ] The TRT investigated an allegation that the 32-inch MS line was forced into } position by the polar crane and 3-ton come-alongs and that " tension" induced in
- the line as a result of movement during the alleged incident was still present
! in the line. -
i il ) -: The TRT determined that repositioning of ,the Unit 1 loop 1 MS line had been - 1 1 performed due to settlement of temporary supports. The TRT learned that the
- partially installed line had sagged due to settlement of temporary supports
- a during flushing of the system and/or construction. The TRT also determined
- a. that the TUEC piping analysis performed 1 year after the alleged incident did not adequately address the full sequence of events involved in the incident.
~
ingly, the TRT on November 29, 1984, informed TUEC that action was require , to resolve this potentially safety-significant condition. I 2.4.5.2 CPRT Approach The CPRT approach to resolve the TRT concerns resulting from the TRT investigation j of the allegations regarding forced movement of the MS line and improper welding of temporary supports is described in Section 4.0 of ISAP V.e. A review of Sections 4.1 and 4.2 of the CPRT plan indicates that specific engineering evalua-- tions of the MS line incident and a generic study of possible damage to other piping will be implemented. p I 03/10/86 IV-78 -NUO797 SEC IV
=
1 The specific engineering evaluation includes: reviews of procedures for pipe erection and placement of temporary and permanent pipe supports; interviews of personnel involved in the MS line incident; evaluations of procedures and prac-4 tices; analytical evaluations of full parametric variations of the line move-ment inputs for the MS line incident; significance of stresses and support loads resulting from the analytical evaluations; reviews of existing UT examin-ations and hydrostatic test data' for the affected MS line; and a possible rein-spection program. - l The generic study for possible damage in other piping, including the' Unit 1, Loop-4, MS line includes: reviews of procedures and specifications for pipe erection and placement of temporary and permanent pipe supports; reviews of Nonconformance Reports (NCRs) and Piping Deviation Request Forms (PDRFs) for circumstances similar-to the MS line incident; interviews of pipe installation personnel to determine piping subjected to adjustments during fitup; review of j
- all other sources of. residual stresses in piping systems; evaluations of the
' significance of residual stresses due to fitup; possible additional pipe fit'up d -evaluations;.and possible modifications to Gibbs & Hill (G&H) specifications i e and/or related procedures to ensure that piping and associated equipment are v not adversely affected during flushing activities and/or by the use of temporary supports.
Section 4.3, " Responsibilities," of ISAP V.e indicates that all activities are to be performed by third party (including a verification of previous work done
- by RLCA) except for the modification (if required) of procedures and specifi-cations for the control of pipe erection, temporary supports and hydrostatic testing and flushing which was to be a Comanche Peak Project Engineering re- -
sponsibility.
.2.4.5.3 ,
Staff Evaluation The staff review of ISAP V.e determined that the details of the specific engineering evaluation and the generic study of possible damage to other than the Unit 1, Loop 1, MS piping was responsive to the actions required of TUEC by the TRT. These actions are given in SSER No. 10, P. N-110, Items 1 through 8.
.A comparison of items in the action plan and the actions required of TUEC by 03/10/86 IV-79 NUO797 SEC IV
o . i ! the TRT found that ISAP V.e was sufficient to unbrella the actions required to resolve the issue, based on an engineering evaluation by the staff. i However, the staff has concerns that: k *
- (1) The third party review of the RCLA work should not be limited to a veri- $
fication errty. Provisions for additional third party investigations should 'g i be provided, particularly since-RetA participation has ended. j { 424 r (2) Although the CPRT has indicated that its investigations performed as part l of ISAP V.e, Revision 3, have concluded that the sequence of events de-
- scribed in SSER No. 10 relating to MS line incident is not correct, the generic implications of settlements of supports and stresses due to hydro-static testing and flushing activities will still be required to be evaluated 4 by TUEC, since the sequence of events described by the TRT could have occur-red elsewhere. t'
/ e
- 2.4.5.4 Conclusions For the issue concerning the repositioning of the main steam line, the specific
- engineering evaluation and generic study described in ISAP V.e, Revision 3, of the CPRT Program Plan provides an acceptable basis for resolution of the issues and concerns resulting from the TRT investigations of allegations regarding l forced movement of the main steam line and improper welding of temporary supports.
However, final acceptability by the staff is contingent upon verification by the CPRT of proper implemer.tation of the details of the specific engineering evaluations of the miin steam line incident and the generic study of possible damage to other piping. i e f l 03/10/86 IV-80 NUO797 SEC IV
+ 2.4.6hAPVI)GapBetweenReactorPressureVesselReflectiveInsulation and the Biological Shield Wall p 2.4.6.1 Introduction
~
The Gap Between the Reactor Pressure Vessel Reflective Insulatien (RPVRI) and the Biological Shield Wall was listed as a miscellaneous issue in NUREG-0797, Supplement No. 8. The concern arose from the TRT's -investigations of allegations in the civil / structural area. 2.4.6.2 CPRT Approach This action plan defines the scope and methodology for evaluating the adequacy of the testing and analysis to confirm that adequate airflow is provided in the annulus between the RPVRI and the shield wall for both units. 1 m CPRT will review design changes to non-nuclear safety-related items to assure n that these changes do not adversely affect safety-related systems. This will be accomplished by reviewing the programs, procedures a'nd related criteria to e determine if the ways in which nonsafety-related items could have significant r influence on plant safety are adequately addressed. The implementation of these procedures and programs will also be reviewed. i W2." : j The Action Plan also addresses the issue of critical clearances by describing a * -
- program to identify potential areas and a review of housekeeping methods. Spaces where physical separation is essential to the function of items in close proxi-mity will be identified as subsequently inspected. In addition QC inspection
- priority fuel load will be made to verify that the critical spaces are free of debris. ,
l l 2.4.6.3 Staff Evaluation i The approach incudes a review of the analysis and test. data of annulus cooling flow. 6 l , 03/10/86 IV-81 NUO797 SEC IV L-_.___ _ _ _ _ - _ . , _ _ _. . - - _ - -_
The staff has reviewed the methodology to be used in addressing this specific i issue. The results of the review will be compared with the FSAR criteria for compliance with licensing commitments. ' 2.4.6.4 Conclusions 4 This action plan is responsive to the issues addressed in NUREG-0797, Supple- ; ment No. 8, and with proper implementation, including review of analysis, test l data, procedures and programs, should resolve NRC staff concerns. j
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2.4.7 HAP-VIholarCraneShimming 2.4.7.1 Introduction
- The TRT investigated the installation of the polar-crane rail-support system. .
~
w ,The result of the investigation was described in NUREG-0797, Supplement No. 8, i . , as a miscellaneous issue. The concern arose from the TRT's investigation of l allegations in the civil / structural area. i 2.4.7.2 .CPRT Approach CPRT will review the history of the crane-support system during construction and its performance during construction. An inspection of the polar-crane rail girder seat-to-bracket connection will be performed as well as a general inspection of the rail and rail-support system. i A measurement program for determining polar-crane movement will be developed
; and implemented. The existing maintenance and surveillance programs will also be reviewed.
l A historical review of the Crane Support System during construction and opera-tion will be conducted. The design requirements established by both Gibbs LARC and the Crane vendor will be reviewed with respect to performance and function. Also, an inspection of the RMC and its support system will be conducted to 03/10/86 IV-82 NUO797 SEC IV 4
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identify deviations that may be safety significant. Finally, all_ design changes and modifications will be reviewed by a third party. The results of the reviews and inspections will be used to identify any devia-tions of safety significance and corrective actions required.
'~
2.4.7.3 Staff Evaluation '~ The staff has reviewed the methodology to be used in addressing this specific issue. The approach includes a general inspection of the polar-crane rail and rail-support system and will perform an analysis which will' determine whether cxisting gaps are ai:ceptable or require corrective action in accordance with FSAR commitments. 2.4.7.4 Conclusion ' This action plan is responsive to the issues addressed in NUREG-0797, Supple' ment No. 8, and with proper implementation, including design review and accept-ability for FSAR commitments, should resolve NRC staff concerns. 2.5 Testing Program Issues Revision 3 ofJ.be. k 4 w Program Plan does not contain the ISAPs covering the testing r crea (the III se'ies)9The cover letter to Revision 3 states that these ISAPs will be supplied on or before March 1,1986. Therefore, this section cannot be reviewed and evaluated by the staff at this time and will be covered in a revision to this SER. L 2.6 Methodology for Resolving New External Source Issues > i At th'e present b e it is uncertain how the new issues will be presented to the Applicant, or how the Applicant proposes to address them. Currently, the CPRT is charged with responding to and resolving the external sturce issues. 03/10/86 IV-83 NUO797 SEC IV !
l IV 3/11/86 SECTION 2.5 I 2.5 Testing Program Issues l The Testing Program Issues are the identified concerns which resulted from the TRT Electrical Group's assessments of -technical issues and allegations in the areas of Electrical / Instrumentation and Test Pro-grams regarding construction and plant readiness testing practices at CP. These issues were presented to the Applicant by letter from the NRC dated September 18, 1984 and the detailed assessments were published in NUREG 0797 Safety Evaluation Report, Supplement 7, issued in January 1985 (Reference Appendix J, Pages J-116 through J-119). I' The CPRT formulated seven Issue Specific Action Plans (ISAP) ' I that address the testing program issues. The staff evaluations of each ISAP are contained in the=f.ollowing sections 2.5.1 through 2.5.7 Although there are seven ISAPs that cddress the testing program, the staff is concerned as to whether the ISAPs collectively provide l , sufficient breadth and depth coverage of the entire testing program to
. provide reasonable assurance that.all testing was conducted in accordance i with the FSAR comitments. During implementation of the program plan, the i CPRT must consider the results of all ISAPs, on an individual basis and j collectively, to assure the adequate breadth and depth that will enable the l l
j CPRT to provide a conclusion regarding the adequacy of the conduct of the CPSES testing program. ! I i
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IV 3/11/86 SECTION 2.5.1 2.5.1 Hot Functional Testing (III.a.1) Revision 3 of this ISAP has not been supplied by the CPRT. CPRT anticipates submittal of this ISAP by the end of March. e 6 l
IV 3/11/86
- SECTION 2.5.2 i l
2.5.2 Test Data Approval (III.a.2) 2.5.2.1 Introduction This ISAP addresses the NRC's concern that the TRT noted during a review of Hot Functional Test (HFT) completed test data that the Joint Test Group (JTG) did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling ' deferred preoperational HFT, - the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing that TUEC is committed to do this. j 2.5.2.2 CPRT Approach The Action Plan in it's current revision contains an excerpt from NUREG-0747 CPSES Safety Evaluation Report
. Supplement 7 Page J-77 which states in part:
. TUEC shall amend the FSAR to reflect their commitment to the TRT that the Station Operation Review Connittee (SORC) and not the JTG will perform these reviews. This requirement, not included j
in the September 18, 1984 letter to TUEC, is necessary because the current version of the FSAR states that the JTG is responsible for reviewing preoperational test data. In this ISAP the CPRT reported that FSAR Amendment 54 dated January 21, 1985 responded to the issue and that this
- action plan is completed. I 1
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IV 3/11/86 SECTION 2.5.2 2.5.2.3 Staff Evaluation The staff's evaluation of this ISAP found that the issue was identified correctly, and by the FSAR Amendment 54 TUGC0 has I responded to the NRC's concern. The current revision of this ISAP deleted the participants roles and responsibilities and the qualifications of personnel. The program plan requires that all revisions of the ISAP will be retained in the Action Plan Files. The staff wishes to clarify it's understanding that if any documentation for evaluation and resolution of the issue was prepared by the CPRT under previous revisions of the ISAP, that documentation will also be retained in the Action Plan Files. A specific example is: ISAP Revision 2 Section 4.2.2.2 RTL - Overview and
, Concur with Startup Group Scope. The retention of documentation is not limited to the specific example. During implementation the staff will confirm that applicable documentation h'as been retained by the CPRT.
l , 2.5.2.4 Conclusion i
. The staff's evaluation found that the issue was identified correctly, and Amendment 54 of the FSAR addressed the NRC's concern. Accordingly, the staff concludes that this ISAP is acceptable, however, acceptance of completion of the ISAP is not included in this '
conclusion. i l i
4 IV 3/11/86 SECTION 2.5.3 2.5.3 Deferred Test Technical Specifications (III.s.3) 2.5.3.1 Introduction This ISAP addresses an NRC concern that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel loak, certain limiting conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested. 2.5.3.2 CPRT Approach This ISAP was initially prepared on October 5, 1985 as a result of the NRC letter to TUEC dated September 18, 1985 which identified a number of NRC concerns related to the CPSES testing programs. NUREG-0797-CPSES Safety Evaluation Report Supplement 7, January 1985 Page J-18 reported that this (issue) is no longer applicable sinde the TRT has been ~ informed by TUEC that these tests will be conducted prior to fuel load. 2.5.3.3 Staff Evaluation The staff verified that the SSER reported that the issue is no longer applicable. i Since the item is no longer an issue the plan
.does not detail the CPRT's scope and methodology for evaluation and resolution of the issue.
IV 3/11/86 SECTIO?; 2.5.3 2.5.3.4 Conclusion The staff's evaluation found that the issue was correctly identified in the plan and verified that the issue is no longer applicable. Accordingly, the staff concludes that the ISAP is acceptable. I 9 O 4 1 l 1 i ]
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IV 3/11/86 SECTION 2.5.4 l l 2.5.4 Test Equipment Traceability (III.a.4) i 2.5.4.1 Introduction This ISAP addresses the NRC's concern that data for the thermal expansion tests (which have not yet been approved by the j JTG) did not' provide for traceability between the calibration of the measuring instruments and the monitored locations, as required by Startup Administrative Procedure-CP-SAP-7. The information was separately available in a personal log held by Engineering. 2.5.4.2 CPRT Approach 1 The CPRT's evaluation of the detail of this issue found it an isolated case. The Plan's methodology described the activity that corrected the questionable data package and provides in-structions to Startup Personnel regarding instrument traceability and test procedure deviations. Additionally, the CPRT will determine the adequacy . of training and startup procedures to assure that the administrative con-trols for documentation of traceability of test equipment are established
~
for the Initial Startup Test Program and also for operations and main-tenance activities. The Plan also addresses the processing of identified discrepancies in accordance with Appendix E, and Corrective Actions in
- accordance with Appendix H.
2.5.4.3 Staff Evaluation This evluation finds that 'the issue is identified correctly and that the CPRT's action will correct the defigient data package. The Plan's methodology is sufficiently broad in scope and depth to evaluate all aspects ' and inferences of this issue, identify potential programmatic problems and initiate actions to prevent recurrence. Accordingly, this Plan adequately addresses the issue and is ! responsive to the NRC's concern. I
IV 3/11/86 SECTION 2.5.4 The staff finds however that although the exist-ing procedures applicable to implementation of the Plan are identified in various paragraphs, the Plan does not comply with the Program Plan Attach-ment.3 ISAP format which implies that there is a section dedicated to the identification of existing procedures. The staff ack'nowledges that the previous revision of the ISAP. has reported that this ISAP is complete, accordingly, revising the Plan solely to include a discrete section to identify the procedures will serve'no purpose. 2.5.4.4 Conclusion The staff's evaluation found that the Plan adequately addresses the NRC's concern and implementation of the Plan will establish the administrative and procedural controls that will assure pre-vention of recurrence of deficiencies pertaining to those which the issue identified. The staff concludes that this ISAP is acceptable. Accept-ability of resolution of the issue is not included in this conclusion.
- - - + --r--
IV 3/11/86 SECTION 2.5.5 2.5.5 Containment Integrated Leak Rate Test (III.b) 2.5.5.1 Introduction This ISAP addresses an NRC concern with the manner of conducting the Containment Integrated Leak Rate Test (CILRT). The leakage rate was calcu'ated by a method different than that committed , in the FSAR and the FSAR was not amended to reflect the change. The TRT questioned the TUEC procedures for documenting and identifying FSAR deviations to the NRC, and that the test was conducted with three isolated penetrations which would not be the containment configuration during normal operations. 2.5.5.2 CPRT Approach Background information in the ISAP stated that the concerns related to the calculation method and penetration isolation were resolved and are documented by NRC-NRR in CPSES Safety Evaluation Report Supplement 12 Page 6-1 Item 6.2.5. These two concerns were resolved by FSAR Amendment 54.
- The CPRT will address the concern pertaining to TUEC's procedures for identifying and reporting FSAR deviations under .
ISAP III.a.1. 2.5.5.3 Staff Evaluation This evaluation found that the issue was identified correctly, and that the closure of the two concerns as reported in SSER 12 was stated accurately in the plan. The staff's i evaluation of ISAP III.a.1 Hot Functional Testing is presented in this report Part IV Section 2.5.3.
IV 3/11/86
- SECTION 2.5.5 l Note: Revised ISAP III.a.1 has not been evaluated by the staff as of 3/12/86.
The ISAP wcn't be submitted to the NRC until late March, 86. 2.5.5.2 Conclusion-The staff verified the accuracy of the plan's l
. reporting the NRC's closure of the concerns related to the calculation method and penetration isolation. Since the remaining concern pertaining to TUEC's reporting of FSAR deviations will be addressed in ISAP III.a.1, the staff concludes that this ISAP adequately addressed the issue and the plan is acceptable. The staff's acceptance of completion of the plan is not included in this conclusion.
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l IV 3/11/86 l SECTION 2.5.6 l l i 2.5.6 Prerequisite Testino (III.c) 2.5.6.1 Introduction i This ISAP addresses an NRC concern that craft personnel signed test records to verify initial conditions for tests in i violation of Start-up Administrative Procedure CP-SAP-21. The procedure j , required this function to be performed by startup test engineers (STE). l
- l. Startup Management issued a memorandum that improperly authorized craft j personnel to perform the verifications on a selected basis.
I 2.5.6.2 CPRT Approach J _ The CPRT will evaluate and resolve the concern i by implementing methodology that will rescind the memo and instruct
! STE's that it has been rescinded, and instruct the electrical test group i
{ (ETG) (craft) personnel regarding the STE responsibilities for validation of test prerequisites, and the conduct of tests under the I , supervision of the STE.
. The CPRT will review all startup interoffice memos to ensure that no directives were issued in conflict with procedure l l
CP-SAP-21. Additionally, all prerequisite test records will be reviewed
~
j to identify other cases that were. signed by craft and evaluate the I results of the memo an'd record reviews for any impact on subsequent
- testing activities. Identified discrepancies will be processed in accordance with Appendix E and corrective actions if required will be
- implemented according to Appendix H.
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i* IV 3/11/86 SECTION 2.5.6 I 2.5.6.3 Staff Evaluation This evaluation found that the issue was i identified correctly and the implementation of the plan is sufficiently broad in scope and. depth to adequately address the NRC's concern. The plan defined appropriate acceptance criteria to determine compliance of the prerequisite testing with the FSAR commitment. - 2.5.6.4 Conclusion The staff's evaluation found that the issue was identified correctly and that implementation of the plans
] methodology will resolve the concern, identify and implement any required corrective action and will determine compliance with the FSAR comitment. Accordingly, the staff concludes that the ISAP is acceptable.
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o IV 3/11/86 SECTION 2.5.7 i 2.5.7 Preoperational Testing (III.d) i 2.5.7.1 Introduction This ISAP addresses an NRC concern that the TRT found that systems test engineers were not on controlled distribution for , design changes, therefore, there is not reasonable assurance that i previously identified (by the NRC) problems in the document control system j . (DCC) had no adverse effect on testing activities. i 2.5.7.2 CPRT Approach j The CPRT will review the applicable procedures i~ to datermine the adequacy of the measures that ensure that startup test engineers (STE) and other test personnel are effectively provided with the current design documents for use in testing activities. In addition, a review of the Startup/DCC interface and interviews with STEs will enable a detennination of the adequacy of past and present practices in meeting the f requirements of testing programs. ;
- An evaluation program will be developed and I
performed which will focus on opportunities for a DCC error to begin a chain of events which resulted in a testing error. -This evaluation will be implemented by sampling of design drawing revisions and change documentation for homogeneous populations of prerequisite tests and preoperational tests. Identified discrepancies will be processed according to Appendix E and any required corrective action will be implemented in accordance with Appendix H._
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)* . IV 2/11/86 . SECTION 2.5.7 i 2.5.7.3 Staff Evaluation , The staff's evaluation found that the issue was identified correctly and that the plan's methodology is sufficiently broad in scope and depth to address the concern. The plan appropriately identifies the areas of activity, the procedures, the types of documents that must be reviewed, and the acceptance and decision criteria that are necessary to evaluate and resolve the issue. The staff's evaluation of the CPRT program sampling methodology is presented in this report, Section . 2.5.7.4 Conclusion The staff's evaluation found that the issue is identified correctly, and under this Plan the CPRT is reviewing the appropriate documentation that may identify deficiencies which will be evaluated to determine the effect of DCC problems on the testing program. Accordingly, the staff concludes that this ISAP is acceptable. e e A d i I i e
.-r, , - , . . . , - . __
Assuming that the issues will be evaluated and resolved under the present i structure and methodology of the CPRT Program Plan, the staff's evaluations, of the adequacy and acceptability of the CPRT's capabilities to resolve these j issues, are presented in a number of sections throughout this report. Part IV, Staff Evaluation of Construction Adequacy Plan, Section 2.0 and all Subsec- l tions 2.1.1 through 2.5.7 present the staff's evaluations of all of the ISAPs : pertaining to these issues. In addition, Section 3.0 and Subsections 3.1 through 3.4 present the staff's evaluation of the self-initiated ISAP under which certain of these issues may be resolved, or, the results of which, when combined with the results of other ISAPs, may enable resolution of the issue. Based on its evaluation of Revision 3 of the Program Plan the staff concludes that the Plan structure and methodology is adequate to address and resolve new issues. This evaluation also considers that new action plan (s) may need to be developed and implemented. The Program Plan in its current Revision 3 lists a number of sources that iden-i tified the existing issues, and may be the sources of new issues. The staff is concerned however: that new issues may emanate from sources other than those
- that are currently listed, and that the Program Plan does not address the manner 9 of the CPRT's receipt of issues from new sources nor how the issues will be validated and entered into the CPRT tracking system for evaluation and resolu-tion. Accordingly, the Program Plan must be amended to describe the CPRT's methodology that will ensure that concerns from new sources are identified and tracked and that the specific source is identified in the Plan. During imple-mentation, the staff will confirm the adequacy of the CPRT's action implemented to resolve this concern.
2.7 Evaluation of closed External Source Issues The staff's evaluation of the Program Plan, Revision 2, raised a concern that the Plan should be augmented to include information to meet the commitment of ad-dressing the potential root cause and generic implications associated with those issues which have been raised by an external source and subsequently closed by that source. The CPRT has responded to this concern by revision to Appendix B,
" Quality of Construction /QA/QC Program." The revised Plan states that concerns l 03/10/86 IV-84 NUO797 SEC IV i
which have been raised and subsequently closed by the external source that raises the issue will be considered for information when conducted root cause and generic implication analyses. . The Staff's evaluation of the Plan, Revision 3, finds that the CPRT has responded to the NRC concern and that the CAP adequately addresses the root cause and generic implications analyses of the closed external source issues. Accordingly, the staff concludes that the response is acceptable. However, the Staff is concerned that, although the action plan results report format (Program Plan, Attachment 5) infers that closure of the issue will be reported, the'er is no clear statement in that format that requires reporting that each issue addressed in the action plan is closed. Therefore, Attachment 5 should be revised to include a requirement to identify each closed issue. During implementation of the Program Plan, the Staff will confirm that this action has been satisfactorily implemented. i l l 03/10/86 IV-85 NUO797 SEC IV
3.0 SELF-INITIATED EVALUATION 3.1 Scoce
- 3.1.1 Introduction l
The construction adequacy program plan is described in ISAP VII.C. This action j plan describes the proposed CPRT reinspection and documentation review of com-pleted and QC accepted safety related construction work activities performed at Comanche Peak. The areas addressed by this program include those which have not been identified as areas of concern by external sources. The objective of this effort is to provide additional confidence that there are no unidentified safety significant concerns related to the quality of construction of the harda were at Companche Peak in areas not addressed by external source issues. The CPRT's Plan consists of a sampled reinspection cf QC accepted, safety related
; construction work, supplemented by a review of related documentation for non- l
- recreatable processes. The scope of the ' Plan includes Units 1, 2 and their common areas. Construction activities are organized into three disciplines as follows:
Civil / Structural i Electrical, and Mechanical. The NRC staff has reviewed the scope, methodology, and process of this ISAP. This has been accomplished through document reviews and onsite audits. All l aspects of this program have been examined from the categorization of installed safety-related hardware into population to the development of inspection lists j from work process attributes. In addition to the presentation made by CPRT personnel at public meetings, the staff and its consultants have performed onsite audits of the construction reinspection and documentation review pro-gram. These audits have enabled the staff to understand and evaluate the frame-work and process for implementation of this plan. 03/10/86 IV-86 - NUO797 SEC IV
3.1.2 CPRT Approach The methodology for CPRT construction adequacy review program consists of establishing reasonably homogeneous populations which are then sampled, evaluated, and the results of these evaluations with conclusions drawn documented in an action plan results report. The approach is to first categorize all installed safety-related hardware into populations made up of homogenous work processes for which statistical samples can be drawn for evaluation. Population and work process descriptions are prepared for each construction category. The popula-tion description describes the boundaries of the population while the work pro-cess describes the activities required to install or construct a certain category of hardware. Attributes associated with each work process are developed from the installation and inspection, procedures and/or specifications used for installation of the subject hardware. For each population, two random samples will be selected using established statistical techniques. The first sample
. provides information about the total population while the second sample, which
; is essentially an expansion of the first, provides information about that a portion of the total population which is required to safely shut down the plant. .
-In parallel with the sample selection, checklists and inspection procedures are e developed from the attributes used to characterize each work process. Both
- inspection and documentation review checklists are developed documsnts from the
- Quality Instructions. Verification packages are then assembled for each sample item to facilitate an inspection or documentation review. Any deviations identified as a result of a reinspection or a documentation review are docu-cented in a Deviation Report which will then be evaluated to determine the safety significance of the deviation. In addition, all deviations are collec-tively evaluated for adverse trends. An action plan results report documenting the overall results of the inspections for all populations is the vehicle for documenting the results and evaluations of this ISAP.
The sample size for each population which is part of the construction adequacy review program is targeted to meet a 95/5 confidence level. This,is interpreted to mean that the sample size is sufficiently large such that one has 95 percent confidence that 95 percent of the attributes in the work process do not have l cny safety significant deviations. The CPRT approach to sampling as described i in Appendix D of the Program Plan identifies the sample size required to achieve l 03/10/86 IV-87 NUO797 SEC IV
the targeted 95/5 assurance. For each work process of interest, a sample of size 60 is taken. If'no safety significant deviations are found in the sample, the work process is accepted. If a deviant is found, the sample is expanded. I Details of sample expansion (s) based on the number of deviations found are included in Appendix D of the Program Plan. The addition sample from the safe shutdown systems referred to as the " engineered sample," may include items from the first random selection. The augmented sample size for each work process, hence, may vary between 60 and 120. - The95/5confidencelevelwasselectedasacriterionto~allowaquaI1tification of the quality of the work process without having to reinspect each and every individual item in a work process. This confidence level is a targeted, rather i than an exact, confidence level. For most applications, the actual confidence may easily be higher than the targeted level. . 3.1.3 Staff Evaluation
~- The staff has reviewed the Construction Reinspection and Documentation Review Plan proposed by the CPRT and has conducted plant audits to evaluate tracea-bility of re-inspection documentation. ThereviewoftheProgramPlanand@
CPRT presentations at public meetings has provided the staff with an understand-ing of the process being used for this ' construction adequacy evaluation program. l The staff's review of the construction adequacy program focused on the sampling process proposed by the CPRT for use in evaluating the various work processes. Review of work processes enabled the staff to determine whether similar ! methodology was being applied for all disciplines. The staff has determined l that similar methodology A being applied regardless of discipline and work " process. Additionally, the staff reviewed some inspection and documentation checklists that were being generated for the re-inspection effort. The sampling procedure is based on assumptions that characterize a binomial population which include: (1) homogeneity of ite:as within a work process; (2) random selection of sample items from a work process; (3) ability to clas-sify an item as acceptable or as deviant with certainty; (4) the number of items l in the work process is essentially infinite.
~
03/10/86 IV-88 NUO797 SEC IV
= -
However, since the number of items in each work process is finitejthe sample sizef will generally be larger than required to meet the 95/5 confidence level, hence increasing that level of confidence above 95/5. There are additional factors that could further enhance this assuranc,e, even though no attempt is made to quantify this enhancement. Some of these factors are given below: (1) The assurance increases with sample size, provided no additional deviations are found. (2) The sampling assurance is increased when a deviant is identified and repaired. For small work processes this increase may be very significant. (3) When a deviation is identified, it serves to identify a potential error - path, which leads to further sampling. This activity increases the sample size, generally giving a still greater assurance. The emphasis of the staff audits of work processes was to ensure that they were 4 - homogeneous, that.an auditable trail existed, and to ensure that key attributes of the work processes were defined. The audits did not address implementation m of the reinspections and document reviews. The staff audited the majority of the populations and found the documentation to be complete and the development of the inspection checklists consistent for all populations. l 1 3.1.4 Conclusions 1 , Based on audits described above, the staff concludes that the program proposed by the CPRT in ISAP VII.c for evaluating the adequacy of construction at Comanche Peak is acceptable. The staff finds the CPRT approach to reinspection to be based on sound statistical principles. The staff believes that this program will provide a significant contribution to the overall assessment of the design and construction adequacy of the Comanche Peak steam electric station. Imple-mentation of this program will continue to be audited by the staff. The CPRT's documentation of findings, collective evaluations, and documentation of results will also be evaluated by the staff. 03/10/86- IV-89 NUO797 SEC IV i 1 --_. . _ ~ , . .. - .. - . . - _ . . . - -
3.2 Electrical Populations 3.2.1 Staff Evaluation The electrical discipline is divided into seven populations which are: (a) Instrument Equipment (b) Cable Trays - (c) Electrical Equipment (d) Conduit (e) Cables (f) Lighting (g) NIS Cable Terminations
. The staff's review of the program was augmented by onsite audit review of docu-f mentation the staff related to Population, Description which addresses the con-4 tent's of each population, the boundaries,'and any specific interfaces germane . p to the population. In addition to the Population Descriptions, flow charts de- &. scribing the work processes were reviewed. The flow charts contain attributes associated with each work process. The attributes provide the basis for check-s- lists which are being developed for re-inspection of electrical systems and components.
Individual population descriptions are discussed below: (a) Instrumentation Equipment. The instrumentation equipment population has two work processes associated with the equipment installation: (1) tubing / piping and-component installation, and (2) instrument installation. Each of the above work processes are supported by several attributes. Documents reviewed during the audit include: (1) Gibbs and Hill Procedures and Spe-cifications, (2) Work Process Descriptions and Flow Diagrams, and (3) pop-ulation items list for instrumentation equipment. (b) Cable Trays. This population has one work process in cable tray installation. ) 03/10/86 IV-90 NUO797 SEC IV
l The cable tray installation work process is supported by several attributes. One of these attributes, welding, has twelve contributing sub-attributes. During the audit the work process and attributes were evaluated to determine h'ow each was derived and approved. The staff also reviewed the following docu-ments: (1) cable tray population description, and (2) cable tray installation work process and flow diagram.
' (c) Electrical Eouioment. The electrical equipment population is made up of two work processes: (1) electrical equipment installation, and (2) field assembly and field modifications. Both work processes are supported by several attr.ibutes. The population includes electrical equipment of var-ious sizes and unique configurations such as electrical penetrations.
-. The above work processes, attributes, and documentation were reviewed during a the audits. The documentation included (1) electrical. equipment population ,
i description, and (2) electrical equipment work processes and flow charts. 4 (d) Conduit. This population is made up of three work processes: (1) selection, r (2) preparation, and (3) installation. .Each work process is supported by m several attributes. The work processes apply to both rigid and flex conduit. The above work processes, attributes, and documentation were reviewed.during the audit. (e) Cables. This population is made up of three work processes which include cables of all sizes. The work processes associated with the cable popula-tion are: (1) prepull, (2) pull, and (3) terminations. Each of the above work processes are supported by several attributes. Each work process and its associated attributes were evaluated to determine - i how each was derived and considered adequate. The staff also reviewed documen- l tation covering (1) cable population description, and (2) cable population work l processes and flow diagrams. 03/10/86 IV-91 NUO797 SEC IV
~ . . ,. ___
3.2.2 Conclusions Based on our review of the Self Initiated Construction Adequacy Program for Comanche Peak we have concluded that: (a,) This program, combined with the review of the external source issues, will adequately cover all plant electrical construction activities. (b) Individual electrical population boundaries are clearly defined. (c) The attributes within each work process are representative of the individual activities which cumulatively encompass a complete installation. (d) The program has provisions for expanding at the attribute level to meet new requirements. 3.3 Mechanical Populations *
~
e- The CPRT has divided the Mechanical Equipment Discipline into the following populations: HVAC Ducts / Plenums HVAC Equipment Installation 1 Large-Bore Piping Configuration c l Small-Bore Piping Configuration Pipe Welds / Material Piping System Bolted Joints / Material Mechanical Equipment Installation Field-Fabricated Tanks Instrumentation Tubing Welds / Material ide.MW, Within each population, work processes will be estebMehed. The CPRT program plan defines each work process as a homogeneous activity and therefore must assure that similar installation procedures, craft, organization and QC inspection procedures were used in the original construction. Random and engineered (safe-
' shutdown) samples will be selected for each population.
03/10/86 IV-92 NUO797 SEC IV
l= , i i l 3.3.1 Staff Evaluation The staff reviewed Revision 3 of the Program Plan and undertook audits of each of the Mechanical Populations. These audits included reviews of procedures, documentation, work processes, and attributes. For each of the mechanical areas, ERC has prepared a " Population Description" addressing the contents and boundary of each category of work. In addition to the Population Descriptions, a flowch p describing the work processes and associated attributes for each DenN population was provided. It is the attri-butes that provide the basis for the inspection checklists. The work process attributes were reviewed in order to verify that each work process would be adequately reviewed. The Specific Staff Evaluation for each of the Mechanical Populations is provided in the subsequent paragraphs. 2 3.3.1.1 Field-Fabricated Tanks ,
.e This population contains eight , field-fabricated tanks. All eight tanks will be w reinspected. The procedures were reviewed and contained information for all v attributes given in the Work-Process Description.
f.3.3.1.2 Mechanical Equipment Installation. The original governing construction document is Gibbs & Hill Mechanical Erec-tion Specification 2323-MS-101 and its implementation is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The original governing quality assurance procedure is Brown & Root QI-QAP-11.1-39 titled " Mechanical Equipment Insta11ation' Inspection". ' Qualitative results of the sampling conducted so far indicate that 20 to 25 percent of the sample drawn is from Unit 2. The remainder of the sample is
'from Unit I and common areas. The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equip-ment only, alignment. The attributes of each work process were reviewed in depth.
ERC personnel indicated that if a particular attribute of the work processes was not addressed when the sampling activity was completed, an assessment would 03/10/86 IV-93 NUO797 SEC IV
be made to determine whether the sample needed to be expanded to include that attribute. If a decision was made not to specifically address that attribute, the basis for this decision would be provided in the report addressing the con-struction adequacy evaluation of, in this instance, mechanical equipment. Work-process homogeneity is evaluated by assuring that the same organizations are involved in the activity and that the procedures have remained nominally con-stant. Since both sampling and evaluation of equipment is made at '- - the work process level, each sample will include sixty evaluations made for each work process. j The ERC reinspection procedures were reviewed and compared to the original construction specifications and procedures for homogeneity of work processes and choice of generic attributes. 3.3.1.3 Piping System Bolted Joints / Materials v Two work processes comprise the piping-system bolted-joint category. They are
- 4. installation preparation and final bolt fit-up. There are approximately 7000 41: bolted joints at the Comanche Peak Power Station. The work processes and their
- e attributes appear to adequately represent the bolting of piping joints. A
- flowchart and population description have been prepared to provide the basis t for the sampling of bolted joints. Several of the attributes given in this population will require both inspection and %g;gmentation review.
y W . @' 3.3.1.4 Large-Bore Piping Configuration /Small-Bore Piping Configuration The large- and small-bore piping configuration construction adequacy reviews are addressed using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping. installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. The Brown & Root isometric drawings provide the basis for sampling both large- and small-bore piping. Large-bore piping includes.that piping which is 2-1/2 inches and larger in diameter; small-bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing containing both large- and small-bore piping were to be drawn as part of a sample, it ! would be used in both the large- and the small-bore work process review. The 03/10/86 IV-94 NUO797 SEC IV
6 installation work process and its attributes are the same for both large- and small-bore piping. The piping considered in this review includes all ASME Code Class piping. ERC reported that all piping of large and small bore is installed to one procedure and by one craft, pipe fitters. Some attributes such as piping valves would obviously be included in any sample drawn for either large, or small-bore piping. There are other attributes such as expansion joints, screw joints, and strainers which, because there are very few in. the system, might not be included in any selected sample. ERC reported that, following the samp1-ing process, a review to assess the adequacy of the sample for adequate repre- l sentation of attributes would be made. However, a specific component, because it was not included in a sample, would not necesssarily be examined only for that reason. 3.3.1.5 HVAC Equipment Installation a The CPRT has divided the safety-related HVAC systems into two mechanical popu-
+ 1ations. One population is HVAC Equipment Installation (active components);
ch -and the other is HVAC Ducts and Plenums (inactive components). Both the active ar-(equipment) and inactive (ducts, plenums and appurtenances) components in these
.ar, populations have been installed by Bahnson Services Company with the exception e of the pad or structural-steel-mounted equipment. This equipment was installed
.s by Brown & Root and is not included in either of the populations. The installation of this equipment will be inspected as part of the Mechanical Equipment Installa-tion population.,
The HVAC Equipment Installation population includes: fans, filters, fan-coil units, air conditioners, dampers (fire, gravity and modulating) and airflow monitoring stations. There are two Work Processes associated with the population, which are: 1) equipment setting and 2) equipment connection. The setting Work Process includes those activities required to position / orient the equipment in the proper location. The connection Work Process includes those activities necessary to connect equipment flanges to supporting duct flanges. There are over 600 samples (items) in this population. The staff undertook audits of this population. The audits reviewed documenta-tion, work processes, attributes and homogeneity. 03/10/86 IV-95 NUO797 SEC IV
s 3.3.1.6 HVAC Ducts / Plenums The HVAC Ducts and Plenums populati_on includes fabricated sheet-metal duct sections, plenums, flexible connections, fittings (elbows, transitions, tees and wyes) and appurtenances. The appurtenances include: turning vanes, access doors and volume dampers. There are three Work Processes associated with the iopulation, whictrare: 1) 'abricating, f 2) installing and 3) welding. The
' number of samples (items) in this population is over 7,100, The random and engineered (safe-shutdown) sample set will be selecte' d for each-population such that each Work Process will be inspected to the 95/5 confidence level.
The staff undertook audits o'f this population. These audits reviewed documenta-tion, Work Processes, attributes and homogeneity. The Work Process attributes
- were reviewed in order.to verify that each would be adequately. inspected. This, w entailed reviewing the installation procedures referred to in the Descriptio~n w Memorandum for Reinspection and Quality Instruction documents for each population.
% A comparison of the distribution of component types in the sample sets (random 7 and engineered) to the distribution in the total population set was made.
This er revealed that all component types were represented in the sample sets, and the distribution closely resembled that of the total population set. 3.3.1.7 Pipe Welds / Material Based upon the fact that both large-bore and small-bore pipe welds were fabri-cated to the same procedure and by the same craft, it was decided by ERC to ) combine these populations. Thestaffreviewedthe(LBWMand58WM)poptfation = basis,- description memorandum,' population description, populations item list and work process definition. ERC indicated that only one work process was ( chosen, Welding. Apparently, regardless of the possible differences in the welds (configuration, material type, or process), each work process involves: (1) common erection specification requirements; (2) common installation pro-cedure requirements; (3) common craft labor performing the same' basic types of
-l operations, (4) common inspection procedure; and (5) a common inspection j organization. -
03/10/86 IV-96 .NUO797 SEC IV
a Since basically only two welding methods were used at CPSES, Gas Tungsten ARC Welding (GTAW) and Shielded Metal Arc Welding (SMAW), ERC has committed to two random samples of 60 welds for each welding method. The staff expressed a concern for the lack of separation of carbon- and stainless-steel welding. ERC pointed out that welder qualification is in compliance with B&R Specifica-tion WES-031, which qualifies a welder to both carbon- and stainless-steel weld-ing. The staff reviewed WES-031 and B&R Procedure CP-CPM-6.90, " Welding and Related Processes", and found very few areas where the procedures or specifica-tions differed with regard to carbon- and stainless-steel welding. Differences were associated with the two welding methods, GTAW and SMAW. ERC sa'd i that of the 120 samples already established approximately 50% were stainless-steel welds.
~
In addition, an engineered sample of 60 welds for each method was chosen to account for safe shutdown systems. In both cases, GTAW and SMAW, the original sample of 60 and the engineered sample overlapped. This necessitated increasing
,the original sample to achieve the engineered sample of 60 welds. In all, a e total number of approximately 180 sample /,will be inspected. ,
1 tes *
- Under the work process identified as " Welding", 24 attributes were identified, C 18 of which are common to both welding methods and to all welds. The remaining 4: six attributes will be inspected as the sample dictates. Additional samples W for these six attributes will be chosen as deemed necessary, or a justification T for not increasing the sample will be given at that time.
3.3.2 Conclusions y In reviewing Revision 2 of the Program Plan, several concerns were raised by the NRC staff in the August 9 and September 30, 1985 evaluation letters to
~
TUGCO. These concerns can be summarized as follows: Inspector Cerr.ification Program. p Basis and rationale for establishing homogeneous hardware populations. Attribute and criterion determination. . Sample expansion criteria. The staff's evaluation and conclusions on the CPRT response to the concern on the Inspector Certification Program is discussed in t : 1 .. - of l this SER. Pwm M2 L / l 03/10/86 , IV-97 NUO797 SEC IV _ 1
A The NRC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.cf, when evaluated collectively with the assemblage of procedures and checklists for the populations, adequately addresses the concerns raised on the basis / rationale for estabitshing homogene-ous hardware populations and the method used in determining attributes / criteria. Based on the results of the audits, the Staff has concluded the following re-lative to the Mechanical Equipment Populations:
- 1. A documented auditable trail of the background exists. '
2.
'The samples selected for the inspections are representative of the type '
and distribution of the components within each population.
- 3. The attributes and associated checklists adequately describe the work processes.,
dr- 4. The Verification (inspection) packages demonstrated that the CAP inspection
- -a will produce an auditable results trail.
73 The concern raised by the Staff on sample expansion criteria has not been re-
- solved to the satisfaction of the Staff. The details of the concerns are given in Section of this SER.
A specific concern on sample selection in the Pipe Welds / Material population is as follows. The original breakdown consists of a sample of 60 LB and 60 SB welds as part of ;
~
two separate populations. The two populations have been combined to account for the similarity in the welding attributes and the welding methods. The staff questions whether the original two 60 sample sets that are now combined into a sample of 120 will be judged as (1) a single sample of 120 or (2) two samples of 60. This discrepancy must be clarified statistically. k 03/10/86 IV-98 NUO797 SEC IV i
o 3.4 Civil / Structural Populations The safety-related Civil / Structural Discipline consists of the folicwing 15 populations: Concret.e Placement Structural Steel Liners Fuel Pool Liner Fill and Backfill Placement Grout-Cement Grout-Epoxy Large-Bore Pipe Supports - Rigid , 1 Large-Bore Pipe Supports - Nonrigid Small-Bore Pipe Supports 4 Pipe Whip Restraints . - i ik Instrument Pipe / Tube Supports
+> Category 1 Conduit Supports l
.HVAC Duct Supports Equipment Supports
'. 3.4.1 Staff Evaluation ,
l The staff evaluation, based on several audits at the CPSES and review of Revi- l sion 3 of the Program Plan, for specific populations is described below. 3.4.1.1. Category I, Conduit Supports (COSP) l Procedures for reinspection of this population was reviewed. Tolerances for the attributes of this population were obtained from the Gibbs and Hill Speci-fication 2323-ES-100, Revision 2, dated October 25, 1980. Paragraphs 2-36 and 4-19 of the G&H specification state that supports shall be installed to detail
- drawings 2323.5-910 and 2323-EI-1705. The ERC Reinspection Procedure contains this set of drawin'gs for the reinspection.
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4 03/10/86 IV-99 NUO797 SEC IV l
s 3.4.1.2 Concrete Placement Population The staff reviewed the Concrete Placement Population. Documents were reviewed to determine if homogeneity of the work processes and attributes had been achieved. The concrete placement population is presently subdivided into three work pro-cesses, each work process having various numbers of attributes. Some of the attributes are to be reviewed by means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and documentation review. Gibbs and Hill Specification 2323-55-9, dated January 16, 1979, was reviewed to assure that the reinspection requirements reflect the original construction tolerances and inspection requirements.
; 3.4.1.3 Structural Steel
's Procedures and documents were reviewed during audits at CPSES to see if homo-4 geneity of the work process and attributes had been achieved for the structural-
; steel population.
A The original Gibbs and Hill specifications and TUGC0 instructions were reviewed, and the tolerances and the inspection procedures were compared with those included in the Reinspection and Documentation Review procedures to assure that the rein-spection requirements reflect the original construction requirements. , 3.4.1.4 ' Liners-Two Populations The following two similar populations were reviewed:
- 1. Containment Liner and Tank Stainless-Steel Liner
- 2. Fuel Pool Liner -
These two populations were reviewed together. - The tolerance and inspection instructions in the reinspection procedures were l compared to the original G&H construction specifications to determine if the , 03/10/86 IV-100 NUO797 SEC IV i -
s ERC reinspection requirements adequately represent those of the original construction. , 3.4.1.5 Pipe Supports Pipe supports were separated into the following populations: Large-bore pipe supports - rigid. Large-bore pipe supports - nonrigid. Samil-bore pipe supports. The large-bore population of pipe supports was divided as noted in order to assure a proper sampling of rigid and nonrigid pipe supports. This is important since the majority of " standard catalog supports" are in the nonrigid category. The small-bore sampling was not divided because the number of nonrigid small- ,
- d. bore supports is very small and also because the type of support is not readily C obvious from the support number (as in the case for LB supports). ERC interids d to sample 60 supports from each of the three groups (LBSR, LBSN, and SBPS).
A 5The SBPS population was made up of four work processes: fabrication, installation, c welding and inspection.
*' The staff reviewed the various documents (description memorandum, population description and basis, population items list, work process justification, attri-bute description and basis. An auditable trail existed such that all work pro-cesses and accompanying attributes could be verified. The staff noted that, under pipe-support welding, two attributes were omitted (cleanliness and base-metal defects). ERC pointed out that i:leanliness was unattainable, both from an inspection standpoint (prewelding attribute) and from the. point of view of document review (cleanliness was not a hold point on the Multiple Weld Data Card (MWDC)). ERC also said tihat they did not include base-metal defects for l supports as an attribute, since it was difficult to see defects through the paint. The staff pointed out that requirements for identifying base-metal de-fects existed in ASME Subsection NF-4000 and B&R Procedure QI-QAP-11.1-28.
After some discussion, ERC committed to put base-metal defects into the attri-bute list and to treat all instances as part of the Construction Adequacy. 03/10/86 . IV-101 NUO797 SEC IV
1* . a 3.4.2 Conclusions The NRC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.c), when evaluated collectively with the assemblage of procedures and checklists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogene-aus hardware populations and the method used in determining attributes / criteria. I . Based on the results of the audits, the Staff has concluded the following, relative to the ".J....: . L' b ;( / 6 W , M- - uv4 + Populations:
- 1. A documented auditable trail of the background exists.
- 2. The samples selected for the inspections are representative of the type
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.l It was noted that the populations which contain Hilti bolts do not require that torque (as an attribute) be reinspected. Torque tests will be performed under ISAP VII.b.4. However, samples from ISAP VII.C will be contained in the - ISAP VII.b.4 population. This will be reviewed by the Staff during the audits of the implementation phase of the plan. The staff has a concern about the statistical mechanics of the overlapping of the regular sample (safety-related items) with the engineered sample (safe I
. i shutdown systems). As explained to the staff, the engineered sample is inde-pendent of the safety-related sample; however, some of the samples may be common J
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- 1) Pages IV-86 through IV-105 I have enclosed the entire section on Quality of Construction, 1 Self-initiated Evaluation for your review. Paragraph 3.2 I was prepared by Angelo Marinos and is in the format that he feels this section should be in, in order to minimize the implementation aspect. Please review paragraphs 3.3 and 3.4, written by Teledyne, to see if you agree they are 0.K. as is, or whether they need to be revised to reflect consistency -
with Paragraph 3.2. I have also included Paragraph 3.1, scope, which might help you in this review.
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i... .m :.. . 3.0 SELF-INITIATED EVALUATION 3.1 ' cope 3.1.1 Introduction The construction adequacy program plan is described in ISAP VII.C. This action plan describes the proposed. CPRT reinspection and documentation review of coa-plated and QC accepted safety related construction work activities perfomed at Comanche Peak. The areas addressed by this program include those which have not been identified as areas of concern by external sources. The objective of this effort is to provide additional confidence that there are no unidentified safety significant concerns related to the quality of construction of the hard-were at Companche Peak in areas not addressed by external source issues. The CPRT's Plan consists of a sampled reinspection of QC accepted, safety related construction work, supplemented by a review of related documentation for non-
+ recreatable processes. The scope of the Plan includes Units 1, 2 and their common areas. Construction
- activities are organized into three disciplines as follows:
fl.ec.tMasl Civil /Stru ral gg , y _
- Elect
- al, and g. pgg
- anical.
~. The NRC staff has reviewed the scope, methodology, and process of this ISAP. This has been accomplished through document reviews and onsite audits. All aspects of this program have been examined from the categorization of installed
. safety-relatedhardwareintopopulatioMtothedevelopmentofinspectionlists from work process attributes. In addition to the presentation made by CPRT personr:e1 at public meetings, the staff and its consultants have performed onsite audits of the construction reinspection and documentation review pro-gram. These audits have enabled the staff to understand and evaluate the frame-work and process for implementation of this plan.
03/10/86 IV-86 NUO797 SEC IV
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n .. . 3.1.2 CPRT Approach 6 The methodology for CPRT construction adequacy review program consists of establishing reasonably homogeneous populations which are then sampled, evaluated, and the results of these evaluations with conclusions drawn documented in an action plan results report. The apprcach is to first categorize all installed safety-related hardware into populations made up of homogenous work processes j for which statistical sampi,es can be drawn for evaluation. Population and work ) process descriptions are prepared for each construction category. The popula- ; tion description describes the boundaries of the population while the work pro- l cess describes the activities required to install or construct a certain category of hardware. Attributes associated with each work process are developed from l the installation and inspection, procedures and/or specifications used for installation of the subject hardware. For each population, two random samples will be selected using established statistical techniques. The first sample provides information about the total population while the second sample, which is essentially an expansion of the first, provides information about that portion of the total population which is required to safely shut down the plant. In parallel with the sample selection, checklists and inspection procedures are developed from the attributes used to characterize each work process. Both inspectionanddocumentationreviewchecklistsare(developed [ocuments)fromthe i Quality Instructions. Verification packages are then assembled for each sample ites to facilitate an inspection or documentation review. Any deviations identified as a result of a reinspection or a documentation review are docu-mented in a Deviation Report which will then be evaluated to determine the safety significance of the deviation. In addition, all deviations are collec-tively evaluated for adverse trends. An action plan results report documenting the overall results of the inspections.for all populations is the vehicle for documenting the results and evaluations of this ISAP. l The sample size for each population which is part of the construction adequacy review program is targeted to meet a 95/5 confidence level. This is interpreted to mean that the sample size la sufficiently large such that one has 95 percent confidence that 95 percent of the attributes in the work process do not have any safety significant deviations. The CPRT approach to sampling as described in Appendix D of the Program Plan identifies the sample size require 3 to acnieve 03/10/86 IV-87 NUO797 SEC IV l l
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the targeted 95/5 assurance. For each work process of interest, a sample of
. size 60 is taken. If no safety significant deviations.are found in the sample, the work process is accepted. If a deviant _is found, the sample is expanded.
Details of sample expansion (s) based on the number of deviations found are included in Appendix D of the Program Plan. The addition sample from the safe shutdown systems referred to as the " engineered sample," may include items from the first random selection. The augmented sample size for each work process, hence, may vary between 60 and 120.
- The 95/5 confidence level was selected as a criterion to allow a quantification of the quality of the work process without having to reinspect each and every individual item in a work process. This confidence level is a targeted, rather than an exact, confidence level. For most applications, the actual confidence may easily be higher than the targeted level. l 3.1.3 ~ Staff Evaluation *
. The staff has reviewed the Construction Reinspection and Documentation Review Plan proposed by the CPRT and has conducted pl. ant audits to evaluate tracea-
^
bility of re-inspection documentation. The review of the Program Plan and by CPRT presentations at public meetings has provided the staff with an understand-
"i ing of the process being used for this construction adequacy evaluation program.
w The staff's review of the construction adequacy program focused on the sampling process proposed by the CPRT for use in evaluating the various work processes. Review of work processes enabled the staff to determine whether similar . methodology was being applied for all disciplines. The staff has determined that similar methodology was being applied regardless of discipline and work process. Additionally, the staff reviewed some inspection and documentation checklists that were being generated for the re-inspection effort. i The sampling procedure is based on assumptions that characterize a binomial population which include: (1) homogeneity of items within a work process; (2) random selection of sample items from a work process; (3) ability to clas-sify an item as acceptable or as gwith certainty; (4) the number of items i in the work process is essentially infinite. 03/10/86 IV-88 NUO797 SEC IV l l l
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' I However, since the number of items in each work process is finite,the sample g sizef will generally be larger than required to meet the 95/5 confidence,1evel, ( hence increasing that level of confidence above 95/5. There are additional j factors that could further enhance this assurance, even though no attempt is i made to quantify this enhancement. Some of these factors are given below: (1) The assurance increases with sample size, provided no additional deviations are found. , (2) The sampling assurance is increased when a deviant is identified and repaired. For small work processes this increase may be v'ery significant. l (3) When a deviation is identified, it serves to identify a potential error path, which leads to further sampling. This activity increases the sample siz'e, generally giving a still greater assurance. The emphasis of the staff audits of work processes was to ensure that they were j homogeneous, that an auditable trail existed, and to ensure that key attributes , i of the work processes were defined. The audits did not address implementation of the reinspections and document reviews. The staff audited the majority of
- the populations and found the documentation to be c'osplete and the development of the inspection checklists consistent for all populations. ~
3.1.4 Conclusions d. h Based on audits described above, the staff concludes that the program proposed by the CPRT in ISAP VII.c for evaluating the adequacy of construction at Comanche Peak is acceptable. The staff finds the CPRT approach to reinspection to be
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based on sound statist 1 cal princip1_es. The sts't believes that this program will provide a significant contributioS to th ow *all assessment of the design M and construction adequacy of the Comancta hu o e an electric station. Imple-mentation of this program will continue to be audited by the staff. The CPRT's documentation of findings, collective evaluations, and documentation of results
\
will also be evaluated by the staff.
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3.2 Electrical Populations 3.2.1 Staff Evaluation The electrical discipline is divided into seven populations which are: (a) Instrument Equipment (b) Cable Trays , (c) Electrical Equipment (d) Conduit (e) Cables (f) Lighting (g) NIS Cable Terminations ! j The staff's review of the program was augmented by onsite audit review of docu- ; mentation the staff related to Population Description which addresses the con-tents of each population, the boundaries, and any specific interfaces germane
]
to the population. In addition to the Population Descriptions, flow charts de- ; scribing the work processes were reviewed. The flow charts contain attributes I associated with each work process. The attributes provide the basis for check-lists which are being developed for re-inspection of electrical systems and components. Individual population descriptions are discussed below: (a) Instrumentation Equipment. The instrumentation equipment population has two work processes associated with the equipment installation: (1) tubing / piping and component installation, and (2) instrument installation. Each I of the above work processes are supported by several attributes. Documents I reviewed during the audit include: (1) Gibbs and Hill Precedures and Spe-cifications, (2) Work Process Descriptions and Flow Diagrams, and (3) pop- I ulation items list for instrumentation equipment. ) l (b) Cable Trays. This population has one work process in cable tray installation. 03/10/86 IV-90 NUO797 SEC IV
The cable tray installation work process is supported by several attributes. One of these attributes, welding, has twelve contributing sub-attributes., During the audit ythe work process and attributes were evaluated to detemine how each was derived and approved. The staff also reviewed the following docu-ments: (1) cable tray population description, and (2) cable tray installation work process and flow diagram. (c) Electrical Eauipment.' The electrical equipment population is made up of two work processes: (1) electrical equipment installation, and (2) field assembly and field modifications- Both work processes are supported by several attributes. The population includes electrical equipment of var-ious sizes and unique configurations such as electrical penetrations. The above work processes, attributes, and documentation were reviewed during the audits. The documentation included (1) electrical equipment population description, and (2) electrical equipment work processes and flow charts. ) l (d) Conduit. This popula' tion is made up of three work processes: (1) selection, - (2) preparation, and (3) installation. Each work process is supported by several attributes. The work processes apply to both rigid and flex conduit. The above work processes, attributes, and documentation were reviewed during the audit. (e) Cables. This population is made up of three work processes which' include cables of all sizes. The work processes ass'ociated with the cable popula-tion are: (1) prepull, (2) pull, and (3) terminations. Each of the above work processes are supported by several attributes. , Each work process and its associated attributes were evaluated to determine how each was derived and considered adequate. The staff also reviewed documen-tation covering (1) cable population description, and (2) cable population work processes and flow diagrams. l 03/10/86 IV-91 NUO797 SEC IV 1
3.2.2 Conclusions a Based on our review of the Self Initiated Construction Adequacy Program for Comanche Peak we have concluded that: (a) This program, combined with the review of the external source issues, will adequately cover all plant electrical construction activities. (b) Individual electrical population boundaries are clearly def'r.ed. (c) The attributes within each work process are representative of the individual
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activities which cumulatively encompass a complete installation. (d) The program has provisions for expanding at the attribute level to meet new requirements. 3.3 Mechanical Populations 9 The CPRT has divided the Mechanical Equipment Discipline into the following Jusw. populations-1 ( HVAC Ducts /Plenues l HVAC Equipment Installation (M ., . ~
) Large-Bor[Tir!.. L...^:,....bnf D
Sr" L. 7 r .. Li.7: .. .^ :. 7 . ( Pipe Welds / Material Piping System Bolted Joints / Material ( 4)
)
g . f)MechanicalEquipmentInstallation (b) / y, Field-Fabricated Tanks - (
) Instrumentation Tubing Welds ) / Material (d,co) each population, work processes will be :_- ....J. rogram plan defines work process as a homogeneou y and therefore must assure that similar ins res, craft, organization and QC inspection i procedures were u e original co .lon. Random and engineered (safe-shut les will be selected for each population.
03/10/86 IV-92 NUO797 SEC IV
3.3.1 Staff Evaluation s. The ' staff reviewed Revision 3 of the Program Plan and undertook audits of each of the Mechanical Populations. These audits included reviews of procedures, documentation, work processes, and attributes. For each of the mechanical areas, 5"C hn ;;;;: :d a "Populati De criptio g addressing the contents and boundary of each category of wor In addit on to the Population Descriptions, a flowchart describing the work processes and associated attributes for each sample population was provided. It is the attri-butes that provide the basis for the inspection checklists. The work process attributes were reviewed in order to verify that each work process would be adequately reviewed. The O H f k St;ff C. & t**c.- fr- -er" ' th "=h;.c.icel "h=aat>*nt narar ranhs. P:;;h Zv
. . .k. owe. bitessutN Nt M I ivi. =[u. . . . .d '- + k-s.\ To & sh h n descHp-ions 3.QQ1 1 Field-Fabricated Tanks -
This population contains eight field-fabricated tanks. All eight tanks will be reinspected. The procedures were reviewed and contained infomation for all attributes given in the Work-Process Description. CAS
- 2. 2. L 2 Mechanical Eauinment incta11ation Y
The original governing construction document is Gibbs & Hill Mechanical Erec-tion Specification 2323-MS-101 and its implementation is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The original governing quality assurance procedure is Brown & Root QI-QAP-11.1-39 titled " Mechanical Equipment Installation Inspection". # [ualitative results of the sampling conducted so far indicate that 20 to f 25 percent of the sample drawn is from Unit 2. The remainder of the sample from Unit 1 and common areasf The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equip-ment only, alignment. The attributes of each work process : sere reviewed in depth. h GC ;:-----f 'di ^ that if a particular attribute of the work processes was not addressed when the sampling activity was completed, an assessment would A 03/10/86 IV-93 NUO797 SEC IV e
be made to detemine whether the sample needed to be expanded to include that attribute. If a decision was made not to specifically address that attri,bute, the basis' for this decision would be provided in the report addressing the con-struction adeq'uacy evaluation of, in this instance, mechanical equipment. Work-process homogeneity is evaluated by assuring that the same organizations are ) involved in the activity and that the procedures have remained nominally con- l stant. Since both sampling and evaluation of equipment is made at the work-process level, eac,h sample will include sixty evaluations made for l each work process. ) The $ reinspection procedures were reviewed and compared to the original construction specifications and procedures for homogeneity of work processes and choice of generic attributes. I E(c) M Piping-System Ralted-Joints / Materials work processes compris he piping-system bolted-joint category. W are installation preparation and final bolt fit-upjThere are approximately 7 C5olted joints at the Comanche Peak Power Station) The work processes and their attributes am adequately represent the bolting of piping joints. A flowchart and population description have been prepared to provide the basis
- for the sampling of bolted joints. Several of the attributes given in this population will require both inspection and documentation review.
- 2. _
Large-Borek:.., L.. :_ 1:__ .'Small-Bore Piping Configuration
/
The large- and small-bore piping configuration construction adequacy reviews are addressed using M Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. The Brown & Root isometric drawings provide the basis for sampling both large- and small-bore piping. Large-bore piping includes that piping which is 2-1/2 inches and larger in diameter; small-bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing containing both large- and small-bore piping were'to be drawn as part of a sample, it would be used in both the large- and the.small-bore work process review. The 03/10/86 IV-94 NUO797 SEC IV i
a ** . installation work process and its attributes are the same for both large- and , small-bore pip g The g considered in this review includes all ASME Code l Class piping. C . m .1:f that all ipin er large and small bordkis installed to one procedure and by one craft, pipe fitters. Some attributes such as piping valves would obviously be included in any sample drawn for either large- or small-bore piping. There are other attributes such as expansion joints, screw joints, and strainers which, because there re very few in the system, might T not be included in any selsteted sample. reported that, following the samp1-ing process, a review to assess the adequacy of the sample for adequate repre-sentation of attributes would be made. However, a specific component, because it was not included in a sample, would not necesssarily be examined only for that reason. M
*S5323r HVAC Equipment Installation The CPRT has divided the safety-related HVAC systems into two mechanical popu-lationsj t.. ,..,..ht'r 4 HVAC Equipsent Installation (active components),
and %e-e% ea 4e.HVAC Ducts and.Plenues (inactive components). Both the active
*. (equipment) and inactive (ducts, plenues and appurtenances) components in these populations have been installed by Bahnson Services Company with the exception of the pad or structural-steel-mounted equipment. This equipment was installed by Brown & Root and is not included in either of the populations. The installation of this equipment will be inspected as part of the Mechanical Equipment Installa- -- tion population. )
l The HVAC Equipment Installation pcpulation inclu'es:d fans, filters, fan-coil units, air conditioners, dampers (fire, gravity and modulating) and airflow monitoring stations. There'are two Work Processes associated with the population,
.ikh cr: 1) equipment setting and 2) equipment connection. The setting Work Process includes those activities required to position / orient the equipment in the proper location. The connection Work Process. includes those activities necessary to connect equipment flanges to supporting duct flanges. 4home-eae-r: !!! . ;' r ---; ' ^..... ,..,..:.".:....
.14 % f.Q $ tN TNaudit[of this populatioy The andtts reviewed documenta-tion, work processes, attributes and homogeneity. .
03/10/86 IV-95 NUO797 SEC IV
- i V .
(N 4seispe" HVAC Ducts / Plenums a The HVAC Ducts and Plenums population includes fabricated sheet-metal duct sections, plenums, flexible connections, fittings (elbows, transitions, tees ~ and wyes) and appurtenances. The appurtenances include: turning vanes, access doors and volume dampers. There are three Work Processes associated with the population l wh4etr sft: 1) fabricating, 2) installing and 3) weldin tv= er of samples p r. ems) in this population is over 7,100. random and engineered (safe-shutdown) sample set will be selected for jeacn populationsuchthateachWorkProcesswillbeinspectedtothe95/5 confidence p K. 4k oo a A -'r"
- .A. ...L ::f t- ' S'r ;:;9-*'r. Dese gudits, reviewed documenta-tion, Work Processes, attributes and homogeneity. The Work Process attributes were reviewed in order to verify that each would be adequately inspected. This entailed reviewing the installation procedures referred to in the Description Memorandum for Reinspection and Quality Instruction documents for each population.
A comparison of the distribution of component types in the sample sets (random and engineered) to the distribution in the total population set was made. This revealed that all component types were represented in the sample sets, and the distribution closely resembled that of the total population set. ~.
. . . ' . ' ' Pipe Welds /MaterM Based upon the fact that both large-bore and small-bore pipe welds were fabri-cated to the same procedure and by the same craft, it was decided by o combine these populations. The staff reviewed the (L8WM and 58WM) popuation basis, description memorandum, o13 ation description, populations item list and work process definition. Indicated that only one work process was__ j chosen, Welding f a- n % , $ gardless of the possible differences in the lds (configuration, material type, or process), each work process involves:
(1) conson erection specification requirements; (2) common installation pro-cedure requirements; (3) common craft labor performing the scoe basic types of operations, (4) common inspection procedure; and (5) a common inspection anhation. 03/10/86 IV-96 NUO797 SEC IV
_. ~ .- - _ .__ . - _ _ _ - _ _ _ _ - _ _ .
.'. . t Since basically only two welding methods were used at Cg, Gas Tungsten ARC Welding (GTAW) and Shielded Metal Arc Welding (SMAW), 15 has committed to two random samples of 60 welds for each welding method. The staff expressed a _o.
concern for the lack of separation of carbon- and stainless-steel welding C ritT ointed out that weiaer quaitrication is in compliance with nam specifica-tion WES-031, which qualifies a welder to both carbon- and stainless-steel weld-ing. The staff reviewed WES-031 and B&R Procedure CP-CPM-6.90, " Welding and Related Processes", and found very few areas where the procedures or specifica-tions differed with regard to carbon- and stainless-steel welM no. Differences eassociatedwiththetwoweldingmethods,GTAWandSMAW[hsaidthatof f the 120 samples alre~ady estan11sned approximately 50% were stainless-steel welds. l In addition, an engineered sample of 60 welds for each method was chosen to account for safe shutdown systems. In both cases, GTAW and SMAW, the original sample of 60 and the engineered sample overlapped. This necessitated increasing the original sample to achieve the engineered sample of 60 welds. In all, a ! total number of approximately 180 saariler will be inspected. , M ' l Under the work process identified as " Welding", 24 ta' tributes were identified, 18 of which are common to both welding methods and to all welds. The remaining six attributes will be inspected as the sample dictates. Additional samples forthesesixattributeswillbechosenasdeemednecessary,orajustification for not increasing the sample will be given at that time. l
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3.3.2 Conclusions In reviewing Revision 2 of the Program Plan, several concerns were raised by the NRC staff in the August 9 and September 30, 1985 evaluation letters to TUGCO. These concerns can be summarized as follows: Inspector Certification Program. Basis and rationale for establishing homogeneous hardware populations. Attribute and criterion determination. Sample expansion criteria. The staff's evaluation and conclusions on the CPRT response to the concern on the Inspector Certification Program is discussed in Section of this SER. . 03/10/86 IV-97 NUO797 SEC IV l
The NRC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.c), when evaluated collectively with the assemblage of procedures and checklists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogene-ous hardware populations and the method used in determining attributes / criteria. Based on the results of the audits, the Staff has concluded the following re-lative to the Mechanical Equipment Populations:
- 1. A documented auditable trail of the background exists.
- 2. ~The samples selected for the inspections are representative of the type and distribution of the components within each population.
- 3. The attributes and associated checklists adequately describe the work processes.
- 4. The Verification (inspe*ction) packages demonstrated that the CAP inspection will produce an auditable results trail.
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0> he concern raised by the Staff on sample expansion criteria has not been re- - j solved to the satisfaction of the Staff. The details of the concerns are given Section of this SER. l A specific concern on sample selection in the Pipe Welds / Material population is as follows. i The original breakdown consists of a sample of 60 LB and 60 SB welds as part of two separate populations. The two populations have been combined to account for the similarity in the welding attributes and the welding methods. The staff questions whether the original two 60 sample sets that are now combined into a sample of 120 will be judged as (1) a single sample of 120 or (2) two samples of 60. This discrepancy must be clarified statistically. 03/10/86 IV-98 NUO797 SEC IV
. .Y 3.4 Civil / Structural Populations The - ' ^ ""H Civil / Structural Discipline cm..l a d th: '?" d ;; 2.
populationst f )OI M g *, Concrete Placement Structural Steel Liners (M)(C) . E d N " '. : . .. . Fill and Backfill Placement NI Grout-Cement Ol p r s - Rigid k4
, ilarge-Bore Pipe Supports - Nonrigid h---P Small-Bore Pipe Supports 5 Pipe Whip Restraints (i ) ,
Instrument Pipe / Tube Supports [J I Category 1 Conduit Supports (4) HVAC Duct Supports d) Equipment Supports (A) 3.4.1 Staff Evaluation ~~ The staff evaluation, based on several audits at the CPSES and review of Revi-sion 3 of the Program Plan, for specific populations is described below.
'A) 1 .1.r Category I, Conduit Supports (C0SP)
Procedures for reinspection of this popula.lon aemreviewed.
# Tolerances for the attributes of this population were obtained from the Gibbs and Hill Speci-fication 2323-ES-100, Revision 2, dated October 25, 1980. Paragraphs 2-36 and 4-19 of the G&H specification state that suppo shall be installed to detail T
drawings 2323-5-910 and 2323-EI-1705. The nspection Procedure contains this set of drawin'gs for the reinspection. 03/10/86 IV-99 NUO797 SEC IV
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0.h ,.1.Z Concrete Placement Population The staff' reviewcd the Concrete Placement Population. Documents' were reviewed to determine if homogeneity of the work processes and attributes had been achieved. The concrete placement population is presently subdivided into three work pro-cesses, each weenmqm==ma== having various numbers of attributes. Some of the attributes are to be reviewed by means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and documentation review. Gibbs and Hill Specification 2323-S5-9, dated January 16, 1979, was reviewed to assure that the reinspection requirements reflect the original construction tolerances and inspection requirements. _' .1.1 Structural Steel Procedures and documents were reviewed during audits at CPSES to see if homo-geneity of the work process and attributes had been achieved for the structural-steel population.
? The origi,nal Gibbs and Hill specifications and TUGC0 instructions were reviewed,
< and the tolerances and the inspection procedures were compared with those included j
~ in the Reinspection and Documentation Review procedures to assure that the rein-spection requirements reflect the original construction requirements. W] 0.4.1.4 Liners-Two Populations , I The following two similar populations were reviewed . Q* 1. Containment Liner and Tank Stainless-Steel Liner
- 2. Fuel Pool Liner is c ; ...'...J %. O.; .T The tolerance and inspection instructions in the reinspection procedures were compared to the original G&H construction specifications to determine if the 03/10/86 IV-100 NUO797 SEC IV
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g reinspection requirements adequately represent those of the original construction. < , Pipe Supports Pipe supports were separated into the following populations: Large-bore pipe supports rigid. Large-bore pipe supports - nonrfgid. Samil-bore pipe supports. The large-bore hulatig ipe support was divided as noted in order to assure a proper sampling of rigid and nonrigid pipe supports. This is important since the majority of " standard catalog supports" are in the nonrigid category. j The small-bore sampling was not divided because the number of nonrigid small-bore supports is very small and also b'ecause the type of support is o readily obvious from the support number (as in the case for LB supports), h ntends to sample 60 supports from each of the three groups (LBSR, LBSN, and SBPS). l The S8PS population was made up of four work processes:- fabrication, installation, l welding and inspection. l The staff reviewed the various documents (description memorandum, population .
, description and basis, population items list, work process justification, attri- l bute description and basis. An auditable trail existed such that all work pro-cesses and accompanying attributes could be verified. The staff noted that, under pipe-support ding, two attributes.were omitted (cleanliness and base-metal defects). pointed out that cleanliness was unattainable, both from an inspection standpo' int (prewelding attribute) and from the point of view of document review anliness was not a hold point on the Multiple Weld Data Card (MWDC)).
cig$so a said that they did not include base-metal defects fo supports as an attribute, since it was difficult to see defects through the
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paint. The staff pointed out that requirements for identifying base-metal de-factsexistedinASMESubsecgionNF-4000andB&RProcedureQI-QAP-11.1-28. After some discussion, E committed to put' base-metal defects into the attri- ; bute list and to treat all instances as part of the Construction Adequacy. l l 03/10/86 IV-101 NUO797 SEC IV l L.__________._____ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ _ . .
46 " , 3.4.2 Conclusions The NRC Staff concludes that Revision 3 of the CPRT Program. Plan for the self-initiated construction program (ISAP VII.c), when evaluated collectively with the assemblage of procedures and checklists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogene-ous hardware populations and the method used in determining attributes / criteria. Based on the results of the audits, the Staff has concluded the following,
'- ' T- '
relative to theCN1 .th/U7ric[mc'pr47 Populations:
- 1. A documented auditable trail of the background exists.
- 2. The samples selected for the inspections are representative of the type and distribution of the components within each population.
- 3. The attributes and associated checklists adequately describe the work l processes.
- 4. The Verification (inspection) packages demonstrated that the CAP inspec-tion will produce an auditable trail. l concern raised by the staff on sample expansion criteria has not been re-
_b _ l
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solved to the satisfaction of the staff. The details of the concerns are given in Section of this SER. It was noted that the populations which contain Hilti bolts do not require that torque (as an attribute) be reinspected. Torque tests will be performed under 4 ISAP VII.b.4. However, samples from ISAP VII.6Tw111 be contained in the ISAP VII.b.4 population. This will be reviewed by the Staff during the audits of the implementation phase of the plan. The staff has a concern about the statistical mechanics of the overlapping of the regular sample (safety-related items) with the engineered sample (safe shutdown systems). As explained to the, staff, the engineered sample is inde-pendent of the safety-related sample; however, some of the samples may be cosmon 03/10/86 IV-102 NUO797 SEC IV
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to both groups. After the safety-related sample has reached 60 and has been identified as such, the engineered tople from the 60 items is identified.
- This sample is then expanded until it reaches 60. Both samples are now designed I(l '
to draw two independent conclusions. The question arises, if a safety -- {% $'
'k i significant deficiency is discovered in a sample ites that is common to both samples, are both samples expanded? This question has not been adequately ad- ,
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I NOTE T0: Dave
- FROM: Vic I think that the attached should cover all the Civil / Structural areas of Concern.
If you have any~ questions call me.
~
i Note: TNe CPRT has . stated in numerous places that Rev. 3 to the Program
- Plan address'es many concerns. I do not think that we can fully respond to
, these concerns without reviewing the Rev. 3 to the Program Plan.
I assume'that the people (i.e., Teledyne and others) who made the original comments will also be addressing the answers to.the concerns. Havea(;oodHolidcy? 4 o Vic 4 I ' 12/23/85 1 1 4
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CPRT NRC Nov. 22 Ref. Letter COMMENTS DSAP VIII Civil / Structural Discipline App. A Section B The CPRT response to this concern states that Rev. 3 Pg.3-59 Pg.123 of 180 of the Program Plan will incorporate the decision Item 6 criteria, identification of specific procedures, schedule, and definition of a reject, as specified in the general DSAP format presented in Attachment 4 of i the program plan. We will review Rev. 3 to determine if the response is appropriate. Pg.3-59 Item 7 The concern that functionality would be used as the acceptance criteria for Unit 1 CTCS has been modified. The CPRT states that the Unit I designs will meet the FSAR commitment. The above modifications will be included in Rev. 3 of the CPRT Program Plan. Pg.3-60 Item 8 The CPRT response will be covered in Rev. 3 to the Program Plan. Pg.3-60 Item 9 The CPRT response will be covered in Rev. 3 to the ! Program Plan. Pg.3-60 Item 10 The CPRT response to this concern is considered adequate. Pg.3-60 Item 11 The CPRT response ref. Section A 3.4 para. 1, 2, and 3. I do not see where this response answers the concern. We should have the person who raised this concern provide input to this response. '/3qr.,7a s /t em.hir.3) Pg.3-61 Item 12 These concerns will be addressed in Rev. 3 to the CPRT Program Plan. We must review Rev. 3 to determine if this response is adequate. DSAP VIII.a: Cable Tray / Conduit Supports - Identification of Critical. Parameters and Physical Modifications App. A Section B The concern was answered by the CPRT by reference to Pg.3-62 Pg.127 of 180 their response of Section A concern 3.4 para. 1, 2, Item 1 and 3. It is not apparent to me what was the underlying reason for this concern. Therefore, this cor.cern must be reviewed by either the person who raised this item or by someone who knows the actual intent of this concern.. Pg.3-62 Iten 2 The CPRT response to these concerns will be covered in Rev. 3 to the Program Plan. Pg.3-62 Item 3 The CPRT response to this concern will be covered in Rev. 3 to the Program Plan.
**\
CPRT NRC Nov. 22 Ref. Letter COMMENTS DSAP VIII.b: Cable / Tray Conduit Supports - Population Identation, Sample Selection and As-Built Pg.3-63 Pg.128 of 180 The CPRT response references Section A concern 3.4 Item 1-6 para. 1, 2, and 3. Para. 1, 2, and 3 states that the
/ response will be contained in Rev. 3 to the Program l
/ Plan.
DSAP VIII.c: Cable Tray / Conduit Supports - Determination of Governing Loads Pg.3-64 Pg.130 of 180 The response to this concern will be contained in Rev. Item 1 , 3 to the CPRT Prcgram Plan. DSAP VIII.d: Cable Tray / Conduit Supports - Testing , Pg.3-65 Pg.131 of 180 The CPRT response references Section A concern 3.4 Items 1-4 para. 1, 2, and 3. Para. 1, 2, and 3 states that the
/ response will be contained in Rev. 3 to the Program Plan.
DSAP VIII.f: Cable Tray / Conduit Supports - System Analysis Pg.3 of 66 Pg.133 of 180 The CPRT response references Section A concern 3.4 Item 1-4 , para. 1, 2, and 3. Para. 1, 2, and 3 states that the response will be contained in Rev. 3 to the Program Plan. DSAP VIII.g: Component Design Evaluation Pg.3-G7 Pg.134 of 180 The CPRT response references Section A concern 3.4 Item 1 and 2 - para.1, 2, and 3. Para. 1, 2, and 3 states that the response will be contained in Rev. 3 to the Program Plan.
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Document Name: KN0Y.1 Requestor's ID: i SIPSB01 Author's Name: John L. Knox Document Comments: , 12/24/85 Transmitted from IBM-PC Destination Name: o SIPSB01 Distribution Name: NRCADMP_EVA_0025 Addressee: Date Sent: t 12/24/85 . Time Sent: 10:41 Message: O
? ? t JOHN GLAD TO SEE YOU. HELLO I WILL NOW START TO TRANSMIT THE THREE FILES OK? OK I HOPE
-APPENDIX A Revision 1
1.0 INTRODUCTION
- I To'llowingtheestablijhmentoftheComanchePeakReviewTeam(CPRT)inresponse to the Atomic Safety /and Licensing ard (ASLB) order (3/12/84) to resolve open .
issues via discipi ne and issue r ated Technical view Teams (TRT's); the ! 1 applicant decide to conduct a c prehensive revi of the design the plant. ; ! This commitmen resulted in th overall Design Ad uacy Program ( P). When - the DAP was c ceived there re several audit d inspection t e activiti already in istence. It s decided to incor orate the findi s of these i ongoing ac vites (known External Source sues) within Included in t DAP, thesre as we activities,/is as the j any futur findings tha may be uncovered. system elated Indepe ent Assessment Pr ram (IAP) by Cygfia which was / revie ng the Compon t Cooling Water ( W) system, and the other review activities such as AT, RIV and SIT. Also included are any design issues The CPRT is responsible for addressing all bsteming from SSER's and the ASLB.ese issuegn order to carryout the task o TERA Corporation to provide overall monitoring of and/or resolution of all external source issues as well as conduct a self-initiated evaluation of the 1 design adequacy of the safety systems of the plant. In order to systematically '
# 7 approach the task. TERA developed a Design Adequacy Program Plan (DAPP). The NRC evaluation of the scope of this plan is the subject of this Appendix of the IY, pe /
Safety Evaluation Report (SER). Additional details pertaining to the f circumstances surrounding the establishment of the DAP are discussed in the v'),r>d-foregoing main body of the report, #y-t+ YHtS I$ WuttntDy DffcuCsen aJ 817/ cr u o s k l , en nw feK . ?<- n tr t w w it.t r er- 7 r+ sf rv o n p , e, m-W fft9-r ANO ' N k !? W W W! /7 WO yk& f f3 % e/ T *f f A/ Coy & W s77t /N o 1
, 4-4 4
2.0 CPRT PROCESS FOR EVALUATION: pd The DAP in order to systematically conduct the intended design evaluation has developed Discipline Specific Action Plans (DSAP's). There are four DSAP's whic(correspondtothefollowingdisciplines:
- 1) Electrical, Instrumentation and Control Systems and Components
- 2) Mechanical Systems and Components
- 3) Civil and Structural
- 4) Piping and Supports ,
Each DSAP contains two distinct sets of activities. One'es concerned with capturing all the existing and future External Source Issues and the other is the Self-Initiated Evaluation of the plant design. The stated goal of the CPRT is to provide reassurance of no undetected safety-significant design deficiencies. The External Source Issues are being identified by a 100 percent review of the External Source documentation which includes correspondence, trans$cripts and inspection reports. The Self-Initiated Evaluation program intends to selectively inspect all the activities involved in the design process for each discipline. Once an issue has been identified either by an External Source or a Self-Initiated inspection it is evaluated for; safety significance, root cause(s) and potential generic implications. A If an issue proves to have safety significance, it will be logge, into the DAP Tracking System (DAPTS) which will aid in the root cause and potential generic implication evaluations. Depending on the results of these evaluations, the process requires corrective action to finally resolve the deficiency, as well as preclude recurrence'. All of the procedures for these evaluation and corrective action steps are part of the individual DSAP. The review of the External Source Issue documents will be an ongoing activity and if the inspection activity from which an issue arises is designed to resolve the issue, the DAP through the DSAP will monitor the resolution and assure that closure is reached. If-the inspectifon betivity is only designed to identify issues the DAP will undertake resolutio1 and closure.
- _ ~ , _ . . _ , _ _ _ _ _ _
p e t t The fundamental concept incorporated into the Self-Initiated aspect of the DSAP is the division of the design process into individual Design Activities. The
; outputs of the design process such as calculations, equipment specifications and construction drawings will be cataloged by Design Activity for a selected Mp nc l
safety system. These will then be known as the occupants of a Design Activity. occu Pd"U e7 e+ The system selected for review is the Auxiliary Feedwater (AFW) system. The evaluation process also intends to inspect items outside of the AFW system if sh*C none of the occupants within a Design Activity for that particular system NN/ represent a adequate level of design complexity. # F N pr>vy The results of the implimentation of the Self-Initiated Evaluation program will M "' be extrapolated to the design of the plant's other safety systems. The basis for the ability to extrapolate lies in the selection of review iteps that f%, g ._ represent a significant level of design complexity and the homogenpity of the yce, y f Design Activity. Both of these important ingredients of the program plan are ~ , , discussed Section 5.1 of this report. The review process or implimentation of p w A n o t,. ' the Self-Initiated portion of the DSAP will be carried out through the use of we t , 7-technical checklists developed specifically for the Review Tasks. The Review g ,f,._ Tasks are relatable to the Design Activities. If ar issue is uncovered through rv the Self-Initiated inspections, it willbe evaluated in a manner identical to rn e. e r-that described above for the External Source Issues. me wevy LET ME PRINT APPENDIX 0 A Revision 0 eure g ,
- R+1cr>
N 3.0 STAFF REVIEW AND EVALUATION APROACH
~7_
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( The Design Adequacy Program (DAP) described in this report represents a major
- Y ,I r-effort in design verifJrication. Sa th: :;rfece tihe depth ;;d :;;cpe sf th ,evo progre E isam-the surfece similai 10 thei. vi an inaeywndent Desivu Vwisiicai.icn rt, oo Procram O n""). 'h; g;;L :f the pr:gr: ahich ; i.v e h tr pc hte the results-to W 'S Wertts4 safety systems. In e dwi te bc :bk te ineke th extrepeletier the ru nd p Ogr:r needs te establh5 5^ ;;r{.ityi for ;;ch Design Activity indiviuually. amar-gi;; ; gert of tha nennram it a e4aa4*irent dep -ter: 'r;, th; c ";rt TC W#
g nciat a with 2n invp. Also, th$ calect tn ef inspeci.ivu si.wm(s) Tivm the _occuoante e' : D;;ign Activity 5:: :n effs d un s e aoliity ui es pr;;r:r - (#8 v a / ras"Its te 50 caliepulai.ed. Other it m; important to the ::::::: ef the 7 tr i Y""*:P Ore. ' 'f "
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- 1) Technic:1 quelity vi Uie impiementing cneckiists, 2)_DAsign Act4vities Li at coiiectively repr esent th; entire design effort-of the pa r-t-icular-disc ipline , -
3)_Exoerienea and capablility Of-the persennci cendUciing the insp;;tf0ns. Du'e to the importanctif tb aforemention items, the staff' approach Therefore, to the t ' review of the program plan concentrate on t gm in particul review and evaluation pepgram scope ss d.rectly ea s structyred to add,re,a of fcun these items. An'other aohl of the aff's effort was toAain cortfidenca hat an ) g ir audihogum4Fitation tral @d for tha devabn=n#E of the prMscope. g g *e . . w t n. The staff's review and evaluation was accomplished by performing a series of programmatic and technical audits of the program scope. The :::f": mc x! pa-tfrip:ted directly i- th: s. edits elen; .;ith discip14ae ceatult:nten The
-::nsultant; : re #ra ; B:ttelle Cel"=h"s; Teledyne; nene65:w n g,L;gnal _ _ _
D haratcry, "ESTEC and independent. Cen5eltents in wouii uiwipline cetegory - we reprc unied at every ..dit, 35: : dits teek piece both in the :t:ff' om tee :nd the effic : ef TEon eneper:tiga ,,;theg; ;;d wit' eppi;sont y.gp :entatisc: prc:~t " ring th: ecurse-*f-the-audL*1 ogram documents such as worksheets, procedures, checklists, personnel resumes, correspondence and engineering evaluation reports were examined. One of the ginftial audits ,0f the DAP took place in the offices of the staff and fdcused gthe program scope as de " d by Revision 2 o the plan, y Applif: ant repregnterfives were not repre ted at this audit. The audit resu!ted in a Set- s of comments on the pro) ram scop &-{see NoonanAe'tters dated
~
8/9/ 5 and 97: 0/85 Thesexomments resultedMnggineering Evaluation which will t asi, to a vis' ion 3 of the progr# plan. The Eng'ineering Eva tionsrvisjon'bsicallyexpande.dthescopA(numbefofDesignActivities l for ach dis pline) in b e Self-Ipitiated portionw f the plan. A subsequent i audit in ,he t ffices of T C oration was conducted to rel the content f ' the !Engiffeer ng Evaluation the staff's comments. The a lso addre ed l the,Aechnica adequac pefsonnel. /Thed selec d checklists and the e' s and resul ence f this audit r presented in of t program e J,# /l following d s ine specific Secti of this r t. ThgJtaf has concludad- . ( thad the e anded set of(Design'Actiwi ies substant 11v reprtisents the breath j g M' prf of._ the design effort required for the\forAtiach diteinline.' Also, the 14mitad l numher of che klists revi d demons ed adequate tec 'ical content. e . c ^f 91o~ - staff does hav a concern ab tt ' lac of A/E e 'riene in the pr am \ f pers onnel. @ s3 e' issue rela to perso nel rience t t also oncerns the %# staff are instanc of indiprd' is with ex veyxperiencein narrow g-technical ,fisld be g assi'gned pection a ivitieb outside at particular g a aretoJAxpertise. f p o *- w if w G e l l
f 4' t t The staff perfomed eder audits relating to the homogenuity of the Design L se [/)auditeActivities, selection 1100 ;;tilized the scryicesofcf inspection item t:ff c66ulianis alvey withand Staff program docu persemel ,
'Torcyenin/The_staf_f_ concludes ty there is insufficient evidence that based on thefor (documentation) given criteria an initial levelfor gth r
of homogenuity. The documentation is lacking for the criteria of methodningy f gj Gef- a The staff does feel that there is adequate framework within the program to M f I assure that meaningful review items will be selected for inspection. The ne d ' o aforementioned conclusions and details thereof are discussed in Sections 5.1
,through 5.5 of this report.
fg e*8/ gv Revision 0 4 V APPENDIX A 5.0 SELF-INITIATED EVALUATION
- 5.1 Scope 5.1.1
Introduction:
T- A I A The Design Adequacy Program Plan (DAPP) was developed to capture and resolve all design related External Source Issues and perform a Self-Initiated Evaluation of the design of the plant's safety systems. The External Source Issue portion of the program is discussed in detatil in Section 4.0 of this report. This Section of the report presents +ha 4taf+4 ---tr;t;ndS; c' the Self-Initiated Evaluation effort. The framework is built upon the following:
- 1) Divisionof the A/E design process into disciplines,
- 2) List of Design Ac 3)Establishhomogen{ivitiesforeachdiscipline, uity for each Design Activity,
- 4) Catalog design output and support documents (e.g. drawings, specifications calculations, etc.) by Design Activity, (these will be known as " occupants of a DesignActivity"),
- 5) Select a safety system for review that represents the design responsibility of the A/E, evw
- 6) Select for inspection a occupant for each Design Activity that is representative of the design effort O
e
e c-t
- 7) Perform a technical inspection to uncover the unkown issues,
- 8) Evaluate the discovered findings for safety significance, root cause and generic implications,
- 9) Assure corrective action and non-reccurance.
The details of these activities are presented in the remainder of Section 5.1 and in the individual discipline Section discussions (5.2 through 5.5). 5.1.2 CPRT Approach b The CPRT program plan approach is to divide the design effort into the following four disciplines:
- 1) Electrical, Instrumentation and Control Systems and Components,
- 2) Mechanical Systems and Components,
- 3) Civil and Structural,
- 4) Piping and Supports.
The design effort of each discipline has been further divided into Design Activities based on the systems and components for which the discipline has prime responsibility. The Design Activities are also identified as to the responsible design organization. There are three classifications for organizations which are Gibbs and Hill (G and H), Texas Utilities Nuclear Engineering (TNE) and Others. The Other classification is intended to provide for the inspection of all design organizations that may have had responsibility for a safety system or major portion thereof. Certain systems or components of the safety systems have undergone third party review during the course of the project. The program intends to review the results of these third party reviews to determine applicability to the listed Design Activities. If a third party review covers one or more Design Activity, it will be classified as a Given'and further inspection will not be required. S e
e c The remaining Design Activities will be inspected via the utilization of technical checklists. The checklists are developed to perform a particular Review Task, e.g. review a certain type calculation or equipment specification. In several instances it is necessary to perform more than one Review Task (checklist) in order to inspect a Design Activity. The relationship of Review Tasks to Design Activities is defined on each discipline matrix. The basic approach of the Self-Initiated Evaluation program is to review a safety system in depth (termed-vertical slice) and extrapolate the results to the other safety systems (termed-extrapolate horizontally). For example, if a particular calculation is found to be accurate from the vertical slice review then it can be inferred that the same type calculations are accurate for the other systems. In order to make this extrapolation the Design Acivity must exhibit the property of homogenuity. Also, the Design Activities for the selected system must be representative of the effort required for the other systems. The CPRT has selected the Auxiliary Feedwater (AFW) and the Class IE Power systems for the vertical slice review. As stated above, the ability to extrapolate review results horizontally depends on the homogenuity of the Design Activity. Homogenuity is based on five elements which must be similar or constant over the design period of the project. The elements are: 1 Criteria, 2 Design consideration or methodology, 3 Design process control,
- 4) Organization,
- 5) Design interfaces.
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The three elements of design; process control, organization and interfaces are considered to be satisfied on a program basis. G and H was responsible for the design of the AFW system throughout the project design lifetime. The project structure (interfaces) did not change in a manner that would affect the results of the design effort. Also, the design effort was governed by a set of corporate procedures that have project requirements for all the involved disciplines. The element of methodology is exhibited in either one of two manners. One, the narrowness nf +he nes3n Ar+4vity such that nnly nna design j g ru - methodoloav nr annenach ic nnecihle fnr nrnducing the result. The other is ! s ,4 that there is a prescribed approach to performina the decign (e.g. engineering ~ standard). The element of criteria is concerned with the constancy of the design basis throughout the design effort. Criteria is found in NSSS process requirements, FSAR comitments, vendor documents and regulatory guides. The program plan provides for an initial level or sense of homogenuity for each Design Activity which will be verified as a first step to implimentation or , inspection. In the event that homogenuity cannot be verified the Design l Activity will be split into new Design Activities until homogenuity can be verifed or 100 percent inspection of the occupants of that particular Design Activity will be conducted. The homogenuity verification process is based on the scanning of Design Activity occupants over the time period of the design effort. Five samples (or occupants) produced at approximately equal time intervals will be selected. Sc:aning is not :n "-depth 4 asp =cth but is ;;fficient te det -'n tS:t t b
- rple: are caibieni ;n ee3 ef i6 fiv; el;;;nti. The results of thir effort will be documented for each Design Activity in an engineering evaluation supported by a checklist. The verification of homogenuity will be completed prior to commencing the in-depth technical inspection of the Design Activity.
Besides homogenuity the ability to extrapolate horizontally the results of the vertical slice inspection further depends on the selection of inspection (review) items. As stated previously the source of inspection items will be the AFW and/or Class IE Power system. If neither of the systems possess an ,r.# occupant of design enmnlexity that is representative of the other cafety # r 8'j systems, the rftview ita= will he selected frnm = the ruetam,__The situation may arise Miere these two systems do not have a particular Design Activity. In [nt.
- this instance the review item will also be selected from another system. The selection of the review items will be documented in engineering evaluation reports.
The inspection of the selected review items will be conducted using Review Task checklists. The checklists are developed for a particular type of design document (e.g. calculation,equipmentspecification,etc.). In order to fully review some of the Design Activities, it will be necessary to utilize more than one checklist. l l l e
,, e e
t The findings of the inspections will be evaluated for safety significance, root cause and generic implications. The process is identical to that followed for the External Source Issues. 5.1.3 Staff Evaluation W ri A The staff undertook a series of audits aimed at approving the scope of the Self-Initiated Evaluation program. The audits covered the following elements of the program plan. 1)DevelopmentandcompletenessofDesignActivities.
- 2) Homogenuity of Design Activities, 3
2{Processforselectingreviewitems, o regr:r perrennal exoerianco and r=n w 'ity. g The staff considers these elements key to the approval of the program scope. The staff was also concerned with the documentation supporting the framework and bases of the program. The initial audit reviewed the entire scope as presented in Revision 2 of the program plan. Comments from this review were submitted to the applicant. A followup audit was concerned with the applicant's an intended expansion of the scope. At this audit the staff was able to concentrate on the completeness of the Design Activity listing. Several of the discipline checklists were also reviewed,a.longwith norennnel avnariance M ::pdi'ity re:=::. The' staff considers documentation essential to the approval of the program scope. Because of this a subsequent audit was performed to specifically review the documentation for Design Activity development and homogenuity. The details of these audits are presented in the discipline Sections (5.2, 5.3, 5.4, and 5.5) of this report. 5.1.4 Conclusions O e e e
e .. The staff has concluded that the general framework of the program is adequate for the intended goal of providing assurance that there are no unknown safety significant deficiencies in the plant's design. Tile _ staff found that the documentation for homogenuity is lacking for the element of methodology. Thisf') f g-,j leaves the program with the need to establish homogenuity rather than verify ~ prf ev5 tFat the ennr11 tion exist t Theref ore. the built-in verification process will p p.W# need tolerform 100 percent scanning of the Desian Activities occuoants for the d su 't element of methodoloqy. The staff found sufficient documentation for the other #_ 'r p . four elements thus they conclude it is only necessary to verify them. For these elements the process of sample scanning (five items spaced equally in time) will be adequate. e The staff found the Design Activity listing to sufficiently_repr25ent_the_ desian eTfort for eacn di_scipline to be able to approve this asAect of the 'g total (l program scope. Tha nee'er by i>hich the nstinn a rti;itic, we , m develeped 4s be::d n the esperiert: Of there 4 ye'ved r:ther th:r : der =:rted :ppr;;;F. 9,ft.v- r T5 refere, the sten cannot be tntal'y ::rt:in th:t :11 the Design L.t-;vities heve tecn .JentiNed :nd re: rv:: fiimi ,juuvement ;n this matter.
~
The staff finds acceptable (in concept only) the process by which the review p r.M items will be selected and if carried out in a well-documented manner should result in a meaningful set of review items. Th staff's r view of program per , el experience resumes esulted i the con usion t at here is a lack fA hands-ondesignexpe ence. Thi conce n is e< pres d because the ultima (success of the' pro am mi ht w 1 be advers y affected. This coulff be avoide0xif steps are'taken o St engthe personne e perience thisArea prior to pTqgram implimentati j IS THAT ALL JOHN I HAVE FINISHED HOW 00 THEY LOOK? l JUST A MIN WHILE I PRINT WHEN YOU ARE DONE LET ME KNOW OK._1 l l l a e l
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^ ^y APPEC " '. J '
SECTION 4.0 4.0 EXTERNAL SOURCE ISSUES 4.1 Introduction p *{ External Source Issues are defined in the Program Plan as being those issues identified by the following: NRC Staff (TRT, CAT, SIT, SRT, Region Inspection Reports and SSER's), ASLB Proceedings, CYGNA IAP, Intervenors and Applicant. The External Source Issues are being addressed in ISAP's and DSAP's. The evaluation of all specific External Source Issues is one of the main objectives of the Program Plan. It is the intent of the Program Plan to identify any safety-significant* deficiencies, to determine root cause and evaluate potential generic implication, and to determine appropriate corrective actions. The goal of the plan is to provide " reasonable assurance" that there are no undetected or uncorrected safety-significant deficiencies associated with the External Source Issues.
/ The Program Plan has an adequate mechanism in place to assure that ESI's ~are identified, tracked, evaluated and closed out by the 6
CPRT. This mechanism has a six-part scope to deal ith ESI's: Identification of Issues Definition of Issues' Development of Action Plan Implementation of Action Plan Corrective Action Results Report The Program Plan requires the review of all External Source documentation in order that all External Source Issues are identified. The Program Plan notes that the review " warrants a degree of selectivity l in determining which documents should undergo detailed reviews..." due to the volume of External Source documentation (response to NRC x' j Evaluation dated August 9,1985). (The staff feels that this degre " 8-
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' APPENDIX A SECTION 4.0 '
- 9' (selectivity in determining the detailed review requires auditing by the )
(staffD. The results of implementation of this CPRT . Action Plan will be I documented in future results reports. New issues identified during the j implementation phase of the Plan will be pursued, and the results of the staff evaluation will be contained in future reports. WC n n~t m 1I.l C f (2 T NPf W of m y
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- .s ::c a s t e d with the hechanical D2scip12ne. The issues are: O .. I .
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k All of thr u c o .c n ns were the result of inspections conducted es pert of the i suai t of tnc Cy. nr Incependent Assessment Pr og r a cr. (IAP). The fire coor- issue j is c or. : e- r n t c. w i t .' inc installation of a non-qualified door. It has been 3 dec20ec tc h. . e in: E. 2seue addressed as part of the OA/DC Construction Adequacy T Flan. The r ca s i ni r.g four issues will be addressed by the Methanical D5AF.
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c e Issues to be addressed as part of the,Mechanscel DEAF are concernad w. . n enc following issues:
) C~L M..n : s. un. Temper a tur e - system components must be re-verified for proper qualificat3cr henever new operat2ng conditions are identifled.
C) Cles: E P 2 ;; i n g - Class 5 designated piping must be designed to remain functional du.Ing and after the SEE. s'
- 3) Singl e Fail ur e - the failure of a single temperature controlled isolation valve in tnn Re s. c t o r- Cool ant Pump Thermal Barrier to close subsequent to a ruptur e 2n the ther mal barrier would result in coolant being released outside centainment.
/ 4) CCW Surgc Ten 6 Isolation on High Radiation Signal - removal of high I roo2ation for surge tant isolation could result in a release that e::ceeds f10CFh10012nats. '
A The CPFti has evaluated these aforementioned External Source Issues and determined that CCW Maximum Temperature, Class 5 Piping and Single Failure ha.c potential generic implications. The generic implications aie such that each can evaluated as part of the Self-Initiated Evaluation of the AFW system which is part of the DAPP. Therefore, the review of the AFW system will provide racolution of the generic implications. The issue associated with the removal of the CCW Surge Tank from being isolated on High radiation does not have a potential generic implication but will be included as a scope e::pansion item (D sign Activit.y) for the Self-Initiated Evaluation Portion of the program. Tha AFP has bden g oped to capturg any future External So ce Issues in'- th7 c h a n i c al '* iscipla e. As discussed reviously G this repo t the r)ew iceue wi11 savaluated for safety signif~cance ' root e, geneMc' ~* implic tion corrective at 'o 'nd nonrecur n
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- t.at r e . i m(-d each c,f the DAFP assi gncd Mechan'cel Djacipline Externe'.
Ecur;6 r+ ' e- pi i ' 04 their a ud i t/~'g f the Cygna IAP. Thejissues were founa to ne .c c r.2 2 1 :- i ca . on, E,1 c er a t i on a,s fincings. ine staff Jias reviewer.; later i l i,; l i < t ; s, t r.: r e p _,e s n a .d io :nd adctti nel Mechanical Distapline issues. ,,II' . e % i 3 r.c l , v . r :c- i. r i ino: c4- t nese j/. i t ems as E::ternal Ecu,r/c e Issues i r, the CNT gVcM / fe y N D 'WY $ o r a 77fa-f j flechan; ch ! AF c .-/ i l c, r oth be ver 1/F 1 ed ._ f wrj
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- rco lew thq DEI ewalvatkon of the four IAP issues i ri or der t.,
aucit the ruu ta:.on for t" safety sigrb cetermination, r
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'T TWy 'Tc o u s s t +. i f t . <- c or._l uceo based on the audits performed that the captu ed fThe
_ Mccnanicel Lis:iplane isaues are appropriate and need further e val uat i on l It is uneie+r e. ether or no* the stated eval unt i on for generic i mpl i c e t i or.,
] I n c l u t.e s : r oo* _cau-e, corrective action and nonrecurrence. The reason ~1s the LM cr. . . s,t at e.:' pot enti al gener-i c i mpl i c ati on evaluation as part of the 5cli-Initiatec E.aluation of the AFW system. The staff understancs this to tr.e e n t h s.t ii: ,.
- 1) thc ope. i t i ng condi ti ons (pressure-temperature) are properly identified 4 -
the AFW s.stcm that the issue is isolated to the CCW system. M;
- 2) t h e- Cl as s E. piping located in the AFW system is properly designed to ba functcral durIng and after the SSE the issue is isolated to the CCW system. [,
,5) the re.ie: t.4 the AFW system does not reveal a probl em with meeting single p.
ou < qfalure eriterta the issue is isolated to the CCW system. T, ITThe stef4 reou)res further dz scussi on of + hic i m ri p r c t a n d i n,.g._in o r d et, ,3& ,.{u l l y l
,dev[luale I the app'cach proposed in the DAPF'. i
[-In gen rel, the s aff agrees with the - neept f capturi g pa t and utt e
,lEifternc1 Source I ou and including hem in t Mecha ical DS P fy eitger
!- ,resolut on or tr. 'torin., The staff reserves fi al App r oval i. t is area unt11
- 'the receitly d . eloped IA issues fre further ana .ed. This w provids the 1 staff wi h th nec ssary as tran e and documentation of the pr ocess f or ( I
.l. capturing fu ure E: ternal Source Issues. .
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, APPENDIX A SECTION 4.4 '
4.4 Civil / Structural Issues 4.4.1 Introduction detrv-T) , The Program Plan identifies External Source Issues in the Civil / Structural Design Area. External Source Issues in this area have been evaluated in ISAP's and the Cable Tray / Conduit Supports (CTCS) Program. These ISAP's and the CTCS Program are intended to meet one of the main objectives of the Program Plan, that being that there is reasonable assurance that there are no undetected and un' corrected
~
' safety-significant design deficiencies associated with any of the External Source Issues. 4.4.2 CPRT Approach pd Tu sf gpw The methodology employed to respond to the External MJude. Source Issues has a six-step approach to identify, define, develop and , implement action plans, determine corrective action and report results. I ro C.craad The two ISAP's in the Civil / Structural Design Area deal **I with the Seismic Design of the Control Room Ceiling and the Steam Gen-erator Upper Lateral Supports. In addition to these ISAP's, the CTCS Program is currently in progress. This is a comprehensive reanalysis and construction as-built review of the cable tray and conduit supports. 9 4.4.3 Staff Evaluation . The staff's evaluation of the External Source Issues in the Civil / Structural Design Activities is based on a review of Revi-sion 3 of CPRT Program Plan and audits of the Comanche Peak DAP scope validation process. The staff also notes that ISAP's reflect the methodology outlined in the Program Plan.
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However, the staff has noted a number of concerns with' g # .J l the_4TCS ."regrr. There hae haan no response by CPKI other than that.F y# f!,.
~ 4 I" e f Revision 3 of the Program Plan will address these concerns, i
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#hf 4.4.4 Conclusion pur E The staff concludes that the CPRT evaluation plan or the External Source Design Activity, including the two ISAP's this f area, is acceptabiep 9 M O t e ot,w IJ nd C st 77 S M Cy I rwr_, ,, w n nr f . a . w . a s.?? ' K ~
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, e M Amm Un.9gg APPENDIX A STAFF EVALUATION OF THE CPRT DESIGN ADEQUACY PROGRAM PLAN (DAPP) EXTERNAL S0lRCE ISSUES 4.6 OA/0C Issues 4 4.6.1 Introduction yd ., The NRC Staff performed a comprehensive evaluation of the Revision of the Program Plan and by letters dated August 9 and September 30, 1985 provided to TUEC the Staff's evalution of the Plan. C By letter dated November 22, 1985 TUE[ submitted its C' responses to the Staff's evaluation. These responses and Revision 3 of the Program Plan provided the basis for evaluation of the QA/QC issues related to the Design Adequacy Program Plan. 4.6.2 CPRT Approach Appendix A does not specifically address QA/QC issues related to design, however the Plan does address the scope and methodology to ideritify and resolve External Source Issues. Resolution of the issues is accomplished through a review of External Source Documents which are listed in the Plan (e.g., SSERs, RIV Inspection Reports, etc.) to identify the issue, and the implementation of ISAPs and DSAPs which evaluate and close the issue. The CPRT approach also relies on a coded cross reference, prepared by the DAP, which identifies the issue and the source document (SSERs, etc.) and issue tracking matrices prepared by the CAPP which identify the issue, the source document and action plan that addresses the issue. he required rogramatic
'77 tty c f? R T' fit.o c- 4 w fcAs) o,e p y-t) ;rtftf g t w ;to = a q o4- co uc c u -
$rw A f TP26~D V//67, w r ,= -2 w DRAi-T ffhjft.Q TfW S/'>f /=r* GWLusty pe, J interface between the DAP and the QA/QC CAP is a significant influence in the resolution of QA/QC issues related to design.
4.6.3 Staff Evaluation vmyc /- The Staff has reviewed Revision 3 of the Plan to assure that the concerns expressed in the NRC's letters of August 9, and September 30, 1985 have been responded to. This evaluation pertains prin-cipally to the QA/QC issues regarding the DAPP (CPRT Program Plan, Appendix
- e. A).
Revision 3 describes the approach and methodology being used to review documentation to identify the issue, prepare a coded cross reference, maintain an ongoing document review to identify new issues and develop new action plans as required. Additionally, the Plan details the DAP approach to resolution of: design issues raised and closed outside the CPRT, external source design issues not closed outside the CPRT, and external source issues closed outside CPRT but also evaluated in the DAP. The response also describes the detail of the interface between the DAP and the CAP QA/QC Review Team to ensure the identification, 1 tracking and resolution of issues. l I The Staff finds the CPRTs response establishes confidence that QA/QC issues (external source issues) related to design will be l identified and resolved in the DAP. This is based on a parallel evaluation of the QA/QC review team (CPRT Program Plan, Appendix B) methodology for identifying and tracking the issues by use of tracking matrices (Reference this report, Appendix B, Sections 4.6.2 and 4.6.3) and the defined inter-face between the DAP and the CAP. Meeugh e response adequately address the, NRC's con-cern regarding design related QA/QC issues (external source issues) h GFRT did not ; eper- = revie4aa +a tt CAPP (CPRT P. %. am Han, appenoix N - l
, e DRAFT G4 ft.at yi NCr-te iace ?: rat: the c; ;; =0. but rC ici on the coded cross reference, the issue tracking matrices (CAPP, Appendix B) and the interface between the QA/QC CAP and the DAP. 4.6.3 Conclusions Based on the evaluation of the response and the revised CAPP Appendix B, the Staff is confident that the QA/QC issues related to design will be identified, and resolved. Accordingly, the Program Plan
- 6. Revision 3, as it addresses the design related QA/QC issues is acceptable.-
However, final acceptance of the Plan will be predicated on the Statt eview of the coded cross reference and the tracking matrices. 1 (4 >J pfl.T L 2 *! W ![ ' ,"- ' OfW" (. ntef fert-r m rzw Peow H p L ewc' nur itect smw n m-MCoos4. At tfitt-7? N st /y c. /+% fce %- cW7M- m v, 732EDyw t w s r rt-O s 4 e<o y oy fm or rius .run-r n w f./ i l I
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DRAFT APPENDIX A STA(FEVALUATIONOFTHECPRTDESIGNADEQUACYPROGRAMPLAN 4.7 Closed External Source Issues The CPRT Program Plan states that those external source design issues that have not yet been resolved will be resolved and closed in the g course of the DAP and identifies the source documentation (e.g., CYGNA ; IAP/SSERs,INPO,etc.)thatidentifiestheissues. The document review is
)
an ongoing activity from which a coded cross reference is developed between DSAP topics and the external source documents for issues related to design. Any new source documents that become available will be similarly reviewed l and new action plans developed as required to address the ide'ntified issues. The action plan results reports will report the path that each issue took in the DAP and will be documented in appropriate cross reference i tables. In parallel with the DAP activity the QA/QC review team is per-forming a similar document review which results in the development of issues tracking matrices that identify the issue, the source document, and the action plan (ISAP/DSAP) that addresses and resolves it. The Staff's evaluation establishes a level of confidence that the DAP will identify, address and resolve the external source design issues. However, the Staff 4 isconcernedthatalthoughtheactionplanresultsreportformat(Program Plan, Attachment 5) infers that closures of the issue will be reported, there is no clear statement in that format that requires reporting at Accordingly, send w
- each 2 btissg[+ nYel-addressed in the actiglan e is closed._N==r.t .
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I N Mbi APPENDIX A SECTION 5.4
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gr ff h[ J f' 5.4 Civil and Structural Design Activities t' < 5.4.1 Introduction c U9 M [/
- k(
The Self Initiated Evaluation of the Civil / Structural 4 DSAP was develo ed to increase the cunfi ence in the verall CPSES Civil /Structur Desj n Area. The purpos'e of these eval tions is to; verify the ality of the design, to issure compliance ith licensing 9 comitments an to identify pofential design eviations deficien es. fnd
' f deviations or deficiencies are identif'ed, the Prosram x lan pr vide the methodology for evaluating generic implications. ~
f This Civil /5tructural Self-Initiated Evaluation will help enhance one of the main objectives of the Program Plan, that being that there is " reasonable assurance" that there are no undetected d deficiencies at CPSES. 4
~
k The topics addressed in the Civil / Structural Self-Initiated Evaluation are Concrete Design, Structural Steel Design, u f HVAC Supports and Other Supports. Examples of the Other Supports include the crane support, equipment supports, penetration sleeve anchors, missile-resistant doors and hatches, and various seismic restraints.
)t 5.4.2 CPRT Approach %
w w [1 The scope of the ~Self-Initiated Evaluation of the I Civil / Structural asign Activity nsists of four phas . phase is intended to define the readth of the revie based on past VP The initia (
) and other r views. The n t phaseidentifies sign attribute and & i
/ character tics. Phase ree is intended to alidate the DSA scop based homogeneous d ign activities. Th fourth and fin phas ,
9
/ determination, identifies final sco sc (ge_ ope , findings, ,trends and
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, 'e b D .1 7 - W APPENDIX A SECTION 5.4 D. This DSA program consists of a " vertical" slice review of the design activity. Phase three of thi program is based on the i Homogeneous Design Actifity (HDA) validation The HDA's were identified basedonthefollowing[ attributes: '
' d riteria j
l Y Wg,P W e y Design Approach and M4thodology [ Organization / Discipline
- Design Control Pro # ss
- 6. -
Design Interface - s
! It is the intent o the program plan that he implemen-tation of th s four-phase scope wi 1 achieve the program's reasonable M urance objective.
5.4.3 Staff Evaluation ) The staff's evaluation of the Self-Initiated Civil / Structural Design Activities is based on CPRT's response to the NRC's staff evaluation of the CPRT Program Plan dated November 22, 1985, Revi-sion 3, to the Program Plan, and audits of the Comanche Peak DAP scope validation process. 7 The staff had noted a number of specific concerns in Pl if the Civil / Structural Design Activity to which TERA has issued responses [ \ (CPRT-13). A concern which was generic to all the Self Initiated Design ) I Activities area was t t TERA was unabl to provide G&H documentation covering design cons,derations, approa. and methodology, and design control procedures 5hich were to be[the basis for determining the homogeneous design activities. This 6&H documentation is now available to TERA for review in the Civil /Strdctural Design Area to assure that l the design activities identified i phase three of the DAP'are indeed homogeneous. ' j b 'T' fit. A I$ kr tl n.fwrt f svtirt-ce o W4- ! a A<'$vt. v r ^4-
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, APPENDIX A
. SECTION 5.4 g -
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There were additional concerns raised by the NRC staff cwe with the selection of concrete and steel structures to be reviewed, the D 'l C' #ce, adequate representation of CPSES Category I structures, inadequate ' sample sizes and inadequate DSAP scope for embedments. It is the posi-tion of the staff that Revision 3 of the Program Plan adequately addresses the concerns. [r M R (f~t. f /p m R vl t d, 5.4.4 Conclusion 7 ihe staff concludes that the CPRT evaluation plan for 4 the Self-Initiated Civil / Structural Design Activity is acceptable. The-staff will audit the implementation of the CPRT Action Plan. [
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APPENDIX A Page 1 of 13
- 5. Self-Initiated Evaluation l
3 % %s ) 5.5 Piping and Supports Design Activities ',) 5.5.1 Introduction A number of external source issues have- been raised in ) the area of piping analysis and pipe support design. These external , source issues have resulted from several sources; the primary sources 1 being the Cygna Independent Assessment Program, the ASLB hearings, and the NRC staff reviews. As a result, the applicant has initiated a { g special piping and pipe support requalification program which will-result in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. Stone & Webster Engineering Cor-poration (SWEC) has been contracted by the applicant to perfom this re-qualification program. In addition, a third-party overview of this effort is being conducted by TERA Corporation (TERA) to provide assur-ance that the objectives of the Design Adequacy Program in the piping and pipe support area are being achieved. The CPRT Program Plan descri-bes the piping and pipe support program and overview in DSAP IX. In this section of the SER, we will discuss the staff review and evaluation of the SWEC piping and pipe support requalifica-tion program. The staff review and evaluation of the TERA effort is provided in Appendix B. Section 4.5 of this SER. l
./ h The staff has reviewed the CPRT Program Plan DSAP IX Attachment 2 and Appendix F Section' II.F which describe the SWEC piping and support effort and the SWEC interface with other organizations, re-o spectively. In addition, the staff has performed several audits at the SWEC offices and at the CPSES site to further understand the depth and I breadth of the effort. Our review focussed on the adequacy of the scope and the completeness of action plan details in addressing the. technical concerns associated with piping and pipe support design which have been raised in external sources as well as in self-initiated reviews.
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~# Page 2 of 13 5.5.2 CPRT Approach , ].
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l pp -t 2 The scope of the SWEC program for the requalification ; of piping and pipe supports include: i i 100% of all ASME Code Class 2 and 3 piping larger than 2 inches (large bore) excluding portions within the boundary of Westinghouse Class 1 auxil-iary branch line stress problems. 100% of all ASME Code Class 1, 2, and 31arge bore , pipe supports. e . small bore piping and pipe supports on a sampling basis. all Class 5 piping and pipe supports within ASME Code Class 2 and 3 stress analysis problem boun-dary, and C all Class 5 supports within the ASME Code Class I stress problems. The CPRT Program Plan in DSAP IX Attachment 2 describes the outline of the SWEC Action Plan. The SWEC Action Plan consists of the following six elements:
- 1) Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria DPA* W W J W -io, rompwm,.,3 =- = =--" ; a r>
2 L U ~r5 o M k N n u W 4-Jhe Design criteria and procedures to be used for h the pipe, stress _and support requalification effgr,L c,,ug,f, by SWEC 7 5 I 'bY '*5:15ded 2 ;mce&res listed g ifovevew.iwr vt+eS r ws.tr w rwa-ewen fm uitc n, vow W ve w .
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77 d -rtnr f M m u r&1" ost r v c W ,- cctw2.jees.W /r mN g #"'jp% fy iO! W O T u-N'MW Tmr M MWM M D w trmr 7'o P't N L r .t* rr W6- /x W L s'WW tw c. t.t ri * - F r& e t cex cr o str-s- e ruema. __
e APPENDIX A Page 3 of 13 Proteaure Title _- Issue Date CPPP-1 Management Plan for Project Quality, Rev. 2 12/02/85 CPPP-2 , Project Organization Charts, Rev. 0 12/02/85 , CPPP-3 Do ument Control Procedure, Rev. 2 11/25/85 CPPP-4 Proj t Records Management Procedure, Rev. I 11/25/85 CPPP-5 Field W ik Procedure, Rev. I 10/18/85 CPPP-6 Pipe Stres / Support Requalification 10/31/85 Procedure Unit No. 1. Rev. 1. CPPP-7 Design Criter- for Pipe Stress and Pipe 11/04/85 Supp rts Rev. 1 , CPPP-8 Support System Ve ification Walkdown [ 10/28/85 g Procedure, Rev. 0 / - CPPP-9 PipeStress/SupportA-BuiltProcedure.I 11/01/85 Unit No. 2. Rev. 1 CPPP-10 Power Division Procedure ted Review of Plant Operatin Mode Cinditions, for 10/31/85 Documen Rev. 0 ' CPPP-11 Administrative Control of Ca c'ulations, Rev. 0 11/27/85 { CPPP-12 Cost and Schedule Control oc\ dure,Rev.0 10/11/85 CPPP-13 ~ Site Construction Suppor Activ ies, Rev. 0 10/11/85 CPPP-14 Procedure for the Pre ration and ntrol 11/05/85 of Project Procedur . Rev. 1 CPPP-15 Small Bore : cress / upport Requalificat(on Procedure \ PM's Project Memora da
\
PM-001 Pipe Suppor ' Computer Program Usage \ 11/01/85 PM-002 Design Cr teria for Pipe Stress and Pipe \ 11/04/85 Suppor PM-003 Desip Information Request Procedure 1/18/85 PM-004 Em dment Plate Evaluation 1 02/85 PM-005 alve Modeling 12/03/85 PM-006 Use of Code Case N-411 for CPSES Stress 12/13/85 Requalification
/ \
, i . .. APP.ENDIX A
~ s
- o f 13 The ma details, however, ar in\o-cont:'ned pr cedure CPPP , PP-6, CPPP-7 and CPPP-8.
x T They will he M:::d t; the %",C ateff vi icvie . A A'4 4t thh i. me nune . . L;;,. .e' = 1 These pro-N cedures will reflect all CPSES FSAR comitments and the ASME Section III Code of Record (with NRC approval changes). In the process of the requali-fication effort, it is expected some changes to this FSAR and ASME Section III Code of Record will be requested by TUGCO. These changes (some pre-viously approved by the NRC for use on A CC SWEC-designed plants) might include p:- W:: :Sn previous rpt v 7 to use the following documents: - NUREG=0484 Code Case N-392 Code Case N-411 Code Case N-413 In addition, Procedures CPPP-6 and -7 will include any specific methods required for the proper treatment of all external source issues which are not covered by the standard SWEC procedures and which are unique to the CPSES plant. A_t this_ S p P*# time, Procedures CPPP-6 and -7 do not include all hctT of the methods requirtd for the resolutinne of pf/6* these issues. ~
//#Y y /W When all work is completed, revisions to these W gg rocedures will be incorporated. It is not ft41FM # gg intended that all of the backup detail or suppor- po v'# 7fJ /M ting SWEC calculations will be included in the "p' g p u" cs g _ ( review procedures.
This detati wiii be avaliasie for at the SWEC offices. t r p ens w w*'- WW'j &. c& W y
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APPENDIX A Pag,e 5 of 13
, TUGC0 has requested (W.G. Counsil letter dated p , g 11/18/85 to V. Noonan) a pproval for the use of Ig# ,
Code Case N-411 from the NRC. This recupst is gd d "* presently under consideration at the NRC. N'I - y
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' g/4 9 O 2) Verification of As-Built Information "W uf: Tt/t
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Since the as-built data will be used as input for er /t (#f4 the SWEC requalification ef fort , it is important ' At *#
,to develoo confidence in its accuracy. m 1%
ppg e 60p p o - The process being used to develop this confidence I' ' # involves walkdowns performed by SWEC, a reliance v>e w rM-r - of previous work by TUGCO, and other work by the W'N CPRT. #p 4:- D
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The walkdowns by SWEC include: N N'
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a) CPPP-5 Field Walkdown pthfft . b) CPPP-8 Walkdown c) SWEC " Stress Reconciliation Walkdown" Previous work by TUGC0 includes their 1) " General Program for As-Built Piping Verification" and. 2)
" Penetration Schedule".
The activities by CPRT to be considered here include the QA/QC Construction Adequacy Walkdown, specifically those for samples related to piping and supports. CPPP-5 Walkdawn. - the purpose of this walkdown by SWEC was to establish confidence in the adequacy of dimensions and functions shown on the as-built drawing to support the initiation of the piping analysis effort. This walkdown is described in SWEC procedure CPPP-5 and the results will be
weutuix a Page 6 of 13 o G # p [0 published in a .e ! <down report.
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% x;i b n f 70r#S"ad 't th- ~,ft0 h *4"" - ' - ^'
,M The walkdown consisted of the field verification i
[ of random samples of four attributes selected by g SWEC. The attributes selected included valve lo- [ $ cation, pipe support location, pipe support func-I f f tion and support orientation. M^ ---- '--- -'
*{*3 T.he walkdown reporr ern avna"+ad 'a ' i'nad
- Q Preliminary results indicated the need for a 100% walkdown of the support and valve orietation attribute. This 100% attribute walkdown has now been completed by TUGCO.
CPPP-8 Walkdown - This is a Piping and Support
- 4. System Engineering Walkdown. The objectives 'of-the walkdown are:
(1) To detemine whether there are technical con-figuration issues, other than existing tech-nical findings from previous reviews, that should be evaluated relative to the functional behavior of the system, and (2) for experienced SWEC personnel to become familiar with the physical aspects of the derign and determine whether additional, or refinements of, design inputs, guidelines, or procedures are necessary for the pipe stress and supports requalification effort. r The walkdown was perfomed on a total of 70 stress
/r problems out of the approximately 360 which are within the scope of the SWEC requalification 4, ef fort.
g M The walkdown was performed by teams of SWEC pipe yA stress analysts and pipe support designs ;
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' I APPENDfX A Page 7 of 13
./ h, . The data is presently being
/ g evaluated and additional verification walkdowns
', N Ah will be performed at the site as needed, w d f M rep;rt ';r t'4r = # #^ * + M ;-rdeu to oe Il (innaau4 ten =y,!=. I SWEC Stress Reconciliation Walkdown - This, as~ in other nuclear plants, will be performed by pipe .
stress analysts with the completed piping stress analyses. The item of most concern here (with respect to as-built information) is gaps and interferences. t
- 6. TUGC0 General Program for As-Built Piping Verifir cation - These represent the walkdowns performed by TUGC0 to satisfy the general intent of NRC IE Bulletin 79-14 Th: 7U000 ; ~ ad" eat" med ?
t ;bd;d CT-QT-11.3, Ee.. 6, Qi-QF-il.13-1, Re<. p 4.,_f" EI-4.5-1, "_ev. Q and TWE-9[ [$_l, Rgy, 0, L Penetration Schedule - The penetration schedule is , a detailed computer listing describing all of the I penetrations in the plant. The schedule lists the type of sealant, type of penetration, openings and a number of other parameters. The stress analyst can obtain all required info relative to clear-ances etc. at penetrations having this available. QA/QC Construction Adequacy Walkdowns - The piping configuration and pipe supports sample walkdowns (See Appendix B. Paragraphs 5.3.3 and 5.4.4 of this report) along with all of-the above will also provide verification of the as-built infonnation .
?0;; CPPP-0, 00;. O , ": :; : p'. 1. 0 ) . -
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APPENDIX A t , *. Page 8 of 13
- 3) Review and Verification of Systems Design input, Seismic Acceleration and Fluid Transients S'WEC will review all drcwings and specifications for systems within this scope. The specifications will be reviewed to assure compliance with
/
j licensing comitments and that all operating modes and conditions are identified appropriately. Existing fluid transient loads will be reviewed ( and new loadings generated, if -required. SWEC ! Procedure CPPP-10 describing the operating condi- .; tions for the plant has been prepared and includes l some of the above data.
' I A third party review of this activity will also be performed. A procedure review will be performed l to verify that the SWEC procedures are adequate to perform their intended purpose. This procedure review will focus on, among other things, the definition and verification of design input.
4 Verification of Existing Pipe Support Design Docu-ments The CPRT Program Plan in DSAP IX Attachment 2 states that the existing pipe support calculations will be reviewed to determine their technical ade-quacy. SWEC originally intended to review existing large bore support calculations on a sampling basis ~to determine their acceptability by using a load comparison method. However, in the M ber 22, 1985 lettff, the approach changed to ph 7, evaluating all large bore pipe supports 70 ~ individually. SWEC Project Procedures CPPP-6 and CPPP-7 describe ^the approach to be used, the design criteria to be satisfied, and the' extent of the review required for the pipe support requali-fication effort. Thus, this Action Plan
, e, APPENDfX A Page. 9 of 13 element has been incorporated into Action Plan Element #1, 5 Resolution or special Technical concerns (By Dave Terao) l
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l l C' S 6 l Reanalysis of Piping Systems and Reevaluation of Pipe Support Designs i (By Dave Terao) I
TPENDIX A Pag *e 10 of 13
,t .-
l 5.5.3 Staff Evaluation
- 1) Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria Due to the fact that the major details of the SWEC requalification effort are contained in the SWEC project procedures CPPP-5, CPPP-6, CPPP-7, and CPPP-8 and since these have not yet been made available to the staff for thorough review, the task of evaluation has been and continues to be very difficult. The primary method of l ev'aluation has been through audits which have been performed both at the rr m SWEC offices and at the CPSES site.
During these audits, draft copies y
) o,f the procedures were available for review.
T is i m is n pen t The staff will con (1 o r this ri a sup ement is R. [ f r/ t ' ' sq,a 2) mms Verification of As-Built Information rc , g +/ f pf AoJ C p (f7 f stu TitI M & aff erhi
- During~ staff audits at the WEC offices and at the P W g (/dCPSES site, CPPP-5, the CPPP-5 walkdown report. CPPP-8, the TUGC0 as-g
( , built procedures, the penetration schedule and the QA/QC piping and pipe e d ~ ga supports samples were discussed and partially reviewed. n ad tion, t8 g 1 p the staff and its consultants performed verification of the -5 an -8 - g alkdowns. f ff g f g 9: 1 The following questions and/or comments remain as open %)/. g ./
'A t .o 9
- a)
V For the CPPP-5 walkdown - the valve and support
/
/, location tolerances used by SWEC range from +/- 3" to +/- 12" depending on the dimension used on the I p
f / drawing. Typically, a tolerance for such a dimen-g k f(g sion is a function of the diameter of the piping system. In this case, there is no relationship. }['I p p - Using this CPPP-5 approach, a valve . or support could be mislocated more on a 3"
$h&-
line F
i
. ", , APPEND 1X A Page 11 cf 13 thanona30"lineandiswithinthegega it4 slimits er o established d e o %~c r in CPPP-5. This deer ant -Me sense- from a pipe stress point of view. The 12"
- &"n pu s irw tolerance should__bflus_ tiff _ed_by SWEC for small r e
diameter piping as a minimum. M CummM t r-
$ b) For the CPPP-8 walkdown, until the final walkdown /tt. a rY report is issued, the evaluation of this task can- WOW f g not be completed. However, a preliminary review ke&go g ,- of a portion oT the data indicates several dis-I V DrAX crepancies with snubber / strut installations such
[ g ggt,' f (f'l'> 89pf ' f as improper alignment and interferences with the rear bracket. It was also noted that there were* A dc 7~l W p t# gM E improper clearances between the pipe and support member at some locations. h 1 y V' A c) SWEC Stress Reconciliation Walkdown Procedure N ' 5 g Ar h^ ' CPPP-6 indicates that a final field walkdown will be perfomed at the completion of the requalifi- .r v i!- cation effort. The purpose of this walkdown is to W W'- pf sie F
- verify that sufficient clearance exists between VW 0F T C pp the piping systems and nearby structures. Based sti (9 ,,
on the preliminary conclusions from the CPPP-8 ccm ; f2, c' walkdown data, the scope of the stress reconcilia- r. f. 5 [ tion walkdown should be expanded to reconcile con- D gy'O cerns such as are noted above in b. gm a r-N d) TUGC0 Penetration Schedule - During an audit at p f_ rv o d
/7 the CPSES site, the content of this schedule was F'*"'
[ discussed with TUGC0 employees. It appears that Wp f LF
- n, the information required by the pipe stress anal-
/ ysis is available in this schedule. The apparent M
wvst pd k 5- F lack of reference of this penetration schedule, pl - p); g - however, in the SWEC Procedure CPPP-7, is of con- p f [ cern to the staff. In addition, the staff plans a e.vo/ t,o v - walkdown to verify the accuracy of the dats in the % f II penetration schedule in the near future. Due to k / {N go the above, the staff considers this to be an open item and will consider it in a supplement to this Ay,g tc 4 _ l G t.e', SER.
, APPENDIX A .Page 12 of 13
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e) QA/QC Construction Adequacy Walkdown - During audits at the site, it was determined that there is a difference of tolerances used within his walkdown versus those used by SWEC in the CPPP-5 walkdown. In addition, it is not clear to the staff that the tolerances used here for gaps
,5 if (e.g., on box frame supports) would be acceptable g'y/ *
# for the SWEC pipe stress requalification effort.
It is recommended that all tolerances here be re-f d f [p d i viewed by SWEC and their acceptance documented. Until this is available for review by the staff, g/ [ this remains an open item and the staff will con-4. j [ ider it in a supplement to this SER.
,f Since, as described above, the total verification of the as-built drawings is a function of a compilation of a number of M*
walkdowns and work by at least three organizations, iLis recommended \ that one document be prepared to _ comoile and integrate all of this Cf g-g fjrmation. Without such a document, it is not clear to the staff if all of this information is compatible and it is not clear that it will lead p c N, to the proper conclusions, f/w C A-(?<.
- 0
\ In addition, since the need for the 100t walkdown #
- e1 p i / of valve and strut orientation came about in CPPP-5 as a result of the M . [ failure of one of the four attributes chosen by SWEC, and since this ' f T failure effects any conclusion relative _to the accuracy of the as-built [g data, it is recomended that a statement regarding this failure and its effect on the accuracy of the as-built data be included in this docu-ment. The comparison of the 100% TUGC0 re-walkdown with the existing as-built data would be helpful in reaching a conclusion. 1 Until all of the documents noted above are avail-able for thorough review by the staff, all of the concerns noted above f are satisfactorily resolved, the verification of as-built data remains as an open item.
APPENDIX A Page 13 of 13 , e . -
- 5.5.4
{This will be very brief and presented in general tems with reference to the detail provided in 5.5.3.) These words have been written by Dave Terao.
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, e .. Appendix A Page 1 of 1 DRA7T r Paragraph 6 - Exclusion of Vendors and Other Organization Activities n (Note: This paragraph deals only with the piping and should be incorporated into a more comprehensive section of this topic). The Class 1 piping is not within the SWEC scope but is the responsibility of Westinghouse. The loads from the SWEC analysis of the Class 2 and 3 piping imposed on the Class 1 piping as well as the requalification results of Class 1 supports (including pipe support i stiffness) will be transmitted to Westinghouse. These interfaces are i i descrioed in procedure CPPP-6 and are considered to be satisfactory by
- 6. the staff. -
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- 5. 2 i 4.cc h e r. . c A E. s.t e a.1 ar.d Components Design Activities M--
5.3.1
Introduction:
gM , The dc-ign documents pr nduced oy the hechanical Discip]2ne incl udes such i tems as i l c. : ciagrams, Fand1D s, piping drawings, equipment (bid and purcha.sei specisicetons and cal c ul at i ons. f 4or mal l . . tne design responsi bi1ity assigned to tt e Mechanical Discipl2ne a- t the A/E involves the technical areas of fluid s ,. t. t e w. , n.draulics. r r. / C , protest. nuclear and operational c onsi der ati ons . The c4 cu11. tion > inval.ed entall both wnole system evaluation ano incividual piete* of eq m p.w.t. Tr.e r esu] t s of these calculations are made psrt of the speci f icati or.s s n .- the arious drawings. The Mechanical disciplinc also produus de m gr. req.:2roments for other disciplines (interfaces). These interisce= u s.u s 1 . . Involvc the disciplines of Instrumentation and Control, Electrica3 a: n Si r uc t ur c.1 . Also, these other c.ii s.c i p 1 i n es cnd e q u i p me r.t vendar+ ) pro. loc the Mech +nical Di sci pl i ne with de si gn data and requirements. There4 ort, the t . e l u e. t l o n of the adequacy of the design produced by the Mecnanical Di scipli ne neeca to focus on both the design documents and the varicus i r.t
- r i nc es .
5.3.~ CPRT Approach: T4 o( 74 er t cr>.r C 4 A C', I ~T--- Tne CFET t h r uv o r, the Sc14-' ei i saluatton porti on of the DAFP intends to inspect the various des > n d.cuments p and the interf6ces. Tht- Iechan ~ cal Di sq g'p,pdducethby lNe39 n the effort Mechani cal' been Di sci diV2ded pl i neinto Design Topica. Tr/De si gn opi cytiavd been furt er br cen down into pesign Att1 itics. A -sign Topi i s,4 g er$r a l category o* design effort,,Auch as; System Pressg e Drop, whe est, a Dep'ign Activity s a particuler, aspect of the topic. An cuan. pie cf a dign Activity under . topic of Sys m Pressure Drcr. would b Gas sy s t e er. Fr.=s arc Drop. (Otner en ..p es of Design ctivities are Open .ystem Heat Re. wel nd C1csed .,
- et Removal. . these instances th Design Topic is. Heat emoval and Rejection.
In the DAFF ther e e re 37 Deyign Activities assigned to the Mechanical D5AF. These are be ol en down into 125 Disign Activities. Fifty of the Design Activities mal.eup Fesision 2 hf the DAPP. The remaindir (75) were added to thc scope of the DAFF by the Phase II Scope Expansion. r=rs n; +8n nori :n
^cta ntimm o.11 bc in=m=c+ad via 'ho im-limentctinn nt +rc'-ic 1 c h c c' 1. :t s. ^- i"di idur1 che:Flict covers M te~rd 2 r. r v i - ht rch O '. the in=nerine nf 2 e m1 ciel , t i on or Mi cmenthnnri f e m+.i nn - in snmo em e it is rpo e : c . , t o -c-e m n ! t e =ovo. g .cc! ! 12t s ar_m o g -ticulu Deci 7 ^ct .,tj h a r.
been full, ...w ectcd, cen r zing 1 chec?lict .s 7 epply t c .- o r - then one Dem 9 Aui4 ,iL7 ^- curr b _ely si : this in 2 tle Me-h eni-eel OCAP ic + h a .. Des i gn Aglivi ty; 5yetom Fluid T [ p r a t ure-af4 i- m/ Mah-a-mue, . '"- i : De:i gn-.-Ac t i V i t y r.equ i r = = the e nmp l ati.on o f_ t11rse-ct=c L 1 1,_ t _ . Tiie par tiuul ac chec!1 mi. - a: 1) . S y = L-...,'F 4 p i n g Airangemr.tn nd Tm=Laiig ef r ovi si on. 'C"), J, naalmum/ Minimum Flow 7 (124- .i d 3 M eat-n:rre' Crp cit, dis An example at a cnecxalst applying to mor n___tb a n nne desion Ad i vi + " i- th ne e er t"r c::v i r c T::! cf " .,m /Minumim Fi1 E w (MMi T O c5cct14=+ aoolies [e+ h r D :i g- ^-+ i vi + 4 =e of c i p i ng tial l w i r- U n o s c . gi rd manui ramk , egnure cand i t i em sna % ct.m ri'id Tr cr :t r r "i -'i -- / Mm' 4r- The relationship of Design Activities to Review w Tcsks (checklists) is presented in the Mechanital DSAP as Table 1 which is
. entitled Mechanical Matrix. The Desir ^ctivitirc 1.-tad .. 7 6 . v.. 2 er the -
E D^c' .equTTUs el seper Le checklist; ir crdcr tv mvnpleiu iheir r ev a en. The .. a .. gV" # c4. O *' nO 1Q3 r,c s i y 4 i6iwm yv A A A}}