ML20196A468
| ML20196A468 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/22/1988 |
| From: | Ebneter S NRC OFFICE OF SPECIAL PROJECTS |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8802050062 | |
| Download: ML20196A468 (29) | |
Text
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. e o UNITED STATES
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+ g g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20$56 O. E
%, ' " " p JAN 2 21988 Docket Nos. 50-445 and 50-446 .
Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company 400 North Olive Street, L. B. 81 Dallas, Texas 75201
Dear Mr. Counsil:
SUBJECT:
CPSES LICENSING AND CORRECTIVE ACTION PROGRAMS We have reviewed Revision 4 to the Comanche Peak Response Team (CPRT) Program Plan and the Corrective Action Program (CAP) plans you have developed to address regulatory compliance and licensing issues for the Comanche Peak Steam Electric Station (CPSES). These programs are described in the references identified in the enclosed evaluation. Our evaluation has also considered the findings of the inspections and audits conducted by the Comanche Peak Project Division and coments received from CASE representatives as a result of public meetings held on April 2 and 7. July 29-30, and December 9, 1987.
TU Electric has developed these programs to respond to issues and concerns raised by NRC inspections, allegations, Atomic Safety and Licensing Board (ASLB) hearings, CYGNA independent assessment results, and, subsequent to these "external source issues," findings of the Comanche Peak Response Team (CPRT) investigations. The varied nature of the design and construction deficiencies that have been identified are evidence of deficiencies in the quality assurance and quality control (QA/QC) during the initial design and construction of CPSES.
As such, the licensing of CPSES will be based, in part, on the results of the current TV Electric programs' ability to identify and correct design and construction deficiencies. The staff has reviewed the TV Electric programs to determine whether they provide an effective means to: (1)identifydesignand construction deficiencies such that, when corrected, there will be adequate confidence that all safety-related structures, systems and components will function properly; (2) develop and implement appropriate corrective and preventive actions to resolve the identified deficiencies, in accordance with the applicable regulatory requirements and commitments in the FSAR, as amended; and (3) conduct the foregoing activities in accordance with the requirements of 10 CFR 50, Appendix B, so as to ensure that effective management controls for all aspects of these activities are established and executed.
Based on the NRC review of the documentation submitted by TV Electric, inspections and audits of associated activities, and consideration of public comments, we conclude that the CPRT Revision 4 changes and CAP plans provide the h$f P
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Texas Utilities Electric Company JAN 2 21988 necessary elements to accomplish the objectives described above, subject to the conditions described in the enclosed evaluation. These conditions were discussed during the public meeting on December 9, 1987. In response, TV Electric submitted comitments to address these conditions by letter dated December 18, 1987. -
This letter constitutes NRC approval of the CPRT and CAP plans. These plans adequately describe the means by which TV Electric intends to establish the adequacy of the design and construction of the Comanche Peak Steam Electric Station. These programs also provide the framework by which we expect to find resolution of any related licensing issues associated with other aspects of the NRC's review of the CPSES Final Safety Analysis Report.
Accordingly, any future changes to these plans that would affect the basis for this approval, as described in the enclosed evaluation, must be approved by the NRC before implementation.
Should you have any questions regarding this evaluation, please contact Mr. C. I. Grimes.
Sincerely,
/ '
" tewart Ebneter, Director Office of Special Projects
Enclosure:
Evaluation cc: See next page
JAN 2 21988 W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Electric Company Units 1 and 2 cc:
Jack R. Newman, Esq. Asst. Director for Inspec. Programs Newman & Holtzinger, P.C. Comanche Peak Project Division Suite 1000 U.S. Nuclear Regulatory Commission 1615 L Street, N.W. P. O.' Box 1029 Washington, D.C. 20036 Granbury, Texas 76048 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worshan, Forsythe, Sampels G U.S. Nuclear Regulatory Comission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street Texas Utilities Electric Company Washington, D.C. 20002 Skyway Tower 400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde. Esq.
Dallas, Texas 75201 Government Accountability Project Midwest Office Mr. Robert E. Ballard, Jr. 104 East Wisconsin Avenue Director of Projects Appleton, Wisconsin 54911 Gibbs and Hill, Inc.
11 Penn Plaza New York, New York 10001 David R. Pigott, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. R. S. Howard San Francisco, California 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.
Pittsburgh, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Renea Hicks, Esq. Washington, D.C. 20C05 Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12548, Capitol Station Bonnie S. Blair Austin, Texas 78711 Spiegel & McDiarmid 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy 1426 South Polk George A. Parker, Chairman Dallas, Texas 75224 Public Utility Comittee Senior Citizens Alliance Of Ms. Nancy H. Williams Tarrant County, Inc.
CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133 Walnut Creek, CA 94596
- a. .
JAN 2 21988 o
W. G. Counsil Comanche Peak Electric Station Texas Utilities Electric Company Units 1 and 2 cc:
Joseph F. Fulbright Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Roger D. Walker Manager, Nuclear Licensing Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette. Esq.
Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 James P. McGaughy, Jr.
GDS Associates. Inc.
Suite 720 1850 Parkway Place Marietta, Georgia 30067 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory i P. O. Box X, Building 3500 Oak Ridge Tennessee 37830
' Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 i Dr. Walter H. Jordan c/o Carib Terrace Motel I
522 N. Ocean Boulevard I Pompano Beach, Florida 33062 i
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b EVALUATION BY THE OFFICE OF SPECIAL PROJECTS OF THE LICENSING AND CORRECTIVE ACTION PROGRNtS FOR THE COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 l
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TABLE OF CONTENTS Page Abbreviations iii I. Introduction and Background 1 II. Discussion 3 III. Evaluation 6 A. Third-Party Review 6 B. Design Validation 9- j C. Hardware Validation 10 l
D. Design-Hardware Reconciliation 11 E. QA/QC Activities 12 IV. Conclusion 13 Y. References 14 Appendix Status of Actions Required by SSER 13 Al i
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< ls ABBREVIATIONS ASLB Atomic Safety and Licensing Board CAP Corrective Action Program CAR Corrective Action Request CASE Citizens Association for Sound Energy CFR Code of Federal Regulations CPRT Comanche Peak Response Team CPSES Comanche Peak Steam Electric Station CYGNA CYGNA Energy Services DAP Design Adequacy Program DBCP Design Basis Consolidation Program D6D Design Basis Document DSAP Discipline Specific Action Plan DVP Design Validation Package EFE Engineering Functional Evaluation FSAR Final Safety Analysis Report GIR Generic Issues Report IAP Independent Assessment Program ISAP Issue Specific Action Plan NCR Nonconformance Report NRC U.S. Nuclear Regulatory Comission PCHVP Post-Construction Hardware Validation Program PSR Project Status Report QA Quality Assurance QC Quality Control QOC Quality of Construction iii
Abbreviations (continued)
RIL ReviewIssuesList(CYGNA)
SDAR Significant Deficiency Analysis Report SRT Senior Review Team SSER Supplemental Safety Evaluation Report SWEC Stone & Webster Engineering Corporation
- TAP Technical Audit Program TRT Technical Review Team (NRC)
TV Electric Texas Utilities Electric Company
't 1
iv
I. INTRODUCTION AND BACKGROUND 8eginning in early 1984, the NRC fomed a special Technical Review Team (TRT) to provide a coordinated and integrated evaluation of numerous technical concerns and allegations related primarily to construction and, to a lesser extent, design of the Comanche Peak Steam Electric Station (CPSES). The results of the TRT's evaluations and inspections were reported in Supplements 7 through 11 to NUREG-0797, "Safety Evaluation ReportRelatedtotheOperationofthepomanchePeakSteamElectric Station, Units 1 and 2" (SSERs 7-11). 3 Those reports sumarized the issues that required resolution before the NRC staff could reach a conclusion with regard to the adequacy of the design and construction of CPSES.
In response to early TRT findings, which were described in letters dated September 18, 1984, November 29, 1984, and January 8, 1985, TV Electric (lead applicant for the CPSES operating license) fomed the Comanche Peak Response Team (CPRT) and developed the CPRT Program Plan to address identified concerns. TV Electric initially submitted its CPRT Program Plan on October 8, 1984, and issued Revision 1 on November 21, 1984, in response to coments on the initial version that were received from the hRC staff during meetings on October 19 and 23,1984. The initial version .
and Revision 1 of the Program Plan were written before the pubitcation of SSERs 7 through 11, which provided the s+1ff's evaluation of the several ,
hundred allegations of design and constuction deficiencies. Following publication of the detailed staff evaluations contained in these SSERs and with the recognition of the need to resolve outstanding issues raised by groups other than the TRT, TU Electric submitted Revision 2 to the CPRT Program Plan on June 28, 1985. Revision 2 expandad on the earlier revision and provided for a corrective action program to be undertaken by TU Electric to resolve outstanding issues from a variety of sources.
In letters dated August 9 and September 30, 1985, the staff provided coments on Revision 2 to the CPRT Program Plan. TU Electric specifically addressed these staff coments in a letter dated November 22, 1985, and followed with Revision 3 to the CPRT Program Plan, dated January 27, 1986.
Revision 3 was supplemented ty letters from TV Electric dated January 31, February 7, February 28 (two letters) May 13 July 23 (two letters), i August 11, and October 17, 1986, t
y All of the references are identified in Section V. ,
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The results of the staff's review of Revn ton 3 to ti'e CPRT Program Plan were presented in Supplement 13 to NUREG W 97 (SSER 13) issued in May 1986, and in letters dated July 31, 1986, January 13, and February 24, 1987. The staff concluded that the CPRT Plan provides an acceptable process for resolving all current and any future issues; however, the staff's acceptance of many elements of the Plan was deferred for review
, during implementation. In addition, the Plan only provided general provisions for corrective actions to be developed based on the results of the two major programs comprising the CPRT Plan: the Qualit Construction (QOC)ProgramandDesignAdequacyProgram(DAP)yof .
Throughout an Independent this time, CYGNA Assessment ProgramEnergy IAP) of(Services (CYGNA) specific aspects continued to condu of the CPSES design, which had begun in late 1983. The ASLB had comented on the CYGNA IAP plan in March 1984 and the scope of the IAP was expanded to address ASLB concerns regarding design control. The LAP is continuing to be conducted under the formal protocol of an independent third-party review.
The results of the IAP are periodically reported in review issues lists (RIls). In response to eac1 issue in these lists TV Electric must develop and document an appropriate refonnse or corrective action.
In early 1987, based on the a n.its of the CPRT activities at that time.
TU Electric elected to develop a comprehensive Corrective Action Program (CAP) which subsumed many of the ongoing activities under the CPRT's design adequacy program. The CAP provides for a complete design validation, as described in more detail in the following evaluation; consequently, the CPRT evaluations in the design area were no longer required. This change, along with editorial changes and updates to reflect implementation details, was incorporated in Revision 4 to the CPRT Plan. The CAP activities and their relationship to the CPRT Plan were initially described in a letter dated January 29, 1987 and two letters dated June 25, 1987, which provided a description of contractor assignments, responses to staff questions, and Revision 4 to the CPRT Plan. Additional descriptions of the CAP activities were submitted bv letters dated August 20 and 28 and September 8 and 23, 1987. In addition, these matters were discussed in public meetings held on April 2 and 7 July 29 and 30, and December 9, 1987. In a letter dated December 18, 1987. TV Electric submitted initial responses to comments nade by the staff durtig the December 9 meeting; these responses included certain commitments, as described in the following evaluation, i
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II. DISCUSSION Yhe nature of the staff's evaluation of the TV Electric programs to establish the adequacy of the design and construction of CPSES acknowledges certain conditions which have resulted from the evolution of quality assurance and quality control (QA/QC) concerns during the course of the plant's design and construction, as follows:
First, the staff recognizes that varied design and construction deficiencies have been identified at CPSES. In addition, programmatic deficiencies have also occurred historically in the QA/QC activities during the design and construction of CPSES. Although the historical implementation of the QA/QC program has consequently been questioned, specific activities (e.g., inspections or tests) conducted under that QA/QC program may be acceptable, provided that the specific activity (e.g., inspection or test) is later validated under a program to which an adequate QA/QC program nas been applied.
Second, the existence of quality-related problems does not necessarily result in design or construction that is unacceptable or irrecoverable.
To establish the adequacy of design and construction under such circumstances, the utility's corrective action efforts must meet the following:
(1) the evaluations and inspections must be sufficiently comprehensive to identify any design or construction deficicncies such that, when corrected, there will be adequa % confidence that all safety-related structures, systems and components will function properly; (2) the corrective actions must be developed and implemented in accordance with applicabla regulatory requirements and commitments in the Final Safety Analysis Report (FSAR), as amended; and (3) these activities must be conducted in accordance with 10 CFR 50, Appendix B, so as to ensure that effective management controls are established and executed for all aspects of these activities.
The staff has evaluated the TV Electric programs against these general objectives to determine their adequacy.
Lastly, by virtue of the unusual history of CPSES, the TV Electric efforts have evolved into a complex set of [.rograms. In addition, the work assignments between the various cons 11tants, contractors and third-party review groups has added to this complexity. To simplify and clarify these efforts, the staff's evaluation is organized in five principal functional areas:
(1) third-party review (2) design validation (3) hardware validation (4) design-hardware reconciliation (5) QA/QC activities 3
The CAP, which encompasses functions 2 through 5 above, is divided into eleven "scopes of work" as shown in Table 1. While the functional approach is similar for each of the scopes of work, as described in the following_ evaluation, the specific methods and procedures vary according to the need (i.e., the nature of the issues and/or deficiencies to be resolved, and the design and construction practices associated with the scope of the work). The staff's evaluation of the methods and implementation of the CAP effort will similarly be organized according to these scopes of work and will be presented in a number of evaluations following the issuance of TU Electric's "Project Status Reports" (PSRs).
It is also important to note that TV Electric has committed to develop and implement a retesting program for safety-related systems and components in Unit 1 because most of the preoperational test program previously completed on Unit i has been affected by design changes, modifications and repairs to the various systems and equipment which have resulted from the corrective action activities. The development of the retesting program is dependent, in large part, on the completion of the design and hardware validation, reconci'iation of design and construction activities, and procedural improvements stemming from past testing experience. The staff expects that the complete preoperational testing program will be repeated, except where TU Electric can amply demonstrate that specific tests need not be repeated or thnt alternative testing is warranted. In a letter dated December 18, 1987, TU Electric indicated that the scope of the Unit 1 preoperational retesting will be develoned by the Joint Test Group in l
accordance with procedure STA 309A, "Deveiopment of System Test Matrices,"
l and approved by the Station Operations Review Committte. Written
! justification will be provided whenever the acccptance criteria from the l previous preoperational test is not retested. The staff finds this commitment acceptable and will monitor the implementation of the retesting during routine inspection activities.
l It should also be notea that, while TV Electric programs do not explicitly l provide a separate method for resolving other pending licensing issues i resulting from the staff's review of the FSAR, the CAP efforts provide the framework to address those issues. The pending licensing issues, which were last compiled in Supplement 12 to NUREG-0797, include open issues from previous staff evaluations of the CPSES FSAR and other issues that might arise from NRC Bulletins, Infonnation Notices, and Generic Letters.
The resolution of these issues will be reported in future supplements to NUREG-0797.
I 4
Table 1 CPSES CORRECTIVE ACTION PROGRAM SCOPES OF WORX 1arge bore s'pe supports l
small bore pipe supports cable tray hangers conduit supports - trains A & B, and train C larger than 2" conduit supports - train C smaller or equal to 2" heating, ventilating and air conditioning (HVAC) mechanical civil-structural electrical instrumentation and control equipment qualification I
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III. EVALUATION The staff's review of the changes to the CPRT plan associated with Revision 4 and the CAP plans is organized into five functional areas:
third-party review, design validation, hardware validation, design-hardware reconciliation, and QA/QC activities.
A. Third-Party Review The major third-party review effort for CPSES desicn and construction is that associated with the CPRT Program Plan. The CPRT is comprised of consultants and contractors, who were not originally associated with the design and construction of CPSES, organized in discipline groups. The purpose of the CPRT, simply stated, was and is to evaluate each of the "external source" issues, conduct a "self-initiated" evaluation to seek out potentially unidentified deficiencies based on sampling typical design and construction activities, and determine root causes, adverse trends and generic implications of any safety-significant deficiencies that may be indicative of significant programmatic weaknesses. The CPRT findings from this effort are then presented to TV Electric as recommendations for the utility to resolve in a corrective action program. The activities of the CPRT are monitored and directed by a Senior Review Team (SRT) comprised primarily of consultants (except for the chairman of the SRT who is the TV Electric Vice President for Nuclear Engineering) recognized for their experience and expertise. The CPRT and SRT effectively serve as a specialized advisory group to TV Electric.
The naff's evaluation of the CPRT Program Plan, through Revision 3, was presented in Supplement 13 to NUREG-0797. That evaluation focused on (1) the Quality of Construction Program (Q0C), (2) the Design Adequacy Program (DAP), and (3) the CPRT QA/QC activities, recognizing that the third-party does not have responsibilities in all of the areas associated with the eighteen criteria of 10 CFR 50, Appendix B. In addition, the staff devoted particular attention to the sampling approaches for the "self-initiated evaluations," in both DAP and Q0C, which were intended to determine whether there were any additional specific or programmatic deficiencies in either design or construction. In Supplement 13, the staff concluded that the CPRT Plan provides an acceptable process for resolving all current and any future external source issues; however, the overall adequacy of the plan was left to be demonstrated primarily by the implementation and results.
Since Supplement 13 was issued TU Electric has developed the CAP, based on preliminary findings from the CPRT self-initiated rey Pews. The CAP provides for a comprehensive design and hardware validat,on, as discussed later in more detail. The CPRT Plan was subsequently revised (Revision 4) to redirect CPRT design review activities so as to eliminate duplication of effort that would be assumed by the CAP activities. That revision also clarifies the details of implementation of the Plan's elements based on experience and describes CPRT oversight responsibilities for the newly formed CAP efforts.
The only substantive change associated with Revision 4 to the CPRT Plan is the suspension of DAP activities. The other changes associated with Revision 4 to the CPRT Plan are editorial or clarify details. The CAP 6
provides for a complete validation of the Gibbs and Hill design which will be conducted by new arciiitect-engineering firms, as described in III.B below. In particular, under Revision 4, the CPRT would not evaluate root causes and generic implications of design deficiencies as they would have under the sampling approach under Revision 3 of the Plan. The generic implications evaluations were necessary to determine when the samples had to be expanded. While the staff agrees that generic implications evaluations are not necessary when a complete design validation is performed, it is still necessary to identify the nature of the deficiencies and weaknesses that have occurred in the design process in the past in order to evaluate the adequacy and sufficiency of the corrective and preventive actions for current and future design activities. Consequently, the staff will require that TV Electric identify the nature of the design deficiencies (i.e., design root causes) that have occurred in the past. In its December 18, 1987 letter, TU Electric committed to conduct such an evaluation and submit the results to the staff by February 1, 1988. The staff finds this commitment acceptable.
The staff has also reviewed the status of the actions required as a result of review of Revision 3 of the CPRT Plan, as presented in Supplement 13 to NUREG-0797 (SSER 13). Because of the creation of the CAP effort, a number of actions required under SSER 13 are not applicable or have been satisfied; the remaining actions will be addressed during the staff's review of the CAP implementation. The status of the SSER 13 actions is summarized in Appendix A.
With respect to the status of the issues identified in SSERs 7 through 11, from which the CPRT Plan was developed, the complexity of TV Electric's programs has hampered the staff's monitoring of these issues and the actions needed to resolve them. Accordingly, the staff will require that l
TV Electric provide a matrix which identifies where the resolution of each
- of the TRT issues and associated actions is addressed. In its December i 18, 1987 letter TV Electric comitted to provide a CPRT "External Source l Issue Matrix" by February 1, 1988. The staff finds this commitment i acceptable.
l With Revision 4 to the CPRT Plan, the CPRT/SRT oversight and advisory role l
- has also been modified by the establishment of TV Electric's Technical l
Audit Program (TAP) and SWEC's Engineering Functional Evaluation (EFE);
these QA activities are described later in more detail. The CPRT/SRT is conducting reviews of these programs to evaluate the adequacy of the CAP efforts, including the effectiveness of the related QA/QC activities performed by TV Electric, and to form part of the basis for judging the specific corrective actions which TU Electric has developed in response to the CPRT recommendations.
The CPRT performs safety-significance evaluations for the QOC program, in i
order to determine when additional sampling is required and to provide l part of the basis for developing reconnendations to TV Electric.
Irrespective of the CPRT's safety significance evaluation, TU Electric documents all of the CPRT findings as potential nonconformances and performs a separate safety significance evaluation, in accordance with 10 CFR50.55(e). If warranted, TV Electric issues a significant deficiency analysis report (SDAR).
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The staff continues to audit and inspect the CPRT activities to assure conforn'ance with the commitments in the CPRT Plan. The results are reported regularly in inspection reports, including whether any violations or deviations were identified during the reporting period. Because CPRT operates essentially as a contractor, TU Electric responds to these inspection reports by identifying those actions the CPRT/SRT has taken to resolve identified deficiencies or weaknesses, and preventive actions TU Electric or CPRT has taken to prevent their recurrence. The resolution of each issue is reported in a subsequent inspection report.
Inasmuch as the staff's inspection of CPRT activities began in July 1985 and the CPRT activities began in November 1984, the staff will require that, for completeness, TV Electric confirm that all of the corrective and preventive actions, which have resulted from the staff's inspection activities, have been applied to those activities conducted prior to July 1985. In its December 18, 1987 letter, TV Electric committed to provide such a confirmation in writing by February 1, 1988. The staff finds this commitment acceptable.
Separate from the CPRT, CYGNA is continuing to conduct an Independent Assessment Program (IAP) of the design and design control process (i.e.,
procedures) for Comanche Peak. The CYGNA review is conducted under a fonnal protocol to ensure its independence. The status of the CYGNA reviewisperiodicallypublishedinreviewissueslists(RIls). TV Electric treats the CYGNA findings as external source issues and they respond directly to CYGNA regarding their concerns. The RILs are periodically updated to indicate how specific issues have been resolved.
The staff has audited the CYGNA review activities and continues to monitor TV Electric's resolution of the issues raised by CYGNA.
The staff intends to consider the CPRT third-party activities afthe principle means by which TU Electric will identify design and construction deficiencies for CPSES. The staff will review the CYGNA IAP and TAP /EFE l
audits (see Section III.E on QA/QC) to the extent that they provide l information on the effectiveness of the CPRT and CAP activities. Based on I the staff's review of Revision 4 to the CPRT Plan and the inspection of the CPRT activities conducted thus far, the staff concludes that the CPRT l
l activities provide an adequate basis for identifying the design and construction deficiencies which could potentially affect safe plant l
l operation, subject to the clarifications provided by the root cause I
evaluation for design, the TRT issue / resolution matrix, and confinnation l
of the applicability of the corrective actions resulting from NRC 1 inspections, as discussed above. The staff's review of the implementation
' of the CPRT Plan will be reported in a separate evaluation of the l "Collective Significance Report," including the related CPRT supporting reports.
L l
l B. Design Validation I As previously discussed, TV Electric decided to conduct a comprehensive CAP based on the preliminary results of the CPRT evaluations. The I principal feature of the CAP is a complete validation of the safety-related aspects of the CPSES design. The design validation is being conducted by Stone and Webster Engineering Company (SWEC), Ebasco Services l Incorporated, and Impell Corporation; these are architect-engineering l
1
firms that were not involved in the original design of Comanche Peak and are collectively referred to as the CAP contractors.
The.TU Electric Design Basis Consolidation Program (DBCP) embodies the procedures for managing and controlling the design validation activities and products. The first step requires that all of the applicable licensing commitments, industry standards and regulatory requirements are assembled into a design basis document (DBD) for a given design or design process. The DBDs also appropriately incorporate the design, procedural or programmatic changes resulting from the CPRT, as reflected in generic issues reports (GIRs) issued by TV Electric.
The CAP effort is divided into eleven scopes of work, as previously shown in Table 1. For each of these scopes of work there is an evaluation process and corresponding set of DBCP-related project procedures (ECE 9.04) which control the design validation, the subsequent hardware validation and the design-hardware reconciliation. The evaluation process reflects the nature of the design process involved in the particular scope of work and directs the manner by which the CAP contractors are to confirm, modify or replace the design or design analysis for safety-related structures, systems and components so as to satisfy the applicable D8D.
Staff audits of design validation activities so far have observed that all design analyses are being checked against the criteria in the DBD. The staff understarids that there may be circumstances such that if one analysis of a like set satisfies all of the criteria, then the set of analyses may be considered validated. The staff also understands that where an analysis must be modified or replaced, then all analyses of a like set must be checked against the affected design criteria.
During the course of the design validation, the CAP contractors will identify specific assumptions and as-built configurations which require later field verification. There will also be circumstances where amendments to the FSAR may be proposed. In order to ensure that such cases are identified and evaluated as early as practicable, the staff will require that TU Electric describe the system that will identify and track potential FSAR amendments and then notify the staff when an amendment is being prepared so that appropriate provisions for the staff's review can be made. In addition, to facilitate the staff's review of the design validation activities, the staff will require that TU Electric catalog the exceptions and application of alternative criteria for the principal design codes and standards. In its December 18, 1987 letter, TV Electric identified the applicable procedures for identifying and processing FSAR changes and comitted to review those procedures to improve the process and assure early notification of proposed FSAR changes. In addition, TV Electric provided information related to the application of the code requirements for the American Institute of Steel Construction in a letter dated December 15, 1987. Similar efforts are underway for the American Concrete Institute, American Society of Mechanical Engineers and various electrical codes. The staff will continue to pursue this matter with TU Electric during the implementation of the CAP activities.
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F-e o When the design validation of a particular analysis set is complete, the analysis and associated DBD are compiled into a design validation package (DVP) for the subsequent hardware validation and design-hardware reconciliation phases, as discussed in Sections C and D below.
The staff concludes that the design validation provisions of the CAP provide adequate design control procedures to assure that consistent design criteria have been established, the safety-related structures, systems and components satisfy those criteria, and that design deficiencies will be resolved in accordance with the FSAR, as amended, and the applicable regulatory re The design validation will accomplish this through (1) quirements.the use of the design basis documents (DB which identify the applicable regulatory requirements, design standards and licensing comitments, (2) the DBCP-related project procedures provide the means to manage and control the certification of existing analyses or reanalysis, and (3) the DVPs provide the means to assemble auditable design documentation. On this basis, the staff concludes that the design validation provisions of the CAP are acceptable.
C. Hardware Validation Once the design has been validated, each of the eleven scopes of work provides procedures to validate the constructed, safety-related structures, systems and components (i.e., hardware) to that design. The reinspection scope is primarily based on the results of the CPRT quality of construction program with respect to the construction attributes for the installed hardware.
The hardware validation effort provides that, for each CAP scope of work identified in Table 1, the related construction attributes are compiled and reviewed by TV Electric's engineering staff. Reinspection or an engineering evaluation is required for each attribute for which there is (1) a related recommendation from the CPRT, (2) a design change in the associated structure, system or component, or (3) a modification to the associated structure, system or component. Whether a reinspection or engineering evaluation is conducted depends on the nature of the attribute, its accessibility, and its relative importance to the design and is controlled through the DBCP-related project procedures for hardware I
validation.
t The procedures associated with the selection of construction attributes and the conduct of the reinspections or evaluations are collectively I
! referred to as the Post-Construction Hardware Validation Program (PCHVP) l as specified in TU Electric's procedure ECE 9.04. The selection of I
attributes to reinspect inherently presumes that those "final acceptance" attributes for which the CPRT did not make a recommendation, or are otherwise related to a design change or plant modification, would satisfy the applicable standards and regulatory requirements. As such, the PCHVP relies principally on the CPRT sample inspections.
As previously discussed, the staff concludes that the CPRT provides an adequate basis for identifying construction deficiencies. However, the extent to which the CPRT recomendations form an adequate basis for defining the necessary I corrective actions depends on the sufficiency of the root cause and generic 1
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implication evaluations which will not be fully revealed until the review of the Collective Evaluation Report is completed and related open items from the staff's inspection of the CPRT activities are resolved. Consequently, in order to ensure that the basis for excluding certain attributes from further reinspection or evaluation is clearly articulated, the staff will require that TU Electric group the excluded attributes according to the construction processes involved, and provide a written justification which will explain how the excluded construction attributes satisfy the applicable regulatory requirements and licensing comitments. In its December 18, 1987 letter, TV Electric committed to propose a method for reviewing the engineering evaluations supporting the groups of uninspected construction attributes and the associated justifications. The staff finds this commitment acceptable and will review this matter as part of the implementation of the CAP activities.
The staff concludes that the hardware validation provisions of the CAP provide appropriate procedural controls which control both the scope and method for the reinspection of the plant's structures, systems and components, so as to provide reasonable assurance that any construction deficiencies will be properly identified and corrected, subject to acceptance of the justification for uninspected attributes. On this basis, the staff concludes that the hardware validation provisions of the CAP are acceptable.
D. Design-Hardware Reconciliation During the course of the hardware validation, and the associated confirmation of design assumptions and as-built configurations, it can be expected that some differences between the design and hardware will be found. The reconciliation phase of the CAP relies on standard procedures to ensure that these differences are appropriately corrected.
Depending on the nature of the difference, either the design must be changed or the affected hardware modified. In either case, the reconciled design and as-built configuration must satisfy the criteria in the DBD or a change in those criteria must otherwise be approved. The resulting changes will then be reflected in the DVP so as to form the documented design of record.
The DBCP-related project procedures provide the means for TV Electric to control the CAP activities and assure the consistency of the CAP contractors' activities and products. Each CAP contractor has developed a DBCP plan which provides for a verification of the final design through satisfactory implementation of their associated CAP procedures, as depicted by the process diagrams in TV Electric's August 28, 1987 letter.
When differences are identified, these DBCP plans work in conjunction with the TV Electric QA procedures (principally, NE0 3.05) for nonconformance reports (NCRs), programatic corrective action requests (CARS), and significant deficiency analysis reports (SDARs). The QA procedures assure TU Electric control over the disposition of the differences, appropriate tracking, and documentation that will be reflected in either procedural changes or design /hardwarechangesintheassociateddesignvalidationpackage(DVP).
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r-The staff concludes that the provisions for design-hardware reconciliation in the CAP provide appropriate procedural controls, and are, therefore, acceptable.
E. QA/QC Activities As a result of the CPRT evaluations (including programmatic concerns raised by the external source issues), among other things, TV Electric has substantially improved the procedures for design and construction activities and has instituted organizational changes to ensure effective management control-and involvement in these activities. These changes have been reflected periodically in TV Electric's response to issues raised in NRC inspection reports over the last two years and were described during the public meeting held on July 29-30, 1987.
In addition to the improvements to the overall TV Electric QA program, TV Electric has implemented two significant measures to provide increased confidence in the effectiveness of the CAP, including the associated QA/QC
, activities of the CAP contractors. These measures are the Technical Audit Program (TAP) and the Engineering Functional Evaluation (EFE). The TAP is an integral part of the TV Electric QA program. The TAP audits are conducted by qualified and experienced QA staff and senior-level engineers / specialists to assure the technical and progrannatic effectiveness of the CAP and to provide oversight of corrective actions resulting from the CPRT recommendations. The EFE is conducted under the SWEC corporate QA program. The EFE is a "vertical slice" evaluation (i.e., cutting through all areas of engineering, design, construction, and related QA/QC) of the Containment Spray System, the Control Room HVAC System, and the Safeguards Building. The EFE provides an in-depth technical evaluation of the CAP to assure that (1) the progran has been implemented, (2) the plant design has been validated, (3) appropriate testing has been completed, and (4) appropriate measures are in place for maintaining the design basis during operation of the plant. The staff has reviewed the scope of the EFE and TAP and finds them acceptable to monitor the CAP activities.
In general, the staff has found that the current QA/QC activities at Comanche Peak are effective and comply with the provisions of 10 CFR 50, Appendix B. The extent of compliance and the effectiveness of the improvements in the TV Electric QA program have been demonstrated by the lack of substantive violations from the Appendix B requirements and the prompt and effective response to violations which have occurred. These findingshavebeendescgbedindetailinthestaff'sinspectionreports The staff will continue to audit and inspect issued since mid-1985. -
these activities for compliance with 10 CFR 50, Appendix B, and will review the results as they pertain to the overall effectiveness of the CAP.
2/ See references in Section V.
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IV. CONCLUSION The results of the CPRT and CAP activities will be documented by TV Electric as follows:
(1) The CPRT-results will be presented in three reports associated with the design adequacy review, the results reports for each of the issue-specific action plans, the collective evaluation report summarizing the construction-related findings and generic implications, and the collective significance report.
(2) The CAP results will be presented in eleven Project Status Reports (PSRs), one for each scope of work identified in Table 1. Each PSR will summarize the results of the related DVPs and identify the manner by which the external source issues have been resolved, as is currently reflected in the generic issues reports (GIRs). In addition, each of the DVPs will include the validated design analyses, hardware validation, reconciliation and related QA/QC documentation.
The foregoing reports will provide the basis upon which TV Electric intends to rely in demonstrating the adequacy of the design and construction of Comanche Peak. However, the staff notes that these programs are planned primarily with respect to Unit 1 and the common parts of the plant. While the intent of these programs is to be applied to Unit 2, the specific plan for Unit 2 has not been presented. Consequently, the staff will require that TV Electric describe the applicability of the CAP to Unit 2. In its December 18, 1987 letter, TV Electric indicated that a review of the CAP is being conducted to distinguish between those actions for Unit 2 which will result directly from the CAP efforts and those which are incorporated into the routine construction management process. The results of that review will be submitted by February 1, 1988. The staff finds this commitment acceptable.
Based on the staff's review of the TV Electric program descriptions, inspection and audit of associated CPRT and CAP activities, and consideration of public comments, the staff concludes that the TV Electric programs provide the necessary means to (1) identify design and construction deficiencies that could affect safe operation of the plant, (2) design and implement appropriate corrective actions to resolve those deficiencies in accordance with the applicable regulatory requirements and licensing commitments, and (3) conduct these activities in accordance with the requirements of 10 CFR 50, Appendix B, so as to ensure effective management controls for all aspects of these activities. On this basis, the staff concludes that, subject to the conditions identified in this evaluation, Revision 4 to the CPRT plan and the CAP plans are acceptable.
The staff will continue to monitor the implementation of these programs through its inspection activities and will report on the review of the programs' results in safety evaluations for the CAP scopes of work, as summarized by the PSRs, and the CPRT/SRT Collective Significance Report and related reports. The staff will particularly look for the adequacy of the procedural controls to implement corrective and preventive actions, including the training of TU Electric personnel to assume responsibility for the contractors' activities.
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V. REFERENCES
- 1. Code of Federal Regulations, Title 10, Chapter 1, Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
- 2. "Final Safety Analysis Report for-the Comanche Peak Steam Electric Station Units 1 and 2," Docket Numbers 50-445 and 50-446', dated April 1978, including Amendments through.65, dated November 1987.
- 3. NUREG-0797, "Safety Evaluation Report Related to Operation of
' Comanche Peak Steam Electric Station, Units 1 and 2," dated July 1981, including Supplements through 13, dated May 1986.
- 4. D. G. Eisenhut, NRC, to M. D. Spence, TU Electric,
Subject:
"Comanche Peak Review," dated September 18, 1984.
- 5. -D. G. Eisenhut, NRC, to M. D. Spence, TV Electric,
Subject:
"Comanche Peak Review," dated November 29, 1984.
- 6. D. G. Eisenhut, NRC, to M. D. Spence, TU Electric,
Subject:
"Comanche Peak Review," dated January 8, 1985.
- 7. V. S. Noonan, NRC, to W. G. Counsil, TV Electric,
Subject:
"Issuance of Supplement 13 to NUREG-0797 Related to Operation of the Comanche Peak Electric Station, Units 1 and 2," dated June 9,1986.
- 8. W. G. Counsil, TU Electric, to NRC,
Subject:
"Comanche Peak Corrective Action Program," TXX-6247, dated January 29, 1987.
- 9. "Comanche Peak Response Team Program Plan and Issue-Specific Action Plans," Revision'4, dated June 18, 1987.
- 10. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Response to Request for Additional Information in Conjunction with Prngram Plan Update "
TXX-6500, dated June 25, 1987.
- 11. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Submittal of Revision 4 to the Comanche Peak Response Team (CPRT) Program Plan,"
TXX-6540/CPRT-932, dated June 25, 1987.
Subject:
"Comanche Peak Programs," TXX-6631, dated August 20, 1987.
- 13. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Corrective Action Program (CAP) Description and Flow Diagrams," TXX-6675, dated August 28, 1987.
- 14. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Technical Audit Program and Engineering Functional Evaluation," TXX-6676, dated September 8, 1987.
- 15. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Post Construction Hardware Validation Progran (PCHVP) Engineering Evaluation Methodology," TXX-6712, dated September 8, 1987.
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- 16. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Post Construction Hardware Validation Program Attribute Matrix," TXX-6783, dated September 23, 1987.
Subject:
"Deviations from Codes, Stan4 rds, and-Regulatory Guides," TXX-7068, dated December 15, 1987.
- 18. W. G. Counsil, TV Electric, to USNRC,
Subject:
"Response to NRC Comments on CPSES Corrective Action Efforts," TXX-7099, dated December 18, 1987.
Public Meeting Transcripts
- 19. April 2, 1987, Transcript of Public Meeting on the Comanche Peak Response Team Program, at Bethesda, Maryland. Docket Nos.
50-445/446.
- 20. April 7,1987, Transcript of Public Meeting on the Comanche Peak Response Team Program, at Dallas, Texas. Docket Nos. 50-445/446,
- 21. July 29-30, 1987, Transcript of Public Meeting on the Comanche Peak Response Team and Corrective Action Programs, at Dallas, Texas.
Docket Nos. 50-445/446.
- 22. December 9, 1987, Transcript of Public Meeting on the Status of Comanche Peak Response Team and Corrective Action Programs, at Dallas, Texas. Docket Nos. 50-445/446.
Related Inspection Reports
- 23. R. P. Denise, NRC, forwarding Inspection Report (IR) 50-445/85-11, 50-446/85-06, dated October 11,1985(CPRT).
- 24. E. H. Johnson, NRC, forwarding IR 50-445/85-13,50-446/85-09, dated December 24, 1985 (CPRT).
- 25. E. H. Johnson, NRC, forwarding IR 50-445/85-14,50-446/85-11, dated March 6, 1986 (CPRT).
- 26. E. H. Johnson, NRC, forwarding IR 50-445/85-16,50-446/85-13, dated April 4, 1986 (CPRT).
- 27. J. M. Taylor, NRC, forwarding IR 50-445/85-17,50-446/85-14, dated January 21, 1986 (DAP).
- 28. E. H. Johnson, NRC, forwarding IR 50-445/85-18,50-446/85-15, dated May 12, 1986 (CPRT).
- 29. E. H. Johnson, NRC, forwarding IR 50-445/86-01,50-446/86-01, dated August 29, 1986 (CPRT).
- 30. E. H. Johnson, NRC, forwarding IR 50-445/86-03,50-446/86-02, dated October 17, 1986 (CPRT).
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- 31. E. H. Johnson, NRC, forwarding IR 50-445/86-07, 50-446/86-05, dated December 22, 1986 (CPRT).
- 32. E. H. Johnson, NRC, forwarding IR 50-445/86-15, 50-446/86-12, dated December 22,1986(CPRT).
33, 8. K. Grimes, NRC, forwarding IR 50-445/86-17, 50-446/86-14, dated September 10,1986(DAPQA).
- 34. J. M. Taylor, NRC, forwarding IR 50-445/86-18, 50-446/86-15, dated September 9, 1986 (DAP).
- 35. J. M. Taylor, NRC, forwarding IR 50-445/86-19, 50-446/86-16, dated November 4, 1986 (DAP).
- 36. E. H. Johnson, NRC, forwarding IR 50-445/86-22, 50-446/86-20, dated March 18,1987(CPRT).
- 37. E. H. Johnson, NRC, forwarding IR 50-445/86-26, 50-446/86-22, dated April 2, 1987 (CPRT).
- 38. E. H. Johnson, NRC, forwarding IR 50-445/86-31,50-446/86-25, dated June 1, 1987 (CPRT).
- 39. E. H. Johnson, NRC, forwarding IR 50-445/87-02, 50-446/87-02, dated June 22,1987(CPRT).
- 40. C. I. Grimes, NRC, forwarding IR 50-445/87-04, 50-446/87-04, dated August 31, 1987 (CPRT).
- 41. R. F. Warnick, NRC, forwarding IR 50-445/87-06, 50-446/87-05, dated i August 5, 1987 (CPRT).
- 42. R. F. Warnick, NRC, forwarding IR 50-445/87-09, 50-446/87-07, dated l
June 26,1987(CPRT).
- 43. R. F. Warnick, NRC, forwarding IR 50-445/87-11, 50-446/87-09, dated September 2, 1987 (CPRT).
- 44. R. F. Warnick, NRC, forwarding IR 50-445/87-13, 50-446/87-10, dated l October 7, 1987 (CPRT).
- 45. R. F. Warnick, NRC, forwarding IR 50-445/87-16,50-446/87-13, dated
! October 23, 1987 (CPRT).
l R. F. Warnick, NRC, forwarding IR 50-445/87-18, 50-446/87-14, dated
- 46. '
l November 5, 1987 (CPRT).
- 47. C. I. Grimes, NRC, forwarding IR 50-445/87-19,50-446/87-15, dated
' October 15, 1987 (Design Validation Program).
- 48. R. F. Warnick, NRC, forwarding IR 50-445/87-23, 50-446/87-17, dated November 16,1987(CAP).
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- 49. 'R. F. Warnick, NRC, forwarding IR 50-445/87-24,50-446/87-18, dated November 12, 1987 (TAP).
- 50. R. F. Warnick, NRC, forwarding IR 50-445/87-25,50-446/87-19, dated t . November 20, 1987 (CAP).
- 51. R. F. Warnick, NRC, forwarding IR 50-445/87-29,50-446/87-21, dated December 16, 1987 (CPRT).
- 52. R. F. Warnick, NRC, forwarding IR 50-445/87-30,50-446/87-22, dated December 16,1987(CPRT, CAP).
- 53. R. F. Warnick, NRC, forwarding IR 50-445/87-31,50-446/87-23, dated December 18, 1987 (CAP).
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r-APPENDIX STATUS OF ACTIONS REQUIRED BY SSER 13 Supplement 13 to NUREG-0797 identifies specific issues associated with the CPRT Plan (Revision 3) that were to be resolved during the implementation of the Plan. Generally, Appendix B to SSER 13 identifies issues associated with the Quality of Construction Program (QOC) and Appendix C identifies issues associated with the Design Adequacy Program (DAP). Because of the implementation of the Corrective Action Program and other events that have occurred since SSER 13.was issued, some of those issues have been resolved or are now moot, while the remaining issues continued to apply to implementation of the current CPRT/ CAP activities.
The staff has reviewed the actions required by SSER 13 and categorized them as follows: (1) issues that are still applicable to the current CPRT/ CAP activities and (2) issues that have been resolved or are not applicable to the current CPRT/ CAP plans. Each of the issues is listed below, in accordance with these groups, by reference to the applicable section of the SSER 13 appendices.
GROUP 1 The following issues continue to apply to the current CPRT/ CAP activities.
These issues primarily concern the implementation of the quality of
. construction activities and the basis for the CPRT's recommendations. These issues will be reviewed in conjunction with the staff's review of the implementation of the associated CPRT results (i.e., Collective Significance Report) and/or CAP scope of work (i.e., Project Status Report), and have been addressed in conjunction with the related staff inspections.
ISSUE SSER 13 Reference Address loss of margin in the safety B.1(1) significance evaluations.
Details of the root cause evaluations B.1(2) for design and construction.
Details of the generic implications B.1(3) evaluations (only applies to construction now).
Homogeneity of the construction B.1(4) populations.
Stratification of construction B.1(5) populations.
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c ISSUE (continued) SSER 13 Reference Restructuring construction populations. B.1(6)
Matrix inspection attributes and B.1(7) hardware populations.
Roct cause and generic implications of B.3, ISAP V.a skewed welds in NF supports.
. Sampling confidence for plug welds. B.3, ISAP V.d Root cause and generic implications 8.3, ISAP V.e of main steam support stresses.
DAP and project inconsistencies in C.2 (4) cable tray methodology.
Review scope for piping and pipe C.3 (2) supports.
Applicability to Class 5 piping. C.3(4)
GROUP 2 The following specific issues have been resolved, as described in the cited references. However, it is important to note that the general concerns, particularly with respect to the root causes of design deficiencies (see Section III.A, "Third Party Review"), will be reviewed as part of the implementation effectiveness of the CPRT/ CAP activities.
ISSUE / RESOLUTION REFERENCE SSER 13 Reference The ISAP audit program was resolved in a B.1(8) letter from V. Noonan, NRC, to W. Counsil, TU Electric, dated January 13, 1987.
The ISAP for Hot Functional Testing was B.2, ISAP III.a.1 resolved in a letter from V. Noonan, NRC, to W. Counsil, TU Electric, dated July 31, 1986.
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r ISSUE /RESOLUTIONREFERENCE(continued) SSER 13 Reference Specific issues related to the implementation C.1 (1) thru C.1 (14) of the DAP and related DSAPs were evaluated during the NRC's inspection of TERA activities C.2 (1) thru C.2 (4) as they related to the design validation program,
.es described by issue in Appendix B C.3(2) to Inspection Report 87-19/87-15, dated Octobe.r 15, 1987; however, most of these C.4 issues became moot when TV Electric began implementation of a complete design validation.
The resolution of these issues is still germane to the extent that DAP findings and related staff concerns identify specific issues which will be resolved by the CAP. The design issues associated with the cable tray methodology and piping / pipe support scope are no longer applicable.
Issue Specific Action Plans format. 8.3, ISAP I.d.3 Additional comments on ISAP VII.b.1 ISAP VII.a.3 issued by letter from V. Noonan, NRC, ISAP VII.a.4 to W. Counsil, TU Electric, dated ISAP VII.a.5 July 31, 1986. Because inspection and ISAP VII.a.6 review of these plans is underway, the ISAP VII.a.7 format concerns no longer apply; the ISAP VII.a.8 results of the staff's review of these ISAP VII,b.1 ISAPs will be included in an evaluation ISAP VII,b.4 of CPRT.
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