IR 05000508/1985006
| ML20198E548 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 10/25/1985 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8511140084 | |
| Download: ML20198E548 (1) | |
Text
-
.
\\
Docket No. 50-508 OCT 251985 Washington Public Power Supply System Attention: Mr. D. W. Mazur Managing Director P. O. Box 968 3000 George Washington Way Richland, WA 99352 Gentlemen-SUBJECT:
DESIGN VERIFICATION ACTIVITIES - WNP-3 References: (1) letter, G. C. Sorensen to J. B. Martin, dated 6/3/85; (2) Letter, G. A. Block to J. L. Milhoan, dated 7/30/85; (3) Letter, G. C. Sorensen to J. B. Martin, dated 8/16/85; (4) Letter, G. C. Sorensen to J. B. Martin. dated 8/20/85 Your letter of June 3,1985 (Reference 1) attached a copy of your Engineering Assurance Program (EAP) Plan for our review and approval.
This EAP is intended to provide a self assessment of the design and design process used for construc-ting the WNP-3 plant to ensure that Final Safety Analysis Report (FSAR) commit-ments and NRC regulations have been met.
You indicated that the EAP would be the second module of your Readiness Review Program.
Initial comments were transmitted to you by D. F. Kirsch's letter of August 2,1985.
Your response to our comments were attached to your letter of August 16, 1985 (Reference 3).
Subsequently your letter of August 20, 1985 (Reference 4) transmitted the resumes of members of the oversight committee for our concurrence.
Additionally, G. Block's letter of July 30, 1985 (Reference 2) provided a set of EAP procedures and instructions.
Based on the NRC staff review of the EAP plan, it appears that the program can provide a satisfactory assessment of the design and the design process.
Therefore, I have determined that your commitment to cnnduct an EAP as a part of your Readiness Review Program and the EAP plan itself are acceptable.
NRC staff comments which should be considered in implementation of the EAP are provided in the attachment of the enclosed NRC Evaluation Report.
The Quality Assurance Branch of the Office of Inspection and Enforcement, which has lead NRC responsibility for inspection of these activities, will be inspecting your implementation of the engineering assurance program to determinc if your design reviews provide confirmation that your plant design complies with your FSAR commitments and NRC regulations.
Sincerely
.
OrMost sinn,td by John U, Martin J. B. Martin Regional Administrator As stated Region (I" WPAng *V
.h RTUodds AEChaffee DFK h-JB artin 10/d/85 10/2r/85 10/.W/85
/85 10 M /85 l
~ [)l
~-
0511140004 051025 f,.'gg PDR ADOCK 0000 O
O I
-
. -
-
-
.
.
.
1 UNITED STATES NUCLCAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF QUALITY ASSURANCE, VEND 0R, AND TECHNICAL TRAINING CENTER PROGRAM QUALITY ASSURANCE BRANCH Report No. 50-508/85-06 Licensee: Washington Public Power Supply System Docket No. 50-508 Construction Permit No. CPPR-154
,
Facility Name: Washington Nuclear Project 3 Reviews Conducted:
August 1, 1985 through September 13, 1985 Site Visit Conducted:
July 2, 1985 Reviewers:
E. V. Imbro, Senior Inspection Specialist, IE H. 8. Wang, Inspection Specialist, IE R. W. Parkhill, Inspection Specialist, IE hI Approved:
//
.
A t@
/
J.~~ U. Milhoan, Chief
-
Date Signed l
Licensing Section l
Quality Assurance Branch l
-
-
'
hl, l.l l,,d.~_, ;~;j t?/.3 5_k ('
G. 1. Ankfum, Chief Date S~igned
l Quality Assurance Branch M
~
{
'l f
/f f l $~
'
Brian K. Grimes, Direct 6r Date Signed Division of Quality Assurance, Vendor and Technical Training Center Programs l
l np i n o l +
^ A outvalUlG5
~
--
- - - - -
- - -
-
-
- -
- -
- - -
-
- -
- -
- -
- -
-
.
_.
-. =
--
.
- -
- - - -
.
. _ _ -
.
.
_ -. -.
.~
_
.
.
.
.
I WASHINGTON NUCLEAR PROJECT 3 (WNP-3) READINESS REVIEW MODULE NO. 2
'
'
OESIGN REVIEW PROGRAM (ENGINEERING ASSURANCE PROGRAM, EAP)
I j
SUMMARY
!
A Readiness Review Program is being conducted at the initiative of the Washington Public Power Supply System (WPPSS) management to assess the adequacy of completed work in the deferred WNP-3 Project prior to restart of construction, and to provide additional assurance regarding the adequacy of the plant's design and design process. Module No. 2 of the readiness review program presents a plan of the Engineering Assurance Program that WPPSS intends to use to ensure that the design of the WNP-3 Project conforms to licensing commitments and NRC t
!
regulations.
,
l WPPSS notified NRC in January 1985 of its intention to include the EAP at its WNP-3 project.
Several meetings were held with the licensee to discuss their
'
EAP.
An evaluation of the EAP plan and other related procedures was performed l
.
by NRC reviewers from the Office of Inspection and Enforcement (IE).
The
~
,
evaluation was performed through a detailed r(view of the EAP plan and related procedures, meetings, and telephone co'nversations with the licensee to discuss
,
j details of.the' program.
,
.
.
.
-
'
,
Our evaluation indicated that the EAP should provide a satisfactory assessment
[
j of the plant's design and the design process.
Implementatioq of the EAP will
{
be inspected by the NRC.
L
'
l
.
)
'
!
)
i l
i i
J
l t
,
i
t i
i
-
,
- -.
- - -
... -
-
_..... _ -.......
'
.
- J'
DETAILS
.
1.
Scope of Review I
The scope of this review consisted of a detailed evaluation of the
,
i Engineering Assurance Program (EAP) Plan and associated documents for
,
j WNP-3.
The details of the implementation of the EAP will be inspected in
the future.
j
.
j 2.
Methodology l
-
.
,
Review and evaluate the EAP Plan and associated documents by the
,
!
following:
1) July'1,1985 site visits; 2) July 2,1985 public meeting i
and 3) in office review of the program plan.
The following information
)
was submitted by the applicant' and formed the basis for the evaluation:
l
In a letter dated June 3, 1985, WPPSS informed the NRC that the
'
-
second module'of the Readiness Review Program would be the Design
'
Review Program (Engineering Assurance Program, EAP) and a copy of the
'
l WPPSS EAP plan was attached for NRC's review and approval,
)
In a letter dated July 30, 1985 (ESS-GAB-85-16) WPPSS provided a set
of procedures and instructions related to the WNP-3 EAP.
,
J
In letter G03-85-461, dated August 16, 1985, WPPSS submitted further
)
information requested by the NRC through a letter dated August 2, j
1985.
- In letter G03-85-467; dated August 20, 1985, WPPSS submitted the j
qualification of the Oversight Committee members for NRC's
concurrence, l
~*
!
In letter (G03-85-514) dated September 5, 1985, WPPSS submitted its
{
short term schedule for the first review topic of its EAP Plan for
}
NRC's information.
1
{
!
!
Y h
,
h e
,
,!
2 i
,
j l
l'
l
.
-.
.-
-...
- _. -
-.
_-.-
. -- --.__
- - -..
-.
-.. _-
'
,
.
3.
Evaluations i
The WNP-3 EAP Plan was reviewed for its adequacy and completeness.
An
!
. assessment of-the EAP was performed by the Quality Assurance Branch (QAB)
.
of IE.
- The EAP contained the following elements.
,
A brief organizational structure.
- Guidelines to select review topics.
z j
Description of design process reviews.
- l-
~ Definitlon of personnel qualifications.
~
,
,
.Desc'r.iption of design' assessments.
- The EAP~ plan doe 5.notLcontain details of the individual design assessments
'
which, according to the plan, willibe issued later. The evaluation of these
detailed design assessments.will be. performed by NRC (IE) when they become available.
.
4.
Findings-i
^
!
Comments and questions regarding.the review of the_EAP plan are contained in an attachment to this evaluation.
d
}
5.
Conclusion The NRC review of the EAP. plan indicates that the plan is capable of
providing an assessment of the design and design process which will
!
ascertain whether or not all FSAR commitments and NRC regulations have
j been met.
Implementation of the program will be subject to further i
NRC inspection.
i
'
i a
o o
,
.s i
e..
,,,
.~,-,vit-.yvr--
.
-ww
, woe-.,-re
,
,
-c c,w
. -, -
-e,,t.eg e-m.,--v-
=,=,-ca i-.
p. w,y 2w r,w
. w -g g - w va. -_gw,+
+y
+ g --. v
,,-o,wew-m,
-
-
.
--__
,
.
.
i ATTACHMENT NRC Staff Comments on WNP-3 Engineering Assurance Program
!
1.
G. C. Sorensen's letter of August 20, 1985 forwarded resumes of the EAP Oversight Committee members. We have no objection to your selectico of Messrs.
S. H. Bush, R. V. Laney, and T. W. Bishop as members of the Oversight Committee
.
subject to confirmation during a future NRC inspection that none of the members have a conflict of interest.
We intend to review the conflict of interest form for each individual which should have been completed in accordance with EAP Procedure E2.103.
'
.
2.
G. C. Sorensen's letter of August' 16, 1985 indicated that the NRC would not be requested to concur in the selection of individual review team members but all selections would be documented and recorded for future reference, and available for NRC review upon request.
During inspection of program imple-mentation we plan to review individual; reviewer qualifications. We expect individual reviewers to have design experience in the area that they are reviewing. However, reviewers should not have been previously engaged in the
'
work that they are reviewing.
In this regard, documentation of the qualifica-tion of reviewers completed in accordance with EAP Procedure E2.102 should i
include the commercial design experience of the reviewers.
With respect to reviewer conflict of interest, Attachment 5.2 to EAP Procedure E2.102, requires
!
individual reviewers to only indicate that they do not own more than $100,000 i
or 1% (whichever is smaller) in stock of any WNP-3 contractors or WNP-3 project.
,
For individual reviewers, the value of stock that can be held appears to be too j
high not to represent an individual potential conflict of interest. Washington i
Public Power Supply System should justify why such a value does not represent a potential conflict of interest and why disclosure of any ownership should be precluded.
L 3.
G. C. Sorensen's letter of August 16, 1985 attached a tentative list of review topics.
It was stated that the topics had been chosen so that,.in the aggregate, they will demonstrate adequacy in all areas of design such as mechanical, civil / structural, electrical, instrumentation and control, including
.the overall process that integrates and reconciles those designs.
It was further stated that the scope (and depth) of each topic will be chosen to ensure that the aggregate of the reviews will assess all significant organizational interfaces and major disciplines, by sampling important products of those activities.
Lastly, it was stated that Phase 2 topics had not yet been chosen,
,
but will be chosen to both extend and complement Phase 1 topics and that the
<
selection of topics will support the overall objective of being representative
,
of the completed design. We agree with the objectives of topic selection.
We will review topic selection to ensure these objectives are fulfilled and
the overall program provides a satisfactory assessment of the plant's design
,
!
and the design process.
In this regard we have the following comments on your tentative topics / subtopics list:
i Based on IE experience with 10VPs and EAPs, design process reviews a.
without in-depth technical review of design products is of limited value. We expect the EAP to consist primarily of in-depth technical
reviews.
'
i
- - -, - -
,,., -
,.
--..
., - -
.
.,-,-.n,c
,.
.,,n
. -.
- -. - ~.
--.-
,,, -,..
-
e.
-
_--
.
.
.
.
-
_..-
. _.-
..
_-
.
.-
-
-
._
.
,
.
2 b.
The tentative topics / subtopics list gives the impression that reviews will be conducted on a topical basis instead of a system basis.
If this were the case then the EAP might address a lot f da-Nn details
-
,
but may miss the overall systems concerns.
Howa".
'r under-
.
standing that the EAP will concentrate on
- i-w m essing design details within the system including 2 m w, w ' W rtquire-ments.
It is also our understanding that 0 e 4 a', M fi-review
- '
will include at least one system priw's AQ# i cN a chitect
engineer, one system with extensivr mi interie, %ghs, ions, and j
AC and DC electrical system (s). W
- dW4 nd the pying and pipe j
supports and civil / structural aret Ji' w M 7eed on a discipline basis.
.
c.
Common design considerations su h.
C v.sa analysis, Seismic II/I and fire protection should be addressed on a subject basis since a
-
particular system may not embody all the design considerations in these areas.
I t
4.
The organization for conducting' the EAP is briefly described in the EAP
.
plan and in EAP Procedure E2.100.
The NRC intends to inspect the EAP organi-
,
,
zational structure to ensure necessary independence from the project is achieved
'
i i
and maintained.
To assist the NRC in future inspections a detailed organization L
chart which describes the duties of EAP personnel, flow of work within the EAP I
organization and the relationship of the EAP organization to the project should be available to NRC inspectors,
'
i 5.
Section 5.3 of the EAP Plan states that the results of the reviews and I
assessments are reported-directly to the Manager, Construction Quality Assurance, i
ADPE and Manager, Engineering Assurance, and include all concerns identified, i
assessment of the significance of the concerns, and specific recommendations for further assessment of any concern judged to have potentially significant
.
implications. The NRC will assess review findings to ensure that the generic
{.
implications of review findings have been or will be addressed.
6.
Following the completion of the Phase 1 program a final summary report should be prepared. This summary report should, as a minimum, provide the following:
l A discussion, by technical discipline, of the effectiveness of the a.
i design process and design adequacy.
b.
A trend analysis of the root causes of all findings and a discussion of corrective actions taken or to be taken for those trends which are most significant.
This trend analysis should demonstrate whether or i
not those findings that appear insignificant when taken by themselves, take on a significance when viewed collectively.
,
Overall conclusions regarding the technical adequacy of design and c.
design process effectiveness for the entire WNP-3 project.
i
'
-
- -
--
---
- -
--
.-
-..
.
- -. - -
.
.
-
.