IR 05000508/1987001

Meeting Rept 50-508/87-01 on 870107.Topic Covered:Util Const Assurance Program.Viewgraphs Encl

ML20211H809
Person / Time
Site:	Satsop
Issue date:	01/30/1987
From:	Richards S, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20211H770	List: IR 05000508/1987001 ML20211H768
References
50-508-87-01-MM, 50-508-87-1-MM, NUDOCS 8702260296
Download: ML20211H809 (27)

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. U. S. NUCLEAR REGULATORY COMMISSION REGION Y Report No. 50-508/87-01 Docket No. 50-508 Construction Permit.No. CPPR-154 Licensee: Washington Public Power Supply System P. O. Box 1223 Elma, Washington 98541 Facility Name: Washington Nuclear Project 3 Meeting at: Region V, Walnut Creek, California Date: January 7, 1987 Prepared by: ,//, I /-Jo -# 7 A. D. Toth, Project Inspector Date Signed Approved by: Gfbbh S. A. Richards, Chief. Engineering Section

/-3d-87 Date Signed Summary:

Meeting on January 7, 1987, to discuss the Supply System Construction Assurance Program for WNP- PDR ADOCK 05000508 G PDR

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DETAILS o

1. Personnel Attending Meeting RV-NRC D. F. Kirsch, Director, Division of Reactor Safety and Projects R. J. Pate, Chief, Reactor Safety Branch S. A. Richards, Chief, Engineering Section A. D. Toth, Project Inspector, WNP-3

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NRR-NRC G. W. Knighton, Director, Project Directorate No. 7 R. S. Lee, Licensing Project Manager IE-NRC B. K. Grimes, Director, Division of Quality Assurance, Vendor, and Technical Training Center Programs F. C. Hawkins, Chief, Policy and Program Development Section G. S. Lewis, DQAVT Readiness Review Project Manager, Policy and Program Development Section ED0-NRC E. W. Brach, Executive Coordinator for Regional Operations WPPSS R. B. Glasscock, Director, Licensing and Assurance G. C. Sorensen, Manager, Regulatory Programs L. J. Garvin, Program Manager, Readiness Review R. L. Knawa, Manager, Construction Assurance Program G. Block, Manager, Engineering Assurance Program i

2. General

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This meeting was convened at tt.e request of Supply System with the agenda shown in Attachment 1. The purpose of the meeting was to review the program basis and scope with recently assigned NRC staff, review current status of the Readiness Review Program, and discuss current concerns of Supply System and NRC staff. View graphs presented by the Supply System attendees are included as Attachment 2 to this repor . Program Basis The Supply System reiterated the principal documents which established the program and defined their understanding of NRC participation. It was stressed that the program was voluntary on the part of the Supply System and was intended to provide an additional level of confidence that the work (design and construction) completed to date meets Supply System programs, commitments to the NRC and NRC requirements. The NRC stated that the WPPSS Construction Assurance Program dated January 1986 will

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form the basis for NRC module inspection-and reviews as stated in the a

February 25, 1986 NRC acceptance letter. The NRC and WPPSS attendees agreed that NRC will inspect and review Supply System activities during formulatiori and conduct of readiness review activities for each module, in addition to reviews conducted after submittal of each module repor " WPPSS Concerns The following concerns were identif'ied by the Supply System and discussed during the meeting: Beginning Point for Reviews

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The 1ack of engineering resources available during the deferred construction status of the plant limit the WPPSS current ability to respond to NRC regarding details of bases for specific FSAR statement The CAP does not itself focus on such issues since it starts with the presumption that the design documents are correc The NRC acknowledged the WPPSS resource constraints and noted that replies to such inquires, raised during future inspections and reviews of WRRP implementation, may be deferred as NRC open questions to be addressed in the future if the Supply System is unable to adequately address and resolve the issue presentl The Supply System stated that engineering aspects were not

. encompassed by the Module C3-01, Earthwork. With respect to discussions of NRC review of that module, it has been clarified that the September 10, 1986 transmittal of the module to NRC explicitly stated that C3-01 encompassed both the CAP (Construction Assurance Program) and EAP (Engineering Assurance Program). Readiness Review Program is Not a Stand-Alone Program The Supply System emphasized that a functioning quality assurance program had existed during design and construction and the performance of that program is considered by WPPSS in conjunction with the WRRP to arrive at a conclusion of adequate constructio The NRC acknowledged that the WRRP was an additional program and not stand-alone. However, the NRC took the position that the WRRP reports needed to reflect an overview which identified the extent that the original QA program was validated by WRRP or otherwise accepted as the basis for conclusion of construction adequac The WPPSS representatives stated that they would in future module submittals clearly iden+y their bases for conclusions reached in the module Comparison to Other Non-Related Programs The Supply System emphasized that the WRRP involves commitments and approaches which differ from readiness review programs at other site .

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The NRC representatives acknowledged that the WNP-3 WRRP was unique a'.

and governed by its own bases and commitments, and not subject to requirements.outside those bases and commitments or comparison to programs at other site Continual Stress on Procedure Reviews The Supply System noted NRC staff questions regarding an absence of CAP detailed re-examination of contractor procedures for conducting wor The NRC stated that adequate consideration of past problems was an NRC concern which encompassed the procedures review question, and this concern would be considered during NRC review of WRRP module report ,

~ Changing NRC Participation in the (Readiness Review) Program-The Supply System noted that several NRC staff reassignments have occurred since the start of the progra The NRC acknowledged that several reassignments had occurred and that this meeting was'a useful and timely review of program baseline

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commitments.* Status of Program

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The Supply System representatives stated that' resource allocation decisions have required'that the Readiness Review Program be terminated July 1987. Current plans call for the Construction Assurance Modules C3-02 and C3-04 (concrete and Structural Steel) to be completed and submitted to NRC in March 2,1987 and July-1987, respectively. The Engineering Assurance Module E3-02 (Civil) will be completed and submitted to NRC July 1987. Module E3-01 (Piping. arid Supports) will most likely not be submitted to NRC due to limitation of resources to resolve outstanding design issue . NRC Concerns

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The following concerns were expressed by the NRC representatives and acknowledged by WPPSS representatives as noted: Review and Utilization of Problem / Performance History Data Recent inspection data indicated that the Construction Assurance Program reviews did not include a timely and thorough examination of past problems and contractor performance history to focus sampling plans and review attribute NRC representatives stated that unresolved questions in this area would be deferred as NRC open issues to be addressed in the futur '

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. Program Scope

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The Supply System described the Readiness Review Program as an additional assurance program, not a stand-alone program, and complimentary to the quality assurance program that was implemented while construction was active. The NRC stated that it had anticipated that the WRRP consideration of such past programs would be incorporated into the WRRP final reports to provide the overview assessment of construction adequac The Supply System representatives acknowledged this concern and agreed to take it under consideratio Selection of Representative Sample Populations Recent NRC inspection data indicated that the licensee selection of sample populations and sample size have resulted in sampling plans not representative of the various activity population Consideration of variability of individual contractors with regard to their individual problem and performance histories, individual management systems, and complexity of work activities would appear consistent with program commitment The Supply System stated that they did not want to unduly bias the sampling plans since this might undermine the validity of generic statistical conclusions. They considered that some construction work, such as concrete placement, was similar for all contractors and was considered as a single populatio The NRC stated that selection of individual populations of contractor work activities would not constitute bias of sampling for those individual populations, since conclusions would be applicable only to those individual populations. NRC stated that the acceptability of individual module reports would be contingent upon representative sampling plans described in program commitment The Supply System acknowledged the NRC concer Disposition Of Outstanding Licensee Internal Issues NRC stated that for some modules, the existing quality assurance program records may include unresolved nonconformance reports, audit findings, design changes, and/or other issues related to the completed work addressed by the modul The future resolution of such matters may require special studies and/or rework of the accepted completed wor The CAP /EAP should assure that such matters are included in an identifiable and retrievable data base to assure future corrective actions. The module reports should identify such item The licensee representatives stated that such matters would be identified in the module reports; the specific approach to referencing the data base in the module report will be determine s'

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e. NRC Acceptance of Readiness Review Modules

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The WRRP considers FSAR and other commitments in its review The NRC review of the WRRP reports will result in a conclusion on the acceptability of the current status (as reflected in the module) of the completed construction and design of the areas addressed in the readiness review module. It should be noted, however that NRC evaluation of many of the commitments (SER review) has not been completed in all cases and therefore acceptance of those commitments may not be a part of the NRC conclusion. Therefore, it is expected that the NRC acceptance of an WRRP module would be contingent upon future determination of acceptability of the commitments and any other open issues / questions needing resolution.

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ATTACHMENT 1

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AGENDA NRC/WPPSS REGION V MEETING WNP-3 READINESS REVIEW PROGRAM JANUARY 7, 1986

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MEETING OBJECTIVES: Introduction of responsible WPPSS and NRC personne Identify differences in NRC/WPPSS interpretation of WPPSS readiness review program commitment Clarify limitations of the WNP-3 readiness review progra Identify current WPPSS and NRC concern :00 P.M. Introduction -

Reason for Meeting R. B. Glasscock 1:15 P.M. Beginning Point for Reviews - Licensing Basis G. C. Sorensen 1:30 P.M. Review of Past Readiness Review Meetings and L. J. Garvin WPPSS Understanding of the Program 2:15 P.M. BREAK 2:30 P.M. Presentation of WPPSS Concerns L. J. Garvin

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Comparison to other non related program Continual stress on procedure revie Changing NRC participation in progra Readiness Review Program is not a stand-alone progra Being measured to new and unknown NRC inspection modules -

that do not seem to address the WPPSS progra :15 P.M. Status of Program - Short and Long Term Schedule L. J. Garvin 3:30 P.M. NRC Concerns A. D. Toth 4:00 P.M. Summary of commitments, agreements and D. F. Kirsch conclusions 4:15 P.M. ADJOURN

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. ATTACHMENT 2

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IN JANUARY. 1985. THE SUPPLY SYSTEM PROPOSED TO CONDUC WITH NRC PARTICIPATION A READINESS REVIEW PROGRAM AT WNP- THE BENEFITS OF THE PROGRAM INCLUDED:

e ENHANCED ASSURANCE OF OVERALL ACCEPTABILITY OF WNP-3 DESIGN AND CONSTRUCTIO e IMPROVED STABILITY BY MINIMIZING LAST MINUTE (LATE IN CONSTRUCTION) IDENTIFICATION OF PROGRAMMATIC PROBLEM .

e NEW WORKING RELATIONSHIP WITH NRC THAT ALLOWS INCREMENTAL ACCEPTANCE OF ACTIVITIES FOR WNP-3 -

INCREMENTAL ACCEPTANCE WAS TO BE IN TWO PHASE e PHASE I - WORK COMPLETED TO DATE e PHASE II - TO BE ACCOMPLISHED AFTER RESTART OF CONSTRUCTION.

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INITIAL PHASE i

e REVIEW OF WORK COMPLETED TO DAT i e FOCUS ON DESIGN AND. CONSTRUCTION PROCESSES AND ON

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THE PRESERVATION PROGRAM IMPLEMENTATION.

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e SAMPLE PRODUCTS OF THESE PROCESSES AND DRAW CONCLUSIONS FROM THE RESULTS OF THE REVIEWS.

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G0AL: REVIEW FOR ACCEPTANCE. THE DESIGN AND CONSTRUCTION l THAT HAVE BEEN COMPLETED TO DAT THE RESULTS OF THE INITIAL PHASE WILL BE THE FIRST INCREMENTAL ACCEPTANCE OF THE PROJECT.

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SECOND PHASE e REVIEW 0F CONTROL SYSTEMS PUT IN PLACE TO COMPLETE CONSTRUCTIO e REVIEWS WILL BE CONDUCTED TO INCREMENTALLY ACCEPT THE PROJECT WORK AS IT PROGRESSES TOWARD LICENSING AND FUEL LOA e DETAILS OF THE SECOND PHASE WILL BE DISCUSSED BEFORE RESTART OF CONSTRUCTIO e 0.QAL: COMPLETION OF THE SERIES OF REVIEWS WILL RESULT IN AN SER WITH NO OUTSTANDING QUESTIONS.

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SEPT. '84 MEETING WITH NRC REGION V AND HQ TO, REVIEW WNP-3 READINESS TO RESTART ' #

OCT. '84 VISITEDV0GTLE(GEORGIAP,0WER)-RhhIEWED' -

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THEIR READINESS REVIEW PLAN , ,

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JAN. '85 SUBMITTED WNP-3 READINESS' REVIEW / PROGRAM, .

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PROPOSAliTO NRC -

MAR. '85 MEETING AT REGION TO DISCUSS DETAILS OF- '

PROPOSAL , ,

i e r APR. '85 MEETING AT NRC HQ TO DISCUSS EAP DETAIL '

'), c 44GL '85 SUBMITTED WNP-3 PRESERVATION PROGRi1 AND ,

(ful) WNP-3 ENGINEERING ASSURANCE' PROGRAM TO NRC , j

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FOR REVIEW AND APPROVA ' ' e

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I NRCWILLINGTOPARTICIPATE75 READINESS / '

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JUL. '85 PUBLIc MEETING - WNP-3 PRESERVATT.0N PROGRAM i,

AND WNP-3 ENGINEERING ASSURANCE PROGRAM /

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' QUESTIONS ANSWERED '

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SEPT. '85 RECEIVED APPROVAL OF WNP-3 PRESERVATION ( PROGRAM

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l SUBMITTED WNP-3 CONSTRUCTION ASSURANCE

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PROGRAM TO NRC FOR REVIEW AND APPROVA \

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RECEIVED APPROVAL OF WNP-3 ENGINEERING

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ASSURANCE PROGRAM

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B(sAdIMPLEMENTATIONOFENGINEERING

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ASSURANCE PROGRAM PUBLIC MEETING - WNP-3 CONSTRUCTION ASSURANCE PROGRAM

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DEC. '85 MEETING AT REGION V TO DISCUSS PROPOSED l f ANSWERS TC WRITTEN QUESTIONS ON CONSTRUCTION i ,AS'SURANCE PROGRAM

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JAN. '86 < ANSWERED NRC QUESTIONS ON WNP-3 CONSTRUCTION

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ASSURANCE PROGRAM

,e FEB. '86 RECEIVED APPROVAL OF WNP-3 CONSTRUCTION ASSURANCE PROGRAM

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APR. '86 8EGAN IMPLEMENTATION OF WNP-3 CONSTRUCTION ASSURANCE PROGRAM

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SEPT. '86 SUBMITTED THE CONSTRUCTION ASSURANCE REPORT ON S0ILS/ BACKFILL FOR NRC ACCEPTANC PAGE 5 0F 18 (1/7/87)

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WNP-3 PRESERVATION PROGRAM OVERVIEW

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.i SDAL: TO PROVIDE THE CONTROLS SUCH THAT EQUIPMENT SYSTEMS AND COMPONENTS. AT THE WNP-3 PROJECT. ARE MAINTAINED AND PRESERVED IN AN ACCEPTABLE CONDITION DURING THE CONSTRUCTION DELA .

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PROGRAM CONTROLS e PROGRAM CONTROLS DERIVED FROM QUALITY ASSURANCE PROGRAM DESCRIPTIONS IN FSA e BOTH THE OPERATIONAL QUALITY ASSURANCE TOPICAL AND DESIGN / CONSTRUCTION QA PROGRAM APPLY.

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THE MAINTENANCE AND PRESERVATION PROGRAMS CONTAIN SEVERAL LAYERS OF DETAIL:

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" SUPPLY SYSTEM WNP-3 PREVENTIVE MAINTENANCE AND PRESER-VATION PROGRAM" SERVES AS THE OVERALL CONTROL DOCUMEN (PROVIDED TO THE NRC ON JUNE 28, 1985).

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WNC-051 " PRESERVATION OF ASSETS - PREVENTIVE MAINTENANCE PROGRAM" CONTAINS BASIC REQUIREMENTS FOR MAINTENANC (PROVIDED TO THE NRC ON MAY 24, 1985).

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SPECIFIC PROCEDURES AND INSTRUCTIONS FOR THE EQUIPMEN COMPONENTS. AND SYSTEMS AT THE PLAN (AVAILABLE AT THE PLANT.)

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PRESERVATION PROGRAM DESCRIPTION ACCEPTED SEPTEMBER 18, 1985.

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ENGINEERING AND CONSTRUCTION ASSURANCE PROGRAMS

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e THESE PROGRAMS HAVE MANY SIMILAR FEATURES e CONFIRMATORY IN NATURE

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e INDEPENDENCE FROM PROJECT l

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ENGINEERING ASSURANCE e G0AL TO GIVE ADDITIONAL ASSURANCE THAT THE DESIGN COMPLETED TO DATE IS ACCEPTABL e PROGRAM DESCRIPTION SUBMITTED FOR APPROVAL JUNE 3, 198 e QUESTIONS ANSWERED AUGUST 16. 198 e PROGRAM DESCRIPTION ACCEPTED OCTOBER 25, 198 e SAMPLE DESIGN COMPLETED TO DAT .

e DRAWS CONCLUSIONS FROM THE RESULTS OF THAT REVIEW AND FROM THE RESULTS OF ALL THE DESIGN REVIEWS.

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ENGINEERING ASSURANCE PROGRAM e SELECT REVIEW TOPIC e SELECT ITEMS FOR REVIEW BASED ON TOPIC, COM-PLEXITY. RESOURCE AVAILABILITY, FEEDBACK FROM CONSTRUCTION REVIEW AND OTHER DESIGN REVIEW e DETERMINE LATEST " PRODUCT" DOCUMENTS EXAMPLES:

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DRAWINGS

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LISTS (I.E., INSTRUMENT. SETPOINT. ETC.)

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VENDOR MANUALS

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DESIGN REPORTS

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PROCUREMENT / FABRICATION SPECIFICATIONS

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UNINCORPORATED DESIGN CHANGE DOCUMENTS e DETERMINE APPLICABLE CRITERIA / INPUT DOCUMENTS EXAMPLES:

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LICENSING (SAR QUESTIONS. POSITIONS. OTHER)

DESIGN SPECIFICATIONS

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OTHER DESIGN BASES

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VENDOR MANUALS

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INTERFACE DOCUMENTS

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STANDARDS. GUIDES

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e PREPARE CHECKLISTS APPROPRIATE TO SUBJECT SUCH AS:

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APPLICABLE CRITERIA INCORPORATED?

CORRECT DESIGN INPUT 7

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AS-8UILT FEEDBACK 7

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DESIGN CHANGE CONTROL WORKING 7

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EQUIPMENT CLASSIFICATION ADDRESSED PROPERLY?

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DESIGN DATA INTERFACE WORKING 7

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SYSTEM INTERACTION CONSIDERED?

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DOCUMENT CONTROL WORKING 7 e REVIEWS WILL BE CONDUCTED BY QUALIFIED ENGINEERS THAT ARE INDEPENDENT OF THE ORIGINAL DESIG e MANAGEMENT AND TEAM LEADERS FOR REVIEWS WILL BE CORPORATE (NON-PROJECT) ENGINEER e TEAM LEADERS FOR REVIEWS WILL HAVE l EXPERIENCE IN CONDUCTING OTHER SIMILAR l REVIEW EFFORTS.

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e FINDINGS DOCUMENTED

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o MANAGEMENT REVIEW AND ANALYSIS OF RESULTS e FOLLOWUP ACTION / TRACKING

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NCRS

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COMMITMENT TRACKING e FEEDBACK TO SUBSEQUENT REVIEWS

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e REPORTS OF REVIEWS SUBMITTED TO NRC FOR REVIEW /

APPROVA PAGE 14 0F 18 (1/7/87)

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e CONSTRUCTION ASSURANCE PROGRAM e SAMPLES CONSTRUCTION COMPLETED TO DATE AND THE RECORDS OF THAT CONSTRUCTIO e DRAWS CONCLUSIONS FROM THE RESULTS OF THESE REVIEW .

e ALSO, PERFORMS THE SUPPLY SYSTEM INDEPENDENT ASSESS-MENT.0F THE PRESERVATION PROGRA PAGE 15 0F 18 (1/7/87)

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I CONSTRUCTION ASSURANCE PROGRAM e SELECT TOPIC

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e SELECT INDIVIDUAL TEAM LEADER AND hEMBER IDENTIFY REQUIREMENTS

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PRESERVATION PROGRAM

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PAST PROGRAMS AND AUDITS

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PREPARE CHECKLISTS PAGE 16 0F 18 (1/7/87)

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e SELECT PGPULATIONS e ,

SELECT SAMPLES

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COVER EACH CONTRACTORS WORK

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COVER ENTIRE CONSTRUCTION PERIOD e CONDUCT INSPECTIONS AND RECORD REVIEWS OF SELECTED SAMPLE DOCUMENT ON CHECKLIST e ASSESS PRESERVATION e EVALUATE RESULTS

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SAFETY SIGNIFICANCE

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e FEEDBACK TO PROJECT e DOCUMENT RESULTS IN MODULE REPORT e SUBMIT MODULE REPORT TO NRC FOR REVIEW / APPROVAL.

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INTER-RELATIONSHIP OF THE READINESS REVIEW PROGRAM PRESERVATION a

ASSESSMENT a

CONSTRUCTION e SELF ASSESSMENT OF PRESERVATION ASSURANCE e WALKDOWNS AND DESIGN RELATED DEFICIENCIES FEED TO EA n v FEEDBACK n v

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ENGINEERING e WALKDOWNS BY ENGINEERS FEED THE ASSURANCE CAP POTENTIAL CONSTRUCTION RELATED PROBLEM PAGE.18 0F 18 (1/7/87)

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CONCERNS e BEGINNING POINT FOR REVIEWS e READINESS REVIEW IS NOT A STAND-ALONE PROGRAM e COMPARISON TO PROGRAMS AT OTHER PROJECTS e CONTINUAL STRESS ON PROCEDURE REVIEW e CHANGING NRC PARTICIPATION IN PROGRAM

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BEING MEASURED TO NEW NRC MODULES - MODULE SEEMS RQI TO ADDRESS SUPPLY SYSTEM PROGRAM.

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STATUS OF PROGRAM CONSTRUCTION ASSURANCE PROGRAM S0ILS AND BACKFILL MODULE - SUBMITTED AND AWAITING ACCEPTANCE CONCRETE CONSTRUCTION - TO BE SUBMITTED BY MARCH 2, 1987 STRUCTURAL STEEL - TO BE SUBMITTED BY JUL :

ENGINEERING. ASSURANCE PROGRAM

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CIVIL / STRUCTURAL DESIGN - TO BE SUBMITTED BY JUL l l

. PIPING & PIPING SUPPORTS - INITIAL REVIEW COMPLETED

- RESPONSES BEING EVALUATED

- REPORT SUBMITTAL - UNSCHEDULED

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