ML20128G523
| ML20128G523 | |
| Person / Time | |
|---|---|
| Site: | Satsop, Washington Public Power Supply System |
| Issue date: | 06/03/1985 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO1-85-0127, GO1-85-127, GO3-85-0299, GO3-85-299, NUDOCS 8507090218 | |
| Download: ML20128G523 (12) | |
Text
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y P.ECEIVED Washington Public Power Supply Sysl@fh' P.O. Box 968 3000GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 i
1583 JU':-7 AH D 38 i
RECiONVI&E i
DOCKET NOS. 50-508 AhD 50-460 l
June 3,1985 G01-85-0127 G03-85-0299 Mr. J. B. Martin Regional Administrator
. U. S. Nuclear Regulatory Consission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
<j L
Dear Mr. Martin:
j
Subject:
READINESS ~ REVIEWS DESIGN REVIEW PROGRAM (ENGINEERING ASSURANCE)
References:
- 1) Letter, G01-85-0027/G03-85-0057, dated January 31, 1985, Readiness Review Program
- 2) Letter, G01-85-0055/G03-85-0153, dated March 20, 1985, Readiness Reviews t
- 3) Meeting held in NRC Region V Office on Me 22, 1985.
i References 1 and 2 both discussed the Supply System's proposed actions with regard to _ Readiness Reviews at our delayed construction projects.
As a result of our meeting at Region V (Reference 3), it was agreed the second module of the Readiness Review Program would be the Design Review Program.
l Accordingly, we have attached a copy of our Engineering Assurance Program Plan for your review and approval.
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8507090218 8506p 0 PDR ADOCK 050 pj o
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Mr. J. B. Martin Regional Administrator U. S. NRC - Region V G01-85-0127/G03-85-0299 Page 2 As also discussed in our MAy 22, 1985 meeting, we would like to meet with you at the earliest practical-time to discuss any comments so that approval can be obtained by approximately July 1,1985.
Very truly yours, G. C. S rensen, Manager Regulatory Programs
Attachment:
Engineering Assurance Program Plan cc: Mr. J. A. Adams, NESCO Mr. G. T. Ankrum, Nuclear Regulatory Commission
- Ms. N.
Bell, Nuclear Information & Resource Services Mr. W. L. Bryan, Washington Water Power Company Mr. H. R. Denton, Nuclear Regulatory Commission
- Mr. R. T. Dodds, Nuclear Regulatory Connission Mr. C.
Eschels, EFSEC Chairman
- Mr. W. M. Hill, Nuclear Regulatory Commission Mr. G. W. Knighton, Nuclear Regulatory Commission Mr. J. R. Lewis, Bonneville Power Administration
- Mr. T. S. Michaels, Nuclear Regulatory Commission Mr. F. J. Miraglia, Nuclear Regulatory Connission Mr. R. V. Myers, Puget Sound Power & Light Company Mr. N. S. Reynolds, Bishop, Liberman, Cook, Purcell & Reynolds
- Mr. E.
Rosolie, Director of Coalition for Safe Power Mr. B. K. Singh, Nuclear Regulatory Connission Mr. J. M. Taylor, Nuclear Regulatory Commission Mr. L. D. Weislogel, Pacific Power & Light Company Mr. B. D. Withers, Portland General Electric Company
- With Attachment l
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- 1.
- 06/03/85 ENGINEERING ASSURANCE PROGRA?4 (EAP) 1.0 PURPOSE The purpose of the Engineering Assurance Program is to provide addi-tional confidence in the technical adequacy of the engineering and de-sign work performed by the Supply System and/or its contractors for nuclear power generation facilities.
2.0 INTRODUCTION
The Engineering Assurance Program consists of activities specifically directed at assessing the adequacy of the technical aspects, as well as the methods of control, of the engineering and design activities of the Supply System and/or its major contractors in producing a quality engi-neering product.
This is accomplished by independently sampling the design activities and products for confirmation by analytical tech-ni ques.
Accordingly, the Engineering Assurance Program functions inde-pendently of the nuclear Quality Assurance Program and will be moni-tored by an independent executive Oversight Committee.
3.0 ORGANIZATION The Engineering Assurance Program is established and implemented by the Corporate' Systems Engineering Department.
The flanager, Engineering Assurance, reports to the Director of Engineering through the fianager, Engineering Systems Support, to provide an independent overview of the technical activities of the organizations performing engineering and design functions.
The Director of Engineering oversees the engineering assurance program to ensure that it is adequately defined and that it is being properly implemented.
Engineering Assurance is staffed by personnel having extensive engineering and design experience in their assigned disciplines and documented technical independence from the area of investigation.
4.0 PROGRN1 PROCEDURES The Engineering Assurance Program procedures are approved by tue Director of Engineering and fianager, Engineering Assurance.
These pro-cedures describe the various Engineering Assurance activities, includ-ing assignment of responsibilities, methods of implementation, and methods of coordinating activities with other organizations.
Page 1 of 10
06/03/85 5.0 PROGRN1 ACTIVITIES The activities-of the Engineering Assurance Program include design pro-cess reviews, independent technical assessments, and third-party design assessments described below.
Engineering Assurance, in effect,.will verify that plant systems, structures, and components assessed will perform to design criteria and performance requirements established for the plant.
Efforts will be made to identify modifications or improve-ments to the design process if deficiencies are identified, but recom-mendations for improving design products will not be made, unless the design will not perform its intended function or satisfy the design criteria.
The technical subjects and design features will be evaluated against good engineering practice and the commitments contained in the FSAR. As a minimum, the specific elements of the design process, as listed in the Appendix, will be verified.
Selection of review / assessment topics is based on the following general guidelines:
e Select areas of review that represent known technical problem areas in the industry, in particular, those that have experienced a large number of changes from original design.
e Select areas that represent known or suspected Supply System and/or contractor difficulties.
e Select representative samples from systems, the design and engi-neering of which are essentially complete, to determine that de-sign of these systems from conception to final acceptance has been carried out in a controlled manner and that the system design meets its intended purpose.
e Select activities that require significant interface with the HSSS supplier and other major vendors.
e Select topics for design process review in a manner that addresses the various aspects of the design process (i.e., design input, interface, process, output, and changes) and provides a reasonable data base by which to judge the adequacy of the design process.
e Select any other topics of management concern.
5.1 Design Process Reviews Design process reviews are performed by personnel under the cognizance of Engineering Assurance.
The objective of these reviews is to develop information by which to judge the adequacy of design controls on the basis of whether the results of the design activities are correct and consistent with licensing commitments and represent good engineering practice.
These reviews are conducted on a sampling basis and are Page 2 of 10
06/03/85 directed at the technical substance of the design process, in contrast to quality assurance audits, which examine procedural compliance.
Design process reviews are conducted by experienced engineers who, by examining the technical aspects of the design, can evaluate whether design activities are being properly conducted.
For example, such re-views can evaluate whether correct and current design inputs are used by affected design organizations and whether design changes are prop-erly evaluated and incorporated into the design.
As a result of these reviews,. judgments can be made as to how well the design activities are controlled by the organizations involved.
The Assistant Program Director, Engineering (APDE) at the project, coordinates any necessary corrective action related to concerns identified as a result of these reviews.
5.2 Design Product Reviews Design product reviews consist of either Independent Design Assessments by personnel assigned to and under the direction of Engineering Assur-ance, or third-party design assessments performed by a third party organization with coordination provided by Engineering Assurance.
These reviews focus on the output of the design process which was evaluated per paragraph 5.1 above.
5.2a Independent Design Assessments Independent design assessments are performed by personnel assigned to Engineering Assurance. These assessments are designed to be indepen-dent verifications of designs.
They do not take the place of normal design verification activities performed by the organizations respon-sible for the design, but are done to provide additional confidence in the technical adequacy of the design.
Independent design assessments are conducted on a sampling basis and are directed at critical and com-plex design features as well as areas of known or suspected Supply System, contractor, or industry problems.
These assessments are con-ducted by experienced engineers who evaluate and verify the design through a review of the design, using alternate analyses as needed.
Where additional manpower is required to perform a comprehensive design assessment, additional engineering personnel will be contracted from outside the Supply System to work under the supervision and direction of the Supply System Engineering Assurance discipline leader (s).
The APDE will verify that appropriate corrective action related to concerns identified as a result of these assesssments is undertaken in a timely fashion by the project.
i Page 3 of 10
06/03/85 5.2b Third-Party Design Assessments Third-party design assessments are coordinated by personnel assigned to engineering but are actually performed by an independent outside engi-neering organization.
These assessments are designed to provide a com-pletely independent assessment of the adequacy of design work performed by the Supply System and its major engineering and design contractors.
Topics for third-party design assessment are designated by the f4anager, Engineering Assurance, and approved for implementation by the Director of Engineering. The design assessment approach (i.e., sampling or com-plete verification) and the specific design features that are reviewed are jointly selected by the Supply System and the third-party engineer-ing organization.- The design assessment methods used (e.g., use of alternate calculations) are detennined by the third-party engineering organization.
Credit may be taken for third-party assessments performed prior to, or in parallel with, the implementation of this program if those assess-ments are applicable and can be qualified as to their independence and general adequacy by the Engineering Assurance Program.
5.3 Results of Reviews and Assessments The results of these reviews and assessments are reported directly to the Manager, Construction Quality Assurance, APDE and llanager, Engi-neering Assurance, and include all concerns identified, and assessment of the significance of the concerns, and specific recommendations for further assessment of any concern judged to have potentially signifi-cant implications.
The review reports are approved by the Director of Engineering and are made available to the NRC through the office of the Director of Licensing and Assurance.
5.4 Oversight Committee An executive Oversight Committee will be retained by the Supply System to monitor the Engineering Assurance Program.
Committee members will be chosen from the business, academic and/or technical communities based on their demonstrated and documented independence from the orga-nization under review and for their qualifications to assess the pro-gram's fidelity, candidness and effectiveness.
6.0 PROGRAM Il1PLEMENTATION Engineering, in conjunction with the APDE, plans and develops schedules for design process reviews, and design product reviews. As stated above, design product reviews may take the form of either independent design assessments or third-party design assessments h
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a
06/03/85 6.1 Design Process Reviews Design process reviews assess the adequacy of design processes in def-erence to a specific design feature or product.
They assess control criteria, procedural effectiveness, organizational interface protocol, information exchange, etc., and they are implemented as follows:
e A review plan is prepared that defines the purpose, scope, special concerns, checklist to be utilized, and any other information per-tinent to conducting the review.
e.
Personnel and organizations to be assessed are notified of the schedule and scope of the review a reasonable time in advance of the review.
e Review checklists are prepared, approved by lianager, Engineering Assurance, and utilized, that identify the procedures governing the activities being assessed and the specific attributes to be evaluated for those activities.
e A pre-review meeting is held with the management of the organiza-tion being reviewed to identify key personnel contacts, discuss the scope of the review, and determine the level of activity in the areas to be reviewed.
e A post-review meeting is held with the management and personnel of the reviewed organization to present and clarify review results.
e A formal review report is prepared, which includes the purpose and scope of the review, results, identification of review partici-pants, and specific observations. Any necessary corrective action is requested from the reviewed organization.
The report is ap-proved by the flanager, Engineering Assurance prior to transmittal to the reviewed organization by the APDE.
e Responses to review observations describing the extent of problems noted and corrective action are submitted to the flanager, Engineer-ing Assurance and APDE, by the reviewed organization.
Engineering Assurance evaluates each response to ascertain whether the com-mitted actions are commensurate with the review results.
If the response is considered unsatisfactory, it is returned to the re-viewed organization through the APDE for revision, Engineering Assurance reviews committed action to verify that such o
action has been taken.
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.o 06/03/85 e
6.2 Independent Design Assessments Independent design assessments verify the adequacy of specific designs or design features in deference to the overall design process. They determine that the correct criteria, materials, calculation and analyt-ical methods were applied correctly to achieve a specific result or performance objective.
Independent design assessments are implemented as follows:
e An assessment plan is prepared defining the purpose, scope, special concerns, and areas to be covered in the assessment.
Check lists are prepared, and approved by the Itanager, Engineering e
Assurance.
e The project team is notified of the schedule and scope in' advance of the assessment time and provides current design information and documentation to the assessment team.
e A pre-assessment meeting is held to identify key personnel con-tacts, discuss the scope of the assessment, and determine the level of activity in the areas to be assessed.
e Clarification of design philosophies, misunderstandings, system operational philosophy, questions, etc., between assessment and project teams may take place as the design assessment proceeds.
e A post-assessment meeting is held between the assessment team and project team (and contractor as necessary) to discuss results of the review.
e A formal report is prepared, which includes the purpose and scope of the assessment and results and identification of observations.
Also, the report includes a list of documents reviewed and alter-nate calculations performed in addition to the elements outlined above.
e The flanger, Engineering Assurance reports the need for further evaluation to the APDE.
The flanager, Engineering Assurance recom-mends any necessary corrective action (i.e., design changes) and monitors the actions taken by the APDE.
e The llanager, Engineering Assurance reassesses the design when the corrective action has been completed.
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06/03/85 6.3 Third-party Design Assessments Third-party design assessments are implemented as' follows:
e The llanager, Engineering Assurance selects and obtains the ser-vices of an outside engineering organization to perform a particu-lar assessment. Approval of the organization selected is obtained from the Director of Engineering.
e The fianager, Engineering Assurance provides a description of the topic to be assessed and defines the purpose of the assessment.
e The fianager, Engineering Assurance selects and obtains copies of the specific design documents needed to perform the assessment. In conjunction with Engineering Assurance, the outside organization determines the design features to be assessed, based on the com-plexity of the design, importance to safety, degree of standardi-zation and similarity to previously proven designs, and degree of design completion shown by the documents being reviewed.
e The outside organization selects the specific design assessment methods (e.g., design review, use of alternate calculations) to be used and prepares an assessment plan defining the scope, methods to be used, special concerns, and other information pertinent to the assessment. A copy of the assessment plan is sent to Engi-neering Assurence for approval.
e A pre-assessment meeting is held to identify key personnel con-tacts, discuss the scope of the assessment, and determine the level of activity in the areas to be assessed.
e The outside organization perfonns the design assessment and docu-ments the results.
e A post-assessment meeting of Engineering Assurance, Project Engi-neering, the outside organization performing the assessment, and any other organizations as determined by the Supply System or the Oversight Committee.
e The outside organization prepares and transmits an assessment report to the fianager, Engineering Assurance, which includes the purpose and scope of the assessment, results, including comments as appropriate on the significance of the results, identification of assessment participants, and a list of documents reviewed and alternate calculations performed.
e The f4anager, Engineering Assurance reviews the report, determines if corrective action is necessary, and reports the results to the APDE and Director of-Engineering.
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06/03/85 e
The Manager, Engineering Assurance includes in the report topics requiring further evaluation to the APDE.
The fianager, Engineer-ing Assurance may recommend corrective action (i.e., design changes).
e The fianager, Engineering Assurance reviews corrective actions for adequacy and performs a reassessment of the design upon completion of the corrective action to close out the review topic.
7.0 RECORDS The Manager, Engineering Assurance maintains sufficient records to de-mostrate compliance with this program.
In this regard, the following records will be retained:
e Review checklists, review reports, and corrective action recommen-dations and follow-ups, o
Correspondence pertaining to reviews and assessments performed, o
Procurement-related correspondence and documents and invoices for engineering services provided by others, e
Assessment reports, documents reviewed, corrective action reports, and reassessment records, e
Calculations, analyses, and other technical documents used or de-rived during the perfonnance of an assessment that contributed substantially to conclusions reached, e
Assessments by the Oversight Committee, e
NRC comments, correspondence, meeting minutes, etc.
8.0 APPENDIX Criteria for Engineering Assurance evaluations are as follows:
8.1 Design Commitment Control Periodic reviews shall be conducted to ensure consistency between de-sign activities and commitments made in technical specifications,11-censing documents, or other regulatory requirements.
Also, Engineering Assurance shall verify that an effective system exists for updating design commitments as changes occur due to design evolution, management decisions, as-built conditions, or regulatory changes.
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n 06/03/85 8.2 Design Inputs Measures shall be established to verify the basis, use, and reasonable-ness of design inputs.
Emphasis shall be placed on confirming the validity and applicability of input information for selected design features.
Sources of the input data shall be identified. Calculations that produce results to be utilized as input data shall be verified.
Engineering Assurance shall confim that design input assumptions are technically valid and reasonable.
8.3 Design Methods lleasures shall be established to verify that the analytical methods used for design calculations are consistent with sound engineering practice and industry codes and standards identified in project licens-ing commitments.
Confimation shall be made that computer programs, including subroutines, have been verified as acceptable, prior to their use. Analytical modeling techniques shall be examined for reasonableness.
8.4 Design Control Measures shall be established to verify that plant system interfaces and interactions have been properly addressed in the design process.
Technical review shall verify that the system and components are de-signed to perfom in nomal, transient, and accident modes in accord-ance with the design criteria.
Review of the flow and documentation of selected design infomation shall be performed to assure that output-to-input between organizations is consistent with applicable design control requirements.
8.5 Design Verification Measures shall be established to verify that design and design veriff-cation perfomed by others are technically adequate.
Particular atten-tion shall be given to assessing the adequacy of methods used for de-sign verification and the qualifications of personnel performing design verification.
8.6 Design Changes lleasures shall be established for verifying the basis and inplementa-tion of design changes.
Particular emphasis will be placed on evaluat-ing the system for control of design changes, prop' r coordination by e
affected disciplines, incorporation into affected design documents, and feedback from the as-installed configuration.
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06/03/85 8.7 Design Records Measures shall be established to verify the adequacy of the system for identifying, collecting, storing, and retrieving design records.
Con-sideration shall be given to ensuring that the design record system provides both adequate documentation and the ability to store and re-trieve documentation during design activities.
Careful attention shall be given to verifying that a system exists for creating an appropriate v
and accurate record of the as-built design configuration.
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