ML20134L293
| ML20134L293 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 08/16/1985 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO3-85-461, NUDOCS 8509030182 | |
| Download: ML20134L293 (12) | |
Text
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'p' o s Washington Public Power Supply System P.O. Box 968 3000GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 US l'G 2l 13 II: og L
fiEGIC,*J V 14:
DOCKET NO. 50-508 August 16, 1985 G03-85-461 Mr. J. B. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
Dear Mr. Martin:
Subject:
SUPPLY SYSTEM NUCLEAR PROJECT NO. 3 READINESS REVIEW PROGRAM
Reference:
Letter, D. F. Kirsch to A. D. Kohler, dated August 2,1985, same subject.
Attached are the Supply System's responses to the questions contained in the attachments to the referenced letter.
Very truly yours, bw,v G. C. Sorensen, Manager Regulatory Programs sek
Attachment:
As stated.
cc: See attached page.
l 8509030182 850816 PDR ADOCK 05000508 A
PDR 1
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l 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 Commission 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. J. L. Milhoan, Nuclear Regulatory Commission l
Mr. F. J. Miraglia, Nuclear Regulatory Commission 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 Commission Mr. J. M. Taylor, Nuclear Regulatory Commission Mr. R. M. Boucher, Pacific Power & Light Company Mr. B. D. Withers, Portland General Electric Company Document Control Desk - U.S. NRC
- With Attachment l
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ATTACHENT 1 WNP-3 PRESERVATION AND MAINTENANCE PROGRAM NRC QUESTION 1:
Describe your program including responsibilities and activities for cleaning, painting, and fire protection.
Include in your description, steps or methodology to preclude painting areas required " safety-related" paint with other types of paints (non-safety related paints).
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 1:
This question is partially answered under Item 4 below, which describes the Supply System work controls.
With regard to fire protection, the majority of the responsibilities reside with the Plant Staff.
Our fire protection program is described below:
A.
Fire Protection System - The majority of the permanent plant island fire protection system has been tested and placed into operation and includes:
e Fire Hydrants e
Fire Hose Stations e
Hose Houses e
Deluge Systems For Turbine Lube Oil & Transformers e
Turbine Building Wet Pipe Sprinkler Systems e
1 Electric Jockey Pump e
1 Electric Main Pump (3500 GPM) e 1 Diesel Backup Pump (3500 GPM) e 2 Water Storage Tanks (300,000 Gal. Ea.)
In addition to the above, there are fire extinguishers located on the plant island, a
fire truck and the capability of cross connecting with the yard fire protection system for an additional capacity of 500,000 gallons at 2500 GPM.
The system is operated by permanent Plant Operations personnel on a continuous rotating shift in accordance with the plant procedures.
B.
Fire Brigade The Operations personnel in conjunction with the on-shift Security personnel, provide a minimum five man fire brigade on a continuous basis.
Backup fire fighting capabilities are provided by the various departments of Fire District No. 5 (Grays Harbor County).
All fire brigade personnel have completed training and receive refresher training as required.
The Operations Supervisor on watch is the designated fire brigade team leader.
ATTACHMENT 1 WNP-3 PRESERVATION AND MAINTENANCE PROGRAM PAGE 2 C.
Fire Protection Surveillance The Operations personnel perform surveillances on the fire protection systems in accordance with the plant procedures which include:
e Normal Rounds e
Valve Lineup Verification e
Pump Testing (Operability and Flow) e Hose Inspection and Hydrostatic Testing e
Hose House Inspections e
Water and Fuel Inventory D.
Fire Protection System Maintenance Preventive and corrective maintenance is performed on the fire protection equipment and systems by the permanent plant maintenance personnel in accordance with the plant procedures.
Maintenance includes Mechanical, Electrical and Instrumentation disciplines.
E.
Fire Protection Controls The project has control processes to ensure that activities such as welding and cutting are performed in a safe manner.
In addition, project procedures limit the exposure to combustible materials by ensuring that coverings, scaf folding, etc., are fire retardant.
F.
Ins)mettons - Inspections are performed on all areas of the plant, Inc' uding the fire protection processes, by an assigned Supply System Safety and Fire Protection Specialist and the representatives from American Nuclear Insurance Companies.
In addition, Quality Control reviews Maintenance Work Requests to include hold points and Quality Assurance performs surveillance of fire protection activities.
Management at the Site also enforces cleanliness control.
Wi th regard to cleaning and
- painting, project specifications and procedures detail the types and applications of paint and consumables (cleaning solvents,
covering material, preservatives, etc.).
These specifications and procedures are controlled documents and the use of these agents is enforced under the work controls described in the response to Question 4.
NRC QUESTION 2:
Describe that artion of the program which assures that systems are drained and will remain free of fluids.
This applies to pumps, heat exchangers, long runs of piping, system or equipment low points, etc.
(Refer to IE Notice 85-56).
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VATION AND MAINTENANCE PROGRAM PAGE 3 SUPPLY SYSTEM RESPONSE TO NRC QUESTION 2:
The S"pply System Preservation Program includes the following requirements with respect to fluid:
Components are periodically inspected
. A.
Inspection Program internally for any foreign material such as water, dirt, and/or contamination.
The inspection frequency is based upon the component's material and its exposure to the environment.
Vapor phase inhibitors are used in 8.
Vapor Phase Inhibitors lubricating oil systems and component internals for preservation.
Particular attention is paid to equipment which is subject to corrosion and/or has close internal tolerances such as pumps, heat i
exchangers, and pneumatic (piston type) air actuators.
C.
Hydrostatic Medium - Systems which have completed hydrotesting have been drained and dried.
Systems which will be flushed for startup will be put into operation or drained / dried or laid up wet with approved chemical treatment.
D.
Operating Maintenance - Equipment extremely sensitive to corrosion products such as hydraulic valve actuators are filled with hydraulic oil and cycled periodically to keep internal surfaces coated.
E.
Inert Gas - Some equipment, especially major heat exchangers, is preserved using inert gas (nitrogen).
This method of preservation is dependent upon the installation status of the equipment and the ability to obtain a seal.
NRC QUESTION 3:
For complex or integrated systems such as the diesel generators, explain how the maintenance and storage recomumendations which may be satisfactory for short to intermediate periods of time (6 to 18 months), are adequate for long term storage (5 years or more).
Have vendors been contacted regarding recommendations for long term preservation of equipment?
i SUPPLY SYSTEM RESPONSE TO NRC QUESTION 3:
Complex equipment and/or systems are being examined for long term (greater than 5 years) preservation.
This equipment has been discussed with the manufacturers and along with AE and Supply System input, long term methods were developed.
In addition, regular inspections ensure the adequacy of the preservation.
Some examples are:
e Emergency Diesel Generators - Preservation methods were developed with the manufacturer which required preservation of the lube oil
- system, fuel oil
- systems, and cylinders using contact preservatives.
These preservatives were pumped through the systems and then hand applied in areas where the pumping did not provide
ATTACHENT 1 WNP-3 PRESERVATION AND MAINTENANCE PROGRAM
-PAGE 4 adequate coverage.
Pumping was required to ensure that areas such as the injectors, chamshaft, etc., were thoroughly coated.
Cooling water systems were preserved using vapor phase inhibitors and regular inspections are performed on the engine internals to ensure adequate preservation.
Externally the engines and generators are located in a stable, weather tight building and separately covered, with external heat applied.
Generator space heaters are energized and insulation resistance testing is performed.
The manufacturer's factory representative was brought to the Site to work with the staff on the first inspections.
e Electronic Instrumentation Power Supplies Preservation methods were developed with the manufacturers which resulted in a load resistor being installed at the output and the power supplies energized.
These power supplies were calibrated until they stabilized and are rechecked and recalibrated, if necessary, on a periodic basis.
Other electronic instrumentation is maintained with coverings and externally applied heat.
A surveillance program which periodically recalibrates specified instruments is used to ensure that instrumentation is not degrading from long term preservation.
NRC QUESTION 4:
Describe the program for preserving the status / configuration of safety related construction with respect to Appendix B requirements.
What aspects nf this program preclude inadvertently performing any maintenance or other activities on safety related equipment or components without the required QA/QC coverage or oversight.
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 4:
This question deals with a subject that has been and will continue to be a major Supply System and project management concern.
The control of work and other activities at the Site are governed by procedures and management controls that are emphasized and have high priority.
These controls are described below:
A.
New Installation - All construction installation of equipment and/or systems, including cleaning and painting, is performed using work packages in 'accordance with Project and Construction Management Procedures.
The work packages are developed utilizing ' engineer approved drawings and no modifications are allowed unless approved by the engineer through modifications requiring a revision to the approved drawings.
B.
Startup ModificM. ions All modifications to equipment and/or systems, including any cleaning or painting, required as a result of startup testing, are performed in accordance with the Supply System Startup Program Manual and implementing procedures.
Modifications require engineer approval.
All modifications require a revision to the approved drawings and any other supporting documenation such as technical manuals, plant procedures, testing programs, etc.
ATTACHMENT 1 WNP-3 PRESERVATION AND MAINTENANCE PROGRAM PAGE 5 C.
Maintenance No modifications to equipment and/or systems are allowed during preventive or corrective maintenance activities.
All maintenance, including any cleaning or painting, is performed in accordance with approved procedures which only allow the return of equipment to its as-built condition.
If equipment cannot be returned to as-built configuration or a modification is needed, changes are implemented by A or B above or by the plant modification procedure if the equipment has been released to Operations.
D.
Management Philosophy - All facets of management at the Site endorse a strong position against unauthorized modifications.
Modification control and the necessity of ensuring that the field installation matches the controlled documents have the highest priority at the Site.
E.
Quality Assurance / Quality Control - Safety related work, regardless of the type (installation, modification or maintenance) is performed only in accordance with approved procedures and requires review by Quality Control for inclusion of necessary hold points.
In addition, Quality Assurance / Quality Control and Site Management J
perform random surveillances of both on-going field and completed i
work.
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NRC QUESTION 5:
With respect to Readiness Review, tentative approval may be given to your maintenance and preservation program based upon your program descript. ion.
However, for NRC to perform a final evaluation and approval of your pro!) ram, you will be required to perform a detailed self-assessment or eva' uation as part of the Readiness Review and the results must be reviewed and accepted by the NRC.
Describe your program for a self-assessment and give a tentative schedule for its completion.
If that portion of your program is not reacly for submission, please indicate a schedule by which we will receive your program and the results of your sel f-assessment, t
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 5:
i The Supply System's sel f-assessment of the preservation will be incorporated into the Construction Assurance portion of the Readiness Review Program.
The results of ~ the self-assessment of preservation will be included in the reports provided to the NRC of the Construction Assurance Program.
We plan to submit the Construction Assurance Program Description to the NRC for approval by approximately September 20, 1985.
The program description will cont 31n a requirement for a bi-monthly rolling 6 month schedule of reviews and construction assurance activities.
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ATTACHENT 2 3
i WNP-3 ENGINEERING ASSURANCE PROGRAM i
i NRC QUESTION 1:
Specific objectives of the Engineering Assurance Program (EAP) were not identified in the program plan.
We assume, consistent with WPPSS letter of Mgy 22,1985, that the EAP will be conducted in two phases as follows:
i
" Phase I would be complete prior to resumption of construction and would j
assess the design process and sample design products in order to provide additional assurance that the design process used in construction l
completed to date has fully complied with FSAR commitments.
Phase II j
would begin following resumption of construction and would include all j
aspects of new or changed design (such as design changes resulting from
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NRR review of FSAR commitments).
The objective of Phase II will be to f
provide additional assurance that the design process used in constructing the plant, fully complied with FSAR commitments as reviewed by NRR.
Specifically, identify the WPPSS objectives in the program plan.
i SUPPLY SYSTEM RESPONSE TO NRC QUESTION 1:
The Engineering Assurance Program (EAP) will be carried out in two phases.
Phase 1 will be complete prior to resumption of construction and i.
will assess the design as it presently exists.
Phase 2 to be performed following resumption of construction, will assess the remainder of the design.
The Phase I objective is to assess the design process and sample design l
products in order to provide additional assurance that the design process used in construction completed to date has fully complied with SAR commitments.
Phase II will include all aspects of new or changed design (such as design changes resulting from NRR review of SAR commitments),
i i
j The objective of Phase II will be to provide additional assurance that the design process used in completing construction of the plant fully t
complied with SAR commitments, as reviewed by NRR.
i NRC QUESTION 2:
The specific review / assessment topics to be included in Phase I or II have not been identified in the program plan.
Please submit or commit to submit for NRC staff review the specific topics to be included in each phase and describe the depth of review for each topic including a discussion of how the list of topics will form a representative sample of I
work completed to date for Phase I, or will be representative of the design - for the completed plant for Phase II.
Final staff approval of either Phase I or Phase II would be contingent upon staff review of the specific review / assessment topics.
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SUPPLY SYSTEM RESPONSE TO NRC QUESTION 2:
I A tentative list of topics for Phase 1 is attached.
Key word sub-topics have been included to indicate the general content of each topic.
The topics have been chosen so that, in the aggregate, they will demonstrate 4
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.
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ATTACHE NT 2 WNP-3 ENGINEERING ASSURANCE PROGRAM PAGE 2 The depth and scope (including checklists) for each review will be established during the development of the Review Plans by the Review Team Leaders and their team of experts.
Development of Review Plans will occur at the first step of each review module at approximately three month intervals to avoid the potential problem raised by NRC Question 4 (below).
In answer to NRC Question 5,
the NRC has been invited to participate in the development of the Review Plans, thereby being afforded the opportunity to ensure adequate depth (content) of the Review Plans.
The depth of the reviews may be adjusted during the course of the review depending upon the finding observed.
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.
Phase 2 topics have not yet been chosen, but will be chosen to both extend and complement Phase 1 topics.
The selection of the topics will support the overall objective of being representative of the completed design.
NRC QUESTION 3:
Discuss program requirements for system walkdowns for items reviewed as part of the EAP which addresses design aspects.
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 3:
The Engineering Assurance Program includes requirements for separate "walkdowns" for each review module.
The Supply System plans to have at least two persons from each review team visually inspect the end products of their review topic.
Each walkdown will be designed to augment the specific topic under review.
Walkdowns will also be performed as part of the Construction Assurance Program (CAP), and the interaction between the two programs will be defined in more detail as the CAP definition is completed.
It is anticipated that the CAP walkdowns will be more " commodity" oriented, and that the EAP walkdowns will be more " system" or " discipline" oriented.
The two will be compatible.
NRC QUESTION 4:
The plan states that personnel and organizations to be assessed are notified of the schedule and scope of review a reasonable time in advance of the review.
Indicate how WPPSS assures itself that such notification does not bias the review process.
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NEERING ASSURANCE PROGRAM PAGE 3 SUPPLY SYSTEM RESPONSE TO NRC QUESTION 4:
The presently-approved procedures require that reviews be performed against paper and haretare dated prior to the date that the organization to be reviewed has access to the details of the Review Plan or prior to the date of notification of review, whichever occurs first, or that any material with a subsequent date be highlighted and treated as a special case with appropriate comments recorded on the rationale for including it in the review.
The WNP-3 project, in its normal course of licensee l
activities, continuously overviews AE design activities, and has occasion to initiate corrections and/or improvements in specific designs, design activities, and the design process.
It would be imprudent on the part of the Readiness Review Program to interfere with that ongoing project activity which is, in fact, a legitimate part of the design control process.
We believe that each Review Team will be able to detect recent activity that might be considered " preparation" for the review, and deal with it accordingly.
NRC QUESTION 5:
Will the qualifications and independence of the members of the Oversight Commiittee and independent third-party reviewers be submitted to the NRC staff for review? This is desirable.
SIFPLY SYSTEM RESPONSE TO NRC QUESTION 5:
The qualifications and independence of the Oversight Committee members, as well as the Review Team participants, whether they are Supply System l
employees or not, will be documented and available for NRC review.
It is our intent to solicit NRC concurrence of Oversight Committee members, and any third-party organizations that may be contracted to assist us, but not on individual Eeview Team members.
All selections will be documented and recorded for future reference, and available for NRC review upon request.
NRC QUESTION 6:
Provide WPPSS plans for notifying NRC staff in advance of any meetings where substantive matters resulting from design reviews are discussed in
(
order to allow NRC the opportunity for attendance at such meetings.
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 6:
Supply System will develop and distribute, bi-monthly, a comprehensive short-term (six month) schedule of significant program events.
The schedule will include:
a.
Review plan development meetings including checklist development.
b.
Schedule of notification of reviews to parties being reviewed including entrance
- meetings, reviews, exit meetings,
and post-review meetings (the latter at Supply System Corporate offices).
ATTACHMENT 2 WNP-3 ENGINEERING ASSURANCE PROGRAM PAGE 4 c.
Schedule of meetings to disposition the findings from each review.
Short-term schedule changes will be communicated to NRC by telephone not less than two weeks prior to the event of interest unless unforeseen circumstances arise, in which case notification will be as timely as circumstances permit.
NRC QUESTION 7:
Discuss how checklists and other detailed review plans by WPPSS and its independent third-party reviewers will be made available for NRC review.
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 7:
Supply System intends to keep NRC notified, through the use of the bi-monthly schedule, of the development of detailed review plans and checklists (see Item 6 above), and NRC is invited to participate in those meetings in Richland at NRC's initative.
Alternatively, NRC may request working copies of the draft plans and draft checklists for timely review and comment.
NRC QUESTION 8:
Will records of qualification and experience of all individuals assigned to the DRP for technical review be accessible for NRC inspection?
SUPPLY SYSTEM RESPONSE TO NRC QUESTION 8:
Records of the qualification and experience of all participants in this program will be available for inspection by NRC, for at least seven (7) years af ter plant fuel load.
r ATTACHE NT 2
-WW-3 ENGINEERING ASSURANCE PROGRAM PAGE 5 Tentative Topics /Sub-Topics Approx. Beginning 1.
Piping and Su> ports / Hangers / Restraints / Stress Sept.1985 Analysis /Brea t Location 2.
Civil and Structural / Coupling / Soils /ARS/ Embeds /
Jan. 1986 Floppy Floors 3.
Design Control / Criteria / Industry Concerns / Document Apr. 1986 control /Interdiscipline/ Vendor /NSSS/ Change Control /
Owner's Groups /As-Built Program 4.
Installation Design / Welding Parameters /Tolerences/
July 1986 Inspection criterta/ Cable Pulling /Rebar Cutting /
Procedure Control / Cleanliness / Test Requirements 5.
HVAC/ Fire Dampers / Redundancy / Heat Loads /CR Habitability Oct. 1986 6.
Electrical / Separation /SC Analysis / Cabling Design /
Jan.1987 Fusing / Supports /Two-Over-0ne/ Protective Relaying 7.
DHR SysteWCradle-to-Grave Review, All Disciplines Apr. 1987 8.
Red Mon / Requirements / Locations / Plate-Out/ Sensitivities /
July 1987 Noise Susceptability 9.
E0uip. Cual/ Seismic / Rad. Zones / Program / Documentation /
Oct.1987 SIEL/5ML/ Shelf Life
- 10. Appendix R/ Areas / Boundaries / Safe Shutdown /FP Detection /
Jan. 1988 M1tigation
- 11. Operability /ISI Design / Accessibility / Testability /
Apr.1988 Human Factors / Interlock Logic 12.
IAC/ Control Room /ASME III/ Control Loops / String Accuracy /
Jul. 1988 AT-WSSS-Owner Interface /EDS/SPDS
- 13. Open Topic / (Topic to be selected after module II Aug. 1988 results are in)
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