ML20137B550

Forwards Comments Re 850925 Proposed Const Assurance Program.Response to Comments Requested to Complete Review of Program

ML20137B550
Person / Time
Site:	Satsop
Issue date:	11/20/1985
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Kohler A WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 8511260294
Download: ML20137B550 (4)

Text

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NOV 201985 Dock'et No.~:50-508 :

Washington Public Power Supply System P. O. Box 1223 ,

Elma, Washington 98541 Attention: Mr. A. D.'Kohler Director 'of Projects

' Gentlemen: ,

Subject:

Supply System Nuclear ' Project No. 3 Construction Assurance In Supply System Letter G03-85-563 dated September 25, 1985,.the Supply System submitted its Construction Assuranc'e Program for NRC review and approval. On

.0ctober 29, 1985,.the NRC staff met with you at Elma, Washington to discuss your proposed Construction Assurance Program. The attached enclosures are NRC

. staff comments regarding your proposed Construction Assurance Program. In order, for us to complete our review of your program, we will need your response to the attached comments.

0iainto daned by D. E, Kirsch Dennis F. Kirsch, Deputy Director Division of Reactor Safety and

. Projects-cc w/ enclosure:

D. W. Mazur, WPPSS R. B. Glasscock,'WPPSS L. J. Garvin, WPPSS J. D. Martin, WPPSS' State of WA .

bec w/ enclosure:

Resident Inspector Mr. Martin, RV-Mr. Faulkenberry, RV '

'Mr. Cook, RV

.RSB/ Document Control Desk (RIDS) .

bec.w/o enclosure: LFMB ' -

REGION V/ dot -

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WNP-3 Construction Assurance Program (Phase I) Questions / Comments

1. Paragraph 5.0 of the program commits to performing detailed inspection walkdowns of sample hardware and detailed reviews of records for compliance with design, installation and acceptance criteria. Do you plan to include a review of installation and inspection procedures in the verification for compliance with design and installation requirements?

2. Paragraph 5.0 states.that all design related findings, concerns and observations will be communicated to the Manager, Engineering Assurance for consideration in the Engineering Assurance Program. Will this be in the form of a memorandum or nonconformance reports?

3. Paragraph 5.1 provides general guidelines for selection of work areas to be reviewed. Do you plan to consider coordination of the Engineering Assurance Program with the Construction Assurance Program? For example, if system or subsystem X is chosen for Engineering Assurance Review, it would seem appropriate to consider a review of system or subsystem X in the Construction Assurance program, as much as practicable. This would provide a continuity of,the review, enable correlation of findings and support a' conclusion of the overall' readiness for the sample system or subsystem X.

4. An Engineering Assurance Program (EAP) normally ends with the AE final product, e.g. drawing, specifications, etc., which is delivered to the Construction Manager. A CAP normally begins at that point and follows through to completion of-the final product. It appears that your CAP program starts at a different point such as the individual construction

-company's' contracts. If this is correct, how does your program determine those documents are correct and complete with respect to the AE final design product? Explain. ,

5. Provide additional information on the interface between the Engineering Assurance and Construction Assurance programs. Especially in the areas such as pipe hanger / supports where problems have been identified at other facilities.

6. Paragraph 5.1 provides guidelines for selection of work that represents known or suspected Supply System and/or contractor problem areas. Do you plan to include areas addressed by open NRC items.

7. Paragraph 5.2 discusses independence of Construction Assurance reviewers.

Will the selected reviewers have participated in the design engineering, field engineering, field supervision, installation or inspection of the work being reviewed? Similar financial considerations applied for independence of the Engineering Assurance Program reviewers should also be considered for the Construction Assurance Program reviewers. It may be appropriate to provide additional discussion regarding the structure of the reviewing organization including first level reviewers, first level managers and decision making responsibilities.

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8. Paragraph 5.3 discusses the management of the results of the Construction

-Assurance reviews. Do you plan to provide separate eports for all normal NRC reporting requirements (10 CFR 50.55(e) and 10 CFR 21)?

9. Paragraph'5.3 discusses the management of the results of the Construction Assurance reviews. Do you plan to perform a self-assessment of the results of the review? Will Supply System senior management be made aware of the review results and participate in the self-assessment? What input will the oversight committee have with regard to results of the review?

10. Please provide a description of the format and content of CAP reports to the NRC. How will FSAR and other NRC commitments be identified in the reports? How will the reports confirm / deny conformance with those commitments in the reports? What level of detail will the reports have?

11. The program assesses the adequacy of completed WNP 3 contractors' work.

Will an evaluation of Supply System work, if any,.be also performed?

-12. Section 5.0 states that "When deficiencies are identified, recommendations for disposition will not be made by the reviewers and inspectors." How will the review team be involved in reviewing the resolution of deficiencies? If they will have no involvement, please explain why not. It may also.be appropriate to discuss what review and approval is needed to confirm or res'olve potential findings / observations.

13. Section 5.4 discusses an " oversight committee". Please provide a more comprehensive description of the structure, resources and charter / functions of the oversight committee. How will their comments / recommendations be handled?

14. Section 6.0 discusses program implementation and selection of review areas. Please describe how the program ensures that all safety related areas will be reviewed. Also, please define the specific areas to be reviewed. How will NSSS, I&C, radwaste, fire protection and emergency power subject areas be addressed?

15. The list of module topics included in the program description seems tentstive and the exact contents of each module has not been determined.

How does your program ensure each aspect of the construction activities will be included in your review? Explain. A diagram may be helpful.

16. Please more clearly define licensee senior management conclusions regarding the CAP review modules, the input of the oversight committee to these conclusions, and the licensee's recommendations to the NRC regarding acceptability of the work reviewed including a statement of conformance to requirements and NRC commitments.

17. Provide additional detail relative to your actions / criteria when the original sample yields deficiencies. Additional discussion may be appropriate regarding the approach for deciding size of expanded sample.

Please include criteria for determining generic conditions.

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,18. Address those areas where the acceptance criteria will-differ from the

t.  : original criteria described in'the SAR.

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' e 19. Describe ~how 10-CFR 50 Appendix B (18 criteria) applies to the Construction Assurance program. A matrix may be helpful.

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- 20'. J Include " Flow Diagram" presented .as viewgraph in public meeting' on

, ' October 29,-1985,-. with program description.

r c .;- 21. ItJaay be appropriate to expand the: discussion on. Phase I and Phase II to

.more clearly delineate'what will be accomplished in each phase and how the total effort -of both phases will provide results that support the

-final' objective of the CAP.

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