ML20137B782

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Submits Response to NRC Re Engineering Assurance Program (EAP) Plan.Eap Procedure E2.102 Revised to Include Requirement That Reviewers Have Commercial Design Experience in Review Area
ML20137B782
Person / Time
Site: Satsop
Issue date: 11/11/1985
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO3-85-660, NUDOCS 8511260349
Download: ML20137B782 (6)


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. Washington Public Power Supply System

. P.O Box 968 3000GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 DOCKET NO. 50-508

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,f'Q November 11, 1985

'G-G03-85-660.

p-Mr. J.! B. Martin s

Regional Administrator d

' U. : S. ' NRC - Region V

'_1450 Maria Lane, Suite 210 Walnut Creek, CA 94596

Dear Mr. Martin:

Subject:

NUCLEAR PROJECT NO. 3 READINESS REVIEW PROGRAM DESIGN VERIFICATION ACTIVITIES

Reference:

Letter, J.B. Martin to D.W. Mazur, dated 10/25/85, same subject.

The'. referenced letter. provides NRC comments on our Engineering ' Assurance Program (EAP) Plan. Those comments requiring our response are provided below.

Comment No. 2 La)

-NRC review of individual reviewer qualifications, i.e.,

commercial design experience, and independence from work being reviewed.

Supply System Response - EAP Pi. : dure E2.102 (now EAP 5.2) has been revised to cinclude the requirement that reviewers have previous conmiercial : design experience in the area they are reviewing, and that such experience be documented.

b)

' Reviewer Conflict of Intemst Supply System Response - The same procedure has been revised to i

reduce the 5100,000 stock (or investment) limit to $1,000 to show -

financial independence of the reviewers from the organization under review.' A ' limit of -$1,000 (rather than zero) was chosen because we believe ~ that $1,000. is masonably small.enough to preclude biased behavior.

- And it avoids the necessity to demonstrate zero-level involvement which could prove difficult ~ given the existence.of mutual ' funds,'

credit -union investments, etc.,

over which.the participant has essentially no control.

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gy, J. B. Martin'

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G03-85-660 November 11, 1985

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Comment No. 3 EAP Review Topics Supply System Response - In' response to your comment on our choice of review,copics, we. have revised our list slightly, and developed a narrative that describes the rationale for the - choice of topics and how they will be interfaced during the course of the review.

This narrative, provided as Attachment 1 hereto, will ultimately become part of the EAP Phase 1 Summary Report.

Note that your comment 3.c has been incorporated

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by cmating the review topic " Hazards Analyses", that will address (via appropriate specialists) HELB/fiELB, Fire Protection, Flooding, etc.

The original set of EAP procedures provided to Mr.

J.

Milhoan has been

- revised.. renumbered and incorporated into the Readiness Review Program Manual cand will be provided under separate distribution for your infomation. -

Very truly yours, G. C. Sorensen, Manager Regulatory Programs sek

Attachment:

As stated.

cc: *Mr. J. A. Adams, NESCO Mr. G. T. Ankrum, Nuclear Regulatory Commission

  • Hs. N. Bell, Nuclear Infonnation & Resource Services Mr. R. B. Boucher, Pacific Power & Light Company Mr. E. - W. Brach, Nuclear Regulatory Commission Mr. W. L. Bryan, Washington Water Power Company Mr. H. R. Denton, Nuclear Regulatory Commission
  • Mr. R. T. Dodds, Nuclear Regulatory Comission Mr. C. Eschels, EFSEC Chairman
  • Mr.- R. F. Heishman, Nuclear Regulatory Commission
  • Mr. T. Michaels, Nuclear Regulatcry Commission -
  • Mr. J. -Milhoan, Nuclear Regulatory Commission 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. B._ C. Withers, Portland General Electric Company Document Control Desk - U.S. NRC

' *Mr. 'T. W. Bishop, O'Brien-Kreitzberg & Associates, Inc.

  • Mr. S. H. Bush, Ph.D., Review & Synthesis Associates
  • Mr. R. V. Laney, Consultant
  • With Attachment

2.3 SCOPE 0F DESIGN REVIEWS 2.3.X Scope of Each Topic 2.3.X.1 Module E3-01,- Piping and Pipe Supports The purpose of Module E3-01 is to assess the adequacy of the AE's piping ' and pipe support design program by sam-pling enough activities in enough areas to ensure that

there are no inadequacies in the piping or pipe support design program.

This purpose is accomplished by select-ing several systems with differing technical require-ments and with differing organizational responsibilities and interface requirements, so as to test all important AE activities and interfaces relative to the pipe and pipe support design functions.

Once this topic is assessed for adequacy, the EAP system reviews that occur after this assessment will not assess this same material,. but will only confim that system-related sources of input to the piping review such as pressures, temperatures, materials, and transient load-ings created by the dynamic characteristics of the Sys-tem (such as water hammer, fast valve response, themal cycling, etc.) are properly developed by the systems designers, and are properly transmitted to the piping and pipe supports design' groups.

2.3.X.2 Module E3-02, Civil / Structural and Hon-Pipe Supports The purpose of Module E3-02 -is identical to Module E3-01 except it' addresses different' commodities.

Once the adequacy of the design functions assessed under this l

topic is confirmed, the reviews that occur later in time will not assess the same material, but will only confirm that the infomation received from the Civil / Structural design groups, such as response spectra, is used prop-erly, and ' that infomation such as heat input, weights,.

compartment pressures, penetration sealing requirsments, l-etc., provided to the Civil / Structural design group by.

the L other.related reviews was properly developed and L

transmitted.

' ddule E3-03, Design Control 2.3.X.3 M

The purpose of Module E3-03 is to assess the generic L

portions of the design control process such as document control (correct revisions being used, appropriate ap-provals, unincorporated change tracking, acknowledge /

receipt, etc.), procedure control, vendor document con-trol / approval,

adequacy and security of current and historical files, and proper procedure hiearchy; and to ATTACHMENT 1 -

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reconcile the findings of this review with the overlap-ping portions of the other review modules such as those attributes listed above, plus change control, open issues control, industry concerns tracking, and specifi-cation control.

2.3.X.4 Module E3-04, Component Cooling Water System (CCW)

The purpose of Module E3-04 is to assess the functional design of a system designed primarily by the AE, and to ensure that infomation developed during system design is -properly. communicated to other design activities such as piping, civil, electrical, Equipment Qualification, etc.,. and that information received from other design I

activities is properly used within the systems design group (s). The primary focus of this review is to ensure i

the form, fit, and function of the CCW system and its major active components such as pumps, valves, tanks, filters, etc., and that the system is designed to per-form its function (s) as described in the FSAR in regard to its capacity, redundancy, single-failure capability, logical interlocking with other systems, etc.

The CCW system's pipe, supports, electrical service, qualifica-

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tion of equipment, etc., will be reviewed under the au-spices of the other review modules as appropriate.

1 2.3.X.5 Module E3-05, Design For Fabrication and Installation l

The purpose of Module E3-05 is to ensure that the AE's requirements for the fabrication and installation of l

systems, structures, and components have been adequately documented and transmitted to the. fabricators and in-

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stallers.

The attributes to be assessed are those that l

describe "in process" activities rather than the final configuration and include requirements such as weld weave width, pre and post heat treatment, weld heat in-put, -. filler material, cable pulling tension limits, preparation requirements (and inspection criteria) for the application of coatings, cold-springing and bending, etc.

2.3.X.6 Module E3-06, Safety-Related HVAC System The purpose of Module E3-06 is to assess the functional design of a safety-related heating, ventilating, and air conditioning (HVAC) system.

An HVAC system was chosen for review because it involves significantly different disciplines and design groups than those assessed under the piping (systems) reviews, and is frequently designed to a large extent by the subcontractor.. The selected system will be reviewed for form, fit, and function of ATTACHMENT 1 L.-.

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the system and its major components such as ducts, fil-

_ters, air handling units, fire dampers, scrubbers, etc.,

~ and its related instrumentation, because it is substan-

.tially different from the normal plant instrumentation.

-In addition, the system will be assessed for its capac-ity, ' redundancy, single-failure capability, and interac-tion with othe HVAC. systems.

The HVAC system's sup-ports, electrical service, qualification of equipment, etc., will be reviewed under the auspices of the other review modules as appropriate.

2.3.X.7 Module E3-07, Safety-Related AC and DC Systems Review The purpose of Module E3-07 is to assess the AE's elec-trical design capability by reviewing representative design activities, and comparing the products of the design with FSAR commitments.

The designs will be as-sessed for capacity, voltage drop, circuit protection, fusing, _ interdependence, shared circuits, cable routing, component specification (MCCs, batteries, switchgear, cable, etc.), interlock and permissive features, protec-tive relaying, " associated circuit" designation, etc.

Tray and conduit supports, qualification of equipment, etc., will be reviewed under the auspices of the other review modules as appropriate.

Additional electrical design will be reviewed under the Hazards Analysis, Module E3-10.

2.3.X.8' Module E3-08, ECCS Review l

The purpose of Module E3-08 is -to assess the adequacy of the AE-NSSS design interface by reviewing the AE's im-plementation of the -NSSS system requirements and by_ re-viewing the technical information exchange between AE

.and NSSS.

The ECCS, comprised of the Safety Injection System (LP and HP), Shutdown Cooling System, and Con-tainment Spray System will be reviewed - as. a composite system for the purposes of this review which will pri-marily assess the AE's portion of the design, and inter-faces with other supporting systems and - disciplines.

Pipe supports, electrical service, equipment qualifica-tion, etc., will be reviewed under the auspices of the other review modules as appropriate.

l 2.3.X.9 Module E3-09, Equipment Qualification Program Review l

The - purpose of Module E3-09 is to ensure that plant equipment will be fully qualified for plant operation by reviewing design requirements, purchase specification requirements, sample documentation packages, and the AE and NSSS EQ programs plans and implementation.

In addi-tion, development of environmental and seismic EQ re-i quirements will be independently sampled and analyzed

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for adequacy, the development of the SREL and SRML will be reviewed along with the extraction, processing, and promulgation of maintenance requirements to maintain /

extend qualified life.

2. 3. X.10 Module E3-10, Hazards Analysis Implementation The purpose of Module E3-10 is to ensure that the design features necessary to support the Hazards rnalysis-are properly incorporated into plant design.

Such features include designs to accomodate High Energy Line Break (HELB) detection and mitigation, fire detection and mitigation, jet impingement and missiles, separation of redundant _ mechanical, electrical and instrumentation, remote shutdown capability, flooding, and compartment pressurization.

The hazards analysis itself will only be spot-checked. - Appropriate coordination between this review and the other design reviews will be developed and documented.

Two-over-one criteria and its implemen-tation will also be assessed.

2.3.X.11 Module E3-11, Design For Operability The purpose of Module E3-11 is primarily to ensure the licensee-that design features-that support / enhance plant operability are adequately addressed by the AE.

Such features include accessibility for operation and main-tenance, isolability for leak detection, heat tracing, human ~ factors considerations, ALARA considerations, and system interlock logic related to plant systems startup and Technical Specification testing requirements.

2.3.X.12 Module E3-12, Instrumentation and Control (I&C) Design The purpose of the Module E3-12 is to assess the ade-quacy of I&C design performed by the AE, including the documentation of the design.

Design features that will be assessed include tubing design (code requirements, slope, vents and drains, use of condensing pots, refer-ence leg design), string accuracy criteria and require-ments, failure modes analysis, mounting requirements, power supply interactions, and a sampling of prepur-chased specification requirements and vendor responses thereto.

Tubing supports, electrical service, welding, brazing, etc., will be reviewed under the auspices of the other review modules as appropriate.

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