ML20137M980
| ML20137M980 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 01/09/1986 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GO3-86-026, GO3-86-26, NUDOCS 8601290117 | |
| Download: ML20137M980 (26) | |
Text
Washington Public Power Supply System P.O. Box 968 3000GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 DOCKET N0. 50-508 $
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0 January 9,1986 s' Ti- A i'-."
G03-86-026 - E 9
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:
NUCLEAR PROJECT NO. 3
! READINESS REVIEW PROGRAM CONSTRUCTION ASSURANCE ACTIVITIES
Reference:
- 1) Letter (GI3-85-442), D. W. Kirsch to A. D. Kohler, subject, "WNP-3 Construction Assurance Program", dated November 20, 1985.
- 2) Letter (G03-85-563), G. C. Sorensen to J. B. Martin, subject,
" Readiness Review Program", dated September 25, 1985.
- 3) Letter (G01-85-0127/G03-85-0299), G. C. Sorensen to J. B.
Martin, subject, " Design Review Program (Engineering Assurance)", dated June 3,1985.
Enclosed is our response to comments on the subject program activities presented in Reference No.1. We trust this information will provide sufficient detail for the staff to complete its review and lead to your approval of the Construction Assurance Program.
A j 'k
Mr. J. B. Martin l G03-86-026 1 January 9,1986 Page 2 7
. Three documents were submitted to you by References No. 2 and 3:
- 1) Overview of the WNP-3 Readiness Review Program ,
- 2) Program Description for the Engineering Assurance Program
- 3) Program Description for the Construction Assurance Program These documents are being revised to include fundamental changes resulting
, from commitments established in the enclosure, and are being sent to you under
- separate cover.
Very truly yours,
. C. Sorensen, Manager Regulatory Programs
?
Enclosure:
Supply System Response to NRC Letter GI3-85-442, NRC Questions on l the WNP-3 Co.1struction Assurance Program (18 pages), and Attachments:
- 1: Draft Outline for Module Reports
[ 2: Operating Charter for the Oversight Committee
- cc
- See next page.
a l
I 4
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Mr. J. B. Martin G03-86-026 January 9,1986 Page 3 cc: *Mr. J. A. Adams, NESCO Mr. G. T. Ankrum, Nuclear Regulatory Commission
- Ms. N. Bell, Nuclear Information & Resource Services
- Mr. T. W. Bishop, O'Brien-Kreitzberg & Associates, Inc.
Mr. R. M. Boucher, Pacific Power & Light Company Mr. E. W. Brach, Nuclear Regulatory Commission Mr. W. L. Bryan, Washington Water Power Company
- Mr. S. H. Bush, Ph.D. , Review & Synthesis Associates 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. W. M. Hill, Nuclear Regulatory Comission Mr. G. W. Knighton, Nuclear Regulatory Comission
- Mr. R. V. Laney, Consultant
- Mr. T. Michaels, Nuclear Regulatory Comission Mr. J. Milhoan, Nuclear Regulatory Comission Mr. F. J. Miraglia, Nuclear Regulatory Comission Mr. R. V. Myers, Puget Sound Power & Light Company Mr. E. Revell, Bonneville Power Administration Mr. N. S. Reynolds (Bishop, Libennan, Cook, Purcell & Reynolds)
- Mr. E. Rosolf e, Director of Coalition for Safe Power Mr. B. K. Singh, Nuclear Regulatory Comission Mr. D. Smithpeter, Bonneville Power Administration Mr. J. M. Taylor, Nuclear Regulatory Comission Mr. B. C. Withers, Portland General Electric Company Document Control Desk - U.S. NRC
- With Enclosure
PAGE 10F 18 SUPPLY SYSTEM RESPONSE TO NRC LETTER GI3-85 ad2 NRC OUESTIONS ON THE WHP-3 COMMPUCTICN ASSURANCE PROGRAM January 3,1986 Ouestion 1 Paragraph 5.0 of the program -s.oits w performing detailed inspection walk-downs 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 regaf rements?
Response
Installation and inspection procedures will be reviewed in the CAP in the following general sense. Team members will use/ read key contractors ' pro-cedures to establish that they implement the design requirements and would result in satisfactory construction products. This review of the procedures will aid their development of inspection and review checklists, and is covered in the CAP procedure on review team planning.
Question 2 Paragraph 5.0 states that all design related findings, concerns and observa-tions will be communicated to the Manager, Engineering Assurance for consider-ation in the Engineering Assurance Program. Will this be in the form of a memorandum or nonconfomance reports?
Response
All observations made by CAP reviewers which are cause for concern, either for the quality of the component or its design, will be identified on an open items list (OIL) in the CAP Office. The OIL items that are design-related, and copies of all NCR's generated by 7 '.eam members that are design-related, will be transmitted to the Manager, Encir:aering Assurance, by memorandum.
The normal handling of NCR's generated by the CAP will be through the existing project reporting system, which has no provisions for special-purpose distri-bution to the Peadiness Peview Program. Therefore, the PPP procedural mech-anism for coninunicating such information will be the transmittal memo.
Question 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 appropri-ate 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.
PAGE 2 of 18
Response
The principal purposes of coordinating the review of the same system or sub-system in both programs are envisioned to be 1) the potential for verifying the design and construction of that system or subsystem, thus providing a conve-nient " vertical slice" review; and 2) the correlation of findings.
It is our intention to provide a representative vertical slice through the design and construction work at WNP-3 by review of (the same or) similar com-ponents. Since the CAP reviews are coninodity and/or discipline oriented, it is neither practical nor desirable to limit the "representativeness" of a sample to a system or subsystem selected for EAP process review. Despite the selec-tion of separate but similar components in each program, the Supply System will add to randomly selected construction samples some specific components which had been selected for design review.
Correlation of findings from the two programs is not precluded by review of separate but similar components. Indeed, this is considered desirable at some point (s) in the Readiness Peview Program. We are considering the need for a systematic method / procedure for correlation and trending of CAP /EAP results from similar modules, and will address this whole subject in the final Phase 1 progran report.
Question 4 An Engineering Assurance Program (EAP) normally ends with the AE final product, e.g. drawing, specification, 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 companies' contracts. If this is correct, how does your program detennine those documents are correct and com-plete with respect to the AE final design product? Explain.
Response
Our case is not different. The EAP will confirm the quality of the final design products, and the CAP uses these drawings and specifications to identify the requirements for construction products, i.e., to establish the acceptable criteria for each component to be inspected and each quality record to be reviewed.
In looking at individual contracts --- remembering that the bases for these contracts are the same drawings and specifications --- the Supply System ensures that every constructor who used the final design products did so correctly and produced or installed hardware of acceptable quality.
The CAP begins with the assumption that the design documents are correct and complete. Assurance that this assumption is valid is provided by the confirmatory reviews of the EAP.
PAGE 3 of 18 l
Ouestion 5 '
Provide additional infomation on the interface between the Engineering Assurance and Construction Assurance programs. Especially in the areas such as pipe hanger / supports where problems have beem identified at other facilities.
Response
The EAP will review samples of 1 sign in selected topical areas from conceptual design through to the final products of design (drawings, specifications and cal culations ) . During preparation of checklists, industry concerns are screened for applicability to EAP reviews, as well as NPC concerns (bulletins, circulars, notices and inspection reports) and the project's own NCR and Part 21 and 50.55(e) files. The resulting EAP checklists are made available to the CAP Manager in EAP review plans, including the specific components of interest.
The CAP encompasses all sa fety-rela ted commodities and construction activ-ities. Once CAP review samples of hardware and quality records are chosen, they will be augumented to ensure inclusion of components that were also assessed by the EAP, but not on a one-to-one basis. In preparing review plans, CAP Team Leaders will also screen various data bases of industry, the NPC, and the project for areas of concern that will aid in developing CAP review check-lists (See response to Question 6.)
In addition, EAP Review Team Leaders will notify the CAP manager of specific and/or unique design attributes that should be considered for inclusion in the CAP reviews. For example, to pay particular attention to the OC methods for skewed-weld fillet-size measurement techniques, procedures and documentation.
During walkdowns at the plant, these same installation / fabrication attributes may also be observed by EAP teams, but not in as much detail as the CAP inspections.
This same concept is applied if the CAP review of a commodity occurs before the related EAP review of the same comodity. In general, the EAP review is expected to preceed the related CAP review, but this is not a program requirement.
Question 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?
Pesponse Yes. Following is a list of sources from which CAP team members will select known or suspected problem areas that pertain to their respective modules, and will be considered by each team in developing review plans , samples, and
- attributes for inspection
l .
. _ _ - _ _ _ - _ _ . ~ _. . ._ . _ . . .- _ _ - _ . . ._ ._ __
i PAGE 4 of 18 o NRC Inspection Items List (0 pen Items)
'~
o List of Project 50.55e's 8 Part 21's
- o NRC Bulletins, Circulars, and Motices i o NCR Trends (8 other project trend reports) i o Related EAP Peview Plans & Checklists o INPO Construction Evaluation Criteria o INPO Recurring Findings j o Allegations, Hot Lines, etc.
l o Nuclear Network, SEP's, SOEP's M0EP's o Lessons Learned - SS, Industry, INPO ,
- o Ouality Verification & Plant Verification Programs, WNP-2 f o Results from Similar Industry Programs
', This list is provided in the CAP procedure on review team planning and is to be considered by each Team Leader.
Question 7 t l
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 ,
i 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.
Response
4 It is a programmatic requirement of the CAP that review team personnel be i independent of the work to be reviewed and of the contractor organization that
- produced that work. However, there is no requirement for CAP reviewers to be
- independent of past design activities, and they may therefore be members of the
! Supply System or AE organizations. There is a procedural reouf rement in the personnel selection process for financial independence, similar to that of the EAP.
The structure of the CAP organization and its members' individual responsi-
! bilities are established by procedure. Basic decisions concerning review i activities are made by review Team Leaders selected for their expertise and i experience in the discipline (module) under review, subject *.o the approval and i participatory involvement of the Manager, Construction Assuran ce.
As with all documents associated with the Supply System's Readiness Review Program, these procedures will be available for NRC inspection in the Program l Manual. The CAP implementation procedures establish the structure and fonnat i
i j
I PACE 5 of 18 for repetitive selectim and review activities. Team Leaders may prepare additional instructions or procedures oriented to specific module activities, and will prepare checklists and instructions to identify the important points to be checked by reviewers and inspectors, and the criteria for acceptance of '
records and hardware.
Question 8 Paragraph 5.3 discusses the management of the results of the Construction Assurance reviews. Do you plan to provide separate reports for all nomal NRC reporting requirements (10 CFR 50.55(e) and 10 CFR 21)?
Response
The existing project reporting system satisfies requirements for irfaming the NPC of 50.55(e) and Part 21 ftems. This existing system will be input by the CAP through the use of project PCP's, which are reviewed in accordance with project procedures for the need to identify and report 50.55(e) and Part 21 issues to the NRC, as a programmatic requirement. In this way, NRC reporting of these issues are " separate" from CAP reporting, but the NPC will receive notification of 50.55(e) and Part 21 f tems in the usual way.
However, all infomation pertaining to findings of the CAP, including the identification and reporting of important issues to the NRC, will also appear in CAP program reports.
Question 9 Paragraph 5.3 discusses the management of the resul ts of the Construction Assurance reviews. Do you plan to perfom 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?
Response
Self assessment of the CAP will be performed by our internal OA Audits organ-ization, the independent Oversight Committee, the Peadiness Review Program Manager, and the Director of Projects. In addition, the CAP and EAP managers will assess each other's programs on an infomal basis. Because this is an important and cos tly sel f-initiated program, the Supply System's senior management is acutely interested in its success, and has comitted to active assessment of its implementation, as outlined in Paragraph 5.3 of the Program Description.
The CAP and EAP Managers interface with the RPP Manager and with each other on an informal daily basis concerning programatic issues and details, and report in writing on a monthly basis. The PRP Manager reports program status, pro-gress, and significant issues to the Managing Director of the Supply System through the Director of Licensing and Assurance. In addition, reports of the RRP are filed for Monthly Program Peview of WNP-3, where the Director of Projects evaluates implementation of the Readiness Peview along with other project issues. The CAP Manager interfaces with WNP-3 Project on a regular weekly basis in the Deputy Program Director's management staff meetings.
PAGE 6 of 18 The Oversight Committee will evaluate the overall program (including all three elements --- EAP , Preservation, and CAP) and provide recommendations for improvements to Supply System management. They are not required to, but may spot-check technical details, findings, and dispositions. Their approval is not required, but Comittee comments must be reconciled for the record.
Periodic meetings are held with the Oversight Comittee to discuss details of the review programs and make observations of program implementation. The Committee is required by its charter to provide written assessments of the program and its ongoing implementation.
Question 10 Please provide a description of the format and content of CAP reports to the NFC. How will FSAR and other NPC 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?
Response
Two types of report will be provided to the NPC covering the activities in the Peadiness Review Program, including the following:
Podule Peports Module Reports will be " final reports" of the individual reviews completed in the EAP and CAP. All the details of each module review will be dis-closed in them, including how the review was organized, the participants' qualifications, the scope of work reviewed, acceptance criteria, the rationale for selecting samples, how reviews / inspections were accom-plished, the details of the results and their analysis, trends identified from the reviews, and recommendations for further action. A tentative outline for the cortents of CAP reports is provided in Attachment 1 to illustrate our intention to adequately describe the work of a typical module in this program.
Final Readiness Review Program Report (s)
At the conclusion of the module reviews, a final report will summarize the work of the EAP and CAP and draw conclusions from the collective results.
It may be desirable to have separate reports for each program element, a decision not made at this time. Such a final report will record the correlation of results among the various modules, including those between the EAP and CAP.
Question 11 The program assesses the adequacy of completed WNP-3 contractors' work. Will an evaluation of Supply System work, if any, be also performed?
PACE 7 of 18
Response
Yes. Specifically, maintenance and preservation work is being accomplished by Supply System personnel in some cases, and components so maintained in accor-dance with requirements of the Preservation Program will be included in CAP review sampling. The maintenance and preservation aspects of and attributes for these components will be reviewed by the CAP, as described in Paragraph A.0 of the Program Description.
Question 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 resolve potential findings / observations.
Response
During construction, as quality inspectors or other plant personnel identify discrepancies in the work, FCP's are prepared and processed through the project 0A program. In this program, a recommended disposition is provided by the PCP initiator when possible, and that reccmmendation may further be modified by the Contruction Panager's field engineers. Such reccmmendations are made by personnel engaged in or very close to the work process, and it is appropriate to use their hands-on knowledge and experience. Feasibility and costs of corrective actions are among the considerations in making such recommendations.
In the cast of CAP reviews, personnel identifying discrepancies are not close o the wdt process and are not expected to possess special knowledge regarding expedient correc.ive action for discrepancies identified on this project. This is especially true because 1) CAP reviewers may not have (probably will not have) worked on the WNP-3 project before, and 2) the unusual circumstances of the project's construction delay. Because of this, it is considered inappro-priate for CAP reviewers to make recommendations for engineering disposition of NCR's.
Following investigation and disposition of identified discrepancies by the AE, the nature of each discrepancy will be known, including its design significance (ability to perform its safety-related design function under design conditions
& loads). At this point CAP reviewers, along with the engineers, can assess the collection of information from discrepancies to establish possible generic significance, the need for further inspection, or future corrective actions.
Such evaluations will be the subject of post-review meetings of the review team, and the results will be included in module reports which are subject to 1 the review and approval of the CAP Manager, PPP Manager, and Director of '
Projects. The post-review meetings are required by procedure and will also l cover team-member response / agreement that dispositions resolved the problems I iden tified. j l
PAGE 8 of 18 Ouestion 13
. Section 5.4 discusses an " oversight comittee". Please provide a more compre-hensive description of the structure, resources and charter / functions of the oversight comittee. How will their coments/recomendations be handled?
Response
This question is addressed in the response to Question 9. The details of Oversight Comittee involvement are established in an operating charter, a copy of which is provided in Attachment 2.
Ouestion 14 Section 6.0 discusses program implementation and selection of review areas.
Please describe how the progean ensures that all safety-related areas will be reviewed. Also, please define the specific areas to be reviewed. How will HSSS, ISC, radwaste, fire protection and errergency power subject areas be addressed?
Pesponse The scope of the CAP includes all safety-related work and certain other work completed at the project prior to the review, on a sampling basis. The everall population of hardware from which samples will be drawn can be envisioned as consisting of sub-populations, grouped according to the Supply System's graded quality designations. All safety-related components are designated OC-I, and include NSSS, I&C, and emergency power systems. Another designation, OC-II A, identi fies those items subject to special quality assurance provisions, although they are not themselves safety-related, and include radwaste and fire protection systems. Both of these sub-populations are reviewed by sampling in the CAP, as described in Paragraph 2.0 of the program description.
Further, selected components from a third sub-population, OC-II, will also be reviewed. These are components important because of a high degree of realf ability to support continued power generation or their high monetary value and long-lead time for replacement.
Question 15 The list of module topics included in the program description seems tentative 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 diagran may be helpful.
Response
Following is the list of module topics planned for the CAP. This list differs from the tentative list only insofar as the last module has been divided into three smaller separate topics. If changes to the list become necessary, they will be made only after notifying the NRC, as with any other program change.
4 PAGE 9 of 18 Module No. Subject C3-01 Earthwork / Soil Compaction C3-02 Concrete, Re-steel & Embedments J
l C3-03 Containment Structure C3-04 Structure Steel a C3-05 Equipment Installation C3-06 Piping and Valves 4
C3-07 Pipe Supports C3-08 Electrical Paceways & Supports C3-09 Cables & Cable Terminations C3-10 HVAC Ductwork, Supports, Controls C3-11 Instrumentation, Tubing & Supports C3-12 Cathodic Protection & Grounding C3-13 Coatings C3-14 Hondestructive Examination C3-15 Miscellaneous Support To illustrate that these modules will contain all the safety-related work at the project, a matrix is presented in Figure 1, identifying all contractors who performed safety-related work and the modules in which each contractor's work will be reviewed.
Question 16 Please more clearly define licensee senior management conclusions regarding the CAP review modules, the input of the oversight conwittee to these conclusions, and the licensee's recomendations to the NFC regarding acceptability of the work reviewed including a statement of confonnance to requirements and NPC comitments.
Response
The Readiness Review Program is expected to confirm the quality of plant design and construction. Senior management will review each module report as it is issued, and will have available the Oversight Committee's assessment of the i
report. A statement about the acceptability of the work will be included in a senior management request to the NPC for acceptance of the review and its results. Trends that become evident during the progress of the reviews will be identified in the module reports, but a final overall conclusion of the work's
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PAGE 11 of 18 adequacy cannot be reached until Phase I of the program is ccmpleted. At that time the program managers will present their findings and recommendations to Supply System senior management in a final program report. Management will also have on hand the NPC Inspection Peports produced during the course of the program. An assessment will be made of program findings, and senior management will prepare a request for NRC approval that includes a statement of confor-mance to requirements and NRC commitments. We cannot predict the exact content of that request at this time.
The Oversight Comittee's role in evaluating reports generated by the Peadiness Review Program is identified in our response to NPC Ouestion 13.
Question 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.
Pesponse It is anticipated that, in cases where reviews yield no deficiencies, informa-tion concerning the quality verification of the sample and a recommendation for acceptance of the represented population of hardware will be included in the module report.
In cases where reviews yield inconclusive resul ts (few design-significant deficiencies or many less-serious discrepanies), further analysis or inspection is necessary to determine acceptability of the represented population. The threshold amounts of reject hardware components may not always be consistent because of the type and number of attributes per unit or the nature of the discrepancies iden tified. The Supply System is engaging a consultant for guidance in this area, and details are not yet available. However, it is intended to provide such evaluative criteria in each review plan. These criteria may vary from module to module according to the number and nature of accept / reject attributes for specific hardware components. Samples expanded in size to resolve inconclusive results will be inspected only for the presence of previously identified deficient conditions or attributes.
Nevertheless, if results are not conclusive after a reasonable analysis, the details of the condition will be fully disclosed and a recommendation will be included in the report for thorough investigation of that hardware population at construction restart.
In cases where reviews yield negative results, those that are clearly indica-tive of design-significant quality deficiencies, the details will be fully disclosed and a recommendation will be included in the report calling for the thorough investigation of that hardware population at restart of construction, at which time adequate resources will be available to address this magnitude of review and corrective action. Where possible, review teams will include recom-mendations for corrective action, based en their evaluation, analysis, and understanding of the problems identified.
PAGE 12 of 18 This evaluative process is part of the overall review process covered by CAP procedures.
Question 18 Address those areas where the acceptance criteria will differ from the original criteria described in the SAP.
Response - '
In general, acceptance criteria established 'in the WNP-3 design documents is the same criteria used in CAP reviews. In or.et specific area, weldino, somewhat newer criteria is anticipated to be applied to the CAP reviews. This is' the visual weld acceptance criteria developed by the Nuclear Construction Issue Group and accepted by the NPC. Use of these criteria necessitates revision of the WNP-3 FSAR, which will be initiated prior to actual use of the criteria.
If other changes to acceptance criteria are called for in the future, they would likewise be identified in an appropriate FSAR revision.
Ques tion' 19 Describe how 10CFP50 Appendix B (18 criteria) applies to the Construction Assurance program. A matrix may be helpful.
Response' ,
Not all the criteria of 10CFR50, Appendix B apply to Readiness Peview Program activities. Figure 2, Matrix of Appendix B Criteria, describes how each criterion applies to the Engineering and Construction Assurance elements of the program.
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4
FIGURE 2
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MATRIX OF 10CFR50, APPENDIX B CRITERIA APPLIED TO READINESS REVIEW PROGRAM CRITERION ENGINEERING ASSURANCE PROGRAM CONSTRUCTION ASSURANCE PROGRAM I. Organization Applies to the organizational freedom Applies to the organizational freedom of participants, including review of participants, including review teams, management, and oversight teams, management, and oversight committee. Organization and inde- committee. Organization and inde-pendence are delineated in the program pendence are delineated in the program description and procedures. description and procedures.
II. Quality Assurance Applies to verification of quality by Applies to verification of quality by review of design activity, to indoctri- inspection and review, to indoctrination nation and training of personnel, and and training of personnel, and to man-to management review of program ade- agement review of program adequacy.
quacy. This criterion is met by This criterion is met by conformance conformance with requirements estab- with requirements established by imple-lished by implementation procedures. mentation procedures.
III. Design Control Does not apply. EAP performs no design Does not apply. No designs or design or design control. However, for design documents will be produced by the CAP.
and design control verification perfor-med by the EAP, the basic philosophy of this criterion is applied, insofar as practicable. Procedures and instruc-tions govern the performance of veriff-cations by independent qualified per-sonnel.
IV. Procurement Document Applies if services are procured from Applies if services are procured from ]!
Control outside sources. Such procurements are outside sources. Such procurements are R governed by corporate and project governed by corporate and project _.
requirements already in place. requirements and controls already in '"
place. 9 G
CRITERION ENGINEERING ASSURANCE PP0GRAt1 CCHSTPilCTICN ASSUPANCE PROGRAll V. Instructions, Applies to most program activities. Applies to most program activities.
Procedures, and Implementation procedures and instruc- Implementation procedures and instruc-Drawings tions are provided where appropriate. tions are provided where appropriate.
VI. Document Control Applies to program description, pro- Applies to program description, pro-cedures and instructions which com- cedures and instructions which com-prise the Program Manual, controlled prise the Program ihnual, controlled in accordance with the corporate in accordance with the corporate program. program.
VII. Control of Purchased Applies if services are procured from Applies if services are procured from Material, Equipment, outside sources. Appropriate monitoring outside sources. Approp iate monitoring and Services of the quality of these services will of the quality of these services will be performed by EAP management, he performed by CAP management.
VIII. Identification and Does not apply. No materials, parts, Does not apply. !!o materials, parts, Control of Material, or components for the plant will be or components for the plant will be Parts and Components provided by the EAP. provided by the CAP.
IX. Control of Special Does not apply. Special construction Appite: if services, such as HDE, are Processes processes will not be employed in used. Appropriate procedures of the reviewing design work. performing organization will govern activities, subject to concurrence of gg CAP management. g;
'n X. Inspection Does not apply. EAP walkdowns are not Does not apply. Timely inspection of 9, inspections in this context. Hardware construction processes and products was ,,
questions that arise from walkdowns by part of the work in place and not a m EAP review team members will be re- part of the CAP. However, for the ferred to the CAP for disposition. inspections performed by the CAP, the basic philosophy of this criterion is applied, insofar as practicable.
Procedures and instructions govern the performance of reviews and inspections by independent qualified personnel.
CRITERION ENGINEERING ASSURANCE PROGRAM CONSTRUCTION ASSURANCE PROGRAM XI. Test Control Does not apply. Testing will not be Does not apply. Testing (except NDE, employed in reviewing design work. . covered elsewhere) will not be employed in reviewing construction work.
XII. Control of Measure- Does not apply. Measurement and Applies to use of special devices in ment and Testing testing equipement will not be used hardware inspections. Devices used in Equipment in reviewing design work. CAP inspections will be furnished by ;
existing project organizations whose ,
approved measures govern control of Male.
XIII. Handling, Storage, Does not apply. No material or equip- Does not apply. No material or equip-and Shipping ment for the plant will be handled, ment for the plant will be handled, stored, or shipped by the EAP. stored, or shipped by the CAP.
XIV. Inspection, Test, Does not apply. The EAP will not tag Does not apply. The CAP will not tag and Operating Status or alter existing tags that indicate or alter existing tags that indicate status of items in the plant. status of items in the plant.
Nonconformance tags that may result fran CAP inspections will be provided through existing project controls promulgated by the generation of NCR's.
XV. Nonconformance Does not apply. Deficiencies in the Applies to the identification of non-Materials, Parts, design or design process are addressed conforming items by CAP inspections and or Components in Criterion XVI, Corrective Action. reviews. This criterion is met by use of existing project controls for reporting deficiencies in hardware and documentation.
5 S
XVI. Corrective Action Applies to identification of errors Applies to the identification of non-or deficiencies in the design or conforming items by CAP inspections and '"
design process. Corrective action reviews. This criterion is met by use SL is processed under existing project of existing project controls for control s. reporting deficiencies in hardware and 5 documentation.
I
CRITERION ENGINEERING ASSURANCE PROGRAM CONSTRUCTION ASSURANCE PROGRAM XVII. Quality Assurance This criterion applies to records This criterion applies to records Records generated by the EAP and is met by generated by the CAP and is met by conformance with requirements estab- conformance with requirements estab-lished by implementation procedures. lished by implementation procedures.
XVIII. Audits Applies to most program activities. Applies to most program activities.
Corporate QA Audit Program will provide Corporate QA Audit Program will provide at least annual audits, at least annual audits.
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PAGE 17 of 18 Question 20 Include " Flow Diagram" presented as viewgrapn in public meeting on October 29, 1985, with program description.
Response
The CAP review process illustrated by the flow diagram shown in Figure 3 will be added to the program description.
Question 21 It may 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.
Response
Phase I of CAP reviews will assess the adequacy of construction completed at the time the reviews occur. Construction work defined as " complete is that which is detennired by the Project's PRIDE program, which was designed to status the work accurately and is being carried on at this time.
Phase II of the CAP will assess the resumption of construction (e.g., adequacy of restarting work stopped in-progress, including methods and programs for dealing with previously identified deficiencies), and the adequacy of new work performed after restart of construction.
The first thrust of Phase II needs to ensure that deficiencies recorded during Phase I are corrected to preclude their recurrence. The second purpose of Phase II will be to ensure that the construction process is adequate, and third, to sample on-going design and construction activities in much the same manner as Phase 1.
The precise output format of Phase II has not yet been established, but it is probable that each review activity will result in a similar series of reports ;
to the NRC. It is anticipated that Phase II may also result in a summary report i that consolidates Phase I and Phase II into a document that supports the application for an operating license. This report can " roll up" previous program activity and acknowledge and address related NRC inspection reports.
Note that an additonal element of Phase 11 may include (perhaps as a separate subject) the readiness of the plant for operation. This aspect, however, is very tentative at this time.
CONSTRUCTION ASSURANCE PROGRAM SELECT TEAM o Team Leader DEVELOP PROGRAM 08TAIN NRC !MPLEMENT PROGRAM = - DEVELOP
- o Enqineers o Description ACCEPTANCE o Procedures & MODULE OUTLINE Instructions = c Reviewers o Budget o Paesentations - n Ident Contractars o Detailed Plans o Schedule o Discussions & Schedules o Ident Each Scope o Public Meetings TRAIN TEAtt o Estahl Setsance o Reviews - o Team Leader.mmens o Prepare Schedule o Teim Member PREPARE INITIAL FEED 8ACK RECONCILE MIEWRECORDS DEVELOP tt000LE MODULE REPORT o Freject HARDWARE 3 RECORDS o Comp 1 Checklist REVIEW PLAN o Participants o Eng Assurance o Comp 3re Results, m' o Adequacy = o Detemina Program Close Open Items Requirements o Review Plans
- o Preservation o Adjust Cap Review o findings o Historical Record o Checklists Resolution o Findings
= o Prepare Sampling o Results o Analyze Results l Rationale o Recomendations o Identify Trends, o Prepare Checklists Safety Signific. INSPECF liARDWARE o Select Sample of a Compi Checklist Hovre & Recorris n== 0 Adeq'ncy sum o Obtain Cao Mar Approval o Preservation o Findings
)
MANAGEMENT REVIEW 08TAIN NRC ' RETAIN RECORDS b o Dfr Licensing (R) ACCEPTANCE o Asseu61e Records FLOW DIAGRAM f,,
o WNP-3 Prog Dir (R) o Overview o Transmit to Pem. -
Storage a o Prog Mgr, RRP (A) o Sampling co o Dir Projects (A) o Reports FIGURE 3
J I
ATTACHMENT 1 TO SUPPLY SYSTEM RESPONSE TO NRC QUESTIONS ON THE CAP i
DRAFT OUTLINE FOR CAP MODULE REPORTS (RESPONSE TO QUESTION 10)
1.0 INTRODUCTION
Describes the overall purpose and scope of the (Discipline / Commodity) review; how, when, and by whom it was initiated and implemented; and how it is reported.
1.1 Purpose and Scope
1.2 Implementation 1.3 Arrangement of the Report ,
2.0 EXECUTIVE
SUMMARY
, An abstract of the report and its results, this section briefly sun-marizes the salient points of the program that deal with the discipline /
commodi ty.
3.0 REVIEW PROGRAM DESCRIPTION Tne basic program to accomplish the module review and inspection is described in this section. This description includes module review plans and checklists, and the procedures and instructions used by the participants. It identifies the contracts covered by the reviews and compares the reviews accomplished with the requirements established by the design drawings and specifications, the FSAR, and the QA program.
3.1 Scope l 3.2 Contract Applicability 3.3 Program Content 3.4 Evaluation of Related Programs 3.5 Procedures and Instructions 3.6 Review Plans and Checklists 4.0 METHODOLOGY This section addresses the rationale applied to sampling, and the tech-
- niques used to select hardware items for inspection. It covers the i philosophy applied to reviews and inspections in this program and the
, methods used to perform them. It also addresses the rationale used to evaluate results so that conclusions may be drawn and appropriate cor-rective actions initiated.
t Page 2 ATTACHMENT 1 (Continued) 4.1 Sampling Rationale 4.2 Review and Inspection Philosophy 4.3 Results Evaluation 5.0 PP0 GRAM MANAGEMENT This section describes the organization and management activities that control the CAP, and the methods by which coordination and control are achieved.
5.1 Organization 5.2 Internal Controls 5.3 Management Involvement 5.4 NRC Involvement 5.5 Peporting 5.6 Audits 6.0 PROGRAM RESULTS This section presents, by contract, the quantitative results of the CAP reviews and inspections, and identifies those instances where further investigation may be necessary.
6.1 Contract XXX 6.1.1 Concrete 6.1.2 Reinforcing Steel 6.1.3 Embedded Items 6.2 Contract YYY 6.2.1 Concrete etc.
7.0 CONCLUSION
S AND PECOMPENDATIONS In this section, summary results are accumulated and conclusions are presented. Recommendations for future action are made by the review team to Supply System management and to the project.
ATTACHMENT 2 TO SUPPLY SYSTEM RESPONSE TO NRC QUESTIONS ON THE CAP OPERATING CHARTER FOR THE WNP-3 READINESS REVIEW OVERSIGHT COMMITTEE
1.0 INTRODUCTION
The Washington Public Power Supply System (Supply System), a municipal corporation of the State of Washington, has contracted with three experienced and qualified individuals to be members of the WNP-3 Readiness Review Oversight Comittee. Members of the committee shall be engaged to collectively provide periodic independent executive assessment of the adequacy, fidelity of implementation, candidness, appropriateness and results of the subject program. The work under consideration is more fully described hereinaf ter.
2.0 GENERAL 2.1 The Consultant / Committee shall:
2.1.1 Review the program plans and procedures and make a wri tten assessment of the adequacy of the plans to satisfy the stated intent, and include any recommendations for improvement.
Committee approval of procedures is not requi red. Any written material and/or minutes of subsequent meetings will be subject to public disclosure. Program plan review shall occur in August or September 1985.
2.1. 2 Review the on-going implementation of the program on a periodic basis, and provide written reports of the assessments. These reviews are to be performed as requested by the Supply System, or as recommended by the Committee with Supply System approval.
2.1.3 Attend periodic meetings of the Committee and senior Supply System participants at the Supply System of fices in Richland, Washington, on a schedule to be mutually established.
2.1.4 Make any recommendations that the Committee collectively considers necessary in order for the Committee to unequivocally certify Readiness Review Program adequacy.
2.1. 5 Be available and able to participate with the Supply System at one or more meetings with the Nuclear Reguitory Commission and express verbally and in wri ti ng , the Committee's collective assessment of the fidelity and ef fectiveness of the Supply System's Readiness Review Program.
3.0 COMMUNICATION PROTOCOL 3.1 The Committee is to interface with the Supply System through the Chaiman, and with the NRC through the Supply System except under extraordinary circumstances.
3.2 The. Committee shall contact the Supply System upper management prior to contacting the NRC if nomal Supply System contacts are not adequately responsive to Committee concerns.
c' OPERATING CHARTER WNP-3 READINESS REVIEW OVERSIGHT COMMITTEE PAGE 2 3.3 The Committee is to send correspondence to the Supply System and not to the NRC directly. The Supply System will file original correspondence, and review all correspondence issued by the Committee. If the Supply System has substantive comments on the correspondence, the Committee will be asked to respond to the Supply System comments. The Committee shall acknowledge receipt of the comments and may revise the initial correspondence at the Committee's prerogative. The Supply System will retain all original s and revisions of the correspondence. The Supply System may attach, or include in the file, any remaining Supply System comments (which will also be transmitted to Committee members) or any related Comittee correspondence ,that could enhance the cohesiveness of the " package." Copies of all material will be retained for inspection by the NRC or the public, upon requesc, 3.4 The Supply System will mail material di rectly to the Committee members, but members should respond to the Committee Chairman unless requested otherwise. The Chairman shall summarize and consolidate input from members and transmi t a " consensus" document to the Supply System with minority views reconciled.
3.5 Minority dissenting opinions should be resolved within the Committee, but may be included in any report at the Chaiman's prerogative.
3.6 The Committee is expected to review all transmittals from the Supply System and to make whatever observations are necessary, or to recommend any changes they see fi t, to be able to endorse the program and its implementa tion, both during the course of the program and at its completion. If the Supply System requires comments on a transmittal to the Committee, the transmittal letter will so state. Unless specifically requested by the Supply System, transmi ttal s to the Committee do not require response or acknowledgement, but the Comittee may respond at their initiative if desired 4.0 FORMAL ASSESSMENTS BY COMMITTEE 4.1 The Committee is required to provide written assessments of the program and its on-going implementation on approximately quarterly i nterval s ,
beginning approximately January, 1986. A final assessment of the entire Phase I program will also be required.
4.2 Tne Comittee is also required to provide written sumaries of Committee meetings and activities if these are not covered in the fomal reports required above.
5.0 MATERIAL TO BE REVIEWED 5.1 Committee members shall review all material transmitted to the Committee by the Supply System, and may review any other related material from any other source the Committee members deem appropriate that could contribute to RRP enhancement.
OPERATING CHARTER WNP-3 READINESS REVIEW OVERSIGHT COMMITTEE PAGE 3 5.2 Committee members will receive:
- 1. Copies of all related NRC correspondence, to and from.
- 2. All related program documents including pl ans, schedules, procedures, etc. , except financial .
- 3. Final drafts and final issue of each Review Plan, including scope, subtopics and review checklists.
- 4. Copies of Review Reports.
- 5. Copies of related NRC Inspection Reports and Supply System answers.
- 6. Summaries of Project responses to findings and summaries of Corporate assessment of findings, screened and compiled to focus on controversial issues.
- 7. Copies of each final draft and the final issue of each Final Review Report with disposttion.
- 8. Any other related material the Committee may request.
6.0 ACCESS TO PARTICIPANTS 6.1 Committee members have unrestricted access to any of the participants in this p rog ram, but are expected to coordinate such access through the Program Manager, Readiness Review. .
7.0 CONFLICT OF INTEREST 7.1 Committee members have signed a Certification of Non-Conflict of Interest (Exhibit 1, attached) and are expected to avoid any activity that would nullify that certification.
7.2 If a Committee member plans to engage in activities that may jeopardize his certification of independence, he shall so notify the Program Manager, Readiness Review in order to resolve the potential conflict.
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