ML20151Y965

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Forwards Revs 1 to Overview of Readiness Review Program, Engineering Assurance Program & Const Assurance Program to Be Incorporated Into Readiness Review Program Manual,Per 860109 Commitment
ML20151Y965
Person / Time
Site: Satsop
Issue date: 01/20/1986
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO3-86-045, GO3-86-45, NUDOCS 8602130233
Download: ML20151Y965 (31)


Text

{{#Wiki_filter:, F1ECSVL1!NED l Washington Public Power Supply System ##C 1 P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 lE L1A8 20; 23 M!31: 31 DOCKET NO. 50-508 9EG W E 4F W.F January 20, 1986 G03-86-045 Mr. J. B. Martin i Regional Administrator l U. S. NRC - Region V i 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Daar Mr. Martin:

Subject:

NUCLEAR PROJECT NO. 3 READINESS REVIEW PROGRAM

Reference:

1) Letter (G03-86-026), G. C. Sorensen to J. B. Martin,

" Readiness Review Program - Construction Assurance Activities", dated January 9,1986. Enclosed are three (3) Readiness Review Program documents that we committed to provide in Reference 1). These documents have been revised as a result of your coments on our Construction Assurance Program document, which were also answered in Reference 1). The enclosed documents will be incorporated into our Readiness Review Program Manual. l If you have any questions, please contact Mr. Jack Garvin at (509) 372-5850. Very truly yours, G. C. Sorensen, Manager Regulatory Programs sek

Enclosures:

Overview of the WNP-3 Readiness Review Program, Revision 1 Engineering Assurance Program, Revision 1 Construction Assurance Program, Revision 1 I cc: See next page. 8602130233 860120 PDR ADOCK 05000508 A PDR S ]

nc '. Mr. J. B. Martin U. S. NRC - Region V January 20, 1986 G03-86-045 Page Two cc: *Mr. J. A. Adams, NESCO i Mr. G. T. Ankrum, Nuclear Regulatory Comission

  • 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 Comission Mr. W. L. Bryan, Washington Water Power Company I

  • Mr. S. H. Bush, Ph.D., Review & Synthesis Associates i

Mr. H. R. Denton, Nuclear Regulatory Commission l

  • Mr. R. T. Dodds, Nuclear Regulatory Comission l

Mr. C. Eschels, EFSEC Chaiman

  • Mr. R. F. Heishman, Nuclear Regulatory Comission
  • Mr. W. M. Hill, Nuclear Regulatory Commission Mr. G. W. Knighton, Nuclear Regulatory Commission I
  • Mr. R. V. Laney, Consultant Mr. T. Michaels, Nuclear Regulatory Commission
  • Mr. J. Milhoan, Nuclear Regulatory Commission 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, Libeman, Cook, Purcell & Reynolds)
  • Mr. E. Rosolie, Director of Coalition for Safe Power Mr. B. K. Singh, Nuclear Regulatory Comission Mr. J. M. Taylor, Nuclear Regulatory Comission Mr. B. C. Withers, Portland General Electric Company Document Control Desk - U.S. NRC
  • With Enclosures l

e ENGINEERING ASSURANCE Pp0GPAM (EAP) NOVEMBER 1985 1.0 PURPOSE The purpose of the Engineering Assurance Program is to provide additional confidence in the technical adequacy of the engineering.and design work performed by the Supply System and/or its contractors for nuclear power generation facilities. The Engineering Assurance Program (EAP) will be carried out in two phases. Phase I will be complete prior to resumption of construction and will assess the design as it presently exists. Phase II 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 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). The objective of Phase II will be to provide additional assurance that the design process used in completing construction of the plant fully complied with SAR comitments, as reviewed by NRR.

2.0 INTRODUCTION

l The Engineering Assurance Program consists of activities specifically directed at assessing the adequacy of the technical aspects, as well as the methods of control, of the engineering and design activities of the i Supply System and/or its major contractors in producing a quality engineering product. This is accomplished by independently sampling the . design activities and products for confimation by analytical techniques. Accordingly, the Engineering Assurance Program functions independently of the nuclear Quality Assurance Program, but will be performed in accordance with the requirements of 10CFRSO, Appendix B, to the extent described in the Program overview. In

addition, the Engineering Assurance Program will be monitored by an independent l

Executive Oversight Committee. 3.0 ORGANIZATION The Engineering Assurance Program is established by the Program Manager, r Readiness Review, and is implemented by the

Manager, Engineering Assurance Program.

The Manager, Engineering Assurance Program, is matrixed from the Engineering Directorate (to which he reports administratively) to the Program Manager, Readiness Review, to whom he reports programmatively. Engineering Assurance is staffed by personnel having extensive engineering and design experience in their assigned disciplines and documented technical independence from-the area of investigation. Rev. 1 i ?.-

4.0 PROGRAM PROCEDURES The Engineering Assurance Program procedures are approved by the Program Manager, Readiness Review, and Manager, Engineering Assurance. These procedures describe the various Engineering Assurance activities, including assignment of responsibilities, methods of implementation, and methods of coordinating activities with other organizations. 5.0 PROGRAM ACTIVITIES (See Attachment 1) l The activities of the Engineering Assurance Program include design process reviews, independent design assessments, and third-party design assessments described bel ow. Engineering Assurance, in effect, will verify that plant systems, structures, and components assessed will perfonn to design criteria and performance requirements established for the pl ant. Efforts will be made to identify modifications or improvements to the dasign process if deficiencies are identified, but recommendations for improving design products will not be made, unless the design will not perform its intended function or satisfy the design criteria. The technical subjects and design features will be evaluated against good engineering practice and the comitments contained in the FSAR. As a minimum, the specific elements of the design process, as listed in the Appendix, will be verified. Selection of review / assessment topics is based on the following general guidelines: Select areas of review that represent known technical problem areas o in the industry, in particular, those that have experienced a large number of changes from original design. Select areas that represent known or suspected Supply System and/or o contractor difficulties. o Select representative samples from

systems, the design and engineering of which are essentially complete, to determine that design of these systems from conception to final acceptance has been carried out in a controlled manner and that the system design meets its intended purpose, Select activities that require significant interface with the NSSS o

supplier and other major vendors. Select topics for design process review in a manner that addresses o the various aspects of the design process (i.e., design input, interface, process, output, and changes) and provides a reasonable data base by which to judge the adequacy of the design process. Select any other topics of management concern. o The depth and scope (including checklists) for each review will be established during the development of the Review Plans by the Review Team Rev. 1

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. The NRC has agreed 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 findings observed. The scope (and depth) of each topic will be chosen to ensure that the l aggregate of the reviews will assess all significant organizational J interfaces and major disciplines, by sampling importa-t products of those activities. Phase II topics have not yet been chosen, but will be chosen to both extend and complement Phase I topics. The selection of the topics will support the overall objective of being representative of the completed design and will be provided to NRC prior to implementation of Phase II. 5.1 Design Process Reviews Design process reviews are performed by personnel under the cognizance of Engineering Assurance. The objective of these reviews is to develop infomation by which to judge the adequacy of design controls on the basis of whether the results of the design activities are correct and consistent with licensing commitments and represent good engineering practice. These reviews are conducted on a sampling basis and are directed at the technical substance of the design process, in contrast to quality assurance audits, which examine procedural compliance. Design process reviews are conducted by experienced engineers who, by examining the technical aspects of the design, can evaluate whether design activities are being properly conducted. For example, such reviews can evaluate whether correct and current design inputs are used by affected design organizations and whether design changes are properly evaluated and incorporated into the design. As a resul t of these reviews, judgments can be made as to how well the design activities are controlled by the organizations involved. The Assistant Program

Director, Engineering (APDE) at the project, coordinates any necessary corrective action related to concerns identified as a result of these reviews.

5.2 Design Product Reviews Design product reviews consist of either Independent Design Assessments by personnel assigned to and under the direction of Engineering Assurance, or third-party design assessments performed by a third party organization with coordination provided by Engineering Assurance. These reviews focus on the output of the design process which was evaluated per paragraph 5.1 above. 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. I Rev. 1

i Walkdowns will also be perfomed 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 "comodity". oriented, and that the EAP walkdowns will be more " system" or " discipline" oriented. The two will be compatible. Construction related concerns observed during the EAP walkdowns will be comunicated to the CAP manager by memorandum, and design-related concerns observed during the CAP inspections will be ccmmunicated to the EAP manager by memorandum. 5.2a Independent Design Assessments Independent design assessments are performed by personnel assigned to Engineering Assurance. These assessments are designed to be independent verifications of designs. They do not take the place of nomal design verification activities perfomed by the organizations responsible for the design, but are done to provide additional confidence in the technical adequacy of the design. Independent design assessments are conducted on a sampling basis and are directed at critical and complex design features as well as areas of known or suspected Supply System, contractor, or industry problems. These assessments are conducted by experie.nced engineers who evaluate and verify the design through a review of the design, using alternate analyses as needed. Where additional manpower is required to perfom a comprehensive design assessment, additional engineering personnel will be contracted from outside the Supply System to work under the supervision and direction of the Supply System Engineering Assurance discipline leader (s). The APDE will verify that appropriate corrective action related to concerns identified as a result of these assesssments is undertaken in a timely fashion by the project. 5.2b Third-Party Design Assessments Third-party design assessments are coordinated by personnel assigned to engineering but are actually perfomed by an independent outside engineering organization. These assessments are designed to provide a completely independent assessment of the adequacy of design work 4 performed by the Supply System and its major engineering and design contractors. Topics for third-party design assessment are designated by the Manager, Engineering Assurance, and approved for implementation by the Director of Engineering. The design assessment approach (i.e., sampling or complete verification) and the specific design features that are reviewed are jointly selected by the Supply System and the third-party engineering organization. The design assessment methods used (e.g., use of alternate calculations) are detemined by the third-party engineering organization. Credit may be taken for third-party assessments performed prior to, or in parallel with, the implementation of this program if those assessments are applicable and can be qualified as to their independence and general adequacy by the Engineering Assurance Program. , Rev. 1

5.3 -Results of Reviews and Assessments The results of these reviews and assessments are reported directly to the Manager, Construction Quality Assurar.:e, APDE,

Manager, Engineering Assurance, and Program Manager, Readiness Review, and include all concerns identified, and assessment of the significance of the concerns, and specific recommendations for further assessment of any concern judged to have potentially significant implications.

The review reports are approved by the Program Manager, Readiness Review, and are made available to the NRC through the office of the Director of Licensing and Assurance. 5.4 Oversight Committee An executive Oversight Comittee will be retained by the Supply System to monitor the Engineering Assurance Program.. Committee members will be chosen from the business, academic, and/or technical communities based on their demonstrated and documented independence from the organization under review and for their qualifications to assess the program's fidelity, candidness, and effectiveness. The qualifications and independence of the Oversight Committee members, as well as the Review Team participants, whether they are Supply System employees or not, will be documented and available for NRC review. The Supply System will solicit NRC concurrence of Oversight Comittee members, and any third-party organizations that may be contracted to assist us, but not on individual Review Team members. All selections will be documented and recorded for future reference, and available for NRC review upon request. 6.0 PROGRAM IMPLEMENTATION Engineering, in conjunction with the APDE, plans and develops schedules for design process reviews, and design product reviews. A: nated above, design product reviews may take the form of either independent design assessments or third-party design assessments The Supply System will develop and distribute, bimonthly, 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). c. Schedule of meetings to disposition the findings from each review. Short-tem schedule changes will be communicated to NRC by telephone not less than two weeks prior to the event of interest unless unforeseen l circumstances arise, in which case notification will be as' timely as l circumstances permit. i Rev. 1

l The Supply System will keep NRC notified, through the use of the bimonthly schedule, of the development of detailed review plans and checklists, and NRC will be invited to participate in those meetings in Richland at NRC's initative. Al ternatively, NRC may request working copies of the draft plans and draft checklists for timely review and comment. 6.1 Design Process Reviews Design process reviews assess the adequacy of design processes in deference to a specific design feature or product. They assess control criteria, procedural effectiveness, organizational interface protocol, infomation exchange, etc., and they are implemented as follows: o A review plan is prepared that defines the purpose, scope, special concerns, checklist to be utilized, and any other infomation pertinent to conducting the review. o Personnel and organizations to be assessed are notified of the schedule and scope of the review a reasonable time in advance of the

review, o

The approved procedures will require that reviews be perfomed against paper and hardware 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 andTreated as a special case with appropriate comments recorded on the rationale for including it in the review. Each Review Team will be able to detect recent activity that might be considered " preparation" for the

review, and deal with it accordingly, o

Review checklists are prepared, approved by Manager, Engineering Assurance, and utilized, that identify the procedures governing the activities being assessed and the specific attributes to be evaluated for those activities, o A pre-review meeting is held with the management of the organization being reviewed to identify key personnel contacts, discuss the scope of the review, and determine the level of activity in the areas to be reviewed. o A post-review meeting is held with the management and personnel of the reviewed organization to present and clarify review results. o A formal review report is prepared, which includes the purpose and scope of the review, results, identification of review participants, and specific observations. Any necessary corrective action is requested from the reviewed organization. The report is approved by the Manager, Engineering Assurance, prior to transmittal to the reviewed organization by the APDE. Rev. 1

o Responses to review observations describing the extent of problems noted and corrective action are. submitted to the

Manager, Engineering Assurance and APDE, by the reviewed organization.

Engineering Assurance evaluates each response to ascertain whether the committed actions are commensurate with the review results. If the response is considered unsati sfactory, it is returned to the reviewed organization through the APDE for revision. o Engineering Assurance reviews committed action to verify that such action has been taken. 6.2 Independent Design Assessments Independent design assessments verify the adequacy of specific designs or design features in deference to the overall design process. They determine that the correct

criteria, materials, calculation and analytical methods were applied correctly to achieve a specific result or performance objective.

Independent design assessments are implemented as follows: o An assessment plan is prepared defining the purpose, scope, special concerns, and areas to be covered in the assessment. o Checklists are prepared, and approved by the Manager, Engineering Assurance.- The project team is notified of the schedule and scope in advance of o the assessment time and provides current design infomation and documentation to the assessment team, o A pre-assessment meeting is held to identify key personnel contacts, discuss the scope of the assessment, and determine the level of activity in the areas to be assessed. o Clarification of design philosophies, misunderstandings, system operational philosophy, questions, etc., between assessment and project teams may take place as the design assessment proceeds, o A post-assessment meeting is held between the assessment team and project team (and contractor as necessary) to discuss result". of the review. o A formal repcrt is prepared, which includes the purpose and scope of the assessment and resul ts and identification of observations. Also, the report includes a list of documents reviewed and alternate calculations performed in addition to the elements outlined above, o The Manager, Engineering Assurance, reports the need for further evaluation to the APDE. The Manager, Engineering Assurance, recommends any necessary corrective action (i.e., design changes) and monitors the actions taken by the APDE. I Rev. 1

o The Manager, Engineering Assurance, reassesses the design when the corrective action has been completed. 6.3 Third-party Design Assessments Third-party design assessments are implemented as follows: o The Manager, Engineering Assurance, selects and obtains the services of an outside engineering organization to perform a particular assessment. Approval of the organization selected is obtained from the Director of Engineering. o The Manager, Engineering Assurance, provides a description of the topic to be assessed and defines the purpose of the assessment. o The Manager, Engineering Assurance, selects and obtains copies of the ' specific design documents needed to perfom the assessment. In conjunction with Engineering Assurance, the outside organization detemines the design features to be assessed, based on the complexity of the

design, importance to
safety, degree of standardization and similarity to previously proven designs, and degree of design completion shown by the documents being reviewed.

o The outside organization selects the specific design assessment methods (e.g., design review, use of alternate calculations) to be used and prepares an assessment plan defining the scope, methods to be used, special concerns, and other information pertinent to the assessment. A copy of the assessment plan is sent to Engineering Assurance for approval. A pre-assessment meeting is held to identify key personnel contacts, o discuss the scope of the assessment, and detemine the level of activity in the areas to be assessed. o The outside organization perfoms the design assessment and documents the results, o A post-assessment meeting of Engineering Assurance, Project Engineering, the outside organization perfoming the assessment, and any other organizations as detennined by the Supply System or the Oversight Committee is held. The outside organization prepares and transmits an assessment report o to the Manager, Engineering Assurance, which includes the purpose and scope of the assessment, resul ts, including comments as appropriate on the significance of the results, identification of assessment participants, and a list of documents reviewed and alternate calculations performed. o The Manager, Engineering Assurance, reviews the report, detemines if corrective action is necessary, and reports the results to the APDE and Director of Engineering. Rev. 1

s o The Manager, Engineering Assurance, includes in the report topics requiring further evaluation to the APDE. The Manager, Engineering Assurance, may recommend corrective action (i.e., design changes). o The Manager, Engineering Assurance, reviews corrective actions for adequacy and performs a reassessment of the design upon completion of the corrective action to close out the review topic. 7.0 RECORDS The Manager, Engineering Assurance, maintains sufficient records to demonstrate compliance with this program. In this regard, the following records will be retained: o Review. checklists, review

reports, and corrective action recommendations and follow-ups, Correspondence pertaining to reviews and assessments performed, o

o Procurement-related correspondence and documents and invoices for engineering services provided by others, o Assessment reports, documents reviewed, corrective action reports, and reassessment records, o Calculations,

analyses, and other technical documents used or derived during the perfomance of an assessment that contributed substantially to conclusions reached, t

o Assessments by the Oversight Comittee, o NRC comments, correspondence, meeting minutes, etc. o Records of the qualification and experience of all participants in this program for at least seven (7) years after plant fuel load. 8.0 APPENDIX Criteria for Engineering Assurance evaluations are as follows: 8.1 Design Commitment Control Periodic reviews shall be conducted to ensure consistency between design activities and commitments made in technical specifications, ifcensing documents, or other regulatory requirements. Also, Engineering Assurance i shall verify that an effective system exists for updating design commitments as changes occur due to design evol ution, management decisions, as-built conditions, or regulatory changes. i 8.2 Design Inputs Measures shall be establi shed.to verify the

basis, use, and reasonableness of design inputs.

Emphasis shall be placed on conffming 1 Rev. 1

g the validity and applicability of input infomation for selected design features. Sources of' the input data shall be identified. Calculations that produce results to be utilized as input data shall be verified. Engineering Assurance shall confim that. design input assumptions are technically valid and reasonable. 8.3 Design Methods Measures shall be established to verify that the analytical methods used for design calculations are consistent with sound engineering practice and industry codes and standards identified in project licensing commitments. Confimation shall be made that computer

programs, including subroutines, have been verified as acceptable, prior to their use. Analytical modeling techniques shall be examined for reasonableness.

8.4 Design Control Measures shall be established to verify that plant system interfaces and interactions have been properly addressed in the design process. Technical review shall verify that the system and components are designed to perfom in noma 1, transient, and accident modes in accordance with the design criteria. Review of the flow and documentation of selected design infomation shall be perfomed to assure that output-to-input between organizations is consistent with applicable design control requirements. 8.5 Design Verification Measures shall be establi_shed to verify that design and design verification perfomed by others are technically adequate. Particular attention shall be given to assessing the adequacy of methods used for design verification and the qualifications of personnel perfoming design verification. 8.6 Design Changes Measures shall be established for verifyinc the basis and inplementation of design changes. Particular emphasis will be placed on evaluating the system for control of desigr. changes, proper coordination by affected disciplines, incorporation into affected design documents, and feedback from the as-installed configuration. 8.7 Design Records Measures shall be established to verify the adequacy of the system for identifying, collecting,

storing, and retrieving design records.

Consideration shall be given to ensuring that the design record system provides both adequate documentation and the ability to store and retrieve documentation during design activities. Careful attention shall be given to verifying that a system exists for creating an appropriate and accurate record of the as-built design configuration. Rev. 1

e. \\ REV. 1 ENGINEERtNG ASSURANCE PROGRAM If l l TOPIC SELECTION EAP 5.1 E I l PARTICIPANT SELECTION l EAP 5.2 + l l l DEV. REVIEW PLAN EAP 5.3 OVER$1GNT l f COMMITTEE) ENTRANCE MTG 1 Y I l PERFORM REVIEW l l 1f TNIRO l ) PARTY. EXIT MEETING REVIEWS l ASSEMSLE DRAFT REPORT l f EAP 5.4 REVIEW DAYS k REVIEW ORAFT WITN EAP MNGR (EAP 5.7) (SIGN FOR APPROVAL) pg(3gg gy) 1f PRINT, OtSTRIGUTE & FILE BARE REPORT (W/O DISPOSITIONS) if TRACK!NG

SYSTEM f

f f f (TS) AVAILABLE AT FILE AT TO NRC CORPORATE (F) PROJECT h h 'I EAP MNGR OtSCUSSES AR 21 S RE PONSE RE -50.55f e)'S e CORRECTIVE ACTIONS. -OFM'S ETC. & INTERFACES WITH -ETC CORPORATE TRANSMIT '- ISSUES 21*S & 55fel'S EAP55 ISSUES RESPONSF DOCU-TO NRC _A MENT TO CORPORATE ASSESSMENT pp, ANO REPORTING PROCESS U k (F) OA TRACKS CORPORATE REVIEWS REPORTABLES RESPONSES l y t r -- - - - ~ i r I0 CORP.ASSEuB. 1 (F) -ISSUES FIN. l APOE FOLLOWS d DINGS / RESPONSE ROLL uP ooc 1 UP ON ACTION TRANSMIT 70 ITEMS C (DIRECTOR AP-NRC l EAP 5.8 PROVAL) _--l--j I TRACKING PROCESS 4 TRACKING t TR ACKING (PROJ) PERIOOIC UP. ,______Y (EAP) Y DATES TO NRC (OA) PAGE11 ATTACHMENT 1 ena

t OVERVIEW OF THE WNP-3 READINESS REVIEW PROGRAM REY. 1 INTRODUCTION The Washington Public Power Supply System has implemented a program of review and inspection of safety-related design and construction activities completed to date at WNP-3. It is entitled the " Readiness Review Program" and consists of the following three elements: (a) The Preservation Program This element addresses the on-going maintenance and protective activities for plant components. (b) The Engineering Assurance Program (EAP) This element covers thel in-depth review of the design process and its implementation. (c) The Construction Assurance Program (CAP) This element provides for l in-depth review of construction completed to date and for self-assessment of the Preservation Program. The three elements, which are discussed in greater detail in separate documents, provide the basis of the Readiness Review Program. The elements are designed to provide a significant measure of confidence that safety-related design and construction activities, completed to date, are acceptable for the eventual licensing of the plant. BACXGROUND Due to economic reasons, construction was stopped at WNP-3 in 1983 and, except for a small amount of work associated with the design of the plant, and of protecting components already in place, the facility is currently in a " preservation" status. At the time construction was shut down, no major questions relating to the quality of work already completed were pending. It is assumed that the design and construction program was successful and, in some ways, WNP-3 is considered a model project for the industry. The CAP and EAP elements of the Readiness Review Program are being initiated by the Supply System as a prudent measure to assure the overall quality of the WNP-3 plant, and are in addition to the aggressive implementation of the Supply System's Quality Assurance Program at the project. Although the Readiness Review Program is not a requirement of 10CFR50, Appendix B, (i.e. the project can be successfully completed without it) the program will be conducted in accordance with the applicable criteria of 10CFR50, Appendix B as detailed in Figure 2 (MATRIX). ORGANIZATION The Readiness Review Program was established by the Supply System Managing Director and is implemented by the Program Manager, Readiness Review who reports to the Director, Licensing and Assurance. The Program Manager, Readiness Review is supported by the Manager. Licensing; the Manager, Engineering Assurance; and the

Manager, Construction Assurance (the organization is illustrated in Figure 1).

A

REV. 1 These individuals form the core of the Readiness Review Program and are independent of jobsite functions and responsibilities. This assures that an independent review and reporting relationship exists to maintain objectivity and unbiased reporting. The managers are qualified for the positions by previous work-assignments, training and experience. Copies of their resumes are on file with the Program Manager, Readiness Review. Each of the managers is augmented (as individual reviews dictate the need) by l independent, qualified personnel to perform the necessary reviews, inspections and analyses. Qualifications of these personnel are also based on previous work assignment, training and experience. Copies of their resumes are maintained by the individual managers. I SCOPE The Readiness Review Program consists of three elements which address preservation, engineering and construction activities at WNP-3. The following is an overview of the key areas of each element. (a) Preservation Program The purpose of the Preservation Program is to ensure that permanent plant t structures, systems and components (particularly those that are i safety-rel ated and those which represent significant economic investments) are properly preserved and maintained. The Preservation Program at WNP-3 is governed by the Quality Assurance Program Descriptions which are in Chapter 17 of the Final Safety Analysis Report. Elements of both the Design / Construction Quality Assurance and the Operational Quality Assurance Programs apply to the Preservation

Program, i

1. Preservation Program requirements and specific instructions and procedures for maintenance are developed by taking into account manufacturers' recommendations; industry experience; regulatory, military and industry standards; and other appropriate sources of information. 4 Evaluation of source information and its development into requirements is appropriately documented. i I Preservation Program activities are conducted using procedures that have been reviewed and approved by the engineering group having cognizance over the components. The review / approval process assures that the specific requirements have been incorporated into the procedures. ] The Project Quality Assurance Group and/or the Operational Quality Assurance Group have the responsibility for conducting overview j surveillances of all activities associated with the Preservation Program. Surveillances are preplanned and are conducted either using i checklists or marked up procedures. The results of surveillances are documented and all deficiencies are tracked until close-out Reports of the results of surveillances are sent to corporate and project QA management and also to the appropriate project / plant management for any needed actions. ;

REV. 1 (b) Engineering Assurance Program The purpose of the Engineering Assurance Program is to provide additional confidence in the technical adequacy of the engineering and design work performed by the Supply System and its contractors at WNP-3. The program is directed at assessing the adequacy of the technical aspects (as well as the methods of control) of the engineering and design activities. This is accomplished by independently sampling the design activities and products for confimation by analytical techniques. Accordingly, the program functions independent of the Quality Assurance Programs. The program will be perfomed in two phases; the first ph'ase covering the design work perfomed prior to construction restart, and the second phase covering the completion of design after construction restart. Program procedures are approved by the Program Manager, Readiness Review and Manager, Engineering Assurance. These procedures describe the various Engineering Assurance activities including assignment of responsibilities, methods of implementation, and method of coordinating activities with other organizations. The activities of the program include design process reviews, independent technical assessments, and third-party design assessments. Essentially, the program will confirm that plant systems, structures and components confom to design criteria. The Engineering Assurance Program will review samples of the design and, also, review the design process used. Conclusions about the adequacy of the overall design will be based upon these reviews. Efforts will be made to identi fy modifications or improvements to the design process if deficiencies are identified; however, reconsnendations for improving the design products will not be made unless the design will not perform its intended function or satisfy the design criteria. The technical subjects and design features will be evaluated against good engineering practice and commitments contained in the Final Safety Analysis Report. (c) Construction Assurance Program The purpose of the Construction Assurance Program is to provide additional assurance that there are no undetected generic quality deficiencies associated wi th the fabrication and installation work perfomed by contractors at WNP-3. The program also will ensure that records generated by the contractors in support of the work are accurate, complete and in accordance with the requirements of their approved Quality Assurance Programs. In

addition, this program provides self-assessment of the Supply System's Preservation Program.

The program is directed at assessing whether WNP-3 contractors' completed work and documentation is in accordance with approved design requirements, Final Safety Analysis Report commitments, and Quality Assurance Programs. The program review process consists of inspections of hardware and review of records. This is to be accomplished in two phases by sampling and reviewing the safety-related work perfomed by each on-site contractor. Phase I of the program covers the work completed prior to the 1983 construction shut down and current preservation activities. Phase II will address the continuation of work - - _ _.

.=. REY. 1 after restart of construction. The self-assessment of the Preservation. I Program will include review of hardware and documentation for components covered by special maintenance requirements invoked by that program. The program is implemented by procedures approved by the Program Manager, i Readiness Review. These procedures will be used for generic review {_ activities. j-The activities of the program include in-depth reviews of representative samples of Quality Class I and Quality Class II-Augmented hardware, j detailed reviews of contractor-generated documentation, detailed walkdown 3 inspections of the documented work, and general reviews of vendor 4 documentation associated with the work being examined. The program i verifies that the reviewed portions of plant systems, structures and i components. are in conformance with design, installation and acceptance criteria; and that all required maintenance and preservation activities i have been accomplished. All apparent nonconformances to design or j acceptance criteria discovered with the installation, documentation, testing, or preservation activities will be documented and processed through the normal project deficiency reporting and dispositioning i program. In

addition, all design-related
findings, concerns and j

observations will be communicated to the Manager, Engineering Assurance j for consideration in the Engineering Assurance Program. SIM4ARY l The primary purpose of the Readiness Review Program is to provide an assessment of the safety-related design and construction activities completed j to date at WNP-3. Because the Nuclear Regulatory Commission (NRC) has agreed to participate in this assessment, it is anticipated that the licensing t process will be expedited by having already accomplished the NRC review of the ] work completed prior to construction shut down. 4 The three elements that are the substance of the Readiness Review Program provide the vehicle by which the assessment will be accomplished. The elements, while being separate in scope, are designed such that information can be freely exchanged between individuals working in any of the elements. For example, the Construction Assurance Program not only assesses construction and preservation but also provides information to the Engineering Assurance j Program. Conversely, the Engineering Assurance Program nct only assesses engineering but may also provide information to alert the Construction j Assurance Program of a possible need for detailed inspection. To provide additional assurance that the Readiness Review Program meets its objectives, the planning and. implementation of the program will be monitored by an Oversight Conunittee of independent consultants who will provide i

guidance, recommendations and on-going assessment of the program as it progresses to completion.

i j By these careful and thoughtful reviews and examinations, the Readiness Review Program will furnish a significant measure of confidence that safety-related } design and construction activities completed to date (along with the preservation program now in place) are acceptable for the eventual licensing of WNP-3. i i 4

  • 1 J

WNP-3 R$A0iNESS REVIEW ORGAulZATION - WPPSS MANAGING DIRECTOR I l DIR E CTOR DIRECTOR DIRECTOR LICENSING 8 ENGINEERING ASSURANCE PROJECTS l QA l LICENSING l s 1 I l l I I I E l WNP-3 l l WNP-2 l l WNP-l l l CENTRAL l PROGRAM MANAGER l i_ _._ _i _i l READINESS REVIEW l [_ l _ _ _ j l OPERATIONS l lCONSTRUCTIOd l l l l l ^ [OUTSIDE SERVICES [-- d ^ l ENGINEERING CONSTRUCTION ^ ^" ^ (REVIEWERS) h-+ -jMODULE I l -l MODULE I l * - - - - - l-- - + luOoutE 2 l -luoDutE 21 -- H I I I I " - +- -{ MODULE N l -{ MODULE M l * - - - - - - - - Q m OUTSIDE SERVICES P \\ ~ s e i

o 1 FIGURE 2 MATRIX OF 10CFR50, APPENDIX B CRITERIA APPLIED TO RTAM RESS REVIEW PRUCRAM CRITERION ENGINEERING ASSURANCE PROGRAM CONSTRUCTION ASSURANCE PROGRAM I. Organization Applies to the organizational freedom Applies to the organizational f reedom - 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 crite'rion 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 governed by corporate and project governed by corporate and' project g; requirements already in place. requirements and controls already in 7: place. t

CRITERION ENGINEERING ASSURANCE PP0GRAH CONSTpilCTION 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-reducac and instructions which com-prise the Program Manual, controlled prise thu Program Hanual, 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. App'ropriate monitoring outside sources. Appropriate 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. No 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 _ Applies if services, such as NDE, 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 CAP management. X. Inspection Does not apply. EAP walkdowns are not Does not apply. Timely inspection of 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 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. g; Procedures and instructions govern the 7: 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, l 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 i ment and Testing testing equipement will not he used hardware insppctions. Devices used in 4 Equipment in reviewing design work. ' CAP inspections will be furnished by existing project organizations whose approved measures govern control of MATE. 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. 2 XIV. Inspection, Test, Does not apply. The EAP will not tag Does not apply. The CAP will not tag i ) and Operating Status or alter existing tags that indicate or alter existing tags that indicate j status of items in the plant. status of items in the plant. Nonconformance tags that may result from CAP inspections will be provided ~ through existing project controls j promulgated by the generation of NCR's. XV. Nonconformance Does not apply. Deficiencies in the Applies to the identification of non-i 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 deficiercies in hardware and documentation. ( XVI. Corrective Action Applies to identification of errors Applies to the identification of non-or deficiencies in the design or conforising items by CAP inspections and design process. Corrective action reviews. This criterion is met by use E l 1s processed under existing project of existing project controls for 5 } controls. reporting deficiencies in hardware and j documentation. 1 i

.a 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 estah-confonnance with requirements estah-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. I T

+. WNP-3 CONSTRUCTION ASSUPANCE PROGPAM Pevision 1, January,1986 1.0 INTPODLCTION The Construction Assurance Program (CAP) will furnish a significant additional measure of confidence that safety-related construction now complete is acceptable for the eventual licensing of the plant. The NPC has agreed to participate in the Supply System's program of review, which has as an objective, the expediting of that licensing process by having already accomplished the NPC review of the work completed prior to con-struction shutdown. The program consists of activities specifically directed at assessing WNP-3 contractors' completed work and documentation activities to approved design requirements, FSAR commitments, and quality assurance programs. The program review process consists of inspections of hardware and review of records. This is to be accomplished in two phases by sampling and reviewing the safety-related work perfomed by each on-site contractor. Phase 1 of the program covers the work completed prior to the 1983 construction shutdown, plus current preservation activities. Phase 2 will address the continuation of work after restart of construc-tion (scheduled for the future). Only Phase 1 reviews and inspections are addressed in this program description. The CAP reviews incorporate the Supply System's self-assessment of the Preservation Program by in-cluding components covered by special maintenance requirements invoked by that program. The CAP is an element of the Supply System's Peadiness Review Program and is being conducted in accordance with applicable Ouality Assurance Criteria of 10CFP50, Appendix B. The applicability of these criteria is established in the overview document for the Peadiness Peview Program. 2.0 PURPOSE The purpose of the CAP is to provide additional assurance that there are no undetected generic quality problems associated with the fabrication and installation work of Supply System contractors during their period of performance at WNP-3. The program similarly ensures that ouality records generated by the contractors in support of the work are accurate, com-plete, and in accordance with the requirements of their approved quality assurance programs for control of WPPSS Quality Class I (OC-I) and Quality Class II-Augmented (QC-IIA) activities. OC-I applies to safety-related construction; OC-IIA applies to non-safety-related work for which additional quality assurance requirements have been invoked. This program also provides self-assessment of the Supply System's pres-ervation and maintenance activities. This provides assurance that the requirements of the Preservation Program have been implemented and that the condition of safety-related components is protected. X

REV. 1 3.0 OPGANIZATION Implementation of the Construction Assurance element of the Peadiness Peview Program is the responsibility of the Manager, Construction Assur-ance, who reports directly to the Peadiness Peview Program Manager. The Manager, Construction Assurance is independent of jobsite functions and responsibilities, thereby assuring independence and objectivity during the review process. The Manager is qualified for this position based on previous work assignments, training, and experience. In addition, the Manager is augmented (as individual reviews dictate the need) by inde-pendent, quali fied personnel to perform the reviews, inspections and analyses. Qualfications of these personnel are also based on werk assignment, training, and experience. Copies of resumes are maintained by the CAP Manager. 4.0 PROGPAM PPOCEDURES The Construction Assurance Program is implemented by procedures approved by the Readiness Peview Program Manager. These Supply System procedures are utilized for generic review activities. Inspections and docunent reviews will be conducted insofar as possible utilizing approved design requirements and acceptance criteria specified in each contract and restated in the contractors' approved quality assurance programs. The adequacy of requirements and criteria are checked by another element of Peadiness Peview: the Engineering Assur-ance Program. Implementation of the project Preventive Maintenance Program will be assessed as part of the CAP reviews. Maintenance instructions furnished by manufacturers provide the basis for establishing preservation criteria for components covered therein. 5.0 PP0 GRAM ACTIVITIES The activities of the CAP include in-depth reviews of representative samples of OC-I and OC-IIA hardware, detailed reviews of contractor-generated documentation, detailed walkdown inspections of the documented wo rk, and general reviews of vendor documentation associated with the work being examined. The CAP veriffes that the reviewed portions of plant systems, structures, and components are in confonnance with design, installation, and acceptance criteria, and that all required maintenance and preservation activities have been accomplished. When deficiencies are identified, recomendations for disposition will not be made by the reviewers and inspectors. All apparent nonconfonrances to design or acceptance criteria discovered with the installation, documentation, tes ting, or preservation activities will be documented and processed through the normal project deficiency reporting and dispositioning pro-gram. All design-related findings, concerns, and observations will be comunicated to Manager, Engineering Assurance, for consideration in the Engineering Assurance Program. This entire process, from development of program activities and review planning to reporting the results and retaining records, is depicted in the activity flow diagram of Figure 5-1. -__

O CONSTRUCTION ASSURANCE PROGRAM SELECT TEAM o Team Leader DE)ELOP PROGRAtt 00TAIN NRC IMPLEMENT FROGRAM = OEVELOP o Engineers o Description ACCEPTANCE o Procedures 4 M000tE OUTLINE Instructions 0 Reviewars o Sudget o Presentations o ident Contractors o Detailed Plans o Schedule o Discussions 4 Schedules o Ident Each Scope ~ o Pubile Meetings TRAIN IEAll o Estahl Sequance o Reviews

=

o Team Leader <mmune o Prepare Scharfule o Team HWeer PREPARE INITIAL FEE 08ACK RECONCitE REvitW RECORDS DEVELOP MODULE N00ULE REPORT o Froject HARDWARE A RECORDS o Comp 1 Checklist REVIEW PLAN e o Participants o Eng Assurance o Compare Results.

== o Adequacy o Determina Program Close Open Itams Requiremants w o Review Plans o Preservatinn o Adjust Cap Review o findings o Historical Record o Checklists Res71ution o Findings = o Prepare Sanolf rq o Results o Analyze Results Rationala o Recocrvna+tions o Identify Trends, o Prepare Chacklists Safety Signific. INSPECT HARDWARE I o Select Simple nf a Comal thacklist Howre & Recorrfs

== o Adequcy sum o Obtain Cao Nor Anoroval o Preservation a Findings MtyArJWui REVIEW 08TAIN NRC ' RETAIN RECORDS o Df r Licensing (R) ACCEPTANCE o Asseeable Records R0W DMRM o kNP-3 Prog Dir (R) o Overvfew o Tran xit to Peru.

n o Prog Mgr. Rk? ( A) o Sampling o Df r Profacts f A) o Reports

M -e an d +--1-& ma ---a REV. 1 5.1 Construction Assurance Review Process The CAP reviews are performed by personnel under the direction of the Manager, Construction Assurance. The objective of these reviews c is to develop information by which to judge the compliance of com-pleted DC-I and QC-IIA work with design / construction requirements and approved acceptance criteria. These reviews are conducted on a sampling basis directed at the final product of the construction i process. The CAP reviews are conducted by qualified and experienced personnel who will examine the installed work and documentation, and l determine compliance with speci fied requirements and acceptance criteria. As a result of these reviews and inspections, determin-ations can be made as to how well contractors controlled the instal-l 1ations and documented the activities of their personnel. The Manager, Construction Assurance, coordinates and analyzes the review and disposition of 'ionconformances related to :oncerns identified in this program. Selection of work areas to be reviewed by the CAP will be based on the following general guidelines: o Select safety-related work activities that address the various aspects of the plant construction process and provide a reason-l able data base upon which to judge the adequacy of the project } construction processes (detailed in Section 6.0). i o Select representative samples from completed OC-I and OC-IIA construction work to deterimine that installation and document-ation, together with the associated material and equipment, have been accomplished in a controlled manner and meet spec- .I ified requirements. o Select work that represents known problem areas in the indus-try; particularly those that have experienced a large number of j design changes. o Select work that represents known or suspected Supply Syster and/or contractor problem areas. The scope of completed construction for CAP review includes that I work which has been previously inspected and accepted in each con-tractor's quality program. Resources for determining this scope 4 include the project's Construction Connodity control Syster (CCCS), which the Construction Manager (Ebasco) used for reporting progress; i j Project Peview of Installation, Documentation, and Engineering i (PRIDE), which is an Ebasco system for establishing a detailed j status of the project; and each contractor's management control system that was in place at the time construction was halted. l The contractors who perforwed safety-related construction work in the various commodities addressed in CAP modules are listed in the Matrix shown in Figure 5-2. I i j I i 4

REV. I E { 9 2 E S E 2 ~ 3 8 : E a = C 3; E ; G $ k-a u m = e = = c ! s a =f I

8

= 3 _ = 0 b a b 5 b ' E E S E C 5 kr j a E E N c 3 5 a R e e te a m 3 b 6 t *e i g$ C W v si l5 g a E E 8 = d c = 2 8 t S e 0g b a g E S & b 5 5 5

  • e g 5

m m o m 4 S d d dd A d i d f d d $f g.3 (DITRACT MR9tR 002 cf 'X X IX X 204 PTL X X .X X 2ne Ascs X l 'X X 21 1 act X. X ( X X l 21C ATKTNSOf1 X X X X lX X X l 7ta POM lX l I X X l 21e acc/rra X X X! 221 LAMPson X X X X 224 M-T/rsTitcRD X X X X X X X X X X X X X X 22cist rcM X X X X X I X X 'X X 231 McME f FM I lX X l 212 WALLAcfIsuP G TOR X X lX X ptt apINNEt X X X X X' X X X X X l 1 9tt att X .X X X l l siim oys X X X X X l X x X 24A McMuttrM X X X X l mt Mr X X X 'X X X X X l MC 71 Terrg X X X X X X X X X X X l FIGURE 1 SAFETY-RELATED WORK PERFORMED BY WNP-3 CONTRACTORS -

REV. I 5.2 Independence of Construction Assurance Peviews The CAP reviews are designed to be independent verifications of contractor installation activities. They do not take the place of normal construction verification performed by the organizations responsible for installation, verification and overview of the work, but are accomplished to provide additional assurance that completed, QC-I and CC-IIA work is in compliance with specified requirements and approved acceptance criteria. These sample reviews' provide additional confidence that all such work on the project meets the requirements for safe operation of the power plant. The basis for j selection of personnel for the CAP includes experience, qualiff-cation, and independence from the installation contractor. Selected personnel,may be assigned from a variety of sources and are directed by the Manager, Construction Assurance. 5.3 Result of Reviews and Inspections The results of these reviews and inspections are reported to Team \\ Leaders and include all concerns identified, nonconfomance reports, deficiency reports, and recomendations for further assessment of any concern or nonconfomance judget to have potentially generic implications. The Team Leaders and Construction Assurance Manager 4 analyze the results for comon causes and characteristics, and infom liNP-3 project management of the results. All significant infomation emerging from the CAP reviews and analyses are compiled establish the adequacy of OC-I and OC-IIA work at the plant; and in l in Module Reports. It will be an objective of these reports to cases where deficiencies in the work have been found to exist, to identify root causes of the deficiencies so that appropriate cor-1 rections can be made for managing and controlling the work or for maintaining preservation components. The CAP Module Peports are approved by the Peadiness Peview Program Manager and the Supply + System's Director of Projects, and will be submitted to the FPC through the office of the Director of Licensing and Assurance. The senior Supply System management will review each Module Report as it is issued, and will have available an oversight comittee assessment of the report. Following approval of the report, the NPC 1 will be requested to accept the review and its results. Ilpon com-pletion of all Module Reports in Phase 1 of the CAP, a final overall conclusion of the adequacy of safety-related construction can be drawn and presented in a final program report. The final report l will also be provided to the NPC with a statement of conformance I with requiments and comitments, and a request for HPC approval. 5.4 oversight Comittee l An executive Oversight Comittee is retained by the Supply System to monitor the Readiness Review Program, including the activities of i the Construction Assurance Program. Comittee members are chosen i l i I

REV. I from the business, academic and technical comunities based on their independence from the organization under review and for their extensive experience and qualifications to assess the program's integrity and effectiveness. The Oversight Comittee will evaluate the overall Readiness Review Program (including all three elements -- EAP, Preservation, and CAP) and provide recomendations for improvements to Supply System management. Periodic meetings are held with the Oversight Comittee to discuss details of the review programs and make observations of program implementation. The Comittee is required by its charter to provide written assessments of the program and its ongoing implementation. 6.0 PROGRAM IMPLEMENTATION Construction Assurance Program reviewers will examine the scope of wo-k in all on-site contracts to determine those contracts that include OC-I and QC-IIA activities, and categorize them for review. Peviews will be conducted in all areas of safety-related construction work, as char-acterized in the following list: o Earthwork / Soil Compaction o Concrete, Pe-steel, and Embedments o Containment Structure o Structural Steel o Equipment Installation o Piping and Valves o Pipe Supports o Electrical Raceways and Supports o Cables and Cable Terminations o HVAC Ductwork, Supports and Controls o Instrumentaion, Tubing, and Supports o Cathodic Protection and Grounding o Coatings o Hondestructive Testing o Miscellaneous Support Activity Because of the multiplicity of the contracts at WHP-3, work of any one kind was typically performed by more than one contractor. Therefore, review activities accomplished in the above categories will cover all contractors perfoming safety-related work, see Figure 5-2. Samples willl be selected from the work of these contractors and will be reviewed as described below. The samples will be directed toward potential problem l areas, and their sizes will be determined from an appraisal of each contractor's perfomance history. The following is a sumary characterization of typical program activities: A. A review plan, prepared by the Team Leader, will define purpose, scope, special concerns, checklists to be utilized, and any other information pertinent to the review, including past special programs that addressed known problem areas. The plan will be approved by the CAP Manager. l

REY. 1 Checklists will identify the contractor, the activities being reviewed, the specific attributes to be inspected and evaluated for i those activities, and the related documentation to be included in i the process. 2. Working with the Construction Assurance Manager, the review Team Leader will detennine the sample to be inspected based on a detailed review of contractor performance history and the extent of con-tractor activity. He will document the sample prior to inspection of hardware. l C. Reviews are to be conducted in accordance with the approved plan. Should it become necessary to deviate from these requirements, the changes, deletions, or additions will be documented (with justifi-cation) by the Manager, Construction Assurance. l D. Members of the review team will utilize the approved checklists when performing their individual activities. Where an apparent discrep-ancy is discovered, reviewers will document findings on project deficiency docurnents, which are processed through the project-l approved system by the A/E. I Final disposition of all defir.iencies will be perfonred by the A/E. Deficiencies will be evaluated by the CAP review team and the A/F. When the A/E and CAP Manager determine that further examination is required to accumulate data to show that a generic problem does or does not exist, the review team will increase the inspection sample for the specific deficiency. E. Review team members will assess the adequacy of the Preservation Program through review of preservation requirements, review of impimentation of the requirements, and review of records associated with preservation activities. The collection of data will fonn the basis for determining whether or not the program is accomplishing its stated objectives. Discrepancies will be documented on the appropriate deficiency document, and concerns and observations will be referred to the appropriate group for resolution. F. Post-review meetings of the review team members will be held to discuss the results of the review, the individual findings and their dispositions, and to prepare a draft report of the investigation for the review of the Manager, Construction Assurance. G. The formal report, approved by the Construction Assurance Manager, will contain all the details of the review, including the purpose l and scope of the review, identification of review participants, identification of contractors

involved, specific
findings, and reconsnendations.

Corrective actions to be taken as a result of engineering dispositions will also be included as a part of the I formal report. The Manager will report the need for further evalu-l ation for possible generic design / construction problens. I REV. 1 7.0 RECORDS The Manager, Construction Assurance, shall maintain records that demon-strate compliance with this program. As a minimum, the following records will be maintained: A. Peview plan checklists. I j B. Qualifications and resumes of Construction Assurance personnel. l l C. Correspondence pertaining to reviews and inspections perfomed. D. Procurement-related correspondence and documents pertaining to nonconfomances discovered during the review process. E. Review reports, nonconformance reports and corrective action reports. F. Assessments and recommendations by the Oversight Comittee, and records of responses to the comittee's' reports. I G. NPC coments, correspondence, meeting minutes, observations and I findings. Upon program completion, the documentation -files of the

Manager, I

Construction Assurance, shall be transmitted to the Project vault as a part of the plant records. 9_ _ _..}}