ML20198F988

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Forwards SER W/Evaluation of QA Program for Design Procurement & Const of WPPSS 1 & 4,based on Review of Amended Psar.Qa Program Complies with 10CFR50 & Acceptable. SER Will Be Supplemented,Pending Second QA Insp
ML20198F988
Person / Time
Site: Washington Public Power Supply System
Issue date: 09/04/1974
From: Skovholt D
US ATOMIC ENERGY COMMISSION (AEC)
To: Moore V
US ATOMIC ENERGY COMMISSION (AEC)
References
CON-WNP-0994, CON-WNP-994 NUDOCS 8605290170
Download: ML20198F988 (20)


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. DISTRIBUTION

_ Docket Files QA Reading

'SEP 4 1974 L Reading Docket Hos.: 50-460 and 50-513 Voss A. Moore, Assistant Director for Light Water Reactors, Group 2. L SAFETY EVALUATION REPORT: WPPSS WCLEAR PROJECTS NOS.1 AND 4(PSAR),

QUALITY ASSURANCE Plant Name:

WPPSS Nuclear Projects Nos.1 and 4 Licensing Stage:

CP Docket Numbers:

50-460 and 50-513 Responsible Branch and Project Manager:

LWR #2-3. T. Cox Requested Completion Date:

August 19, 1974 Review Status:

Complete The Safety Evaluation Report which provides our evaluation of the Quality Assurance Program for design, procurement and construction of the WPPSS Nuclear Projects Nos.1 and 4 is enclosed. This evaluation is based on our review of the amended.PSAR, other applicable documentation and discussions with the applicant.

- We conclude that the Quality Assurance Program as described in the WPPSS Nuclear Projects Nos.1 and 4 (WPN 184) amended PSAR and answers to AEC staff questions ccmplies with the requirements of 10 CFR Part 50. Appendix B and the guidance included in Regulatory Guide 1.28 and is acceptable for design, procurement and construction.

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Discussion with Regulatory Operations and a review of the Initial RO Inspection Reports indicate that there are no major open items at this time. RO's second Quality Assurance inspection has not been perfomed and their suninary i

statement on the QA Program will not be published in time to be included with this report. The SER will be supplanented when this infomation is received.

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8605290170 740904 PDR ADOCK 05000460 Donald J. Skovholt, Assistant Director E

PDR for Quality Assurance and Operations Directorate of Licensing Enc 10sure:

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SAFETY EVALUATION REPORT

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WPPSS NUCLEAR PROJECTS NOS. 1 AND 4 QUALITY ASSURANCE FOR DESIGN, PROCUR$4ENT AND CONSTRUCTI0fl DOCKET fiOS. 50-460 Af D 50-513 17.0 QUALITY ASSURAl:CE 17.1 General The description of the Quality Assurance (QA) Program for WPPSS Nuclear Projects Nos.1 and 4 (WPfl 1&4) is contained in Section 17 of the PSAR as amended by Anendments 2, 4, 6 and 8.

Our evaluation of the QA Program is based on a review of the amended Section 17 of the PSAR and related discussions with the applicant to e

determine if Washington Public Power Supply System (WPPSS) and its principal contractors, United Engineers and Constructors (UE&C) and Babcock and Wilcox (B&W), comply with the requirements of Appendix B to 10 CFR Part 50.

UE&C is responsible for architect-engineering, -

construction management, and QA services; B&W is responsible for the nuclear steam supply system.

17.2 WASHil!GT0tl PUBLIC POWER SUPPLY SYSTEf1(WPPSS)

Organization WPPSS has delegated to UE&C the responsibility for the mechanical, structural, and electrical design and construction of the plant and the QA Program related to those items. The responsibility for design, procurcment, and quality assurance of the nuclear steam supply system und t.uuipw ents i as been delegai.co to caw.

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for purchase contracting and administering the UE&C and B&W contracts to assure the quality and safety of WPPSS Huclear Projects Nos. I and 4.

In the original WPPSS submittal of the PSAR, there was a Manager of Quality Assurance reporting functionally to the Deputy Managing Director and administratively to the Manager of Regulatory Programs. The staff questioned the acceptability of this organizational arrangement on the basis of lack of organizational freedom and conflict ~of interest for the

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Manager of Quality Assurance. WPPSS responded with an organizational change which is shown in Figures 17.1-1 and 17.1-2. Figure 17.1-1 shows the WPPSS organizations and Figure 17.1-2 shows the organization of the Manager of Compliance.

The Manager of Compliance supervises the Manager of Quality Assurance-Projects and Manager of Quality Systems who are

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directly responsible for establishing and implementing the Quality Assurance Program.

The Manager of Compliance is on the same organizational level as the Manager of Engineering, Senior Project Managcr, and the Managu of Fuel and Technical Studies.

These managers supervise the principal WPPSS organizations in which the Manager of Compliance oversees QA activities. With this organizational arrangement, the staff finds the QA organizations have adequate freedom to identify problems affecting quality and to assure that solutions can be obtained and implemented.

The Manager Quality Systems has been assigned authority.and is responsible for developing and establishing the QA Program and for monitoring its

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and for directing, evaluating, and coordinating UE&C's home office, vendor surveillance and construction site QA activities.

The WPPSS Managing Director has delegated to QA department personnel the authority and responsibili.ty to perform a.ny actions necessary including stop work authority, to accomplish their mission.

WPPSS Engineering is responsible for reviewing and approving equipment and construction specifications, and for reviewing, drawings for technical adequacy and inclusion of quality requirements. Prgject Management reviews and approves equipment-and construction specifications for proper contractural requirements, awards purchase contracts and administen these contracts to assure adequate quality. Fuel and Tech Studies support Engineering and Project Management.

WPPSS requires that both the Manager Quality Assurance-Prcjects and Manager Quality Systems have the equivalent of a BS degree in Engineering (or in a related field) plus five years experience in Quality Assurance activities.

To achieve the necessary background and experience for WPPSS staff personnel, an indoctrination and training program has been established.

Individuals engaged in the QA Program will be involved in formal training programs and on-the-job training by WPPSS supervisory personnel.

We find the WPPSS managerial qualification requirements and the QA staff training satisfactory.

The staff finds (1) that WPPSS has adequately described in writing the authorities and duties of persons and organizations performing qualit' assurance functions, (P) that the QA organization is independent of organizations perfonning quality related activies, (3).that the 4

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organizations have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementatior. of solutions.

Program WPPSS's original QA Program description in the PSAR did not provide enough detail to adequat61y describe the QA Program for design, procurement, and construction of WPPSS tiuclear Projects Nos.1 and 4 (WPf11&4).

In respone to our request for a more detailed, comprehensive description',

WPPSS provided an expanded and improved description of their QA Program in Amendments 2, 4, and 6 and 8.

The QA policies and procedures used to administer the QA Program are i

contained in the WPPSS Quality Assurance Program itanual which is prepared

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by the Manager, Quality Systems, approved by the flanager, Quality Assurance-Proje, cts and authorized by the flanaging Director. WPPSS has provided a brief description of each of the procedures and a cross index to the related criteria of Appendix 8 to 10 CFR Part 50 in the PSAR.

Based on our review of this information, we conclude that each criterion of Appendix B to 10 CFR Part 50 has been specifically included in written procedures within the WPPSS QA Program.

The structures, systems, and components that are subject to this program have been identified in the PSAR.

WPPSS has committed to comply with the requirements of the Gray Book (5itt.::

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l Plants.) The staff finds this comittment satisfactory.

A comprehensive system of' planned and documented audits is described by WPPSS in the PSAR. These audits will be used to verify compliance with all aspects of the QA Program and to assess QA Program effectiveness.

The implementation of each applicable criteria of 10 CFR 50, Appendix B is' audited annually. WPPSS audits include:

1.

UE&C's home office, site and vendor surveillance activities 2.

B&W's home office, site and manufacturing activities 3.

Site contractors activities 4.

WPPSS home office and site activities Audits are performed in accordance with written procedures or checklists by appropriately trained personnel having no direct responsibilities in

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the area audited.

Audit results are documented and reported to appropriate levels of management for corrective action. Responses to WPPSS's audit findings are verified for implementation and effectiveness during follcu-up audits.

The staff finds WPPSS's audit activities satisfactory.

Based on our review of the description of the QA Program contained in Section 17 of the PSAR, as araended, we conclude that the applicant's QA Program complies with the requirements of Appendix B,10 CFR Part 50 and is acceptable for the design, procurement, and construction of WPfl-l&4.

17.3 UtlITED Ei!GIj'EERIt'G F. C0f5TRUCT10fl INC.(llE&C)

UE&C has contracted with WPPSS to provide the Architect-Engineering, Construction l'anagement and QA services for WPPSS fluclear Project flos.1 and 4 (WiiP-l&a). As Architect Engineer and Construction f4anager, UE&C

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is responsible for generation and administration of specifications for procurement of equipment and construction activities. The QA services include hon $e office QA, vendor surveillance and site QA'and construction inspection.

The responsibility for Quality Assurance within UE&C rests with the Vice President-Administration. The Vice-President-Administration is on the same organizational level as the Vice President-Power Generation and the Vice-President-Construction, thus assuring organizational independence (See figure 17.2-1.)

/The Manager-Rel.iability and Quality Assurance (R&QA) reports directly to the Vice President - Adninistration and-has been delegated full responsibility for the total quality assurance activity within UE&C. He has been granted authority to control further processing or delivery of nonconforming material.

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The organization for the Manager of Reliability and Quality Assurante is i shown on Figure 17.2-2. Quality Engineering is staffed with engineers of s

'various disciplines. The Quality Engineering group is responsible for reviewing all engineering and procurement documents, preparing surveillance instructions, planning and coordinating audits of QA activities and QA procedures, planning and coordinating vendor audits with the QA Audits Group and training personnel. The R&QA Manager has assigned one of.

Quality Engineers as the Project QA Engineer (QAE) with responsibility for UE&C's Quality Assurance activities.

The Materials Engineering Group assists in selecting material for new applications, assists in solving inspection report problems and performs audits of metallurgical procedures and controls. The Audits Group is responsible for planning.

coordinating and implementing UE&C's audit program. The Quality Services Group is responsible for vendor surveillance, qualification of wldiN procedures and personr.ci, nondestructive examinations, and Field Quality Ar.surin c.

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The Field Quality Assurance organization is s,hown on Figure 17.4-1.

The' Field QA organization is independent of~ the Construction f4anager and includes Engineers knowledgeable in all phases of construction, quality assurance and quality control.

They are responsible for implementing all QA/QC activities at the site including construction inspection.

i The engineering function is performed by the UE&C Power Division, headed by the Nice President-Power Generation, who is responsible for the design, and engineering of the nuclear power plant.

The purchasing function is performed by the Purchasing Group headed by a llanager-Purchasing who reports to the Vice President-Adminstratiin and is responsible for i

procurement of equipment to requirements specified by the Power Division.

Procurement activity on WPfl-l&4 is limited to contract administration

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and expediting. (See figure 17.2-1)

Based on our review of the description of the corporate organizations in the PSAR we find that UE&C has established and described a corporate organization which is capable of developing and implementing a QA Program in compliance with 10 CFR 50, Appendix B.

In addition, this organization is structured such that personnel performing QA functions in the UEIC organization have sufficient authority and organizational fredom to perforc, their critical functions effectively and without reservation.

UE&C's original QA Program description in the PSAR did not provide sufficient detail on the QA Program to allow us to complete our evaluation. UEEC prov Hed. "

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in Anendments 2,4,6, and 8, a more detailed and comprehensive description of their QA Program.

The QA policies and procedures used to administer the QA Program are contained in WitP-l&4 project Quality Assurance Procedures Manual.

These policies and procedures define the technical, administrative and quality related inputs to documents affecting the quality of safety related structures, systems and components. ' The QA Procedures Manual contains a policy statement signed by the UE&C Company President which instructs,all UE&C organizations and personnel to adhere to UE&C QA policies and procedures. A matrix has been provided to show the principal procedures which implement the criteria of 10 CFR 50 Appendix B.

A brief description of the procedures has been provided.

Based on our review of this information, we conclude that. each criterion of 10 CFR 50 Appendix B has

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been specifically included in written procedures in the UE&C QA Program.

The structures, systems, and components that are subject to this program have teen identified in Table 3.2-2 of the PSAR.

UE&C has committed to comply with the requirements of the Gray Book (Guidance on Quality Assurance Requirements During Design and Procuremen:

Phase of fluclear Power P.lants) and.the apolicable AEC Recitlatory Guides.

We find this commitment satisfactory.

3 UE&C has described a system of planned and documented audits with provisions for corrective and follouup action. Audits are perfomed ir :::e+ce t.'i +S "*i + Mn proe rfurce ce chachlit** by anorooria+niv o

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trained persunnel having no direct responsibilities in the area audited.

Audits are scheduled on the basis of importance, but will be performed at least annually or at least once during the life of the activity, whichever is shorter.

The UE&C Vice President Administration arranges for a corporate audit of the activities of the UE&C Reliability and Quality Assurance Depart-ment for conformance to provisions of th.e UE&C Nuclear Quality Assurance Manual annually.

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The staff finds the UE&C description of their audit activities, including the corporate audit of the QA Program, satisfactory.

Based on our review of the description of the QA Program contained in Section 17 of the PSAR, as amended, we concludc that the UE&C QA Program g

complies with the requirements of Appendix B to 10 CFR Part 50 and is acceptable for the scope of UE&C's responsibilities for the design, pro-curement and construction phase of WPN-l&4.

17.4 BABC0CK & WILC0X (B&W)

B&W has contracted to furnish the Nuclear Steam Supply Systen (NSSS) for the facility.

B&W is responsible for establishing a Quality Assurance Program and assuring that the program requirements and procedures are followed. Within the B&W organization, the Nuclear Power Generation Division (NPGD) has been delegated the overall responsibility for administering the QA Program.

NPDG cxecutes contracts for commercial nuclear steam

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The concept within B&W is to

. treat all B&W manufacturing and fabricatirg organizations as outside suppliers, and manage the QA Program accordingly.

The organizations within NPGD which are primarily involved in quality assurance activities are the Reactor Department, the Fuel Department, Purchasing, Quality Assurance (QA), and the New Product and Services Department. The organization structure is shown in Figure 17.3-1.

The staff has reviewed the B&W organizational structure and the descript.fon of responsibilities and authorities in the PSAR and finds that the Manager of Quality Assurance has adequate authority and organizational freedom to effectively direct and control the QA Program. Further, personnel performing QA functions in the B&W organization have sufficient authority I

and oiganizational freedom to perform their critical functions effectively

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and without reservation.

i The original PSAR description of the B&W QA Program was incomplete.

The applicant revised the PSAR by,providing an expanded, more detailed and improved description of the BOW QA Program. Our review of this expanded description is discussed below.

The QA Program is defined in the Nuclear Power Generation Procedures which are prepared by the Manager QA and approved by the General Manager NPGD.

The procedures are made effective by a policy statement signed by the Gencial Manager NPGD rhich directs that necessary policies, manuals, and procedures be followed. At the staff's request, the applicant furnished a cross index of B&W procedures and the related criteria of Appendix B

'to 10 CFR Part 50.

Based on a review of this information, we conclude that each criterion of Appendix B to 10 CFR Part 50 has been included

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a 11 within the B&W QA Program for this facility.'

We find that the B&W training and indoctrination program described in the SAR is satisfactory.

We find the B&W list of systems and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to health and safety of the public to be acceptable.

We find the B&W QA Program to be acceptably structured to the guidance and ANSI Standards included in the Gray Book.

The General ihnager NPGD regularly assesses the effectiveness of the QA Program through consultation with the managers who report to him and through l

the monthly report of the QA flanager summarizing the detailed i

reports from the QA operating group managers.

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'N The staff concludes that the applicant has adequately described the B&W QA Program for this facility which embodies sufficient policies.

procedures, and instructions to fu'lly implanent 10 CFR Part 50 Appendix B for safety-related structures, systems and components.

We conclude that D&tl's QA Program for this facility demonstrates an acceptable QA organization with adequate policies, procedures, and instructions to implomont a program.that will satisfy the requirements of Appendix,B to 10 CFR Part 50 and Regulatory Guide 1.28.

17.5 conclusions The staff concludes that tha Quality Assurance Program as described in tha PSAR for WPH-1 A4 and in the related amendments complies with the requirement:

of 10 CFR Part 50, Appendix B, the recommendations of Regulatory Guide 1.23

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JULY 1974 WASHINGTON PUBLIC POWER luPPLY SYSTEM WPPSS ORCANIZATION

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WASHINGTON PUBLic POWER SUPPLY SYSTEM UE&C R&QA DCPART 'ENT AND THE I

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