ML20210S889
| ML20210S889 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 06/30/1975 |
| From: | Skovholt D Office of Nuclear Reactor Regulation |
| To: | Deyoung R Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-1697 NUDOCS 8605290492 | |
| Download: ML20210S889 (18) | |
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l JUN 3 01975 DISTRIBIRION Docket Files FA11enspach QA Reading NPR Reading JCostello Docket Ws. 50-508 AGarland and 50-509 RL 11mer DSkovholt JGilray RMCDemott R. DeYotrig, A4sistant Director for Light Water Reactors, Group 1, RL SAFEIY WA111ATIN REPORT: WPPSS MX2 EAR PM17BCTS NOS. 3 A?O 5 (PSAR),
QUALITY ASSURA!CE BRANm Applicant: Washington PLblic Power Stpply Systea l
Plant Nane: WPPSS lbclear Projects !b::. 3 and 5 Licensing Stage: CP Ibcks Mz:bers: 50-508 and 50-509 Responsible Brauch: IMt 1-3 Project knager:
P. O'Reilly Requested Cagletion Date: Jtme 16,1975 Review Status: Complete lhe QA Dranch has coupleted its twview of Sections 13.1, 13.4, 13.6, 14, and 17 of the PSAR thmugh Amen 3 ment 12 for WPPSS Maclear Prof ects Nos. 3 and 5 (NNP-3 and WNP-5). Our SIR input for these sertjens is attached.
We concitde that the quality assurance progren, conduct of operations, and initial tests and operation as described in the MF-3 and WNP-5 PSAR, thmugh Amen &ner.t 12, are acceptable for the design, procurement, and construction of WNP-3 and WNP-5.
f the Office of Inspection and Ihfousment (I4E) has conducted inspections to examine the implementation of the 10F-3 and WPF-5 QA program. Based i
on their inspections and assessment, ICE corchias that implementation of PSAR -itments in the MF-3 and WNP-5 QA progran is consistent with the statas of the project.
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.Jaed by, a@c J. Skovhok Donald J. Sisyvholt, Assistant Director for Quality Assurance 4 Operations Divisica of Reactor Licensing
Enclosure:
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l 13.0 CONDUCT OF OPERATIONS 13.1 Organizational Structure of Applicant The Washington Public Power Supply System (WPPSS) is responsible f
for the design, construction, quality assurance, testing and operation of WNP-3 and WNP-5.
Ebasco Services, Inc. has been selected to provide engineering design and to manage construction. Combustion Engineering Inc. will design and manufacture the nuclear steam supply system.
The Projects Division, through an assigned Project Manager,is responsible for implementing WPPSS's responsibility relative to the design, procurement, construction, and startup testing
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of WNP-J and WNP-5.
Technical' support to the Projects Division for WNP-3 and WNP-5 will come primarily from the Technical Division. The Operations Division will be responsible for the operation and maintenance of the facility.
Quality assurance aspects of the project are discussed in t
l Section 17.0 of the SER.
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j The station organization for the operation of WNP-3 and WNP-5 will consist of a technical staff of approximately 94 persons for one unit operation and 167 persons for two unit operation under the direction of the Plant Superintendent and Assistant Plant Superintendent. Reporting to the Assistant Plant Superintendent will be:
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l a Maintenance Supervisor with a staff of approx'imately 62
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persons, who will be responsible for all plant maintenance; an Operations Supervisor with a staff of approximately 68 1
J persons responsible for plant operation; a Health Physics-i Chemistry Supervisor with a staff of approximately 20 persons responsible for plant health physics and water chemistry; and a Technical Supervisor with a staff of approximately 11 persons responsible for m:nitoring plant performance and j
providing technical support for operations and maintenance.
This is a conventional type of plant organization to provide an onsite operating and technical support staff for plant operations.
k The shift crew for one unit operation will consist of at least five persons, one of whom will hold a senior operator license and two of whom will hold an operator license. The shift crew for two unit operation v.ll consist of at least ten persons, two of whom will hold a senior operator license and four of whom will hold an operator license.
The applicant has stated that the qualification requirements for plant personnel will equal or be better than the minimum requirements set forth in ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." This meets the NRC staff position stated in Regulatory Guide 1.8 " Personnel Selection and Training."
Primary offsite technical support for plant operation will be provided by the Technical Division.
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We conclude that the applicant has established an acceptable organization to implement its responsibilities relative to the design and construction of WNP-3 and WNP-5, and that the proposed plant organization, proposed personnel e
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qualiis :ations, and the plans for offsite technical support of plant operations are acceptable.
13.4 Review and Audit The applicant has indicated in Section 13.4 and described in Section 16.6 his plans for providing review and audit of plant operations. These plans generally conform to those stated in ANSI 18.7-1972, Administrative Controls for Nuclear Power Plants" and are acceptable for a PSAR review.
13.6 Plant Records The applicant has stated that records will be maintained in accordance with 10 CFR 50, Appendix B Section XVII.
We conclude that this is acceptable for a PSAR review.
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e 14.0, INITIAL TESTS AND OPEP.ATION The initial test programs for WNP-3 and WNP-5 will be conducted by the applicant who will receive technical direction and. support I
from the NSSS vendor (Combustion Engineering, Inc.) and the 1
, architect-engineer (Ebasco Services.. Inc.). The applicant has committed i
to develop and execute the test program in accordance with Regulatory Guide 1.68, "Preoperational and Initial Startup Test 4
Programs for Water-Cooled Power Reactors." The applicant's preliminary plans for the program are considered to be acceptable and should, when implemented, provide for verification of the functional adequacy of the facility. The details of the test program will be reviewed by the staf f during the FSAR review.
We conclude that the applicant has made acceptable plans for the staffing, development and conduct of the initial test programs.
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17.0 QUAL 11Y ASSURANCE i
17.1 General i
The description of the quality assurance (QA) program for hNP-3 and WNP-5 is contained in Section 17 of the PSAR through Amendnent 12. Section 17 describes the QA program of the applicant, Washington Public Power Supply System (WPPSS); the architect-
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engineer and construction manager, Ebasco Services, Inc. (Ebasco);
1 and the supplier of the nuclear steam supply,systen, Canbustion Engineering, Inc. (CE).
J Our evaluation of the. description of the' hKP-3 and hNP-3 Q\\ program is based 5
on a review of this infomation and detailed discussio1s with the applicant to determine the qualification and capability of the applicant and his principal contractors (Ebasco and CE) to comply with the requirments oY Appendix B to 10 CFR Part 50, applicable Regulatory Guides, and industry standards.
WPPSS has contracted with CE to supply the nuclear steam supply systs and with Ebasco to supply the architect-engineering and construc-tion management services. CE and Ebasco are responsible for establishing satisfactory Q\\ programs for their scope of work. WPPSS is responsible 3
for the total kNP-3 and hKP-5 QA progrcm and is organized to control and verify the QA programs of its principal contractors.
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i 2-f 17.2 Washington Public Power Supply Systm
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Organization The hPPSS corporate organization is shown in Figure 17.1-1.
'Ihe Projects Division is assigned primary responsibility for obtaining quality objectives, and quality assurance (in the TechnictJ. Division) is assigned responsibility for assuring achievement of qutlity objectives.
Organizations performing functions which assist the Projects Division in obtaining quality objectives are Engineering and Licensir.g in the Technical Division, the Construction Division, Procurement and Stores N
and Central Files in the Administrative Division, and the Operations I
Division.
'Ihe Manager, Quality Assurance reports directly to the Manager, Technical Division (See Figures 17.1-1 and 17.1-2). lie is on the same organizational 1cvel as those whose work activities he verifies, and he has direct access to the hTPSS Managing Director and his Deputy to obtain satisfactory resolutions of problems. Based on our evaluation, we find that the Manager, Quality Assurance has sufficient freedom from project cost and schedule pressures, q
'I has freedom to identify problems affecting quality, and can assure that solutions are obtained and impicmented. We also find that with this corporate organization stnicture, the QA organization has l
adequate organizational independence and reports at a sufficiently high management level to accomplish its objectives.
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The WPPSS hhnaging Director has delegated to the Manager, Quality Assurance authority and responsibility to establish and implement i
a QA program and has issued a written statement (included in the i
PSAR and in the Quality Assurance hhnual) stating that QA program requirements are mandatory for all persons performing quality related t
.activities. 'Ihe hTPSS Managing Director has also delegated to QA personnel the authority and responsibility to perfom any
'1 actions necessary, including stop work authority, to obtain satisfactory quality.
hPPSS implements its Q\\ functions by means of the organization shown in Figure 17.1-2.
The Manager, Quality Assurance is responsible for directing and controlling the QA pmgram; the Manager, Quality Systes is responsible for developing the QA program and monitoring its impicmentation and effectiveness; the Project Q\\ Manager is responsible for managing and coordinating project quality assurance activities and for functional direction of Ebasco's Q\\ program and activities; the Lead Vendor Surveillance Engineer is responsible for i
i providing vendor surveillance services to the project QA team; and the Senior QA Engineer provides technical and managerial expertise to i
the QA organi:.ation.
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l Our evaluation shows that hTPSS has: adequate provisions for
' mplementing their QA program through the QA organization described i
I above and authority fron the Managing Director to enforce QA require-ents j
and to stop work if required. Based on our evaluation of the hTPSS QA organization, we find that:
it is sufficiently independent of the organizations whose activities it verifics; it has cicarly defined authorities and responsibilities; it is so organized that it can identify quality problems in the other organizations i
perfoming quality related activities; it can initiate, recommend, or provide solutions; and it can verify implementation of solutions, j
h'e therefore conclude that the hTPSS QA organization complies with Appendix B and is acceptabic.
Program The QA policies and procedures used to define and administer the QA program are contained in the hTPSS Quality Assurance Program Manual which is developed by the Manager, Quality Systems, reviemd by the Manager, Quality Assurance,and approved by the Manager, Technical i
Division, and Deputy Managing Director. Chapter 17 of the PSAR provides a list of these policies and procedures, a description of the i
scope of each procedure, and a matrix of the procedures cross
" referenced.to each criterion of Appendix B to 10 CFR Part 50 The l
I structures, systems, and components comprising the safety items which are subject to this program have been identified in the PSAR. Based on our review of this infonnation we conclude that each criterion of Appendix B to 10 CFR Part 50 has been specifically included in written procedures within the hNP-3 and hN)-5 QA program.
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WPPSS has cohnitted to comply with the Regulatory Guides and i
j industrial standards that are contained [in the PRC docunents entitled l
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" Guidance on QA Requirments During Design and Procurement Phase of I
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& clear Pbwer Plants - Revision 1," May 24,1974 (WASil 1283, Revision 1) i l
and " Guidance on Quality Assurance Requiremen'ts During the Construction i
Phase of Nuc1 car Pbwer Plants," May 10,1974 (WASH 1309). Based on this commitment and hPPSS definition of their policies and pmcedures, we find they have described an acceptable QA program, hPPSS, by source evaluation and surveillance, will assure that: its principal contractors and subcontractors have adequate Q\\ programs, inspections will be performed to docttnented inspection instructions by qualified personnel, and results will be recorded, tTPSS will assure by surveillance and audits that personnel performing inspections are free from undue cost and schedule pressures of the project.
hPPSS Itas developed a comprehensive QA training program to insure that QA personnel are qualified to a level commensurate with their responsibility. The hTPSS QA training program is' administered
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by the QA Training Engineer and consists of initial indoctrination and i
training, on-the-job training, training courses and sessions, and continuing i
education. We find that h?PSS has described a satisfactory training
- program, i
hPPSS has established program requiroments for hTPSS and its contractors which assure there will be a docunented system of records attesting to quality.
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A' system of planned and docunented audits will be used by h?PSS to verify compliance with all aspects of the QA program and to assess its i
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effectiveness. Audit results are doctmented and reported to appropriate j
levels of tunagement for corrective action. Responses to audit findings are verified for implementation and effectiveness by follow-up audits.
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We find the hPPSS program for atdits to be satisfactory.
On an annual basis, hPPSS top level managment will arrange for an independent audit and evaluation of the adequacy of the scope, impicmentation, and effectiveness of the h?PSS QA pmgram. This will be accomplished by knowledgeable personnel outside the QA organization j
to obtain an objective program assessment. Results will be reported to the hTPSS Managing Director or his Ibputy.
Based on our revicw of the description of the QA program contained in Chapter 17 of the PSAR, we find: adequate and well defined procedures, a co:nitnent to the NRC QA guidance doctments, assurance of an independent inspection program, an adequately defined
'l training program, a doctmented system of records attesting to qtulity, an audit system to inform nanageant of the effectiveness of the QA program, and satisfactory management assessment of the status and adequacy of the QA program.
We conclude that.hPPSS QA program for hSP-3 and WNP-5 incitdes an acceptable QA organization with adequate policies, procedures, and instructions to implement a program that will satisfy the requirments of Appendix B to 10 CFR Part 50.
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7 tn 17.3 Ebasco Services, Inc. (Ebasco) g Ebasco is responsible for architect-engineering and construction l
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management of NNP-3 and WNP-5. Eis includes all plant structures, systems, and components except those pmvided by CE. He Ebasco organization responsible for design, procuranent and construction activities is shown in Figure 17.2-1.
he Materials Engineering and Quality mmpliance Department, which is responsible for the QA pmgram, reports to the Nuclear Vice President and is technically and administrative 1y independent of Engineering, Construction, Purchasing and Pmjects organiza-l tMns wimo work activities it verifics. We find that with this 4
corporate organization structure, QA has adequate independence and f
reports at a sufficiently high management level to accomplish its objectives.
P The Engineering and Construction Senior Vice President has delegated, through the Nuclear Vice President to the Director of Materials Engineering h
and Quality Gmpliance, the authority to enforce compliance with the QA pmgran requirements. His applies to all Ebasco personnel perfoming quality
- related activities.
I Re Director of Materials Engineering and Quality Compliance (See Figure l
17.2-1) is responsible for managing and directing the QA program for i
design, procurement and construction activities. He is assisted in this o
effort by the Materials Application Chief Engineer, the Materials Engineering laboratory Manager, the Vendor Quality Cogliance Chief Representative, I
l the Chief QA Engineer, and their staffs.
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l 3 Ebasco's QA program functions at two levels: QA and quality control (QC). QA is a program planning, surveillance and auditing function over engineering, constmction, purchasing, a
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vendor, and subcontractor QC operations. QC includes the inspection function at the constmction site which reports to the Project j
Superintendent, but works to inspection instructions approved by QA engineering. QC personnel report to the Project Superintendent at the same level as the Construction Superintendent and the Senior Resident Engineer whose work it verifies (See Figure 17.2-1).
f QA and tp personnel have the authority and freedon to identify quality problems; to initiate, recommend, 'or provide solutions; and to control further processing, delivery or l'nstallation of a nonconfonning item i
until proper disposition of the deficiency or unsatisfactory condition has been approved. We conclude that the Ebasco QA organization is structured such that it is independent of the organizations whose wrk it verifies and that personnel performing QA/QC functions have sufficient authority and organizational freedom to perform their critical functions effectively and without reservation.
l The QA program applies to all safety related structures, systems, and components within the Ebasco scope of work. Ebasco has committed I
to follow tlic QA guidance provided by NRC in WASil 1283, Revision 1 l
and WAS!! 1309.
The QA program for design includes review of applicable engineering instructions, procedures, specifications, and drawings by the QA organization to assure that ouality requirements are clearly, accurately, and adequately stated. 'Ihc program requires that design work be verified or reviewed by
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qualified individuals not responsible for originating the i
design and that a detemination be made that the engineering l
Instructions, procedures, specifications and drawings comply with regulatory requirements and design bases.
E For procurement control, QA measures provide for the review of procurement I
docunents to assure that the stated quality requirements are adequate
.for supplier qualification and for approval of the suppliers' QA program.
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,The program provides for inspection, surveillance,and audit of the suppliers' QA programs for safety related structures, systems, and components 1
to assure conpliance to procurement requirenents.
During construction, the program provides for onsite QA and QC involvement
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including inspection, nondestructive testing, retention of records, and 5
processing of deficiencies, nonconfomances,and design changes.
The QA program provides for a comprehensive system of detailed audits to be performed by the Ebasco Q\\ organization. H e audits encompass the review and evaluation of all quality related activities associated with the QA program and involve prucedures, work areas, hardware, activities, l
and records. The program requires that the audits be conducted in f
accordance with preestablished procedures by qualified personnel not J-having direct responsibilities in the areas being audited. He results are docunented and distributed to appropriate levels of management.
i In our review we have evaluated the Ebasco QA program for compliance with the Comntission's regulations and applicable Regulatory Guides and industry standards. Based on tl.is review,we conclude that the Ebasco QA program contains the necessary Q\\ provisions, requirements,and controls for compliance with Appendix B to 10 CFR Part 50, applicable guides 9
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and standards and is acceptable for the design, procurement and constmetion of WNP-3 and hNP-5.
17.4 Combustion Engineering Inc. (CE) 1he CE QA program has been evaluated as discussed in the Safety Evaluation -
Report for Cessar System 80 NSSS which is attached as an appendix to this report.
17.5 Implementation of Quality Assurance Pmgram The Office of Inspection and Enforcenent (IEE) has conducted inspections to examble the implementation of the h?:P-3 and hKP-5 QA program. Based on their inspections and assessment, IGE concludes tidt implementation of PSAR comitments in the hKP-3 and hKP-5 QA program is consistent with the status of the nuclear project.
17.6 Conclusion j
In our review, we have evaluated the QA program of hTPSS, Ebasco, and Combustion Engineering for hKP-3 and hNP-5 to detemine compliance with l
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the Nuclear Regulatory Comission's regulations, applicable Regulatory Guides and industry standards. Based on this review, we conclude that
.i WPPSS and its pr.incipal contractors have described an accept,able organization, and that the QA progran (1) complies with Appendix B to 10 CFR Part 50 and applicabic guides and standards and (2) is acceptable for the design, procurenent, and constmetion of hKP-3 and hKP-5.
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