ML17276B699

to Plant Verification Rept, Dtd Oct 1982

ML17276B699
Person / Time
Site:	Columbia
Issue date:	06/30/1982
From:	MATLOCK R G, SHEN P K, TIMMINS D C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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ML17276B697	List: ML17276B695 ML17276B698 ML17276B699
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))I NP-2 P LANT YERIFICATION io~o/a<t ECHNICAL SPECIALIST FF ICE OF THE NNP-2 ROGRAM DIRECTOR PREPARED BY~IMMI NS CONCURRENCE'

'IATLOCK ROGRAM DIRECTOR, NNP-2 APPROVALS' HEN DIRECTOR TECHNOL'OGY

'i s IBB DIRECTORS'ENERA'I'ION

" LASSCOCK IRECTORp LICENSING AND ASSURANCE ECHNI CAL FF ICE OF DIRECTOR.<'./Mi'P'".SPEC I A'liI'ST-'i" THE f'1ANAII'NG c'ASHINGTON PUBLIC POWER SUPPLY SYSTEM UCLEAR-,PROJECT NO, 2 (WNP-,2)OCTOBER'982 REyI S ION'3.Q go 2:Inch&

~~~~s MNP-2 PLANT VERIFICATION

',!'ONCURRENCE l PREPARED BV~'i Il%INS ECHNICAL SPECIALIST FFICE OF THE 4V-2 PROGRAM DIREGToR&/19+s i~OCK ROGRAN UI RECTORY IIP-2 APPRovALs:

~3).s s HEN Dr RECToR TEceeux Y s/c(z I I IRE~<i HANNON DrgcTOR SAFETY R SECURITY SSCOCK R QNLITY ASSURANCE DIREcTOR GENERATroN

~-'EKANP EcHNrcAL SPECIALim'..:.

FFICE OF THE Of%GING DrREcToR A t~~ttASHINGTQN PUBLIC P SUPPLY SYSTEM UcLEAR l'ROJEcT tIO, 2 P-2)UN'982

~i,<.0 I C 1 ,)\" l~Co--

WNP-2 PLANT VERIFICATION TABLE OF CONTENTS Secticn BACKGROUND ANO PURPOSE OVERVIEW OF PLANT VERIFICATION Pacae A.B.C.0.E.Requirements and Design Reverification Construction Veri f'ication Performance Verif'ication Operating Envelope Verif'ication Conclusions 3 5 7.8 9~INDEPENDENT ADMINISTRATION OF THE PROGRAMS 10 A.8.Requirements and Design Reverif'ication Quality Verif'ication Program IV.A.B.C.0.F.Engineering Record Review Requirements Reverification Design Reverification Processing of Findings Schedule Ccmponent inspections WNP-2 UNIQUE VERIFICATION ACTIVITIES 14 16 17 20 25 28 29 APPENDIX A-DEVELQPMB/T GF DESIGN A-1 A.B.C.0.E.F.G.H.I.J.Burns and Roe Organization Burns and Roe Procedures Design Requirements Design Documents Detail Design Design Change Control Design Documentation Prepared by Site Eng'ineering Prepurchase Vendor Interf'ace Construction Contractor Interf'ace Supply System Assessment of Design Verification A-3 A-5 A>>6 A-9 A-14 A-18 A-23 A-24 A-25 A-25 APPENDIX 8-INDEPENDENT TECHNICAL REVIEWS 8-1 A.8.C.0.E.Burns and Roe Off-Project Audits and Special Design Reviews General Electric-Reviews of Burns and Roe Design Supply System Review of'urns and Roe Design Review oi'ipe Hanger Criteria and Procedures Bechtel Engine ring Management Group 8-7 8-10 8-16 8-18 TABLE OF CONTENTS (CONTD)Section APPENDIX C>>WNP-2 QUALITY ASSURANCE~Pa e C-1 A.B.C.Organization Responsibilities Management Support C-2 C-4 C-ll APPENDIX D-RESTART PROGRAM D-1 A.B.C.D.E.F.G.H.I.Reduction'f Non-Contractor Backlog Specification Reconciliation Deficiency Review Procedur Review Training and P rsonnel Qualification Reviews Management Systems Review Corrective Action Evaluation Independent Review D-2 0-3 0-4 0-5 0<<6 D-7 0-8 0-9 0-10 APPENDIX E-NORMAL PLANT VERIFICATION ACTIVITIES E-1 A.B.C.Construction Verification Performance Verification Operating Envelope Verification E-2 E-8 E-13 I, BACKGROUND AND PURPOSE

\~V\'I'V\I V~-~'\VEV V"V 1 I,'I II\~

WNP-2 PLANT VERIFICATION BACKGROUND AND PURPOSE This report presents in a single document the bases for confidence that WNP-2 has been designed and constructed to meet applicable regulatory requirements and Safety Analysis Report commitm nts.The Plant Verifica-tion Program described herein is part of a broader WNP-2 Plant Completion Plan, as shown in Figure 1.Plant Verification was first conceived as a response to the Supply System Managing Director's request for a"...well documented basis for my acceptance of plant completion, safety and technical adequacy." (See Attachment 1.)This request, issued in January 1981, six months after he assumed the Directorship, came during a one year's construction suspen-sion r quired to correct prior quality problems of several construction contractors.

The report desc ibes programs which were conducted or begun during the suspension to identify and correct deficiencies and re-establish an ade-quate quality level for completed work.It also describes the changes in management practices which the Supply System adopted to correct'hese early construction problems, including the employment of a more exper-ienced construction management/systems completion contractor to assist in maintaining a high level of quality following construction restart in June 1981.In addition to re-establishing the construction quality baseline for past work and describing methods for assuring that it will be continued to completion, the report also describes the bases for confidence in the design as developed by the architect-engineer and the nuclear steam sup-ply system contractor.

When both are complete, these design and con-struction verification activities would, under normal circumstances, be sufficient to demonstrate the technical adequacy of WNP-2.However, in response to the Managing Director's request for an acceptance revi w and noting the design quality problems encountered at Diablo Canyon and elsewhere, the Supply System has decided to take several addi-tional steps which go beyond normal practice, and which address NRC's concerns for strengthening quality assurance for nuclear plants under construction.

These include a reverification that the design require-'ents for all safety systems are complete and clearly doc@vented and, by independent design reviews of three selected systems confirm that these requirements were correctly reflected in the detailed design documents used in construction.

Any deficiencies noted in these reviews will be submitted to an independent Findings Review Committee for evaluation and disposition.

The Plant Verification Program and the implementation of several of its critical elements will be subjected to independent techni-cal audit by an outside firm.October 1982, Rev.1' Plant Verification is an ongoing process in the design, construction, and testing of a plant.While this report summarizes the entire process, it focuses on verification activities beyond normal industry practice, namely the Requirements and Design Reverification reviews.These reviews, in combination with the in-proc ss design controls and the con-struction-quality assurance activities, will provide confidence that WNP-2 was designed and constructed in accordance with Supply System commitments.

E'I F-la-October 1982, Rev.1 FIGURE 1 MNP-2 PLANT COMPLETION PLAN SCOPE MNP-2 PLANT COMPLETiON PLAN CONSTRUCTION COMPLETION PLANT.V ER I F I CAT ION ORGANIZATIONAL READINESS OPERATIONAL.

READINESS 0'E T P~~*r,~I,~,

)Dater Fromr Subject Reference' N T E 8 0 F F I C E hi E M 0 R'A N 0 U M WASHINGTON.

PUBLIC POWER SUPPLY SYSTEM ATTA'CHMENT 1 January 22, 1981 G 0 8~o chey, Director', Nuclear Safety (8396)~~~~Ferguson, itanaging Oiractor (387)ACCEPTANCE REVIEW PLANS FOR SUPPLY SYSTEM NUCLEAR FACILITIES Dhtributtonr Q EDC WNP-I/4 Q EDC WNP.2 Q EDC WNP<ls Q Admln File A'Squire (387)OM Mazur (821)RG Matlock (901A)OE Oobson (1000).PK Shen (388)HE Witherspoon (135 LL Grumme (390)lb/RLF Ib/GOB 3 Confirming our~ecent discussions on this matter, I would like to request that you develop detailed"acceptance review" plans for each of our Projects which wi11 assure a thorough, syste-matic review by Supply System personnel of our nuclear plants prior'o turnover from our contractors for commercial operation and which will.constitute a.well-documented basis for my accep-tance of plant completion, safety and technical adequacy.As we discussed, t%Supply System reviews will involve all of our technical organizations.

The plan should cover design docu-mentation and safety reviews, engineering cer tifications, construc-tion completion/turnover process, startup testing and operational readiness assessments culminating in fully operational plants ready for commercial power production.

In developing these plans for plant acceptance.

first priority should be given to MNP-Z.For MNP-Z, special~onsideration should be given to assuring that any undetected quality defects that sig-nificantly affect'plant performance or safety would be identified and corrected in the course of our functional testing and acceptance r eviews.md 3 WP 142 RX EI i 5 b II, OVERVIEW OF P LANT VE R I F I CAT I ON

!fl 0 II.OVERVIEW OF PLNT VERIFICATION Plant Verification is accomplished through proper implementation of de-sign, construction, and testing practices; an appropriate level of check-ing and auditing against suitable standards; and a thorough evaluation and disposition of defects found.A number of the verification activi-ties are standard practice in the course of designing and constructing a nuclear power plant.These baseline activities, which form the founda-tion for Plant Verification, are summarized in this section and presented in more detail in the appendices.

In addition, Plant Verification, for WNP-2 includes several major activities related to assurance of quality in construction plus design requirements and design reverification re-views which go beyond normal industry practice.The basic elements of Plant Verification for WNP-2 as shown in Figure 2 are: o Requirements and Design Reverification

-The WNP-2 design process, including the independent design reviews and technical audits that have been performed meet the requirements of 10CFR50 Appendix 8 and ANSI 45.2.The Requirements Reverification and Design Reverifica-tion reviews together with the independent processing of findings from these reviews go beyond normal industry practice.The purpose of these additional reviews is to: 1)provide increased confidence that the WNP-2 design is correct and complies with regulatory re-quirements, 2)provide a documented review of design near completion for the plant acceptance review directed by the Managing Director, and 3)address the recent industry concerns about quality controls in the design process, e.g., Diablo Canyon.o Construction Verification

-In addition to the Quality Assurance orogram for ongoing work, confidence in the adequacy of WNP-2 con-struction is provided by: 1)The Restart program which was an ex-tensive review and quality program upgrading activity initiated in July 1980 to correct previous problems and preclude their recur-rence, 2)the ongoing Quality Verification Program which is designed to establish the adequacy of construction completed before July 1980, and 3)the component inspection and tests performed as part of the system turnover process.The Restart and Quality Verification Programs, while unique to WNP 2, are not perceived as something be-yond normal industry practice in that they establish an acceptable quality baseline from which ongoing construction with adequate quality controls can depart.Component inspection and testing are also part of the normal turnover process;however, the scope of these activities at WNP-2 are more extensive than usual.o Performance Verification

-The testing program to ensure that com-ponents and systems perform in accordance with design requirements is based on industry experience and hRC requirements.

October 1982, Rev.1 o.Operating Envelope Verification

-The NNP-2 process for assuring that the Technical Specifications and plant operating, maintenance, and emergency procedures are consistent with the design, industry experience, and regulatory requirements follows standard industry practices.

Each of the four elements of Plant Verification is discussed briefly in this section and more fully in other parts of the report as not d.-2a-October 1982, Rev.1 A.Requirements and Design Reverification In October 1981, the Supply System began an engineering transition activity to accept from Burns and Roe the engineering responsibility for design changes made to the plant after completion.

As part of this transition, and in response to recent design quality problems experienced elsewhere in the industry, the Supply System decided to perform a completeness check of the WNP-2 engineering records, which.includes a review of the design requirements for all safety systems, and an in-depth design review" (reverification) of three systems.The methodology and scope of these reviews are described in Sec-tion IV.The objectivity and integrity of the reverification reviews of the three systems are assured through: o Organizational structure and overview from the Office of the Managing Director to assure independence from the WNP"2 Project and appropriate resolution of findings, o Use of engineers that were not involved in the original design, o Use of procedures and checklists and training of the engineers that will perform the reviews, o An independent findings r'eview process to validate and assess the significance of findings, and o Review of the plans and audit of the process by highly quali-fied, independent technical consultants.

The steps to ensure the objectivity of the Requirements and Design Reverification reviews are discussed in more detail in Section III.As discussed in the opening paragraphs of this Section, the Require-ments and Design Reverification reviews will provide"increased" confidence in the design adequacy of WNP-2.These reviews do not include a re audit of the WNP-2 design control proc ss and its im-plementing procedures.

It has been concluded based on previous re-views and audits that the in-process design controls have been ade-quat and comply with the applicable project commitments (10CFR50, Appendix 8, ANSI N45.2 and Safety Analysis Reports).This conclu-sion is supported by: o WNP-2 uses a standard, General Electric BWR-5 Nuclear Steam Supply System (NSSS).The Balance of Plant (BOP)design and the control and integration of the overall plant design was performed by an experienced Architect Engineer (Burns and Roe).General Electric performed reviews of the BOP design to assure that it was consistent with the NSSS interface require-ments.Throughout the development of the WNP-2 design, the Supply System has participated in the design process through specification of Owner requirements, design reviews, and audits.October 1982, Rev.1 L~4I~0 As discussed in Appendix A, design verification activities were performed as a matter of routine practice.The standardized, General Electric BWR Quality Assurance Program provides for extensive documentation of their design control proc ss and de-sign verification.

Past and recent reviews and audits of the Burns and Roe design process have confirmed that adequate de-sign controls have be n used.Similarly, the overall design review process of site construction contractors and prepurchase equipment suppliers (including the Burns and Roe review of the contractor

's design submittals) was evaluated by the Supply System and fcund to be adequate.The process, controls, and normal review and verification ac-tivities associated with the development of the WNP-2 design are summarized in Appendix A.I o In addition to the"normal" design process used by Buxns and Roe, many independent technical reviews of'he plant design have been conducted which contribute to the level of confidence in the design adequacy.Areas of independent technical design r views include Burns and Roe off-project design reviews, Gen-eral Electric NSSS/BOP reviews, Supply System reviews of sys-tems, EDS Nuclear Inc.review of pipe hanger criteria and methods, and Bechtel r views of more than 320 specific des'gn issues.The scope and depth of these reviews are summarized in Appendix B.

B.Construction Verif ication Verification of the construction quality is provided by the in-place Quality Verification Program for construction completed before July 1980 and by the overall WNP-2 Quality Assurance Program for ongoing construction (after July 1980).From the fall of 1978 through the spring of 1980, a number of pro-blems were identified by both the Supply System and the NRC which indicated that the quality assurance (QA)programs of several of the major construction contractors

-at WNP-2 were not effective in achieving the required quality levels in their work and the work of some of their subcontractors.

In addition, tho increasing backlog of unresolved or recurrent construction quality problems during this period indicated that the actions taken by WNP-2 Project Management were not successful in achieving timely, ef f ective resolution of quality problems.Therefore, in July 1980, the Supply System issued Stop Work Order No.9 which stopped all Quality Class I and Seismic Category I construction work at WNP-2.In addition, the NRC (under 10CFR50.54(f))

requested information on the steps to be taken by the Supply System to strengthen management control of the project and to provide reasonable assurance that the contractor's QA programs would be effective.

The stop work at WNP-2 was in effect for approximately one year.,-.During the recovery proc ss, known as the Restart Program, a number of actions were taken to improve the WNP-2 QA Program.They include:: o Strengthening project management by, consolidating the responsi-bility for design and construction under the WNP-2 Program.Director, o Hiring a more experienced, nuclear Construction Management

'.=organization (Bechtel Power Corporation), o Improving the overall level of Quality Assurance and Quality Control (QC)by revising work procedures and quality programs to assure compliance with licensing requirements, specifica-tions, codes and standards, and to preclude recurrence of the previous problems, o Reducing the backlog of unresolved construction quality problems, o Improving the timeliness and control of engineering direction to the field, and o Assuring that the impacts of quality problems on hardwar in-stalled before the work stoppage will be identified and corrected.

Most of these activities have been accomplished.

The remaining ef-fort is completion, of the Quality Verification Program, which ad-dresses those activities necessary to assure that the hardware in-stalled prior to the stop work is adequate.The Quality Verification Program (QVP)covers components, systems, and structures that are Quality Class I and/or Seismic Category I.It requires a sample review of documentation for completeness, ac-curacy and disposition, and sample reinspection of installed hard-ware.The Quality Verification Program is the result of corrective action initiated by the WNP-2 Restart Program (summarized in Appen-dix 0).The reviews and reinspections conducted under.the QVP are based on the construction specification requirements that were re-viewed for compliance with the FSAR during the Restart Program.In addition, a list of generic problem areas identified during the Re-start Program were used as input to the QVP sampling process.The Quality Verification Program is structured to provide flexi-bility for adjustments in the program's scope based on the results of the ongoing reviews and reinspections.

The minimum sample size for reinspection is ten percent of the hardware that was installed, inspected, and accepted prior to Duly 1980.The Quality Verifica-tion Program, which is discussed in more detail in Appendix E, will establish an adequate level of confidence in construction completed prior to Duly 1980.In addition, the progress and results of this program are reported bi-monthly to the NRC and are monitored by the Inspection and Enforcement Branch, Region V.Verification of ongoing construction

's provided by the overall WNP-2 Quality Assurance Program, which is summarized in Appendix C.Bechtel Power Corporation, as Construction Manager and Systems-Completion Contractor, is implementing a standardized QA Program.This program, through the Bechtel Quality Assurance and Quality Con-trol organizations provides the necessary controls, surveillanc, and auditing activities to insure that the quality of in-process construction is adequate.In addition, as discussed in Appendix C, the Supply System has suf ficient overview and controls on the Bechtel Quality Assurance Program to establish confidenc for the Supply System in the quality of ongoing construction.

An additional activity deserving mention is the augmented system turnover inspection and testing being performed by the Supply System Test and Startup organization.

This inspection addresses proper equipment maintenance and to date has included over 39,000 compon-ents (refer to Subsection IV.F).While the primary objective is to correct problems which occurred prior to 1980, this activity provides extra assurance of correct construction through review of equipment maintenance records and inspection of installed equipment.

October 1982, Rev.1 Appendices D and E summarize the nature, scope, and principal re-sults of the completed activities (Restart Program), and the key features of the ongoing programs to'complete the verification of construction quality at WP-2.Many of the activities described were completed or initiated as part of the Restart Program..There-fore, the majority of the detailed results are contained in the Re-start Program record.-Sa-October 1982, Rev.1 C.Performance Verification In-plant tests verify that the components, systems, and structures are functionally integr'ated and perform in accordance with the de-sign and plant performance requirements.

Plant features that are not testable under certain postulated accident scenarios and natural phenomena (e.g., tornados, earthquakes, etc.)are verified or con-trolled through equipment qualification testing, engineering anal-ysis, and consideration for such items as materials selection, interlocks, administrative procedures, redundancy, and diversity.

The in-plant tests are conducted under both normal operating condi-tions and over a wide range of abnormal/transient events.The tests include: o Component and system lineup tests, o Individual and integrated system preoperational tests, o Individual and integrated system power ascension tests, o Testing and operation with approved procedures, and o Testing and operation with trained and qualified Supply System personnel.

The scope of the testing program and the process used to ensure that tests are developed and implemented in a controlled manner are dis-cussed in Appendix E and are documented in detail in other approved documents and procedures, e.g., the Coroorate level Test and Startup Program Manual.

0 t 0.Operating Envelope Verification Operating Envelope Verification is the process of assuring that the Technical Specifications and plant operating, maint nance, and emer-gency procedures are consistent with the design, the as-constructed plant, industry experience, and the applicable regulatory require-ments and Safety Analysis Reports.For WNP-2, this process follows standard utility practices and is summarized in Appendix E.The Technical Specifications are prepared and reviewed by the WNP-2 Operating Plant Staff.The Technical Specifications are also re-viewed by General Electric and Burns and Roe to assure consistency with the design.An additional independent technical review will be conducted by the Supply System engineering group responsible for implementation of the Requirements and Oesign Reverification, re-views.The final approval and issuance of the Technical Specifica-tions rests with the Nuclear Regulatory Commission.

The procedures for plant operation, maintenance, and emergency re-sponse are generally prepared by the WNP>>2 Operating Plant Staff, making maximum use of existing documentation from other similar op<<crating plants.The review process is typical of that used within the industry.After preparation and review by the operations staff, procedures receive a multidisciplined technical and safety review by a Plant Operations Committee which include Operational gA and an on-site Safety Engineo ing Group.In addition, a Corporate Nuclear Safety Rev-'ew Board overviews this proc ss.

E.Conclusions The activiti s discussed in this report when complete will verify that WNP-2 has been designed and constructed in compliance with our commitments.

The normal controls for the design of WNP-2, combined with the Re-quirements and Design Reverification reviews to be performed by the Supply System (and any followup corrective action)will provide a high level of confidence in th completed d sign.The Quality Verification Program will ensure that construction ccm-pleted prior to July 1980 is acceptable or reworked as necessary.

The WNP-2 Quality Assurance Program will ensure that effective qual-ity controls are imposed, on in-process construction.

These quality-related activities will verify the adequacy of construction.

En-plant testing will serve as a final step in verification of the design and construction of WNP-2.The satisfactory completion of the testing programs, in conjunction with other Supply System ac-tivities r lated to operational and organizational readiness, will'ring WNP-2 into the commercial operation phase.

FIGURE 2 ELB1ENTS OF PLANT VERIFICATION PLANT VERIFICATION REQUIREMENTS ANO OESIGN REVERIFICATION CONSTRUCTION VERIFICATION PERFORMANCE VERIFICATION OPERATING ENVELOPE VER IF ICATION 0 Co III, INDEPENDENT ADNINISTRATION OF THE PROGRAf'1 III.INDEPENDENT ADMINISTRATION OF THE PROGRAMS As noted in the preceding Section II, verification is achieved through proper implementation of design and construction, combined with tests, reviews, audits, and inspections conducted by qualified individuals other than those who performed the original work.The Supply System has conducted such reviews as part of its basic design and construction pro-grams in accordanc with 10CFR50, Appendix 8, and ANSI N45.2.The Sup-ply System conducted additional technical and quality reviews to correct construction problems which arose prior to Duly 1980.These basic ver-ification programs, wi>>, wnen complete, provide an acceptable level of confidence in the d=sign and construction of WP-2.These programs are described in Appendices A through E.Going beyond this, the Supply System has taken particular care to assure the independenc and objectivity of the Requirements and Design Reveri-fication reviews which are over and above normal industry practice.This Section describes the steps taken to insure the credibility of the Requirements and Design Reverification reviews and the evaluation and disposition of findings from these reviews.-10-October 1982, Rev.1

Requirem nts and Design Reverification The Requirements and Design Reverification r views as described in Section XV, consist of a completeness check of the NNP-2 engineering record, a review of the design requirements for all safety systems, and an in-depth technical-review of three selected systems.The Requirements and Design Reverification r views will be performed by the Supply System using personnel who were not involved in perform-ing the original design.The technical personnel performing the reviews will be chosen primarily from the Systems Design Engineering group, although special expertise from other Supply System organiza-tions and/or outside engineering groups and consultants may be used.Burns and Roe personnel are involved in the collection of the engineering records to be reviewed and the initial completeness check for some systems.However, they are not involved in either the Requirements or Design Reverification reviews.The Systems Design Engineering group has about 25 engineers with an average experience of approximately 12 years.About one third of the group have advanced degrees.The individuals assigned to tho reviews include a mix of disciplines covering electrical, mechani-cal, nuclear, structural and instrumentation and control.-The organizational responsibilities and interfaces associated with per-forming the reviews and processing the findings are briefly described below.Details of the findings reviews process, including independence, are discussed in Subsection XV.O.Figure 3 shows the Supply System organizations responsible for the design, construction, and testing of WNP-2 and the Systems Design Engineering group, that is responsible for performing the Require-ments and Design Reverification reviews.The Systems Design Engine-ering group is independent of the NNP-2 Project and reports to the Director of Technology.

Their review activities also receive ap-proval and overview from the Office of the Managing director.Figure.4 includes the principal interfaces associated with conduct-'ing the Requirements and Design Reverification reviews and process-ing th findings.A flowchart of the process for the review, evaluation, and disposi-tion of potential findings from these zeviews is shown in Figure 5.The selection of the specific design features, calculations, etc., to be reviewed will be based on a number of inputs including the results from the Requirements Reverification review, the QA Program (previous design/engineering problems identified in the QA record),-11-October 1982, Rev.1 and the Burns and Roe and contractor records.Systems Design En-gineering is responsible for preparing the review procedures, selec-ting the specific features to be reviewed, performing the reviews, and participating in processing the findings as indicated in Figures 4 and 5.The Technical Specialist, Office of the WNP-2 Program Director, is responsible for coordinating the verification activities between the WNP-2 Project, WNP-2 Operations, and WNP-2 Test and Startup.-lla-October 19B2, Rev.1 The Technical Specialist, Office of the Managing Oirector, is re-sponsible for approving the overall scope of the reviews and the findings review process.This includes the composition of the find-ings'review committee, conducting special reviews as indicated in Figure 5, and providing management overview of the program.'n-cluded are independent reviews of the program scope and of implemen-tation by organizations both internal and ext mal to the Supply System.Some of the reviews will be p rformed by an independent technical auditor.In addition, a senior management review group has be n established to assist in development of the scope of an audit program and to monitor the followup corrective action.Refer to Attachment

l.

B.Quality Verification Program The Quality Verification Program (QVP), described in more detail in Appendix E, is the final phase of th WNP-2 response to the Duly 1980 stop work.This program is in-place and is monitored frequently by the NRC as mentioned in Section II.The organization and structure of the QVP are described in Quality Verification Instruction No.1 (Volune III of the RCSW Manual).The program is managed by Supply System personnel reporting to the WNP-2 Manager of Construction.

Hardware reinspections are performed by Bechtel (primarily on the previous mechanical contractor's work)or site contractor quality control inspectors in accordance with project approved reinspection programs.The minimum sample size for reinspection is ten percent (lOX)of the hardware completed, inspected, and accepted prior to Duly 1980.Under the program credit may be taken for reinspections performed for other reasons (e.g., NRC IE Bulletins);

however, this requires a formal assessment by the Supply System and concurrence by Project Quality Assuranc that the other: inspection meets the re-quirements of the QVP.

PLANT VERIFICATION ABRIDGED ORGANIZATION HANAG ING DIRECTOR DEPUTY HAHAGING DIRECTOR TEQttt ICAL SPECIALIST DIRECTOR LICENSIHG a ASSURANCE DIRECTOR OPERATIONS DIRECTOR MNP-2 PROGRAH DIRECTOR PQIER GENERATION DIRECTOR TEQINOLOGY T EQI tl ICAL SPECIALIST MNP-2 QUALITY ASSURAtl CE HAIIAGER MNP-2 ENGINEER ItlG HAtIAGER I r I MNP-2 CONSTRUCTION HANAGER MNP-2 PLANT HANAGER MNP-2 TEST a START UP HAtl AGER SYSTEHS ENGINEERING C)0 O Cl tD MIIP-2 I, ICENSIIIG HAH AGER GQIERAL EI.ECTRIC NSSS BURNS a ROE AE BEQITEL ENGINEERIIIG HAtiAGEHEHT GROUP SEQITEL SYS.COHP.d CONST.HhttAGEHENT SYSTEHS DESIGN EttGINEERIIIG GROUP{Xi FQ LlttE HAT RI X Figure 3

PLANT VERIFICATION ABRIDGED ORGANIZATION MANAGING DIRECTOR DIRECTOR LICENSIHG a ASSURANCE DEPUTY MANAGING DIRECTOR DIRECTOR OPERATIONS HGN'RE V I EM GROUP TEQINICAL SPECIALIST IIANAGENEHT OVERVIEM OUTSIDE TEQI.AIID IT OR DIRECTOR MNP-2 PROGRAtl DIRECTOR PQIER GEHE RAT ION DIRECTOR TECHNOLOGY T EQt HI CAL SPECIALIST COORDINATION OF MNP-2 PRDGRN RESPOHSE TO REVIEM FIIIDIKGS F INDINGS REVIFtl PRUCI S MNP-2 DUALITY ASSURANCE MANAGER ENGINEERING DESIGN PRQILEN AREAS MHP-2 I ICENS It(4 HAtt AGER'SAR I C)I o 0 EO g LltlE MATRIX tD It HP-2 EHGINEERING NAtt AGER GENERAL ELECTRIC NSSS BURNS a ROE BEQITEL ENGINEERING IIAtt AGENEtt T GROUP~NSSS I IHFO~AE EHGR~ENGR DES I GH I RECORD I PROBLEH AREAS INFORHA'I ION Fl N IIAHAGENNY 07ERVIBI INPUT TO THE REOUIREHEHIS AND DESIGN REVERIFICATION REVIEMS MNP-2 COttSTRUCT ION HAHAGER lt HP-2 PLAttT ttAH AGER 8EQITEL SYS.CONP.a COttST.HANAGEHEIIT COtt TRACTOR ENGR.RECOllD I I P%ER ASCENSION TEST PROGRAtl MNP-2 TEsT a STARTUP HANAGER I I PREOPERATIONAL TEST PROGRAtt SYST06 EHGINEERIHG SYSTEHS DESIGN ENGINEERING GROUP IDENT IF I CAT ION OF FINDIHGS a REVIIM OF RESPONSE'I I I I Figure 4 0 4 RES PONSI8LE SYS.ENGR.LEAD ENGR.AND MGR.SYSTEMS DESIGN ENGINEERING FINDINGS REVIEW COMMITTEE WNP-2 PROJECT TECH.SPEC.OFFICE OF THE MANAGING DIR.PREPARE PFR i REVIEM AGRE E RE lE ADll T IUtlAL IHFORIIAT OH I tlAUE tlUAT f PROJECT EINI NEER ING RESPOHSIBLE NGINEfRING ORG,'gU~El A~OQIOllAL SAFETY~C IttFORHATIOtt/

RECONSIOERATIQl ISSUE EVALUATE DEF IC IOICY DEFINITION CONDO C'T SPf CIAL REVIN REVISE/PROV IDE AOD'L IHFO.REVIN RE VIEM REVIEM 0 AGREE ASSESS VAL I 0 I TY VAL ID'Z C7 I P C7 PROJECT ENGltlffRING TECH.SPEC.~MIIP-2 PROG.DIR.OFFICE PROGRAH HOttlTORlttG DISAGREE AGREE (UIILESS PROCESSED TD C)OOCUIIEIIT ASSESS SICtlll ICAIICE PERFORII CLASSIFICATION DHC PROJECT gh REPORTABLE COND I I'IOUS REV IN REVIN PROPOSEll COttRECFIVE ACFIOtt PLAN CAP REV IN PROJECT EHGINENING RESPONSIBLE EHGIHEERIHG ORG.PREPARE CAP i PFR-POTENT IAI FINnltlG REPORT FIGURE 5

0 I C=O

~f ATTACHMENT 2 l NTEROFFICE MEMORANOUM WASHINGTON PUBLIC POSER SUPPLY SYSTEM Date: May 24, 1982 To: A~ms es R.L.F guson, Managing Director, 387 s ii~WNP-2 PLANT COMPLETION PLAN Memo dtd 1-22-81, R.L.Ferguson to G.D.Bouchey,"Acceptance Review Plans for.Supply System Nuclear Facilities." Distdbutioiii 0 EDC m-X(4 C3 EDC Wte-2 Cl EDC mPC(5 0 Admin File RL Ferguson, 387 JR Honekamp:ar, 387 DW Mazur, 385 JW Shannon, 370 A Squire, 386 Addressees:

WC Bibb, 685 GD Bouchey, 370 RB Glasscock, 280 RG Matlock, 901A PK Shen, 580~)In my memorandum of January 22, 1981,, I requested that acceptance review plans be developed for each of our nuclear projects with first priority given to WNP-2.The stated purpose of these plans was to provide a well documented basis for my acceptance of.the facility and the readiness o.the organization to operate the facility in compliance with our commitments.

In addition for WNP-2, special consideration should be given to assuring that quality defects that could signi-ficantly affect plant performance or safety will be detected and corrected in the course of our reviews and functional testing.As you know, we now have a WNP-2 Plant Completion Plan and are in the process of finalizing the WNP-2 Plant Veri fication Repor t to document the basis for our confirmation thai the plant was designed and constructed in accordance with our commitments.

To assure me that this process as it evol.ves will meet the objec-tives of my January 22, 1981, memorandum, I have asked John Honekamp to develop and implement a program of independent technical reviews and audits of the WNP-2 Plant Completion Plan and the associated Plant Verification Report.These r views and audits should utilize organizations both internal and external to the company in a concept parallel to a financial audi t where the bulk of the audits are conducted by independent internaI organizations and an outside firm is utilized to review and validate, the internal audit process and periodically check the implementation of selected aspects.The first phase of this program utilizing Technical Audit Associates to review the draft Plant Verification Report is in progress.The next phase will require a continuing participation of senior management from several departments to achieve a well balanced, coordinated program with effective feedback for correc-tive action where required.I am, therefore, requesting that you provide this participation thr ough a senior management review group chaired by John to periodically:

Review the scope, structure, and balance of the audit program and recommend changes as required to assure that it achieves its objectives.

WP~1et R2 Addressees Page 2 May 24, 1982 Assess the validity and significance of the findings generated by the audit program and provide feedback to improve the program as appropriate.

Receive the feedback from the outside independent auditor and assist in development of corrective action where appropriate.

Review the progress of the audit program and recommend changes in priority or allocation of resources as required.Review the results of the audit program and.the effectiveness of follow-up action.In addition to periodic meetings with me, the managemen.

review group should provide to me written reports of its findings and recommendations.

At this point,'a group composed of Peter Shen, Bill Bibb, Don Bouchey, Bob Glasscock, and Bob Natlock and meeting on a monthly basis would appear adequate.However, the responsibility for establishing the structure and functioning of this group have been delegated to the Chairman.John will be in touch with you to establish the final composition and schedule for the management review group.

IY, H N P-2 U f'J I Q U E VE R I F I CAT I ON ACT I V I T I ES l'f L WNP-2 UNIQJE VERIFICATION ACTIVITIES Assurance that the WNP-2 design and construction are correct must come primarily from the basic design, construction, testing, and quality as-surance programs, which are derived largely from industry standards and hRC requirements.

Over and above such considerations, the Supply System has initiated the Requirements and Design Reverification reviews to pro-vide increased confidence that the WNP-2 design is correct.These re-views aze considered unique and beyond normal design practice.1'n addi-tion, an augnented system turnover inspection program is being performed to ensure equipment is adequately maintained.

The Supply System is reviewing the design requirements of all safety sys-tems and is performing an in-depth independent design review of three selected saf ty syst ms.These reviews are referred to as Requirements and Design Reverification, respectively.

The term reverification is used, rather than verification, because the design has been and continues to be verified by the normal design process (refer to Appendices A and B).The Supply System's reviews constitute an additional level of design verification.

In addition to the Design Reverification reviews of the three selected systems, two other significant reviews are being performed which will provide input to Design Reverification and add confidence in the adequacy of the WNP--2 design.They are: 1)the collection and review of the WNP-2 engineering record on a system basis by Supply System and Burns and Roe engineering personnel, and 2)a review of the design of ASIDE Code piping and supports by Bechtel and Supply System engineers (described in Appendix B).These reviews are separate from the Design Reverification reviews in that their schedule is tied to the system turnov.r process, and the resoluticn of problems and deficiencies from these reviews are handled by normal WNP-2 procedures.

Both of these reviews were started before the Design Reverification reviews and will continu after they are completed.

However, for the three systems selected for Design Reverifi-cation, the two other reviews will provide input to the Design Reverifi-cation reviews a" follows.The engineering record is being collected and reviewed to prepare for the transition of engineering responsibility for future design configuration control from Burns and Roe te the Supply System.This review is pro-cedurally controlled and is performed to ensure the completeness of the engine ring record for all plant systems.During the coll ction of the engineering record, the design requi.ements for all safety systems are reviewed to assure that they az..complete and clearly document d as the basis for future d sign changes.Sine the same Supply System group will also be performing the Design R verification reviews on the three selected syst ms, the collection and review of the engineering record will serve as the starting point for the Design Reverification reviews.-14-October 1982, Rev.1 The review of ASME Code piping and supports by Bechtel and Supply System engineers is clearly an in-depth design review as evidenced by the check-lists included in Appendix B (Attachment 18).These reviews are indepen-dent in that neither the Bechtel nor the Supply System engineers conduct-ing the reviews were responsible for specifying or performing the subject design and analysis work.Therefore.

this review will be taken credit for in the piping and support portion of the Design Reverification re-views.For the three selected systems, the findings from the piping and support reviews will be processed through the special findings review specific to Requirements and Design Reverification (Subsection IV.O).The scope, rationale for selecting the three safety systems, review cri-teria, and steps in the Requirements and Design Reverification reviews are discussed in Subsections IV.B and C.Subsection IV.E presents the schedule for performance of these and related activities.

The augmented turnover inspection and testing program, which is also con-sidered to be beyond normal industry practice is being performed by the Supply System's Test and Startup organization at the time of system Pro-visional Acceptance.

The additional inspections and tests are being per-formed due to the long construction duration for WNP-2, i.e., concern for idle components and systems and some contractors'ast maintenance activ-ities.To date, over 59,000 components have been tested or disassembled, inspected, and refurbished.

Additional information on this program is discussed in Subsection IY.F.-15-October 1982, Rev.1 A.Engineering Record Review Engineering records will be collected and reviewed on a system-by-system basis.The schedule basically follows construction comple-tion by means of the system Provisional Acceptance and'Turnover dates (refer to Attachment 2 of Appendix E).The task of assembling an engineering record will begin near the Provisional Acceptance date for each system and will be completed before the Turnover date for preoperational testing.Each system will have a package that wi'l contain, but not be limited to, the following:

o A description of the system including the definition of its boundaries (based on a functional capability), o System design criteria, o A list of current, applicable Burns and Roe/General Electric and vendor drawings, o A list of current, applicable Burns and Roe and vendor calculations, o A list of current, applicable Burns and Roe Technical Memoran-duns (documented technical positions on specific engineering issues), o A current Master Equipment List (applicable portion only), and o A list of open engineering items/concerns.

B.Requirements Reverification l.Objective and Scope The Requirements Reverification reviews consist of collecting the engineering record and reviewing the design requirements of all safety systems to assure that they are current, complete, and clearly documented.

These design requirements will be the basis for future design configuration control.The systems or portions of systems subject to Requirements Reverification are listed in Table 1.This list includes: o All front line active systems required to function during anticipated, abnormal, and design-basis transients to maintain the plant response within the limits described in the FSAR.o Support systems essential to the operation of these front line systems.o Other active systems included because of their operational importance or because they are r'equired in response to beyond design-basis events.Several systems which are not requir d to function or support the front line systems during transients do cross the contain-ment boundary and hence are isolat d during some transients.

Sine the only required active function in these cases is iso-lation, these systems were not included on the basis that the design requirements associated with-isolation will be addressed many times during the Requirements Reverification for the sys-tems listed in Table l.2.Review Criteria The design requirements for the systems listed in Table 1 will be reviewed for completeness against the design considerations listed below.This list is based on ANSI N45.2.11-1974 (Qual-ity Assurance Requirements for the Design of Nuclear Power Plants)and is abridged in a manner which considers the stage of construction, the systems being reviewed, and focuses on key design parameters.

The design requirements review will consider: o Basic functions of the system and and the major components ,and structures of the system, o Performance requirements such as capacity, rating, and system outout, October 1982, Rev.1 o Codes, standards, and regulatory requirements including the applicable issue and/or addenda, o Design conditions such as press uze, temperature, fluid chemistry, and voltage, o Loads such as seismic, wind, thezmal, and dynamic, o Environmental conditions anticipated during operation such as pressure, temperature, humidity, corrosiveness, site elevation, wind direction, nuclear radiation, electromag-netic radiation, and duration of exposure, o Interface requirements including definition of the func-tional and physical interfaces involving structures, sys-tems, and components, o Material requirements including such items as compatibil-ity, electrical insulation properties, protective coating, and corrosion resistance, o Mechanical requirements such as vibration, stress, shock, and reaction forces, o Structural requirements covering such items as equipment foundations and pipe supports, Hydraulic requirements such as pump net positive suction head, allowable pressure drops, and allowable fluid velocities, C Chemistry requirements such as provisions for sampling.and limitations on water chemistry, o Electrical requirements such as source of power, voltage, raceway requirements, electrical insulation, and motor requirements, o Layout and arrangement requirements, o Operational requirements under various conditions such as plant startup, normal plant operation, plant shutdown, plant emergency operation, special or infrequent opera-tion, and system abnormal or emergency operation, o instrumentation and control requirements including indica-ting instruments, controls and alarms required for opera-tion, testing, and maintenance.

Other requirements such as the type of instrument, installed spares, range of measurement, and location of indication should also be included,-18-October 1982, Rev.1 o Redundancy, diversity, and separation requirements structures, systems, and components, o Failure effects requirements of structures, systems, components, including a definition of those events accidents that they must be designed to withstand, and and o Test requirements including in-plant tests and the conti-tions under which they will be performed, o Fire protection or resistance requirements, o Materials, processes, parts, and equipment suitable for application, and o Saf ety requirements for preventing personnel injury in-cluding such items as radiation hazards, restricting the use of dangerous materials, escape provisions, from enclo-sures and grounding of electrical systems.3.Requirements Reverification Process The proc ss for Requirements Reverification will include the following steps: o Prepare and approve implementing procedures and tions, and conduct training on implementation of quirements Reverification process, o Assign a cognizant system engineer responsible Requirements Reverification of each safety system, instruc-the Re-for tho o Obtain system design requirements source documentation, and o Evaluate the design requirements source documentation against the review criteria identified in Paragraph IV.S.2.For the three selected systems, the results of the above review will be used as input to the Design Reverification reviews to confirm that the proper design requirements were used as the input to the detailed design.4.Report and Documentation of Findings The findings from the Requirements Reverification reviews for the three systems selected for Design Reverification will be processed in accordance with the special findings review ac-tivity that is an integral part of Design Reverification.

Re-solution of problems and deficiencies from the Requirements Reverification reviews of the other safety systems and the re-view of the engineering record (refer to IV.A)will be reported and processed in accordance with normal WNP-2 Project procedures. October 1982, Rev.1 C.-Design Reverification l.Objective For selected safety systems verify that the design is based on the requirements identified by the review performed in Subsec-tion IV.8 and that the design is adequate.This r view will verify that the design process correctly translated the design bases identified by the Requirements Reverification review into the.detailed design=and the design documents ultimately trans-mitted to the construction and fabrication organizations.

A procedural review of the design proc ss, i.e., design and implementation procedures, is not within the direct, scope of this task.These processes have been reviewed and demonstrated effective through previous technical and quality assurance audits and Supply System reviews.(Refer to Appendices A and 8 for design process, details).However, as part of the reviewing engine r's assessment of his findings, he will review the ap-plicable elements of the design control process to determine if a deficiency in the process contributed to the finding.2.Systems and Review Scope Three systems hav been selected for an in-depth Oesign Ro ver-ification review by the Supply System.The selection proc ss focuses on the more ccmplex systems in terms of both the design and, design int rfac s and includes within th sample of syst ms a comorehensive range of hardwar types and: design d'ci-plines.The crit ria used for the selection were: o The system, or a majority of its f atures, shall be impor-tant to the safe shutdown and cooldown of the reactor, o The systems selected shall include the main design inter-faces between Burns and Roe, the NSSS suppli r (GE), and the construction contractors, and o The systems selected shall include saf ty-related mechan-ical components, piping, instrumentation and controls, electrical equipment, and cabling.The emphasis on systems important to safety will assure that the reviews include the more complex and comprehensive design criteria which are associated with safety-relat d systems.The specific systems selected are: o Residual Heat Removal System, suppression pool cooling mode, o High Pressure Core Spray System, and o Reactor Feedwat r System from condensate valves COND-V-142A and B (condensate side of reactor feed pumps)to the reactor vessel nozzles.These systems are complex, interact with other safety and non-safety systems, represent both Burns and Roe and NSSS design activities, and includ the major d sign interfaces between GE, Burns and Roe, and site contractors.

Their design also re-quires the application of site specific seismic response spec-tra developed for WNP-2 and the new containment loads.It should be noted that the review scope of the Reactor Feed-water System includes non-safety piping and components, i.e., from the condensate valves to the containment out r isolation valves.This provides for review of the feedwater control sys-tem and the following boundary interfaces:

ASME Section III/ANSI B31.1, Quality Class I/Quality Class II, and Seismic Category I/Seismic Category II.These three systems will be reviewed in detail starting with the design requirements and-extending through the development of the design documents.

This will assure that the design cri-teria have been adequately applied in the design of the selec-,.ted systems.The review will include consideration for the>.structural, mechanical, electrical, and instrum ntation and" control aspects of the system design.More specifically, the..r view will be conducted to assure the systems/structures and their components have been properly classified in accordance with 10CFR50 and to assure the ad quacy of the engineering de-sign including, but not limited to, computer modeling, analy-ses, calculations (including assumptions, input and output), related design interfaces, design drawings and specifications,=and review of as-built drawings.The detailed scope of the review will be defined in the Design Verification Plan developed for each of the three systems as described in Paragraph IV.C.4.The items selected for review will emphasize those areas that are not verified during the preoperational and power ascension testing programs (e.g., pipe analysis and support loads, transfer of key design information between organizations, and separation criteria).

These design elements would be emphasized over pressure drop calculations and valve operation logic that are normally verified during the testing programs.Each Design Verification Plan will include at least one hundred (100)key points to be checked.In this context, a check.point may include verification that an impor-tant, derived design input is correct, or confirmation that revised design inputs were properly transferred at a key design interface, or a detailed review of a pipe stress analysis.The check points will also be selected in a mann r to allow an as-sessm nt of the performance of the principal design organiza-tion in selected areas.

During the process of these reviews, the results will be used to further guide the direction of the Design Reverification effort, e.g., the depth of review for specific items, the pur-suit of problem areas, and the need for changes of the review scope.Changes in the program scope will require the approval of the Office of the Managing Director and will be documented in the program record.*Review Criteria The review consists of two phases: 1)an integrated system review that focuses on system functional and interface criteria using a generic system checklist, and 2)a component review that focuses on the specific design requirements for selected components, including piping and supports, and the development of the design fo'r those components.

The latter review is based on a modified ANSI N45.2.11 checklist.

In addition, the design requirements for the selected systems will be evaluated to determine whether they are considered as"accepted" or were derived.In some cases, e.g., new contain-ment loads, where the design requirements have been widely re-viewed and accepted, the review of the requirements will be limited to confirmation that the approved loads were correctly applied.In those cases where the design requirements were derived from"accepted" criteria, the Design Reverification review will examine the process of deriving the requirements on a sample basis.Design requirements that are treat d as"accepted" during this portion of Design Reverification will be identified in the record of the review.The component vendor design activities are not included in the review.However, confirmation that the correct design inputs were properly transmitted to the vendor and that the correct design outputs were used by the interfacing engineering organi-zations is in the review scope.The design review will address the following:

System Design Review: o Are the system functional requirements satisfied?

o Is the AWE code properly applied for the system piping and components?

o Are the applicable m chanical, electrical, and instrument-ation and control separation criteria satisfied'?

o Are the component redundancy requirements satisfied?

o Are containment isolation requirements satisfied? October 1982, Rev.1 o Are the system heat removal requirements satisfied?

o Are the system power requirements satisfied'?

Are the system control requirements satisfied'?

Are corrosion prevention requirements satisfied?

o Has the design properly considered radiation exposure to plant personnel'?

o Are the system layout and arrangement requirements satisfied?

Component Oesign Review o Were the component design inputs correctly selected and incorporated into design'?o Are assumptions necessary to perform the design activity adequately described and reasonable'?

Where nec ssary, are the assumptions identified for subsequent reverifications when the detailed design activities are completed?

o Are the appropriate quality and quality assurance require-ments specified?

o Are the applicable codes, standards, and regulatory re-quirements including issue and addenda properly identified and are their requirements for desicp met?o Have applicable construction and operating experience been considered'?

o Have the design interface requirements been satisfied?

o Was an appropriate design method used?Is the output reasonable compared to inputs?Are the sp cified parts, equipment, and processes suitable for the required application'?

Are the specified materials compatible with each other and the design environmental conditions to which the material will be exposed'?Has the design properly considered radiation exposure to plant personnel'?

Are the acceptance criteria incorporated in the design do uments suf ficient to allow verification that design requirements have been satisfactorily accomplished?

October 1982, Rev.1 o Have adequate preoperational and subsequent periodic test requirements be n appropriately specified?

4.Oesign Reverification Process This process will be integrated with the Requirements Reverifi-cation process described in Paragraph lV.S.4.The process ror Oesign Reverification will include the following steps: o Prepare and approve implementing procedures and instruc-tions, and conduct training on implementation of the Oe-sign Reverification process, o Assign a cognizant system engineer responsible for the Oesign Reverification of each selected system, o Generate design process flowcharts which include the source documents of the design criteria, the responsible design organizations, and the design information transmit-tal paths, o Obtain the.system design documentation, o Select the components ance system design featur s to b reviewed and prepare a Oesign Verification Plan unique to each system which considers:

the design proc ss flow-charts, methods of design verification (d sign review, alternate calculations, and qualification testing), com-ponent importance to proper system operation, system/component complexity, areas of redesign, load combina-tions, design margin, etc., o Obtain Technology management concurrence to the individual Oesign Verification Plans and suomit them to the Office of the Managing Oirector for review, o evaluate the design documentation against the review cri-ter'a identified in Paragraph lY.C.3, and o Edenti fy and evaluate deficiencies as described in Sub-section IV.O.5.Report and Oocumentation of Findings A sunmary report of each safety system Oesign Reverification review, including all Potential Findings, their classification and corrective action plans, will be prepared.

O.Processing of Findings The purpose of this Subsection is to discuss the processing of Potential Findings identified during the Design Reverification reviews.This pro-cess shall review, evaluate, classify, and ensure appropriate corrective action is initiated for each Potential Finding.Figure 6 is a basic flowchart of the findings review process.It is repeated here to assist in und rstanding the text of this Subsection.

A Potential Finding is defined as a deficiency, in the use of design re-quirements, in the development of the detailed design, or in the final design or design changes issued for fabrication or construction, that renders the proper function of that component, system, or structure in-determinate or precludes its proper function for its required modes of operation.

Upon identification of a Potential Finding by the responsible system engineer, he shall prepare a Potential Finding Report (PRF).The PFR shall includ: a description of the deficiency, the basis for ident-ifying the deficiency as a Potential Finding, the probable cause, an as-sessment of its s'gnificanc, and a recommended classification.

The en-gineer may'nclude a proposed corr ctive action at his option.The PFR is.reviewed by Systems Design Engineering (SDE)supervision/

management for adequate content, accuracy, and initial conclusions.

The PFR is then transmitted to the Findings Review Committee (FRC)for eval-uat'on and classification.

In the event the Potential Finding's a po-tential'10CFR50.55(e) or 10CFR Part 21, it shall also be processed in parallel by Project Quality Assurance (QA)in accordance with applicable project proce'dures'.

The FRC shall be composed of senior technical personnel with broad, com-mercial nuclear experience.

The Committee shall include a balance of engineering disciplines and will be chaired by the Technology Director-ate, Assistant Director for Generation Engineering.

It will include a representative of the corporate licensing group, the Plant Technical Staff Manager who reports to the Directorate of Power Generation (via the Plant Manager), the Technical Specialist, Office of the WNP-2 Program Director, and a fifth member to be selected by the Chairman.The fifth member can be external or internal to the Supply System provided that the individual selected does not report to the WNP-2 Project.In addition to the five designated members, the committee structure will include provisions for designated alternates within the constraint that not more than one member shall report.to the WNP-2 Project and this mem-b r shall not serve as an alternate chairman.The use of alternates on the FRC will be minimized in order to preserve continuity in the findings review process.To convene a FRC meeting, a minimum of five members must be present.In addition, an independent technical auditor will be informed of the=scheduled FRC me tings and their'agenda.The auditor will participate in a sufficient number of meetings to make a meaningful assessm nt of the findings review process.All PFRs, including their classification and corrective action plans, will be provided to the auditor.'CO-,25-The Committee, as their first function, shall establish a procedure that defines the charter of the FRC and details the proc ss foz evaluation and classification of Potential Findings.The procedure shall include cri-teria to be used in assessing the impact of a Potential Finding on the design adequacy of WNP-2.The criteria shall include, but not be limited to, the following'onsiderations:

o Is the Potential Finding unique to a specific component or system'?o Is the Potential Finding generic in nature to a component type, com-ponent/system function, methodology, analysis aooroach, etc.?o Is the Potential Finding due to human error, lack of procedure im-plementation, or inadequate orocedural controls (design control pro-c ss problems)'

o Is the Potential Finding a safety issue'o Is the Potential Finding significant to the design adequacy of NNP-2'?In the event a Potential Finding is safety r lated and was not identified as a potentially reportable condition by Systems Design~mgineering, the Committee shall notify Pro)ect QA of the condition per site procedures.

The Committe shall review each Potential Finding identified during the Design Reverification reviews.The PFR shall be discussed by the re-sponsible system engineer with the Committee.

The Committee shall deter-mine if the PFR has sufficient information to allow for validation and classification of the Potential Finding.The Committ e shall aequi" additional information, as needed, frcm Systems Design Engineering or the responsible engineering organization.

=The Committee shall determine if the Potential Finding is valid.If the Committee disagrees with the validity of the finding, it shall be return-ed to the originator of the PFR with-the reasons for that conclusion.

If the originator concurs with the Committ e's evaluation, he shall document his concurrence.

If the originator disagrees with the Committee's posi-tion on the validity of the PFR, he may request a Special Revi w which is conducted under the direction of the Technical Specialist, Office of the Managing Director.In the event the Potential Finding was already be-ing processed as a potentially reportable condition, the result of that evaluation would govern the validity of the PFR and the conduct of a Spe-cial Review would not be nec ssary.The result of the 1OCFR50.55(e) or lOCFR Part 21 zeview would feedback accordingly into the proc ssing of the PFR by the Findings Review Committee.

If the Committee determines the PFR is valid, it shall then classify the Potential Finding as: 1)a Finding for those items which significantly impact the design acequacy, or 2)an Observation for those items which do not significantly impact the design adequacy.The criteria for signifi-cance shall be in the governing FRC procedure and shall include, but not-25>>

be limited to: those criteria applicable to 10CFR50.55(e) and 10 CFR Part 21 reportable conditions, or a Potential Finding associated with a Y design control problem (including implementation) that could lend itself (to repetitive or other deficiencies that may fall within the 50.55(e)or Part 21 critria.In assessing the impact on design adequacy of the lat-ter criteria, the Committee may direct that further investigation be per-formed by Systems Design Engineering or the responsible engineering organization.

Observations are transmitted from the Committee to WNP-2 Project Engine-ering for corrective action as appropriate.

This includes interface with the responsible engineering organization (Burns and Roe or GE)or record-ing of the Observation for defered action.Findings are provided to WNP-2 Project Engineering for transmittal to the responsible engineering organization for corrective action.A response date is established for a proposed corrective action plan to be returned and submitted to the orig-inator of'he PFR for review.The proposed plan shall be reviewed and concurred to by the PFR originator and by the Committee.

Should there be disagreem nts on the adequacy of the proposed plan that cannot be re-solved by a consensus, the disagreem nt will be noted in the record and reported to the Office of the Managing Director for resolution.

In the event the responsible engineering organization provides information that may change the original validity or classification of a Potential Find-ing, that information shall be used in the.findings review process for-reconsideration and changes in the record as appropriate.

In addition, the Observations and Findings are transmitted from the Committee to the.Technical Specialist, Office of the WNP-2 Program Director, for coordina-~, tion of other projec'rganization activities that may be involved in the;, 4L resolution of the subject item.-),,M.'he Committee shall docum nt its activities and conclusions for each;-PFR.The~r, related internal and exteral correspondence, corrective

-,;action plans, and Committee docum nts shall be filed by the responsible:.:, system engineer.This information will be included in th final reports" provided by Systems Design Engineering on the review of each of the three selected systems.Q Schedule The Requirements and Design Reverification activities are associated with four (4)principal phases: 1)preparing procedures, 2)assembling the engineering record and performing the Requirements Reverification, 3)performing the Design Reverification, and 4)compiling results and con-clusions into final reports.Procedures are being prepared to provide guidance and direct the engine-ering record, Requirements and Design Reverification reviews.These pro-cedures are scheduled for approval by early July, refer to Figure 7.The procedure which governs the activities of the Findings Review Committee (FRC)will be approved by mid-July.It is not anticipated at this time, that the FRC will be in session before September 1982, due to the early stage of the Design Reverification review.As noted on Figure 7, the assembly of the engineering record and the Re-quirements Reverification review have begun for the three selected sys-tems.Completion is scheduled for mid-July.Design Reverification starts with an assembled engineering record and the results and open items from the Requirements Reverification review.These items are inputs to the development of each system Design Verifica-tion Plan (OVP), refer to Subsection IV.C.The OVP is not separate from the Design Reverification review, but is the plan for performing the in-depth review for each of the thze systems.The DVPs are scheduled for completion by mid-September, with the subsequent Design Reverification reviews projected to oe finished by early 1983.Refer to Figure 7.Prior to Systems Design Engineering issuing their final reports on the review of each of the selected systems, t¹findings evaluations must be completed and related corrective action plans must be established.

Al-lowing time for the evaluations, interface with the responsible engine r-ing organizations, and their responses to Findings, the reports and FRC activities are scheduled for completion by mid-April 1983.The final report which addresses overall design adequacy based on the Requirements and Design Reverification reviews follows in May 1983.This report, which includes input from the individual system reports and from the FRC activities, will be prepared under the Technology Directorate by the As-sistant Director for Systems Engineering.

The schedule of activities should provide for any necessary followup by the responsible engineering organizations and related construction re-work, if any, in a manner to support fuel load in September 1983.In addition, as noted on Figure 7, there are scheduled audits, interim reports, and evaluations of the reviews.The three scheduled assessments by Supply System management allow for revisions to the program in the beginning and middle, and evaluation of its implementation and need for expansion in scope near completion of the reviews.

F.Component Inspections As discussed in the opening paragraphs of this Section, extensive com-ponent inspections and tests are being performed.

The inspections and tests are performed in the following manner.As a part of th system Provisional Acceptance (PA)process, a PA package is pr pared which contains, among other items, copies of the component maintenance records.Based on a review of these records by the Supply System Test and Startup organization, information gathered during the PA walkdown of the system, and experience with similar components on prior PA turnovers, a decision is made to proce d with the system lineup test-ing (refer to Appendix E, Section C)or to disassemble and inspect com-ponents prior to system lineup testing.When it is decided to perform a detailed inspection, the disassembly and inspection is performed by Test and Startup personnel using the approved component maintenance procedure that will be used during plant operation, or an approved system lineup test procedure.

The results of these maintenance and inspection activities are documented as part of the plant component maint nance record.Significant deficien-cies found in the process of conducting these inspections are reported through the Test and Startup Program.The QA function is accomplished under the Operations QA Program.Examples of these inspections, their findings, and the corrective action are provided in Table 2 to this Sec-tion.Based on a review of Table 2, it is clear that proper layup condi-tions and cleanliness have been a problem.It should be noted that the stainless steel portion of the reactor coolant pressure boundary had not come in contact with water due to construction or testing activities prior to the Reactor Pressure Vessel hydro.A concern for stress corrosion cracking due to improper layup, therefore, does not exist.To date approximately 39,000 components and pieces of equipment have been inspected or tested.All procedures for inspection, testing, and rework are written by Supply System startup and operations personnel.

Vendor representatives have been used-to assist in inspections, e.g., Byron-Qackson and Ingersol-Rand during disassembly and reassembly of pumps.The majority of the components and equipment turned over are in good con-dition.The problems encountered have generally been on items PA'd be-fore the Duly 1980 stop work.A number of actions have be n taken to improve cleanliness control and maintenance.

With general housekeeping improved, fewer problems have be n encountered with recent systems under-going PA.-29-October 1982, Rev.1 Startup S stem Number 1.0 3.0 5.0 6.0 7.0 8.0 9.0 10.0 13.0 15.0 16.0 20.0 22.0 25.0 36.0 37.0 39.0 45e0 47.0 50,0 58.0 63.0 72.0 81.0 84.0 87,0 88.0 TABLE 1.SYSTEMS SLBKCT TO REQJIREMENTS REVERIFICATION Title Nuclear Boiler System Reactor Recirculation System Remote Shutdown System Reactor Core Isolation Cooling System High Pressure Core Spray System Including the HPCS Diesel Low Pressure Core Spray System Residual Heat Removal System Standby Liquid Control System Control Rod Drive System (Partial)Reactor Protection System Neutron Monitoring System Nuclear System Servt,cing Equipment Primary Containment Atmospheric Control System Primary Containment Atmospheric Monitoring System Process Radiation Monitoring System Radiation Monitoring Syst m (Partial)Standby Gas Treatment System Supervisory Control System (Partial)Standby AC Power System DC Electrical Distribution System Standby Service Water System Main Steam System Feedwater System Reactor Building Emergency Cooling Systen Control, Cable, and Critical Switchgear Rooms HVAC System (Partial)Standby Servic Water Pump House HhV System Diesel Generator Building HE<V System Page 1 of 1 October 1982, Rev.1 4 l TABLE 2 TEST AND STARTUP CCMFONENT INSPECTIONS Equipment Ins ected T ical Findin s Corrective Action improper layup after initiall installation.

RHR-P-2B RN-P-2C h tutors RN-P-2A I o Excessive corrosion due to 1 o Cleaned and sandblasted prior to reassembly.

Presently in-insuring proper layup condi-tions are maintained, i.e., dry air purge.o Wrong 0-rings used during I o Installed the proper 0-rings initial assembly of pumps and corrected vendor manual.due to error in vendo" manual.I o Foreign materials found in I o Removed all materials and in-pumps (i.e., wood, nails).sured proper cleanliness was maintained during reassembly.

I o Found motor heater de-I o energiz d and motor not pro-I tected from construction dirt.Energized heaters after in-specting and cleaning motor.RfR-P-2B I o A unique finding was a de-I o Reworked pump case.fective weld in the pump case.LPCS-P-1 I o Excessive corrosion due to I o h i4aotor improper layup.I o Wrong 0-rings used during I o initial assembly of pumps due to error in vendor manual.Cleaned and sandblasted prior to reassembly.

Presently in-suring proper layup conditions are maintained, i.e., dry air purge.Installed the proper 0-rings and corrected vendor manual.I o Foreign materials found in I o Removed all materials and in-pumps (i.e., wood, nails).sured proper cleanliness was maintained during reassembly.

o Found motor heaters de-I o Energized heaters after in-energized and motor not pro-I spection and cleaning motor.tected from construction I dirt.I Page 1 of 4 October 1982, Rev.1 TABLE 2 (Condt)Equ pmen Inspected T pical Findin s Corrective Action HPCS-P-1 I o Excessive corrosion due to I o h Motor improper layup.Cleaned and sandblasted prior ,to reassembly.

Presently in-suring proper layup conditions are maintained, i.e., dry air purge.I o Wrong 0-rings used during I o Installed the proper 0-rings initial assembly of pumps and corrected vendor manual.due to error in vendor manual.o Foreign materials found in I o pumps (i.e., wood, nails).Removed all materi.als and in-sured proper cleanliness was maintained during reassembly.

o Found motor heaters de-I o Energized heaters after in-energized and motor not pro-I spection and cleaning motor.tected from construction dirt.COND-P-lA COND-P-1B COND-P-1C I Motors o Foreign material and exces-sive corrosion problems.Cleaned and sandblasted prior to reassembly.

Presently in-suring proper layup conditions are maintained, i.e., dry air purge.Removed all mat rials and insured proper cleanliness was maintained during reassembly.

I o Improper clearances on shaftl o Reworked by machining to proper couplings.

clearance or obtained new couplings.

o Found motor heat rs de-I o Energized heaters, cleaned and energized and motor not pro-I inspected motors.tected from construction dirt and debris.COM3-P-2A COND-P-2B COND-P-2C o Corrosion problems.o Cleaned and sandblasted.

Replaced impeller.Energized heaters, cleaned and inspected motors.o Defective impeller found in I o COND-P-2B.I I I o Found motor heaters de-I o I energized and motor not pro-I I tected from construction I I dirt and debris.I Page 2 of 4 October 1982, Rev.1 TPBLE 2 (Condt)Equ pmen Ins ected T ical Findin s Corrective Action Main Gen-I o erator h I Its Seal I Oil System I I o Found the generator and ex-citer shafts grounded due to dirt lodged in the gen-erator blower and damaged insulation on the generator b carin dowels.o Cleaned blower and replaced damaged dowels.Dirt, weld slag, and rag I o Cleaned seals and piping.found in the seal and piping.Mechanicall o Excessive dirt and foreign Vacuum I material due to missing Pumps 8 I screens.Motors I I o Damaged motor bearings.o Cleaned, inspected, and in-stalled screens.I o Ordered bearings to replace I dama ed ones.Static In-verters 1, 2, h3 o Experienced an initially high failure rate on some component parts.I o Maintained inverters in an en-ergized condition and reworking as required, dealing with ven-dor to determine the cause of problem.Batteries I o Poor and improper 2', 125V I installation.

250V, h Racks o Improper storage.I o Insuring proper installation of I batteries and racks.I I o Replacing, reworking, and or-I dering new batteries and racks I as nec ssary.I I o Insuring that all storage re-uirements are met.HEi:V (General)o Poor and improper mainten-ance has caused damage to dampers and motors (bearing rob lems).o Cleaning and reworking as necessary.Valves (General)o Poor and improper storage has caused damaged seals, shaf ts and bonnets.o Clean, inspect, rework, and replace as necessary, stroke and insure smooth operation.

Page 3 of 4 October 1982, Rev.1 TABLE 2 (Condt)Equipment Ins ected T ical Findin s Corrective Action Instrunen-I o Poor and improper storage tation I has caused damage.(General)I I o Improper instrument.

I o Clean, inspect, functionally test and replace as necessary.

o Replaced with correct instruments.

o Open NCRs on Contract 58, instrument racks shipped with some instmaents missin.o insure instrument is installed, functionally test and close NCRs.Electrical I o Poor and improper mainten-(General)I ance of installed equipment.

I I o Incorrect installation and design.o Clean, inspect, test, and re-place as necessary.

o Obtain redesign via BAR engi-neering and insure correct installation.

o Incorrect or no fuses or overloads.

o Installed correct and needed items.Page 4 of'October 1982, Rev.1 RESPONSIBLE SYS.ENGR.LEAD ENGR.AND MGR.SYSTEMS DESIGN ENGINEERING FINDINGS REVIEW COMMITTEE WNP-2 PROJECT TECH.SPEC.OFFICE-OF THE MANAGING DIR.PREPARE PFR i REVIEW.Af E AE f S ADII IT IDNAI IHFOAIIAT I ON lttADEQIIAIE 8 PROJECT EHG INEERIHG RESPOIIS IBM EHGINEERIN ORG.Rft)t~tf)IHFORNAT I Otl/~DU)OttAL SAFETY~C RECONSIDERATION ISSUE 6 EVAl.OAT E OEF ICIEIICY DEF I tl1 T ION CONDUCT SPECIAL REVIEW REVISE/PROVIDE Ate'L INFO.REVIEW REVIEW AGATE SACR f REVIEW ltt Al ADEQUATE ASSESS VALIDITY VALID CI~t I A'al I/1 CA C>PROJECT ENGINEERING TECII SPEC o WHP 2 PROC.DIR.OFFICE PROGRAN NON ITOR IHG DISACREE~AGREE (UNLESS PROCESSED TO C)ASSES'S 5 ICtt I I ICAtlLE PERIOIUI CLASSIFICATION DOCUHENT tD ttC PROJECT QA REPORTABLE COHD IT Ioti 5 REVIEW~PFR-POTENI'IAl REVIEW PROPOSED CORRECTIVE ACT ICN PLAtl CAP FINDIIIG REPORT AEV IF W PROJECT f HG INEERIHG RESPONS IBM ENC IREE'R IIIG ORG.PREPARE CAP FIGUAf 6 1982 APR HAY JUtl JUL AUG SEP OCT NOV DEC JAtl FEB HAR-APR HAY JUtl JU<AUG SEP OCT flOV DEC ASSEMBLE E.R.~~~PERFORH.R.D VELOP D.V.P PERFORM D.R.T.A.A.I.R.,H.R.I.R.,H.R H.R.NRITE S.D.E.R TS PERFORM F.R.C.ACTIVITIES PERF 4 RELATEl F.R.C.CONCLUSIONS FINAL REPORT ENGINEERING 6 CONSTRUCTION AS NECESSARY COMMEttCE FUEL LOAD NOTES: EtlGINEERItlG ORO REQUIREME EVER IF ICATION DESIGN ERIF ICATION SYST DESIGN ENGItlEERING T NICAL AUDIT ASSOCIATES E.R.SUPPLY SYSTEtt(SDE)

ItlTE R IH REPORTS I.R.R.R.SUPPLY SYSTEH HAtlAGEHEtlT REVIEIt H.R.D.R.S.D.E.T.A.A.FIGURE'7 APPENDIX A APPENDIX A OEYELOPMENT 0F'ESIGN WNP-2 has a standardized, BWR-5 NSSS which was designed under the General Electric BWR Quality Assurance Program.Based on this standardization and the numerous reviews and audits performed on the NSSS design by GE and other util-ities, the focus of this Appendix is primarily on Burns and Roe, the Architect Engineez, in the following areas: o Organization, o Oesign process, and o Oesign interface with other organizations.

In addition, a review performed by the Supply System to determined the ade-quacy of past and ongoing design verification for the Burns and Roe and con-tractor (excluding NSSS supplier)designs is discussed.

The General Electric design control program is presented in Attachment 1 (GE letter Gc~-2-82-17) to this Appendix.This attachment is a brief statement of their program;however, extensive details are provided in the NRC approved, GE Quality Assuranc Topical Report, NED0-11209-04A.

Supoly System Corporate Quality Assurance (QA)routinely audits the General Electzic activities associated arith WNP-2.As with Burns and Roe these audits evaluate complianc with SAR commitments, 10CFR50, Appendix B, ANSI N45.2, and implementing procedures.

The audits az performed on the various GE facilities which interact with'HNP-2 through design, procurement, or fabri-cation (inc'uding fuel).Tyoically, two (2)or more audits aze performed on GE per year.The audits are procedurally controlled and documented.

QA deficiencies are discussed with GE Pro)ect Management, resolved, and re-audited to verify im-plementation of corrective action.Examples of ar as audited include: o GE audit performance, o Procedure complianc in general, o Control of design changes, o Technical int rface controls, o Control of purchase orders, o Shipment and protection of reactor pressure vessel with internals, o FSAR review cycle, o Design control, o Drawing control, o Design verification, and o Calculations.

The performance of these audits has provided additional assurance to the Supply System of the adequacy of the GE design for WNP-2.The audits have confirmed the extensive documentation of the GE design process based on their implementation of ANSI N45.2.11 in 1975 and the use of the standardized, GE BWR Quality Assurance Program which was approved by the NRC in 1976.-A A.Burns and Roe Organization Pre-January 1, 1976 Burns and Roe had a number of Divisions through which it carried on its Corporate business.Of major interest relative to design are the Power Engine ring Division and the Project Operations Division.The Power Engineering Division had within it, among other depart-ments, the Chief Engineers who through a Deputy Director reported to the Vice Presid nt, Power Engineering Division.Each Chief Engineer had a limited number of Supervising Engineers who act d in thei behalf due to the number of projects in progr ss.-It was the func-tion and responsibility of each Chief Engineer, or his delegated Supervising Engineer assigned to a project, to establish criteria in his particular discipline for the overall plant design, to review the work on a periodic basis, and to approve drawings and specifications.

The Supervising Engineer was not to perform the engineering and de-sign, but was to review and approve the engineering and design docu-ments generated by the project staff against the criteria and pro-vide a guide to the project staff in interpretation of criteria.The Project Operations Division provided a project with management, engine ring, and design pe sonnel to meet project requirements.

The responsibility to implement the engineering c iteria established by the Chief Engineer (Supervising Engineer)r sided in the Lead En-gineer.The Lead Engineer was r sponsible for developing the de-sign, calculations, specifications, and draw'ngs for the cognizant discipline.

His primary functions were to lead the discipline and to provide day-to-day direct'on to engineers and designers of the sam discipline who were assigned to the project.He was also re-sponsible.

for coordinating his group's activities with Lead Engine-ers of other disciplines.

During the course of the work, scheduled reviews and close lia'son between the cognizant Supervising Enginee and the Lead Engineer assured that the detailed design or the p oje t met the established technical standards and criteria.Drawing and specification sign-off authority was in the scope of the Supervising Engineer for the Chief Engineer.2.Post-January 1, 1976 During a Burns and Roe reorganization in January 1976, all of en-gineering was consolidated into the Engine ring and Design Oi vi-sion.The Chief Engineers reported, through a Deputy Director, to a Vice President who was Division Director of the Engineering and De-sign Division.The position of Supervising Engineer was combined with the Lead Engineer position into a new classification entitled Group Supervisor, who reported to the Chief Engineer.The function of the Power Engineering Division was completely changed and for the purposes of this discussion is no longer connected with WNP-2.

The'Group Supervisor represents his respective Chief Engineer on the project and carries full responsibility and authority within the scope of his discipline for the applicable project related work.He is responsible to provide technical direction for the engineering, design, and draf ting ef forts, including calculations, specifica-tions, and drawings in his discipline.

'He is jointly responsible to the cognizant Chief Engineer and to the Project Manager for project administration, and reports to both of them.The Group Supervisor has the authority to make all technical decisions except for those specifically reserved to the Chief Engine r.Where authorized by the Chief Engine r, he applies his professional engineer's seal to drawings and specifications.

However, he obtains th approval sig-nature of the cognizant Chief Engineer on documents which define the basic criteria for the project, such as project criteria documents, general arrangemonts, flow diagrams, and one line diagrams of major systems.Project Managem nt was provided through th Project Operations Divi-sion.Project Management reports to the Yice President of the Pro-ject Operations Division.A t chnical decision by the Engin ering and Design Division may be qu stioned by Project Management; how-ever, Project Management has no technical responsibility for the project.First-line Project Management is implemented on a disci-pline basis by the Project Engineers.

Refer to Figure l of this.Appendix for a current WNP-2, Burns and Roe Project organization.

-A B.Burns and Roe Procedures Burns and Roe established, at the beginning of the project, the necessary procedures to perform the engineering and design activities.

The engine-ering procedures,"E", and Quality Assurance procedures,"Q", were de-veloped from'Burns and Ro standard procedures, and were subject to ap-proval by the Supply System.As the project progressed, additional pro-cedures were prepared to control procurement and construction activities.

In 1978, the project initiated the Project Procedures Syst m developed to implement the Burns and Roe Nucl'ear Quality Assurance Manual which had been approved by the Quality Assurance Branch of the NRC.Selected pro-cedures for the scope of services provided by Burns and Roe, modified in some instances due to project commitments, were issued to replace the"K" and"Q" series procedures.

The project procedures currently in use can be r lated directly to the elements of lQCFR50, Appendix B, through the procedures matrix contained in the Burns and Roe Nuclear Quality Assur-ance Manual.Controlled cooies of the current, applicable proc dures are available and in use by the various WNP-2 related Burns and Roe organiza-tions.Table 1 of this Appendix lists the proc dures related to design activities.

A copy of the earlier procedures are contained in the Burns and Roe pro-ject files.

C.Design Requirements The design requirements for WNP-2 were developed from many sources.The major equipment vendors, General Electric (NSSS)and W stinghouse (tur-, bine generator), dictated the interface between the NSSS and the Balance of Plant.The environmental and geological conditions of the plant site were es-tablished by consultants to Burns and Roe and the Supply System.These conditions led to the development of site specific design requirements in compliance with State and Federal regulations, as well as industry stan-dards for related design practice.Other design requirements were es-tablished by applicable codes and standards, and the NRC{AEC)require-ments for design and construction of nuclear power plants.1.NRC (AEC)-At the time of the development of the WNP-2 design re-quirem nts, the AEC had issued a number of min'mum design standards called General Design Criteria, Appendix A of 10CFR50 (dated May 21, 1971).The nuclear{safety related)systems had to be evaluated against these General Design Criteria.The NRC (AEC)also issued Appendix B of 10CFR50 (dated July 27, 1970), Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.Appendix B establishes Quality Assurance re-quirements for the'design, construction, and operation of the struc-, tures, systems, and components.

At the same time the AEC had also issued eleven (ll)safety guides of which ten{10)were applicabl to BWRs.T¹se safety guides, although issued as guidance at that time, were included in t¹WNP-2 design requiremonts.

Over the past d cade, the NRC (AEC)r quirements have evolved through the Code of Federal Regulations, Regulatory Guid s, NUREGsBranch Technical Positions, IE Bulletins, miscellaneous directives, etc.The current requirements and commitments for WNP-2 are pri-marily identified in the PSAR and FSAR.2.NSSS-In 1970, specifications for the NSSS were prepared by Burns and Roe and issued for bid to Westinghouse, Combustion Engineering, Babcock 8 Wilcox, General Electric, and Gulf General Atomics.Gen-eral Electric (GE)was awarded the contract on March 23, 1971.De-sign requirements for the NSSS were developed by GE, including t¹reactor and primary syst m detailed configuration and the contain-ment envelope requirements.

For auxiliary services and systems within the NSSS contract scope, GE provided specifications, flow diagrams, and NSSS requirements imposed on"the Balance of Plant (BOP)systems.These requirements formed the basis for the majority of the safety systems in the plant.A listing of the documents pro-vided by GE is available in the Burns and Roe Project Technical Con-trol Log.-A Turbine Generator-The contract for the turbine generator was awarded to Westinghouse on May 2, 1967.This early date was select-ed to assure that the Supply System obtained a place in the Westing-house order line for this long lead item, even though the detailed requirements, for, the turbine generator were not known at the time.The contract'-was let for an 1100 MW machine.with estimated steam and back pressure conditions.

Westinghouse provided detailed require-ments for the interfac of its equioment with the remaining BOP equipment and the NSSS.A listing of the documents furnished by Westinghouse and other vendors and contractors is available in the Burns and Roe.Project Technical Control Log.Environmental

-WNP-2 environmental requirements are contained in the Environmental Report, originally prepared and submitted to the AEC in support of the request for a Construction Permit.In addi-tion to members of its own staff, the Supply System utilized inde-pendent consulting firms and individuals specializing in the various disciplines to assess pertinent envizonmental'aspects of the WNP-2 design, the site, the surrounding environment, and the interaction with local and regional environments.

The Environmental Report, Construction Permit-stage, focused on the impact of construction.

In 1977, the Environmental Report, Opera-ting License stage (EROL), was submitted.

The EROL focused on the impact of operation.

The NRC completed their review and issued the final Environmental Statement in Oecember 1981.Geology-Available information included geologic and'seismic infor-mat'on provided from a reservoir of subsurface data oased on geo-logic observations and studies conducted near the site from 1903 to 1945 (reconnai'ssance geology), 1945 to 1970's (groundwater charac-tezisiics and bedrock studies), and in the 1960's to pr sent (seis-mic history and potential seismic activity).

Soils i.nvestigations in 1971 and 1972 provided the subsurface condi-tions and design parameters for foundations under plant structures and for the general site area.Field and laboratory tests were per-formed on samoles r covered from borings and test trenching to de-termine physical, chemical, static, and dynamic soil properties.

In recent years, the Supply System Hanford Geology Program was de-veloped and will remain as an ongoing activity tomaintain an under-standing of the contemporary geologic process in the Columbia Pla-teau and recent geological findings.This will ensure the accept-ability of the safe shutdown earthquake for the plant.Members of the program's advisory panel include Weston Geophysical Research, Woodward-Clyde Consultants, Northwest Energy Services Co., United Engineers and Constructors, and Burns and Roe.-A 6.Codes and Standards-The use of codes and standards for th most part were imposed on the design of WNP-2 by r gulatory and State requirements.

In other cases, the designer elected to ref erence applicable codes and standards as requirements in the design docu-ments in lieu of describing detailed requirements.

Appropriate edi-tions and addenda of the codes and standards were used in the design of WNP-2.A complete listing of those imposed are contained in the various contract specifications; the principal codes are also refer-enced in the PSAR/FSAR.

-A 0.Oesign Oocuments General Arrangements

-The general arrangement (GA)drawings were initially begun by using the Cooper Nuclear Station (CNS)GA's as a model with aporopriate changes for the increased NSSS size (1100 MW ve sus 800 MW).-The major difference between CNS and WNP-2 was the containment configuration.

CNS used the inverted light bulb d sign with a torus, while WNP-2 used the over-and-under containment.

This difference had to be accommodated in the WNP-2 GA's.As information was obtained from GE, Balance of Plant equipment suppliers, and Sup-ply System-preferences were resolved, the GA's were revised accord-ingly.Suoervising Engineers reviewed these drawings bi-weekly dur-ing peak development periods, and at the 70K and 100K completion stage in accordance with Burns and Roe procedures.

The original issue of these drawings were contained in the PSAR.As the design developed, the GA's were revised accordingly.

2.Flow Diagrams-Flow diagrams were divided into two main categories, NSSS and BOP.The Burns and Roe NSSS flow diagrams were developed from GE flow and process diagrams.They were supplemented by line, valve, and equipment designations unique to WNP-2 to orovide a uni-form system of identification compatible with BOP systems.These diagrams were updat d as the overall design developed.

Flow dia-grams for syst ms subsequently added to the plant (e.g., Main Steam Isolation'lalve Leakage Control System)weze developed as the need arose.BOP flow diagrams were initially developed using CNS flow diagrams as a guide.As system information became available, these diagrams were updated as r quir d.Instrumentation requizements obtained from GE, equipment suppliers, and the Supply-System, were combined with Burns and Roe zequir ments and included in the design.Oia-grams were reviewed for criteria compliance oy the Supervising En-gineers at the 70K and lOOX completion stages in accordance with Burns and,Roe procedures.

Ther was a continual interchange of information between the project disciplines during the development or the flow diagzams.Reviews oy the Lead Engineers with their comments ar recorded on marked copies of th flow diagrams.These diagrams are available in the Burns and Roe project files.One Line Oiagrams-One line diagrams were developed in accordance with the criteria and direction provided in the Burns and Roe En-gineering Crit ria Oocument and the Engineering Standards.

Source documents for these diagrams included: o Motor and valve lists (equipment to be supplied), o Burns and Roe Technical Memorandums (economic and technical analyses),-A o Vendor requirements (primarily NSSS), o Supply System'equirem nts (power system interface), o Calculations, and o Engine ring-sketches.

The diagrams were approved by the electrical engineering discipline, with a concurring review sign-off by the nuclear and mechanical en-gineering disciplines.

4.Logic Diagrams-Logic diagrams were prepared by the instrumentation and controls (IAC)discipline to illustrate system operation and to provide information for the preparation of electrical control dia-grams (elementary diagrams).

The logic diagrams were divided into two main categories:

o NSSS (GE)supplied logic diagrams, and o Balance of Plant logic diagrams.The BOP logic diagrams were also divided into two categories o BOP logic diagrams prepared by th turbine manufacturer, known as the Automatic Turbine Control Flowcharts and the BWR-DEH Control System Diagrams, and o Other BOP logic diagrams prepared by Burns and Roe.The Burns and Roe BOP logic diagram developement program had several sources.System design descriptions or Technical Memorandum were issued by the cognizant system engineers which described major points of consideration in system functional requirements.

System configurations and essential features, equipment performance speci-fications, and limits were also obtained from Burns and Roe specifi-cations,'endor supplied specifications and drawings, meetings with vendors, and various correspondence.

The logic diagram, upon completion, was reviewed by the cognizant'lectrical, mechancial, nuclear, Lead Engineers and Group Super-visors to assure conformance to system requirements.

This review is documented by the appropriate reviewer's signatuze on the logic diagram.5.Elem ntary Diagrams-Elementary diagrams were developed by the electrical engine ring discipline using NSSS, Burns and Roe, and vendor logic diagrams.-A For NSSS components, preparation of elementary diagrams consisted mainly of reformating GE data.For BOP components, elementary dia-grams were developed from the IAC discipline logic diagrams.The diagrams were approved by the electrical engine ring discipline, with a concurring review sign of f by the engineering discipline

~hose equipment was.addressed on the particular drawing.PSAR/FSAR-The Preliminary and Final Safety Analysis Reports (PSAR and FSAR)contain the ccmmitments made by the Supply System to the NRC for WNP-2 design, construction, and operation.

Th PSAR was pr pared as a part of the Application for a Construc-tion Permit (CP), and thus contains commitments r lated to the de-sign bases for WNP-2.The PSAR-was prepared by Burns and Roe and reviewed by the Supoly System and General Electric, as appropriate.

The PSAR commitments wer revised and new commitments added as a result of NRC (AEC)r view of the PSAR.The FSAR was-prepared as a part of the Application for an Operating Lic nse (OL)and contains, in addition to the design bases, mor direct'operational commitments.

This report was also primarily pre-pared by Burns and Roe, but with much more involvement in both pre-paration and review by the Supply System staff.This is due mainly to the fact that 1)the Supply System staff was considerably larger than during the PSAR preparation, arid 2)the operational commitments impact the manner in which the plant will be staffed and operated.A Supply System Lead Technical Reviewer or author has been assigned responsibil'ty for each FSAR sdction.Approval by the Lead Techni-cal Reviewer is required prior to initial approval of the section or any modifications thereto.The Lead Technical Reviewer is responsible to assuze that the sec-tion is technically correct, me ts NRC requirements (Code of Federal Regulations), and appropriately addressed NRC guidance documents, e.g., Regulatory Guides, Standard Review Plans, and Branch Technical Positions.

In addition to a Lead Technical Reviewer, most FSAR sec-tions were also assigned a secondary reviewer.1n general, the se-condary reviewers wer selected from c ntral Supply System organiza-t'ons or a project organizat'ion other than that of the Lead Techni-cal Revi wer.Final approval of an FSAR section or changes thereto require the approval, not only of the Lead Technical Reviewer, but also the Plant Manager, Project Engineering Manager, Licensing, and the Oeputy Oizector, Safety and Security.Documentation of the SAR review process is maintained as part of the WNP-2 licensing files.Supply System contractors (principally Burns and Roe and GE)uti-lized similar, formalized internal procedures for preparation, tech-nical review, and control of FSAR sections and lic nsing reports.

The Nucl ar Regulatory Commission (NRC)conducted an ex ensive re-view of th WNP-2 FSAR which involved hundreds of formal questions and numerous meetings between the NRC staff and consultants and the Supply System staff and contractors.

The comprehensive process of preparation and review of the Safety Analysis Reports (PSAR and FSAR), along with the strict control of SAR changes and NRC commitments, r presents a significant clem nt in ensuring that the WNP-2 d sign requirements wer appropriately spe-cified and implem nted.7.Engineering Crit ria Document-The Engineering Criteria Document, togeth r with the PSAR/FSAR (including amendments), defines the basic engineering and architectural concepts that were followed in the d sign of WNP-2 to assure a soundly engineered project.These docum nts contain the technical and functional requirements (in-cluding applicable regulatory requirements, design bases, and oth" industry and quality standards) that gov n the design of the over-all plant.Each section of the Engineering Criteria Document was prepared by the cognizant Supervising Engineer (Group Supervisor, after 1976)and approved by the Chief Engineer in that discipline.

The criteria were divided and categorized under architectural, civil/structural, electrical, mechanical, nuclear, instrumentation, and stress.The detailed engine ring and design effort proceeded in accordance with the approved criteria document.Of necessity during the course of a project of this duration and complexity, criteria had to be added or modified.Therefore, periodic additions and revisions were made using a controlled system, Project Criteria Advance Change, which provided the revised data to all particioanis pending the is-suance of a formal revision of the Engineering Criteria Document.Each, change/addition was originated by the cognizant Supervising Engineer/Group Supervisor and approved by the Chief Engineer in that discipline.

Documentation of the Chief Engineers'pproval is con-tained in the Burns and Roe project files.8.Technical Memorandum

-The Technical Memorandum is a document whose original purpose was to record the results of special engineering studies that were developed, during the course of'he project and to distribute these data internally to cognizant engineering person--nel.Later, these documents were also used to submit the engineer-ing information to the Supply System for information or approval, as applicable.

Each Technical Memorandum has a unique chronologically controlled number.The index to the memoranda is by number refer-ence with subject and title, enabling access to specific topics.Each memorandum is prepared by cognizant engineering personnel, re-viewed by the cognizant Group Supervisor and by Project Management-prior to issuance.There is no formal approval cycle for the Tech-nical Memorandum other than the sign-off of the memo itself.'jO 9.Engineering Sketches-Engineering sketches are uncontrolled docu-ments utilized by engineering personnel primarily for the following:

o Preliminary studies, o Development of d sign details, and o Economic analyses and cost comparisons.

Tne sketches do not require checking and approval.Their numbering is controlled and they are filed as a collected body of documents.

Where sketches are utilized to develop design details, they are transmitted to the Design and Drafting Group for incorporation into design drawings.The engineering review, checking, and approval is, therefore, performed on the final design drawing.10.Engineering and Design Standards-The Engineering and Design Divi-sion has a Standards Department responsible for the developement of the Engine ring and Design Standards.

Senior engineers are assigned to this department to prepare technical standards to be used by all Burns and Roe projects.Each engineer has access to a copy of the standard developed for his discipline.

Each standard and each re-vision to a standard is approved by the cognizant Chief Engineer.When the, design of WNP-2 was started, the standards had not been formalized and, therefor , were not imposed.As the standards were formaliz d, instructions were issued that they be used for future work on WNP-2.-A E.Detail Design T he detail design of WNP-2 was procedurally controlled in accordance with'he requirements of 10CFR50, Appendix B.Th se procedures provided for the establishment of design criteria, utilization of the criteria during the detail design effort;design interface review, independent reviews, and design change control in accordance with requir ments established for the original d sign.The detail design proc ss used the established de-sign requirements to generate calculations to support the development of design drawings and specifications to control the procurement, fabrica-tion, and construction of structures, systems, and components.

Calculations Calculations were performed to develop the deta'1 design require-ments of the structures, systems, and components.

The results of these calculations were used to develop the design drawings and de-sign specifications.

These calculations were prepared, indepen-dently checked, approved, and revised in ac ordance with a docu-mented procedure.

The procedure required the use and identification of applicable criteria, assumptions, and r ferenc s used in the per-formance of the calculation.

If assumptions were used that required verification at a later date, the procedure requires the verifica-tion of the adequacy of these assumptions prior to finalization of the calculation.

W¹n the d sign required modification as a result of assumption zesolution, the procedure required that appropriate action be taken to correct the design.Calculations were approved by the cognizant Supervising Engineer/Group Supervisor.

Evidence of the approval is demonstrated by sign-off on the calculation.

Before a calculation is started, the deta'ls of th assumptions made, the codes to be followed, etc., are listed on a lead sheet.In order to avoid misdirection in design, this lead she t was con-.curred to prior to performance of the calculation.

2.Specifications Prior to the preparation of design specifications, procedures were developed to control their preparation, review, and approval.The procedures provided for the generation of various internal, exter-nal, and final issues of design specifications.

The design specifi-cations-prepared for WNP-2 are composed of bidding documents and plans and specifications.

The bidding documents requested the sub-mittal of contractural, technical, and Quality Assurance information with the bid to evaluate the adequacy of the bid.The plans and speci ications provide the contract conditions, contract drawings, if applicable, and technical and Quality Assurance requirements.

The specification division designations used followed those estab-lished by the Construction Specification Institute.

Each design specification typically contains a technical section, contractor Quality Assurance requirements (specific section for safety-related components), special pzocess and welding require-ments, as applicable, and general and special conditions.

The de-velopment and proc ssing of design specifications were monitored by a specification:,coordinator who was responsible to assure implemen-tation and compliance with procedural requirements.

Burns and Roe Project Management and the Supply System determ'ned the scope of work to be included in each design specification.

Based on the scope of work, each Lead Engineer involved would assign a cognizant engineer to prepare their discipline' technical re-quirements or section for the design specification.

These drafts were reviewed by the Lead Engineer before they.were given to the specification coordinator.

Upon receipt of all technical sections, the specification coordinator assembled the drafts into a design specification.

The drafts became the Burns and Roe Comment Issue and contained all the sections, technical, non-technical, and bid-ding documents, required for a design specification.

The Burns and Roe Comment Issues were routed with a specification review and ao-proval signature sheet to each discipline providing input and Qual-ity Assurance for review, and then to Buzns and Roe Project Manage-ment and the cognizant Supezvising Engineers for.aporoval.

Comments generated during the revi ws were documented in the.routed copy and initialed by the reviewer.After completion of the".view cycle, the, comments generated wer either acceoted for incorporation into the next issue of the design specification or resolved by the pre-par r of the draft with the revi wer making the comment.The Burns and Roe Comment Issue pr paration, r view, approval, and comment resolution as descrioed above was,typical for each of the design specification issues prepared..

The issues of a des'gn spec-if'cation were the Burns and Roe Comment, Client (Supply System)Comment, Client Concurrence, and the Bid Issues.Each of the issues that were rout d for review and aopzoval are filed and maintained in the Burns and Roe specifications history file.The final issue of a design specification is the Bid Issue.The approval of this issue oy Burns and Roe and the Supoly System Pro-ject Manager is documented on the design specification's Bid Issue Approval She t prior to sending the specification to prospective bidders.Ouring the bidding period, changes to design specifications were accomplished through design speci f ication addenda.Addenda were prepared by cognizant engineers and reviewed and approved only by those disciplines and Supervising Engineers involved in the change and who revi wed and approved the original design specification.

-A Bidder proposals were received by the Supply System and copies were transmitted to Burns and Ro for review and recommendation for con-tract award.The proposals were reviewed by the cognizant disci-pline engineers for technical content, by Quality Assurance for quality requirem nts, and by Project Management for overall ade-quacy.Recommendations for award were documented by the reviewers and incorporated in a letter to the Supply System.Changes to the design specification w re prepared, reviewed, and approved in the same manner as the original design specification.

The initiating document for a change was the Project Change Notice (PCN)which is described below under drawings.3.Drawings Design drawings were prepared to control the design, component fab-rication, and construction of)SP-2.The construction drawings were developed based on the general arrangement drawings, flow and one line diagrams, and structural, system and component detail design requirements developed through calculations and contractor provided design requirements.

Drawing preparation, review, approval, changes, and controls were established by documented procedures.

These prodedures provided for drawing format, identification and'evision control, periodic reviews during development, interdisci-pline review, design and drafting checks, engine ring reviews, and formal approval by Burns and Roe and the Supply System.Th-actual pr paration of design drawings was an iterative proc ss between"he various engineering disciplines providing the necessary information to complete a drawing.Because of this iterative process, interdiscipline reviews were per-formed and several ch ck prints were issued during the development of d sign.These check prints were checked by design and drafting personnel to an established checklist and then routed for review to the various discipline engineers who provided the drawing input.Prior to 1976, this review included cognizant discipline and Lead Engineers, and the cognizant Supervising Engineers.

The Supervising Engineer reviewed and signed a comment print and associated calcula-tions to assure the design inputs were reflected in the design.Since 1976, the cognizant Group Supervisors have provided this re-view.Upon resolution of all comments, the drawings were routed for final engineering review and approval with the latest comment print.Upon approval, drawings would be issued for information, bid, fabrication or construction, depending on project needs.The comment print was filed.The comment prints and the final drawing provide the docunented evidence of the Burns and Roe interdiscipline and independent drawing r view for WNP-2.Drawing changes were processed in accordance with the requirements for the preparation of the original drawing.However, the technical changes were identified in Project Change Notices (PCN).jO In 1978, the Project Engine ring Directive.(PED)was initiated as the change mechanism to forward design changes to the construction contractors.

Similar to the-PM, the PEO control proc ss required interdiscipline revi w as applicable.

Refer to the following sub-section for design change control details.Drawing control'is currently maintained through the Drawing Control Log (DCL)which lists each design drawing, the drawing's current.revision level," and, changes/FEDs issued against each, drawing that have not be n incorporated..

The DCL is a controlled document which is updated bi-weekly to reflect the=incorporation of PEDs, the re-vision of drawings, and new, unincorporated changes/PEDs.

This doc-ument is distributed in a controlled manner to project organizations and construction contractors.

-A F.Design Chango Control The preparation, review, and approval of the detailed design documents were previously described.

This subsection discusses the controls for changes to these docum nts.1.Project Change Notice (PCN)Burns and Roe uses a formal procedure to revise contract documents after they have been released for construction and issued to the Supply System and/or the contractors.

In the New York office, re-visions of contract documents such as drawings and specifications can only be made by issuance of a Project Change Notice (PCN).The PCN is a form completed by the originator of the change and records the description of the change, the reason for the change, the impact of the change on budget and capital costs, the impact of the change on schedule and the estimated engineering costs, and schedule by discipline for implementation, of the change.Th PCN is approved by appropriate levels of managem nt.Each PCN is rev'ewed by all en-gineering and design disciplines in a meeting, prior to starting the work, to discuss the interdiscipline effects of the change, and the total impact on the plant.An adminstrative control system is used to ensure close-out of the PCN after the design work specified has been completed and issued by revision of the affected project documents.

After the work on the PCN is completed, the cognizant Group Super-visor prep"res a draft con"rect Change Orde" descr'bing the change the reason for it, and incorporates the revised drawing and specifi-cations.If the change involves mod'fication of the technical con-tent of the specification, the cognizant Group Supervisor signifies Burns and Roe approval by signing and sealing the last page of the original copy of the Change Order with his professional engineering stamp.The change is formally routed among the engineering disci-plines-involved with the change for signature approval.After re-view, it is sent to the contractor who indicates his approval of the change by executing and forwarding copies to the Supply System.The Supply System indicates acceptance of the change by executing and distributing the final Change Order.Subsequent to August 1978, changes to construction contracts were ma'de by the issuance of a Project Engineering Directive (PED)rather than changes to the drawings and specifications directly.The PED is incorporated at a later date at which time the appropriate pro-fessional engineer's seal is applied to the drawing or specification change.:0-a-A Contract Waiver Request (CWR)The Contract Waiver Request (CWR)was used by the Burns and Roe, New York office.A CWR'is originated by a prepurchased contractor to propose a deviation from a specified requirement.

Examples of the conditions subject to waiver are material substitution, configura-tion or mat'ial changes of hardware items, and deviations in per-formance characteristics.

The cognizant engineer dispositions the waiver request consistent with consideration for the'design needs, and,evaluates the overall effects and interface possibilities that arise if the waiver is approved.The CWR is then submitted for re-view and aooroval by Burns and Roe Quality Assurance and Burns and Roe Project Management before being returned to the contractor.

Nonconformance Report (NCR)Nonconformance Reports (NCRs)are prepared to identify and report nonconformances (i., deficiencies in characteristics, documenta-tion, or procedure which renders the quality of an item or service unacceptable or indeterminate) during fabrication or construction.

The requirements for the control of nonconforming items have been part of all construction contracts since the beginning of WNP-2 construction.

All NCRs are dispositioned by Burns and Roe and concurred with by Quality Assurance.

Nonconformances wnich violate commitments to the Safety Analysis Report, design criteria, design bases or design mar-gin with respect to performance or safety are present d to the Non-conformance Review Board, which includes reoresentatives of-the Sup-ply System, for final dispos'tion.

Prior to 1980, the Burns and Roe site office only dispositioned those NCRs uithin their authority as defined by procedures.

All other NCRs were deferred to New York for disposition.

Since 1980, when Group Suoervisors were assigned to the site, no distinction is made between the engineering authority of the site and New York office for NCRs.Therefore, the majority of NCRs are dispositioned at the site.Originally, NCRs were required for all quality class nonconfoxm-anc s.When WNP-2 Construction Management became an integrated or-ganization (Burns and Roe and Supply System), NCRs became required only for nonconforming conditions r lated to Quality Class I and Seismic Category I items.Quality Class II and G, Non-seismic Cate-gory I nonconforming conditions th n became controlled by contractor programs.All NCRs which appxoved deviations to design drawings or contract specifications caused the initiation of an engineering change docu-ment, e.g., PCN or PEO, which in turn caused a drawing and/or speci-fication to be revised.NCR records=have been maintained throughout the life of the project and are available in the WNP-2 project files.-A 4.Project Engineering Directive (PED)A PED is a document originated by a responsible Burns and Roe engi-neer, in either the New York office or at the site engineering of-fice, to provide a contractor with new or revised engineering and construction direction.

The originating discipline for the PED has the responsibility to identify needed interdiscipline reviews.The performance/results of the interdiscipline reviews are recorded on work sheets and filed.PEDs include revisions to approved drawings, specifications, procedures, or solutions to problems requiring en-gine ring direction.

The PED contains the necessary details perti-nent to a work scope to fully identify construction or implementa-tion requirem nts.The PED is considered by the contractor as of-ficial technical direction from Burns and Roe carrying the technical authority of the original approved-for-construction drawings and specifications.

This system facilitates more timely action which minimizes the impact of changes on contractor engine ring, and fac-ilitates maintenance of the construction schedule.In conjunction with the PED, the Drawing Control Log (DCL)is used to record a listing of the latest issued revisions of Burns and Roe contract, drawings and the PEDs agains each of these drawings that have not been incorporated.

Similarly, the Specification Control Log (SCL)records all changes made to the technical specifications by PEDs not yet incorporated into the specification.

5.In addition to the above general Burns and Roe design controls, the': Burns and Roe site engineering organization has and is utilizing the follow'ng to mainta'n control of design documentation and changes, thereto::0 Request For Information (RF I)-The Request for Information (RFI)started as a simple device for the construction contrac-tors to obtain answers and minor direction on daily construc-tion problems.These problems included, but were not limited to, technical information clari.fication, resolution of various , contractor, interfaces, and Construction Management interfac.These RFIs were answered by Burns and Roe site'ngineering within the constraints of procedures delineating the authority of site engineers on technical matters.In an effort to simplify and speed-up the communications be-tween the construction contractors and Burns and Roe Engineer-ing (site and New York), the purpose and scope of the RFI was expanded in February 1976 to include the functions of the Re-quest For Contract Change (RCC)and the Contract Waiver Request (CWR).For those items of a significant nature (refer to Para-graph F.5.c, Request For Contract Change), Supply System review and approval of such RFIs was still required.In August 1978, when the PED became the design change document, such control by the Supply System was passed to review and approval of a PED, which complemented the RFI, based on dollar, quality class, and schedule related criteria.(=~

Records/files of RFIs, their answers and internal routing for reviews by engineering disciplines and QA, have, be n maintained.

Beginning in 1980, with the transfer of Burns and'Roe-Group Supervisors to the site engineering organization, FFIs are no longer.required to be dispositioned by the New York office.Engineering Change Notice (ECN)-The Engineering Change Notice (ECN)was used to issue a change to a drawing or specification to the construction contractors on an immediate basis, where there was insufficient time to formulate and issue a change order due to status of the construction.

The ECN showed the new conditions exactly as it would appear on the revised Burns and Roe drawing or specification.

The cognizant Lead Fngineer at the site determined the need for an ECN;'f.the subject of the ECN was within the guidelines of'the procedure on the author'ity for resolving discrepancies and nonconformances in the field, the cognizant Lead Engineer and'the Resident Project Engineer could approve'and issue the.ECN to the construction contractor.

If the subject of the ECN was not within the guidelines for resolving discrepancies and non-conformances in the field, the cognizant-Lead Engineer would either have the cognizant Supervising Engine r in New York is-sue the ECN or he would obtain from the cognizant Supervising Engineer written-authorization to issue the=CN;All ECNs were assigned a Project Change Notice (PCN)'umber.This PCN was used to track the incorporation of the FCN into the revised drawing or sp cification.

All ECNs were'ncorpo-rat d into the drawings/soecirications bv the Burns and Roe New York office.Logs and files of FCNs we"o maintained at the New York offices.The use of ECNs stopped with the beginning of PEDs in August 1978.Request for Contract Change (RCC)-The Request for Contract Change (RCC)was a document initiated by the construction con-tractors to request changes to Burns and Roe drawings and spec-ifications., The request had to include information regarding benefit to the Supply System and whether or not the change in-volved a cost adjustment.

RCCs could (but not nec ssarily)have the followings effects:.change cost, change schedule,.

affect interfaces, modify quality class levels, require speci-fication changes, and/or require drawing changes.-A RCCs were initiated by const uction contractors and submitted to the Burns and Roe Resident Project Engineer at the WNP-2 site.If the subject matter of the RCC was within the guide-lines of the procedure on authority to resolve technical mat-ters at the site, the Lead Discipline Engineer could disposi-tion the RCC.If the subject matter of the RCC was outside the guidelines, the Lead Discipline Engineer would either send the RCC to New York or would obtain written authorization from the cognizant Supervising Engine r to disposition the RCC.After disposition, the RCC was reviewed/signed by the Burns and Roe site QA Manager and the Resident Project Engineer.RCCs which changed the quality classification of an item, affected sche-dule, or if it significantly increased the cost of the Project, required a review by the Supply System before being returned to the contractor.

The contractor could not implement the RCC until a fully signed copy of the RCC was received.Changes in the purpose, and scope of the RFI in February 1976 eliminated the need for further use of the RCC.-,A G.Design Documentation Prepared by Site Engineering Mith the transfer of Group Supervisors to the site in 1980, Burns and Roe site engineering was authorized to generate and issue-design documenta-tion.The authorization initially applied to hanger detail drawings, but was later extended to piping isometric and pipe whip zestraint drawings.The procedures for the generation and approval of these drawings parallel Burns and Roe, New York office procedures and Corporate standards.

The drawings aze issued via a controlled distribution to the contractor, Sup-ply System and other intexnal Burns and Roe users.The design of the drawings are primarily changed by Project Engineering Directives (PEO).Calculations are originated and fil d at the site;copies of r lated de-sign calculations are sent to New York.The New York office also codes and microfilms the calculations.

All calculations are prepared and con-trolled in accordance with approved project procedures.

Records/files are maintained at the site foz all the design drawings gen-erated by.the site as well as changes to the drawings.The methods which have been established by and'or the Burns and Roe site activities for the control of design are an extension of the controls established by Burns and Roe Corporate policies.These policies have been successfully used on other nuclear power plant projects.-A H.Prepurchase Vendor Interface Major equipment items were prepurchased by Supply System to allow the timely delivery of the equipment and vendor drawings so that the proper interface could be engine red in support of schedule needs.Specifica-tions were issued giving the performance requirements of the equipment.

In addition, these specifications requir d th submittal of ngineering and Quality Assurance docunentation to Burns and Roe for review and ap-proval.The documentation submitted was reviewed by cognizant engineers and Quality Assurance, as applicable, to assure the equipment would meet specification requirements, provide interface design information, and establish the quality program and procedures to be used for the work.The vendor document control system implemented by Burns and Roe provides for the docunenting of receipt of submittals, routing of submittals to cognizant discipline engineers and Quality Assurance, and disposition of the submittals.

The reviewers of each submittal dispositions and ini-tials the document for thei" discipline.

Upon completion of the inter-discipline review, the cognizant engineer makes final disposition of each submittal by indicating

'he status of the document;App'roved, Approved-As-Noted, or Not Approved.Copies of the dispositioned submittals are distributed to the contractor, Supply System, and cognizant project per-sonnel in accordance with the doceoent distribution schedule.If the disposition of a document was other than approved, the contractor is re-quired by contract to correct the submittal in accordance with the com-ments and to resubmit the docum nt for revi w and approval.The General Electric (NSSS)submittal process is different than the ven-dor document control system discussed above.GE submittals ar proces-sed, revi wed, dispositioned, and commented upon, but there is no re-quirement for resubmittal.

General Electric is responsible for the NSSS design and the docunents provided for BOP interface d sign requirements.

Errors, concerns, or NSSS/BOP interface problems, identified by Burns and Roe or the Supply System,.were documented in correspondence to GE.Such items were pursued to disposition and corrective action accordingly.

A vendor surveillance program was implemented by Burns and Roe to assure that prepurchase contractors were providing equipment in accordance with contract requirements.

The vendor surveillance program consisted of es-tablishing a vendor surveillance plan for each prepur chase contract, Quality Assurance program reviews, implementation audits of the program and applicable procedur s, surveillance of fabrication, witnessing tests, and final inspections for release for shipment to the construction site.Each vendor surveillance was documented in a report and distributed to the contractor, Burns and Roe Project Management and the Supply System.Deficiencies were tracked and resolutions documented and distributed to appropriate project organizations.

~-A t I.Construction Contractor Int rface 1.Document Review and Approval The construction contractors are required to submit detail drawings of'll the'equipment they are to supply.These documents are re--vi wed by Burns and Roe to assure that the contractor has met the specification requirements.

In some cases the contractor performed design, in which case he was'equired to submit the design for re-view and approval by Burns and Roe.Prior to submittal, transmit-tals were to be reviewed and checked by the contractor; therefore, the Burns and Roe review was made to assure compliance with the specification requirements; such as, use of proper loads, materials, or stresses, etc.The review procedur is similar to that outlined in Prepurchase Vendor 1nterface.

Mast of the review of contractor's design calculations were performed in the Burns and Roe New York office.2.Burns and Roe Quality Assurance The WP-2 Quality Assurance organizations responsible for performing surveillances and audits of, construction contractors has changed over time.Initially, Burns and Roe performed these functions until 1978 when the Supply System and Burns and Roe Quality Assurance or-ganizations merged into an integrated organization.

In the inte-grated organization, the Supply System became.responsible for the WP-2 Quality Assurance functions and were assisted by Burns and Roe Quality Assurance personnel.

Subsequently, in June 1981, the-inte-grated oroanization was disbanded and B chtel became responsible for the contractor related Quality Assurance functions as discussed'n Apoendix C.

J.Supply System Assessment, of Design Verification The objective of the design verification evaluation was to determine if adequate design verification had been performed by the Supply System, Burns and Roe, and contractors on Quality Class I systems.The proce-, dures and practices used did not r suit in an easily auditable process;however, it was expected that an in-depth review would substantiate WNP-2 compliance with our commitments.

Efforts were undertaken to interview involved parties and gather objective evidence of design verification in Supply System files, at Burns and Roe, and within the contractor organi-zations.The Supply System expended several man-months reviewing in de-tail Burns and Roe and contractor practices, both across interfaces and within the individual design organizations.

The objectiv evidence ac-quired demonstrated that design verification has occurred on WNP-2 in compliance-with project commitments, PSAR/FSAR, ANSI N45.2, and 10CFR50, Appendix B.1.Burns and Roe Design Control The Burns and Roe design control procedures were reviewed specifi-cally to determine their compliance with applicable requirements and to determine their implementation status on WNP-2.Additionally, extensive auditing of the design control process has been performed by the Supply System and Burns and Roe Corporate QA, refer to Ap-<.pendix B.~LC The Burns and Roe generated documents governed by des'gn control.requ'rem nts (ANSI N45.2 and IQCFR50, Append'x B Crit rion III)are.'alculations, drawings, and specifications.

T¹Bu ns and Roe,...*.~WNP-2 project procedures governing the design control function for,".these or related documents are listed in Table l.The Burns and Roe Engineering and Design Standards have contained'" checklists used in the performance of calculations, and the calcula-tion procedure requires resolution of all checker comments prior to the checker signing and initialing the calculation.

The signing and initialing of the calculation by the checker is the objective evi-dence that the review function was performed'in accordance with the Engineering and Design Standards and that comments have been resolved., The Burns and Roe design input controls included establishing.the Engineering Criteria Document.This document is based primarily on the WNP-2 SARs, Supply System requirements, and NSSS requirements.

These design criteria have been procedurally controlled, as pre-viously discussed in this Appendix.In the design process, design inputs and contractual interfac s were considered during preparation, r view, and approval of design docu-ments.Checklists, similar to those in ANSI N45.2.11, were incor-porated in the Burns and Roe Engineering and Design Standards-in Dune 1981 and are used during the review process to ensure that the design inputs have been considered.

-A The design output is the result of the procedurally controlled de-sign process discussed in the PSAR/FSAR and described in this Ap-pendix under Design Documents and Design 0 tail.Changes to the design output documents are controlled the same as the original design.It was concluded by the Supply System that the Burns and Ro design control process through the origination, checking, various reviews, and approvals of the design documents did perform the necessary de-sign reviews/verifications to be in compliance with the WNP-2 com-mitments on design verification.

Procedures have been in-place that control the design and design interfaces.

Tne procedures do comply with the applicable commitments and requiremets, and the implementa-tion is demonstrated in the design documents on file.Moreover, extensive audits over the duration of the project have not identi-fied adverse trends in the design control area.As discussed fur-ther in Appendix B, Subsection I.C (Special Design Reviews), the adequacy of the Burns and Roe design process was further verified by design reviews.2.Construction and Prepurchase Contractor Design Verification Supply System engineers met with the major onsite Quality Class I constzuction contractors to determine the extent of their design verification efforts.A checklist was prepared and used in the evaluation, contract specifications were reviewed to determine the contractor scope of design, and the contractor's Quality Assurance manuals were reviewed to determine their commmitments to design ver-ification.

The d sign control methods used were discussed with con-tzactoz engineers actively engaged in the design process.Examples of design documents wer randomly selected and reviewed, by the Sup-ply System to determine the depth of design review performed, both"in-house" by the contractor and by Burns and Roe.The onsite con-tractors reviewed were: Contract No.Contractor 213 Pittsburgh-Oes Moines Ste 1 Company (POM)(Containment) 215 216 217 W&/Boecon/GERI (WBG)(Mechanical)

Waldinger Corporation (HVAC)Sentry Automatic Sprinkler Company (Fire Control)218 Fischbach/Lord Electric Company (H.ectr cal)Johnson Controls (Controls)

-A Burns and Roe engineers, both onsite and at the New York office, were interviewed to determine how they review design document sub-/~mittals from contractors.

/Additionally, prepurchase equipment suppli rs were contacted and efforts made to visit their design offices to review design control and verification procedures.

The suppliers (contracts currently closed)~refused to allow access for this review;theze fore, the Burns and Ro files were used to review related design docum nts.A checklist was used and similar preparations were made to perform the review.The prepurchase contractors reviewed were: Contract No.Contractor Velan Engineering (Nuclear Valves)53 Stewart and Stevenson, inc.(Diesel Generators)

H.K.Porter (Air Handling Units)The conclusion from this review was that adequate design verifica-tion has occurred on contractor designs.The contractor design doc-uments were preoared and reviewed/checked by different engineers.

Frequently, the d sign documents were also reviewed by an organiza-tion on subcont act to perform specific design functions or analy-ses, including d sign verification.

In addition, approval of the design docum nts was often perform d by an individual other than the originator or checker.Reviews by Burns and Roe of contractor submittals,was investigated to determine the degree that they constituted design verification.

While Burns and Roe states that their reviews of submittals is per-formed to determine compliance with the design specifications, the Supply System review concluded that Burns and Roe engineers were in fact performing design review and in some cases alternate calculations.

A review of the Burns and Roe comments noted on a random sampling of submittals indicates that the Burns and Roe reviewer performed more'han a review for comparison.

to the specification.

Specific ex-amples indicate that assumptions and their validity, design inputs and basis, and applicable codes and standards were considered.

The results of each Burns and Roe review aze clearly noted.Every transmittal reviewed has the design document stamped as Approved, Approved-As-Noted, or Not Approved, with the initials of the review-ing engineer.If the reviewer felt that more comments were neces-sary, a separate Burns and Roe sheet was attached.-A-2B-The Burns and-Roe review was an independent, third party check of the contractor's design documents.

in the case of M3G, their original design and design responsibility for small-bore pipe and supports has been totally transferred to Gilbert/Commonwealth, and engineering subcontractor to Burns and Roe.-A

0 r~,0 QO TABLE 1 BURNS AND ROE WNP-2 PROCEDURES PROCEDURE NUMBER SITE SPECIFIC PROCEDURE TITLE MNP-2-005-MNP-2-006 MNP-2-007 MNP-2-009 WNP-2-012 MNP-2-015 WNP-2-016 WNP-2-017 MNP-2-018 WNP-2-019 MNP-2-020 MNP-2-022 MNP-2-023 MNP-2-024 WNP-2-025 MNP-2 Indoctrination and Training Plan Prepurchased Documentation Deficiencies Design Change Control System Logic Diagrams Control Request for Information or Change Inspection and Enforcement Bulletins and Circulars Award of Purchase Orders (MNP-2 Project)Project Engineering Directive (Site Actions)Drawing Control Log (DCL)and Specification Control Log (SCL)Project Engineering Directive (PED)Home Office/Richland Actions Management of Controlled Proprietary Documents Security System-Classified Document Handling Procedure Contract Waiver Request Review of MPPSS Test Procedures and Test Results ASiME Code Class I Stress Report Log Page 1 of 4 PROCEDURE NUMBER SITE SPECIFIC WHP-2-036 WHP-2-038 WNP-2-039 WNP-2-040 WNP-2-041 MNP-2-042 WNP-2-043 WNP-2-044.1

~WNP-2-044.2 WNP-2-044.3 WHP-2-044.4 WNP-2-045 WNP-2-046 WNP-2-048 WNP-2-049 MHP-2-053 WHP-2-054 PROCEDURE TITLE Revision of GE Nylars for Contract 59 BOP Panels Calculation Control and Nicrofilming Procedure Review and Approval of Vendor/Contractor Documents guality Assurance Control Requirements in Specifications Startup Problem Report (SPR)Site Only Vendor Drawing Update Instruction Technical Audits of Site Engineering Valve List Updating Procedure Specialty List Updating Procedure Equipment List Updating Procedure Instrument Lis.Updating Procedure Project equality Assurance Surveillance (Site Engineering)

Update of Master Copies of Construction Contract Specifications at the Richland Washington Office Site Review and Approval of Vendor/Contractor Documents Distribution of Electrical Miring Diagrams (EWDs)Engineering Hold Technical Audits of Contractor Engineering Q4 Page 2 of 4 PROCEDURE NUMBER PROJECT MANAGEMENT HNP-2-PM-000 HNP-2-PM-006 WNP-2-PM-008 HNP-2-PM-013 WNP-2-PM-014 HNP-2-PM-016 ENGINEERING

'(DES IGN HNP-2-ED-001-HNP-2-ED-002 HNP-2-ED-003 HNP-2-ED-008 HNP-2-E0-008.1 HNP-2-ED-009 WNP-2-ED-010 HNP-2-ED-013 HNP-2-ED-016 HNP-2-ED-019 HNP-2-ED-020 PROCEDURE TITLE Project Instructions Document Distribution Control (Nucl ear Projects)Project Plan Indoctrination and Training of Project Personnel (Nuclear Projects)Safety Analysis Reports (Nuclear Projects)Review and Approval Signature Requirements for System Descriptions, Drawings, Technical Specifications and SAR/ER Engineering Review and Approval of Project Drawings Client Approval of Drawings and Specifications Repor ting of Defects and Non-Compl iance (Nuclear Projects)Project Criteria Document (Nuclear Projects)Technical Standards Appl icabil i ty List Review, Certification, and Approval of Technical Specifications Calculations Special Design Review Use of Technical Standards Evaluation and Implementation of Changes to Standards Other Than Nuclear Regulatory Re-quirements Design Reports Page 3 of 4 PROCEDURE NUMBER PROCEDURE TITLE WNP-2-QA-001 WNP-2-QA-002 WNP-2-QA-004 Audits of Project Quality Assurance Program (Nuclear Projects)Corrective Action Requests (Nuclear Projects)Processing of Nonconformance Reports NOTE: (a)Based on Corporate'Procedures

Q Page 4 of 4 IC PR 0 tl 6 DIRECTOR-PROJECT OPERATIONS II.CAIITER l HECIIANI CAL EtlGINEERS R03tTf DIR C R UtlP-2 4-0 3.A.7FnQT 1IECII/ttUC LIC ON HP.RELAT IOIIS 68-00.L.IN Otl tRR;FCr 1 IGR.SIGR.EIIGR.]IGR.IIOODBURY RICIILAtlD

.3.VERDDDI R 48-20 A.II.KUGLER 48-600.MURL 0 I RTI'.TOIL~

W6ZO K.0 N SITE 6-00.I.CYGELHAN~uiifABLR SIT I SUPPORT 02-00 C IY.ROB IIISOII CltRFORAK Q1K A Y ASSURAIICE.I L 0 I I L 1 I I I I I BIIAL I ACS RAIICA RICIILAtlD SITE EtlGR.22-0001 II.R~YUIU LL I I QUAL TY A URANCE IIOODBURY EtlGR.Sf.HAttAG R DESIGN DRAFTIIIG~B.~Ot A.BNOVYllf I I I I I-I I I I Rev.2 11/1/81 O PROJECT EtlGIIICERItlG tthflhGER WOOUBURY LRMRB R AM O'fiCIPm R..IIAI ii SECRETARY 0.RA1E T7ftr ftR~STRESS 5 STRUCTURAL D.C.BAKER GROUP S P R HUC/NECII/IIVAC

~C0NH GROUP UP R tlUC ANALYSIS GR(UP ELEC J F UPeR TRICAL AKfR GROUP SUP'R ItiSTRUHEtlMTIO!I GROUP UP'R ARCIII TECTURAL'GO H R tlG tl~asm~~.F.IIESS'USHtiER SCARLETT.CAREY Kl!ALAF fmRPIIY C CK E SNAIL I GALAIITER ROSEN LIEUW RAY ELECIR Chl.EttGIIIEER IIAAR KAHTERtthtt NESS, G.VALGNAII VOSEILLA IHSTRUI NT T Oil ENGINEERS GROUP IJP'R CIVIL STRUCTURAL

.0 OtIM GRO R STRESS C.CIIUNG ILUG EAT BIIBLDfttG KRRRI.'K i ENGINEERS IkOIA ROCIIFORD DE IGIIER M.gUIILI051T>>fcl GARNES HEIIM FARIIZZO GHOSII OLCOTT JOSIII JERK IIIS LAURI TSEtl CABO FEI)AK IIARTNAN WEAVER tt ORAFTSMEH YU HcootthLD GROSS CANAVAH h.IIUILES'IULLER R I CHARDSEtl AUDER TIIOIH'SOft>>

HEtlCEK FOREINtt NIITAGUE GRUSZCEYNSKI CLERKS EOtlE GRhtlF IELD*VERI TY U INN>>-Part-time assigwent to WIIP-2 Rev.2 11/I/01.0

~,'PADJCCT DIIIECTQK Qt P:2 1 J.A.FoAiTESI tl~R UP UP R ISOR EIIGItlEt Balll HhtlAG 8 8 ICIILAttO AG-20[~KUGL II fECRFYAR 48-206 T.MALKER IIH.A T.All-BIS 2 A.RGURLm PLANN NG CII OUL tlG EE I I I I I I-I I UHCHtl IIUF SUPERVISOR

~ZIH..It:K HH-0 L RK AT 0-2 SUPERVISOR OGAI A LEC R INSTROIEIITATIOtl GROUP SUPERVISOR 40-204 G.M.BRASTAO I I 28 CC CCIISING SUPERVISOR 8-20 0.IICCCIIT ALLIIGII(f RS 0-2~0..1LTi 48-211 P.E.PEISTRUP 48-223 J.L.BEVAII 48-212 J.E.PARKER 48-220 II.M.5IEIITIIIK L.II.POLEIITZ~COIIIRACT EtlGIIIEER 0 48-221 48-228 48-224 48-218 ,40-213 48-214 40-222 48-219 L.O.SHARP P.T.IQIROSE R.S.AYLMARO Il.C.IIORIIING OPEN OPEN OPEN OPEtl IIUCLLUI~IIG II 2 S48-234 48-253 40-236 40-241 40-250 40-251 40-252 40-254 48-235 48-237 48-238.48-239 48-240 48-242 J.G.OEL RO AR 0 S.Gl AHtl ltt1 8.II.SUPREIO J.C.SCIIEETZ 0.II.IIUHTINGTON R.E.GREEN 8.).VAttEREH S.J.S'TOKES OPEII OPEII OPEII OPEN OPEtl OPEtl EHCTRf AL 4 H R A EIIGIIIEERS HG tlG ti R A.LUK IC 0.K.OABOLL ffCCI.PT IAL E 48-20 II.C.OUER O Rev.2 11/I/01 PROJECT DIRECTOR/Nt(P-2 (GA.RR.SITE-02 Y C H f(G HGR.0-26.UK IC tNG.UPDh E GH.U W OKO X C.CR Y-0 0 Y.G(ml C K I R 0.((GIN FIELD Et(GI((EERIHG

-023 J.IKAb7ASH ROJ.EtlGINE R IIEC(t t(VC/BLDG.

SVCS-002.Cl NHKH PAO..tG tl R CIVIL STRUCTURAL 76-003.f(08 (G INt(GERS 76-00.Y RO.(Glf(tt:R ELECT/I&C-0DD H.llÃft ITfltl I'AOJ.EtG tl R ft(GR.SUPPORT 016 R 1 G ENGR.SERVICES-0 2 G.ACK N Rev.2'1/I/01 EIIGft.HGR.S W~OY TE I.CCCYYG GCIIII PROS.IIGIIIER~IIECII IIUCIGI.OG.

SUCS.6-002~CIIEK AOH H.A S.76-521 H.HELSOH 76-528 F.HATIIEWS GR UP S P RV SOR BLDG.SVCS GROUP S PEfl 1SOR I IECII IIUC II~OUR UC(IIUISOR IIELOIHG lf ZOOI~tot fER N T TUP SUPPORT f755 A SHE LEAD 0 S GII EttGR.NOTE: Typical organization below Resident Project Engineer 6B Rev.2 11/1/81

.QO g QENERALI ELECTRIC, GENERAL Ei ECTRIC COMPANY OOMCSTIC SWR PROJCC'T5 OCPARTM CNT ITS CIIRTNCR AVCNLIC SAN JOSC~CAI,I<ORNI*

QSIRS ATTACHMENT l CIIOCNCW O'RORKC OCNCAAl HANA4CR Responds to: N/A February 5, 1982 GEWP-2-82-17 RESPONSE REQUESTED BY: N/A Dr.R.G.Natlock Program Director, WNP"2 Washington Public Power Supply System P.O.Box 200 ttail Drop 9Q60 Richland, Washington 99352

Dear Dr.Matlock:

'UBJECT: M02808 MPPSS HANFORD 2 CONTRACT 2 GENERAL ELECTRIC DESIGiN CONTROL PROGRAt1 As requested by B.A.Holmberg on February 5, 1982, the'fo',lowing is the description of the General Electric Design Control Programs for your use in discussions with the NRC.The General Electric commitment to provide a design control program for the Mashington Public Power Supply System's Hanford 2 plant is documented in Volume V, Tab.1, Part II of the contract.A detailed description of the General Electric design control program to be applied to the Hanford 2 plant is documented in the Preliminary Safety Analysis Report (PSAR), Volume', Appendix 0, Sections 0.4.2,"Classification of Systems 8 Components," and 0.4.3"Design Control." The PSAR was docketed by the AEC in August 10, 1971.The design control program described in Sections 0.4.2 and 0.4.3 of the PSAR addressed:

classification of systems and components within the General Electric scooe of su"ply as safety essential or non-safety essential; general design'control commitments; system design;overall design review;component design;design of purchased equipment; design of General Electric manufactured mechanical equipment, fuel, instrumentation and controls;and field change control.On Harch 19, 1973 a construction permit, for Hanford 2 was issued to Washington Public Power Supply System based in part on the above identified PSAR sections.Beginning in August 1971, the date the PSAR was docketed, the General Electric.design control program for Hanford 2 was implemented as described in the PSAR.Subsequently, however, the design control program has undergone numerous revisions, descriptions of which are contained in Section 3,"Design Control," oi the following General Electric documents:

Dr.R.G.Matlock Page 2 February 5, 1982 o Nuclear Energy Division Boiling Water Reactor guality System Summary, Revision 1-T, March 17, 1971 o Nuclear Energy Division Boiling Mater Reactor guality System Summary, Revision 2, September 15, 1971 o Nuclear Energy Division Boiling Mater Reactor guality Assurance Program Description, Revision 3, June 1, 1972 o Nuclear Energy Division Boiling Mater Reactor guality Assurance.Program Description, Revision 4, Narch 1, 1973 (NEDO-11209) o Nuclear Energy Division Boiling Water Reactor equality Assurance Program Description, NED0-11209-01, Nay 1974 o Nuclear Energy Division BMR guality Assurance Program Description, NED0-11209-02,'ecember 1975 o Nuclear Energy, Division BMR guality Assurance Program Description, NED0-11209-03A, November 1976 o Nuclear Energy Division Group BWR equality Assurance Program Description, NEDO"11209-04A, Harch 1978 o Nuclear Energy Business Group BMR guality Assurance Program Description, NED0-11209-04A,=

Revision 1, February 1980 o Nuclear.Energy Business Group BWR equality Assurance Program Description, NED0-11209-04A, Revision 2, October 1980 o Nuclear Energy Business Group BWR guality Assurance Program Description, HED0-11209-04A,-Revision 3, August 1981 NED0-11209-03A, November 1976, and all subsequent revisions of NEDO-11209 have been accepted by the NRC as guality Assurance Licensing Topical Reports.The General Electric.design control program described in'NED0-11209-04A, Revision 3, Section 3,"Design Control,"'addresses:

general design control commitments; design interface control;system design;standard reactor island design;design of purchased.

engineered equipment; design of-reactor equipment components; design of controls and instrumentation;

-.design of fuel;design of high-density fuel storage equipment; design verification; team design review;design change control;field change control;design change application.

The design control program described in HED0-11209-04A,'evision 3, Section 3,'"Design Control," is being implemented currently on General Electric design work being done on Hanford 2.,0 Dr.R.G.Matlock Page 3 February 5, 1982 In summary, the General Electric assurance of design control is based on a very rigorously

'applied design control program.We have had a gA design control program in effect since 1969 and have continuously updated this program to meet our changing organization and Regulatory requirements.

As can be seen in Attachment 1 (GE Hanfoi d 2 Design Control Program)and the NEDO-11209 documents listed above','he General Electric Design Control Program is a well defined and docu.ented program which assures General Electric control of all design, testing and modification.

The basic General Electric Design Control Program applied to General Electric work for the Hanford 2 was and is a generic program applied to all General Electric nuclear power plant design work performed from August 1971, the date the PSAR for Hanford 2 was docketed, to the present time.Since August 197l, the.General Electric Design Control Program has been audited extensively by the Washington Public Power Supply System and other General Electric utility customers.

There have been as many as 30 audits a.year conducted by the Washington Public Power Supply System and other General Electric utility customers during the past ten years.Additionally, the AEClNRC has conducted two to four annual inspections-of the equality Assurance Program including at least one annual inspection of the design control program starting in 1974.ln addition to the external audits, audits are also conducted internally by NEBO.Attachment 2 summarizes the results thru 1981 of independent audits conducted by two NEBO or'ganizations whicn are assigned responsibilities for audit of the GE Nuclear Energy Business Operations (NEBO)Design Control Program applied to Hanford 2 and other nuclear projects.A description of their functions and a summary of the audit results are given below: 1.Nuclear Energy Product IK guality Assurance Operation (NEPII(AO) reports directly to the Vice President and General Manager, NEBO, and is assigned responsibility for auditing the NEBO engineering and project management organizations for compliance with approved quality systems, procedures, and instructions.

2.During the past 10 years, NEP8(AO conducted 47 audits of the design control program applied to Hanford 2 and other nuclear power plants thru 1981.These audits resulted in 552 findings.Satisfactory corrective actions have been taken for 544 of the findings.Satisfactory corrective actions have been formally committed and scheduled to close out the remaining 8 items.3.The Nuclear Reliability Engineering Operation (NREO)reports directly to the Vice President and General Manager-Nuclear Engineering Division, and is assigned responsibility for Dr.R.G.Matlock Page 4 February 5, 1982 conducting periodic audits of design activities that affect product quality.The NREO auditing organization was formed during 1975 primarily to provide assurance of compliance with the increased design control requirements stemming from ANSI Standard N45.2.II and Regulatory Guide 1.64'.Ouring the past 6 years, NREO has conducted 39 audits of the design control program applicable to Hanford 2 and other nuclear power plants.These audits resulted in 212 findings.Satisfactory corrective actions have been taken for 201 of the findings.Corrective actions have been formally committed and scheduled to close out the remaining 11 findings.The above describes the basic design control program and outlines the reasons.we feel we have maintained a rigorous design control program and have confidence in our system.Very.truly yours c~C~'..i, Eugene W.O'Rorke Attachments cc: F.A.MacLean, w/att.R.E.Skavdahl, w/att.M.M.Allison J.A.Forrest J.H.M.Miller, w/att.R.E.Snaith File No.22.2 GE MAHFORD 2.GH CONTROL PROGRAM e GENERAL DESIGN REQUIREt1ENTS DEFINED-ACTIVITIES CONTROLLED BY DOCUt1ENTED SYSTEt1S AND PROCEDURES.

QUALITY REQUIRt1ENTS AND STANDARDS SPECIFIED IN DESIGN INPUT DOCUMENTS.

MATERIALS, COllPONENTS, AND PROCESSES SPECIFIED AND CONTROLED IN THE DESIGN DOCUMENTS.

DESIGN VERIFICATION PERFORt1ED BY INDEPENDENT VERIFIERS.

CMAHGE CONTROL IHPLEHENTED TO SAME LEVEL AS ORIGINAL DESIGNS..OHE SYSTEH FOR DESIGN CONTROL IHPLEHENTED FOR BWR DESIGN ACTIVITIES.

INTERFACE CONTROL DESIGN DOCUMENTS REVIEWED FOR INTERFACE COflPATIBILITY PRIOR TO FINAL ISSUE.INTERFACES DOCUl1ENTED AND CONTROLLED AS DESIGN INPUTS AND DESIGN INTERFACES.

PROCEDURAL INTERFACES DEFINED BY ENGINEERING OPERATING PROCEDURES.

DESIGN PROCESS DESIGN SPECIFICATIOHS TIED TO PROJECT REQUIREHENTS

-APPROVED AND APPLIED BY CONTROLLED SYSTEM.DESIGN SPECIFICATIONS FORM TME BASIS FOR DETAILED SYSTEM, STRUCTURE AND COMPONENT DESIGNS.STATUS tlAINTAINED BY COHPUTERIZED ACCOUNTING SYSTElt.INDEPENDENT DESIGN VERIFICATION PERFORt1ED FOR CURRENT DESIGNS.DESIGN FREEZE PERFORt1ED AFTER REVIEW AGAINST BALANCE OF PLANT (FURNISHED OUTSIDE GE)AND CONTRACT REQUIREMENTS.

DESIGN t1AINTAIt<ED UtdDER FORttAL CHANGE CONTROL-DESIGN llISTORY TRACEABLE AND RETRIEVABLE.

f'AH: vf/105L ATTACMt1ENT 1 PAGE l OF 0 GE ItAtlFORD 2 DESIGtl CONTROL PROGRAM DESIGN VERI F ICATIOt)CURRENTLY PERFORHED ON DESIGN DOCUMENTS USING OtfE OR A COHBINATIOtt OF TIIE FOLLOWING APPROVED HETllODS.o It)DE PENDENT DESIGN REVIEWS o QUALIFICATION TESTING o ALTERtNTE CALCULATIONS o INDEPENDENT CllECKIt<G PROCESS STRENGTIIENL'0 AND EVOLVED OVER TIIE YEARS-CllRONOLOGY OF CIIANGES FOLLOWS: o OCTOBER 1969 TO JUNE 1972-SAFETY RELATED DESIGNS REVIEWED OR CIIECKED FOR ACCURACY.o JUtlE 1972 TO tNY 1974 SAFETY RELATED DESIGNS FORtNLLY VERIFIED-RESULTS DOCUMENTED.

o HAY 1974 TO SEPTEHBER 1977-.SAFETY RELATED DESIGNS FORHALLY VERIFIED WITH RESULTS AND IDENTIFICATION OF.VERIFIER DOCUHENTS.

o SEPTEMBER 1977 TO MARCH 1978-INDEPEtlDEtlT VERIFICATION PROGRAM EXTEtlDED TO DESIGNS SAFETY AtlD NONSAFETY RELATED.o tlARCN 1978 TO PRESENT REQUIRHENTS FOR USE OF SUPERVISORS AS VERIFIERS DOCUMENTED IN ADVANCE OF VERIFICATION.

~pl: vf/105L.'"'~CIIHENT 1 20F4 GE ItAtlFORD 2 Gtl CONTROL PROCiR/N-DESIGN RECORDS FORMAL DESIGN RECORD fILES (ORF'S)REQUIRED FOR ACTIVITIES SINCE 1975.OESIGtl RECORD fILES TREATED AS PERttAttEHT LIFETIttE RECORDS.o HICROFILtlED Itl DUPLICATE.

o COPIES OF FILES llAINTAINEO IN OFFSITE VAULT.o RETAINED FOR LIFE OF POLlER PLANT.FIELD CHANGES CONTROL CHANGES RESULTING fROtl FIELD DEVIATION DISPOSITION REQUESTS REVIEWED AND APPROVED BY EHGINEERIHG.

ENGINEERING CttAHGE tlOTICES ISSUED TO CtkAHGE DESIGNS.CONFIGURATION RECORDS OF DESIGN CHAtlGES tlAINTAltlED AS PERINNENT RECORDS.FRH:vf/105L ATTACtltlEHT 1 PAGE 3 OF 4 GE IIANFORO 2 DESIGtk CONTROL PROGRAM DOCUHENT CONTROL DESIGNS FORt>ALLY DOCUVEHTED, ISSUED ntlO COHTROLLFD.

DISTRIBUTION CONTROLLED TO USERS AND ItlTERFACIHG I-UWCTIOHS.

DESIGN flISTORY NAIHTAIHED AS LIFETINE ARCIIIVE RECORD FOR ORIGItlAL DESIGN AHD CftAttGES TIIERETO.CflANGE CONTROL tlhtlAGEHENT Cftht4GE CONTROL BOARDS AHD ADDITIONAL CllAHGE CONTROL CffECK POINTS ADDED SINCE 1975 TO IHPROVE qUALITY AHD APl LICATIOH.CftANGES AUTflORIZED OH EHGINEERIHG DOCUllENTS BY CONTROLLED EHGIHEERIHG CflAtlGE NOTICES (ECN'S)ONLY.p.rf/105L~fit>EWT 1 j co~i tlUCLEAR EWf:RGY BUSItlESS OPERATIONS (NEBO)AUDITItlG RESPONSIBILITIES AtlD AUDIT RESULTS RELATED TO DESIGN CONTROL PRODUCT 8c UALITY ASSURANCE OPERATION (RESPONSIBLE DIRECTLY TO TflE VICE PRESIDENT AHD GENERAL MANAGER, NEBO)AUDITING THE NEBO ENGINEERING AND PROJECT llAWAGElfENT ORGAtlIZATIONS FOR COtfPLIANCE MITH APPROVED QUALITY SYSTEllS, PROCEDURES AND INSTRUCTIONS.

YEARS OF AUDITS 1971-1981 NUMBER OF AUDITS 47 NUNBER OF FIND I tlGS.552 FINDINGS OPEN AT END OF 1981 RELIABILITY EHGINEERItlG OPERATION (RESPONSIBLE DIRECTLY TO TflE VICE PRESIDENT AND GENERAL HANAGER, NUCLEAR tl RN 0 CONDUCTING PERIODIC AUDITS OF DESIGN ACTIVITIES THAT AFFECT PRODUCT QUALITY.YEARS OF AUDITS 1976-1981 HUt1BER OF AUDITS tlUNBER OF FINDINGS 212 FINDINGS OPEN AT EHD OF 19&1 FAN: r f/105tf ATTACHHEHT 2 PAGE 1 OF 1 J

APPENDIX B APPENDIX 8 INDEPENDENT TECHNICAL REVIEWS The purpose of this Appendix is to present in one location a discussion of the completed or ongoing, major independent technical revi ws of the Burns and Roe scope of design of WNP-2.The reviews have encompassed a large percentage of the Burns and Roe design.The depth of the reviews has varied;however, in general the depth has been sufficient to ensure a definite and positive con-tribution to th adequacy of d sign.Th ac omplishnent of these r vi ws, in conjunction with their corrective action, provide an improved level of confi-dence in the quality of the design of WNP-2.The following areas of independent technical'review are discussed:

o Burns and Roe off-project audits and Special Design Reviews,-o General Electric reviews of Burns and Roe design, o Supply System reviews of Burns and Roe design, o Review of pipe hanger criteria and procedures, and o Bechtel Engine ring Management reviews of Burns and Roe design.

A.Burns and Roe Off-Project Audits and Special Design Reviews Since the beginning of the WNP-2 Project, Burns and Roe has performed regular Technical Engineering Audits on their design with of f-pro ject engine ring personnel, i.e., personnel from corporate staffs or from other Burns and Roe projects.In addition, Quality Assurance Audits on the WhP-2 d sign proc ss are frequently performed by the Burns and Roe Corporate QA organization.

To address the issue of design verification raised during an NRC audit of Burns and Roe, in-depth Special Design Re-views have been performed on specific systems by off-project engineers.

These audits and reviews are considered to be independ nt, specifically the auditing/reviewing engine rs have not been previously involved with the design of WNP-2.It is concluded that the performance of the audits and reviews provide additional confidence in the design adequacy of WNP-2 (refer to the following paragraphs for details).1.Technical Engineering Audits To insure the adequacy of design, procedurally controlled, Technical Engine ring Audits are scheduled semi-annually on each engineering discipline of the WNP-2 Project by engineers from the staff main-tained by the Burns and Roe Engineering and Design Division.These audits are initiated'nd administered by the Burns and Roe Corporate and project Quality Assurance organizations and are under the tech-nical control of the Burns and Roe Chief Engineers.

The cognizant Chief Engineers assign of f-project engineers from their staf f or from other projects to perform the Technical Engineering Audits and specify the area to be audited.The objective of these audits is to"'ssure that the detailed design complies with the basic criteria established for the design and that proper engineering practice is being used.The auditors review the design for compliance with such'ocuments as the Engineering Criteria Document, PSAR/FSAR require-ments, and NSSS requirements.

The audits are formally documented and findings issued.Each finding issued requires that appropriate corrective action be specified and implemented to the satisfaction of the cognizant Chief Engineer.Upon resolution of all findings, the auditor r views the deficient areas and, if satisfactory, closes the audit.Documentation of these audits are contained in the Burns and Roe project files.The Technical Engine ring Audits were performed in accordance with Burns arid Roe procedures 2808-Q-4.8 (home office)and WNP-2-043 (site)..~The Scope of the individual audits has varied considerably; however, in general, the audits have been in-depth, i.e., to the detailed level.Typical docum n'ts associated with the audits are: o Burns and Roe Engineering Criteria Document, o WNP-2 PSAR/FSAR, LO o General Electric PAIOs, Process Diagrams, Functional, Control Diagrams, Design Specification Data Sheets, System and Com-ponent Design Specifications, etc., o Burns'nd Roe prepurchase and construction specifications, o Burns and Roe calculations, and o Burns and Roe general arrangements and flow, one line, logic, and elementary diagrams.Representative categories of comments and findings from the Tech-nical Engineering Audits include: o>Hath errors, o improper assumptions and applications, o Insufficient or erroneous design input and lack of reference to source data, o Needed document revisions for reconciliation with design, o Improper sequ ncing of events, o Lack of r ference to equation sources, o Errors in drawings and diagrams, o Improper function of hardware due to design error(s), and o Lack of incorporation of NSSS/BOP interface zequizements.

Refer to Attachment 1 for a typical Technical Engineering Audit.Since November 1972, ninety eight (98)of these audits have been performed.

Refer to Attachment 2 for a list of the audit subjects.2.Quality Assuzanc Audits In accordance with 10CFR50, Appendix 8, internal Quality Assurance Audits of WNP-2 Project activities are conducted by Burns and Roe Corporate Quality Assurance personnel.

These personnel are not as-sociated with the WNP-2 Project.The audits, which are procedurally controlled and docum nted, are performed to evaluate: 1)the ade-quacy and effectiveness of the Burns and Roe project related Quality Assurance Program, and 2)the implementation of the quality affect-ing procedures by project personnel.

In cases where the project does not have its own procedures for specific areas, Burns and Roe Corporate standard procedures govern.

Deficiencies identified during the audits are docunented and discus-sed with Burns and Roe Project Management to assure adequate under-standing o f the findings, so meaningful corrective actions are taken.Re-audits of deficient areas are performed on a tim ly basis to verify implementation of the corrective action.Audit closure is accomplished by memorandum to the Burns and Roe Project Manager.Docunentation of these audits are contained in the Burns and Roe project files.The Quality Assurance Audits were originally performed to a check-list with focus on compliance to and understanding of t¹general 10CFR50, Appendix B requirem nts.The areas audited were Engineer-ing, Construction Management, Quality Assuranc , and contractor (supplier) interface.

Engineering activities (design process)were audited approximately twice each year.Later in the Project, the audits were performed with a standardized Audit Finding Report form which referenced the specific item or criterion of 10CFR50, Appendix B that was being aud'ted.Refer to Attachments 3 and 4 for examples.The Quality Assurance Audits w re performed in accordance with Burns and Roe procedures 2808-Q-4.3 and WNP-2-QA-001.

Examples of engineering activities which are audited include: o Implementation of procedu e requirements, o Control and implem ntation of design changes, o Content and approvals of design information and documentation, o Use of and referenc to design input data, o Use of as-builts, o Use of stop work and engineering holds, o Generation and changes to prepurchase and construction specifications, o Design interface'ctivities, o Training and indoctrination, o Changes to the Engineering Criteria Document,.~o Use and applicability of Burns and Roe Technical Standards, and o Use of commitment tracking systems and tickler files.Since August 1971, thirty nine (39)of these audits have been p r-formed on Bur'ns and Roe engineering activities.

Refer to Table 1 for a list of the engine ring related audits.jO Special Design Reviews The Burns and Roe Engineering and Design Division contains a depart-ment responsible to perform design reviews in accordance with es-tablished procedures (NNP-2-ED-013).

A number of these reviews were performed in'-compliance with ANSI N45.2.11 using a design input and design verification checklist.

NNP-2 is not committed to ANSI N45.2.11;therefore, these design reviews are not performed on all systems.Special Design Reviews are, and have been, performed at the request of Burns and Roe Project Management or a Chief Engineer.The design review is performed by a team of senior engineers selected from other projects or departments not associated with the design of NNP-2.This ensures an independent, third party check.The results of the review are documented and the review remains open until all findings are resolved.Special Design Reviews, performed to WNP-2-ED-013 in compliance with ANSI N45.2.11,'have been performed on the following systems: o High Pressure Core Spray, o Low Pressure Core Spray, o Residual Heat Removal, o Standby Servic Mat r, and o Standby AC Power.The r vi w covered only items w'thin the Burns and Roe scope of design.In addressing the NRC audit issue of design verification, it was proposed that by Burns and Roe performing these reviews on random safety systems the results would demonstrate the adequacy of the Burns and Roe d sign process.The Special Design Reviews evaluated the design of the selected systems in the various operational modes against the Burns and Roe design criteria, the interface require-ments from the NSSS, and applicable NRC requirements.

If no safety significant findings were identified, then the conclusion would be that the design process was satisfactory.

The definition of a safety significant finding was the following:

o If the finding had not be n identified, would the functional capability of the system be impaired such that it could not perform its design safety function, and o If the answer to the above was yes, was the finding unknown and not being addressed prior to the Special Design Review.-B inherent with the second question is that the design was complete and not in-process.

From the five (5)Special Design Reviews, a total of forty nine (49)findings were identified and independently reviewed by Burns and Roe and the Supply System.It was determined by both organizations that none of the findings were safety significant.

Those findings re-quiring followup action have, or are being completed and closed out.Special Design Review SDR-80-6, Residual Heat Removal System, is provided as Attachment 5.The evaluations of the individual find-ings of SDR-80-6 are provided as Attachment

6.

General Electric Reviews of Burns and Roe Design General Electric (GE)has a policy to ensur that the NSSS safety-related BOP interface requirements are understood and properly implemented by the Architect Engineer (Burns and Roe).This function prior to 1979'was per-formed by GE by div rse means: day-to-day project management correspon-dence, participation in the preoperational and power ascension proce-dures, physical review of the plant, and participation in the preopera-tional and power ascension tests.Additionally in 1979, GE assigned qualified representatives to an inde-pendent, permanent design review team.This team, composed of members of domestic projects and systems engineering departments, review each pro-ject, including the NSSS/BOP interface, using selected questions that have been developed by the GE lead systems engineers based on importance to safety, operability, and problems previously identified on other projects.The team assigned to review the NIP-2 design interface in 1979 submitted a list of questions to Burns and Roe which addressed the Nuclear Boiler, HPCS, RCIC, RHR, LPCS, and Off Gas, and specific environmental require>>ments for equipment.

The review was lim'ted to the quest'ons submitted by GE (refer to Attach-ment 7)and subjects that arose as a result of the in-process review.The first review was conducted at the Burns and Roe offices in New York in December 1979 with particioants from the Supply System, Burns and Roe, and GE.The review was concluded with seven (7)open items to be closed by the responsible project organization.

These open items were subse-quently resolved.Documentation of the findings and their resolution is contained in the Burns and Roe project files.In December 1980, GE conducted another BOP interface review.The systems and equipment reviewed included: o Refueling and servicing equipment, o Orywell cooling requirements, o Control Rod Drive System, o Leakage Control System, o Feedwater Control System, o Emergency AC Power System, o DC Power System, o Turbine Generator Control System, and o Main steam piping, contaiment to the turbine.

The review was held at the WNP-2 site with the Supply System, Burns and Roe, and GE in attendance.

This review also concluded with a minimum number of open items to be addressed by the responsible project organiza-tion for resolution and closure.In addition to these large BOP interface reviews, there have been fre-quently scheduled meetings addressing specific interface items and the general progress of the design of the project betwe n the Supply System, Burns and Roe, and GE.Conference notes of these meetings are located in the Burns and Roe project files.Examples of specific Burns and Roe de-sign areas discussed/reviewed in this manner include: o Feedwater controls, Flow element location Mixing relative to enthalpy requirements Transient response requirements Low flow control Operating.

logic Feed pump details o NSSS/turbine generator interface, Turbine sequence monitoring Turbine system analysis for interaction and compatibility with the NSSS (e.g., valve closure and load rejection)

Reactor Recirculation System transfer (auto to manual)Interlocks o.Containment layout of pipe whip'restraints,'

-Drywell cooling (heat load), o Main steam safety relief valve discharge line pressurization, o Electrical separation, o Containment vessel retrofit program in general, N 4 o Hydrodynamic loads, and o Loads on submerged structures.

-B In addition, certain areas of the BOP design which may affect the safety or performance of the NSSS were provided to GE for review and comment.Related problems or concerns identified by GE were primarily addressed to Burns and Roe by formal correspondence.

Examples of these subject areas include: o Mater quality and sampling thereof, o BOP accommodations, Primary containment

'ompatible seismic characteristics for NSSS components Shielding of radiation sources Compatible turbine generator and steam bypass capacity Compatible wiring, cable, and tubing Reactor pressure vessel (RPV)and NSSS piping thermal insulation RPV to containment refueling bellows seal RPV pedestal and sacrificial shield wall NSSS equipment foundations NSSS equipment drain 1'nes Details of radioactive waste processing o Utility services for NSSS (mechanical), Cooling water Makeup water Emergency equipment cooling water Ventilating, heating, and cooling Plant air o Utility services for NSSS (electrical)

Standby AC power Plant OC power (120V/240V) 24V OC power.-8>>9-C.Supply System Review of Burns and Roe Design The Supply System has had extensive involvement in the review of the Burns and Roe scope of design.The types and focus of these reviews to be discussed, have varied over time.The main areas of review include the following:

o Contract technical specifications, o Specific technical subjects, o Design of specific systems, o New design to address industry/NRC issues and concerns, o Changes to design, and o PSAR/FSAR (refer to Appendix A).Each of these categories is discussed in the paragraphs below.It is believed that the broad scope of these reviews and their general depth have contributed to an improved quality of the design of WNP-2.1.Contract Technical Specifications The general process of producing contract technical specifications is discussed in Appendix A to this report.A flow chart of the Sup-ply System internal review process in illustrated in Figure 1 (PMP 4-8.8).The Supply System cognizant Reviewing Engineer had the fcrllowing:..

pertinent responsibilities:

o Review the specification for te'chnical adequacy,.

o Prepare an Engineering Design Review Checklist (refer to At-tachment 8)for Quality Class I Specifications, and o Docunent significant Supply System comments on an Comment/Resolution Form (refer to Attachment 9).In the process of these reviews there were required supplementary reviewers.

Their responsibilities were: o Licensing Engineer-Review the specification to ensure that PSAR/FSAR and Environmental Report commitments and regulatory requirements were included, o Operations

-Review the specification.for proper consideration of the operability and maintainability of equipm nt, systems, and/or structures, and o Quality Assurance-Review the specification to ensure the ade-quacy of the quality assurance requirements.

There reviews were performed by the Supply System, through the time'period that the Project was issuing construction and prepurchase contracts.

As the issuance of design changed from major areas to bits and pieces, i.e., the design was essentially complete, the re-view was primarily turned to Project Change Notices and Project En-gineering Oirectives.

The discussion.

of the review of.these docu-ments is the subject of a following paragraph.

The Supply System review of the contract technical specifications is considered to have been a third party check of these documents.

2.Specific Technical Subjects Numerous t chnical subjects within the Burns and Roe design scope were reviewed by the Supply System and discussed in meetings with Burns and Roe.Ref r to Section IX (addressing conf rence notes)of this Appendix for examples.It should be mentioned here that the Supply System has had extensive involvement in the development and progress of the Containment Vessel Retrofit Program (CVRP)for WNP-2.The CVRP addresses the results from the analyses of poten-tial thermal-hydraulic loading conditions due to main steam safety/relief'valve (SRV)discharge and postulated loss-of-coolant acci-dents (LOCA)in BWR olants having a.Mark II pressure suppression containment system.The activities of this program include: o SRV considerations, Line clearing load Quencher arrangenent in the suppression pool Quencher discharge load 0 Quencher condensation performance Submerged structure loads o LOCA considerat'ons, Pressure and temperature transients Vent clearing and pool swell loads Loads during condensation oscillation Loads during chugging Steam condensation loads on submerged structures o Load conbinations, o Fatigue considerations.

ln addition to the above, the Supply System performed a recent eval-uation of the Burns and Roe hange and stress activities.

The ob-jective of this evaluation was to assess the processes and methodo-logies currently being implemented by Burns and Roe in finalizing the piping and hanger designs and to make recommendations for im-provement.

This evaluation addressed administrative and technical matters.Pertinent issu s warranting mention are: o Resolution of faulted-end movements (seismic, LOCA)as related to analyses of supports, o, Resolution of loads to be included in seismic boundary anchors (non-seismic piping reaction to an earthquake), o Preparation of a stress design guide and a controlled reference sunmary to improve calculation quality, and o Improvem nts in the documentation of stress and pipe support calculations.

System Design Reviews In Dune 1977, the Supply System initiated system design reviews.Input to these reviews consisted of: 1)recommendations based on" the review of the initial pilot system, and 2)the review and under-standing of the Burns and Roe design process.The review of the process included the flow of information between Burns and Roe en-gineering disciplines and the flow of information from vendors.In addition to the process review providing insight to the Supply Sys-.tem reviewing engine rs, recommendations for improvements were made.to Burns and Roe.System design revi ws were perform d on thirty two (32)systems, refer.to Table 2.The revi wing engineers were of the nuclear/mechanical, electrical, and instrumentation and control disci-plines.The reviewing engineers were to focus on the identification of design errors that could prevent the system from operating as required or that could pose concerns relative to licensability.

Standard documents used in the process of this review consisted of: o Burns and Roe Engineering Criteria Docunent, o PSAR/FSAR, o Design specifications, o Flow, logic, elementary, process, and analog loop diagrams, o Instrument data sheets, and o Master Parts List (MPL).gO-8 The review typically consisted of the following (as applicable):

0'nterface between mentation Diagram I Interface between related Burns and the General Electric (GE)Piping and Instru-and.the Burns and Roe flow diagram, the GE logic and elementary diagrams and the Roe logic and elementary diagrams, 0 Interface between major equ'ipment suppliers and the Burns and Roe design, o Interface between the Burns and Roe logic and elementary diagrams, o Interfac between the GE logic and el mentary diagrams, and o Review of instzunent data sheets, MPL, design specifications, etc.for correctness.

The comments and findings identified during this review were docu>>mented (refer to example, Attachment 10)and resolved.4.Project Change Notices and Project Engineering Directives The use of the Project Change Notic (PCN)and Project Engine ring Directive (PED)is discussed in Appendix A to this report.Briefly, these documents are used to implement new design or design changes.'he Supply System initiated reviews of PCNs in Duly 1975, and of PEDs at their inception in August 1978.Revi wing engineers originally performed zoviews on all PCNs and used a checklist wnich addressed the reason/need, technical impact, cost, and schedule.The depth of the review was dependent on the magnitude and natuze of the proposed new design or design change.In 1977, the revi w of PCNs was further formalized by the issuance of a Project Management Procedure which governed this activity.Particular att ntion was drawn to the soundness of the proposed de-sign change and its related details.Emphasis was applied to: o Revisions to regulatory commitments, o Revisions to drawings, specifications, and procurement documents, o Equipment procurement or modification, and o Equipment installation, test, and operating requirements.

In the performance of this review, the Supply System defined the PCN as a Design Change Notice (OCN), Design Change Review (OCR), or'De-sign Change Study (DCS), depending on the nature of the PCN.Refer to Attachment 11 for details.

In August 1978, PcDs were initiated as a design change docum nt.In the same time period, due to the volume of design changes (PEDs and PCNs)and the observed benefits from their review by the Supply Sys-tem, minor design changes were eliminated from the formal review process.The Supply System criteria for requiring review became: o Deviation from SAR or environmental commitments, o Deviation from design criteria or from applicable codes and standards, o Change in safety or quality classifications, o Reduction in operability or'maintainability, o Total cost of change exceeds$50,000, or o New design.PCNs and PEDs were sent to the Supply System.The'implementation of the criteria for review was performed by the Supply System reviewing engineers.

As before, the reviews were performed in a formaliz d manner, refer to Attachment 12, with continued emphasis on technical adequacy.During the next several years, in order to better control design changes (PCNs)originated by the Burns and Roe New York office, all PCNs issued during certain time periods were reviewed by the Supply System.Similar reviews were performed as discussed above.In March 1981, a project reorganization occurred which placed the majority of the previous Supply System, WNP-2 Project Engineering-staff directly into Burns and Roe as new employees.

This chang resulted in the remaining Supply System Project Engineering Staff-being significantly reduced, retaining very senior engineering and engineering management personnel.

Since this time, the focus of reviews has been on select engineering issues, not including the day-to-day design changes.Quality Assurance Audits Similar to the Burns and Roe Corporate Quality Assurance (QA)audits discussed in subsection I of this Appendix, the Supply System per-forms routine audits of the Burns and Roe WNP-2 Project to assess the compliance of the design process with SAR commitments, ANSI N45.2, 10CFR50, Appendix B, and implementing procedures.

These audits are performed on each Burns and Roe design office (New York, site, and Richland offices)twice each year.Supply System Cor-porate Quality Assurance has performed the reviews on the New York office.Corporate and Project QA have shared the audit responsi-bilities for the Burns and Roe site and Richland offices.-B The audits.are procedurally controlled and documented.

1dentified deficiencies are discussed with Burns and Roe Project Management, resolved, and re-audited to, verify implementation of corrective action.Examples of areas audited include: o Implementing procedure compliance with SAR commitments, ANSI N45.2, and 1OCFR50, Appendix 8,'Review.and approval of Burns and Roe drawings and diagrams, o QA requirements of specifications, o Consistency of QA documentation requirements and content, o Burns and Roe auditing performance, o Implementation of design changes, o Performance of calculations, o Management followup on corrective action, o Oesign control process used to produce the design of the stand-by service water system, o Training, and o Review and approval by Burns and Roe of vendor information.

The Supply System audits have identified Burns and Roe QA defi-ciencies throughtout the history of WNP-2;however, basic compliance with the SAR commitments, ANSI N45.2, and 10CFR50, Appendix 8 have been established.

Of particular note is the reduction in QA find-ings in specific areas since 1978, e.g., improvements in procedure and instruction compliance, and corrective action implementation by Burns and Roe management.

Continued C ficiencies, however, have been observed in the stress discipline.

Supply System management is aware of this problem and has recently taken additional corrective

-action to minimize recurrence. 15-D.Review of Pipe Hanger Criteria and Procedures In June and July 1980, EDS Nuclear, Inc.under contract to the Supply System performed an independ nt, technical review of the large-bore pipe hanger design methods, criteria, and procedures being used at WNP-2.The review was performed in accordance with the EDS Nuclear Quality Assurance Program.The results of this review were documented in EDS Nuclear Re-port No.01-0740-1101, dated July 31, 1980.The scope of the EDS review was to examine the large-bore (2 1/2 inch and above)pipe hanger design criteria and procedures used at NNP-2 for their technical adequacy and to provide a comparison of those criteria and pro-cedures with others being used in the nuclear industry.The procedure review was primarily limited to technical issues;however, some admini-strative areas were addressed.

The method employed in performing the task was to review the hanger cri-teria and procedures, and to conduct, interviews with individuals in the hanger group, in order to identify areas warranting further investigation and to obtain background information.

The following docum nts were reviewed: o Mechanical contract technical specification on pipe supports (Con-tract 215, Section 15Q), o Burns and Roe Hanger Grouo General Procedure and Design Instruction, o Pipe Support Design Guide and work procedures (M-400 through M-411), o Hanger Group Engineering Standards, o Burns and Roe internal hanger design review, o Lists of hanger engineer concerns, and;0 o Hanger calculations.

Interviews were conducted with the following groups: o Area engineers, o Personnel responsible for base plate testing, o Equipment qualification personnel, o Hanger designers, and o Burns and Roe site and home office management. 16-Based on the document reviews and personnel interviews discussed above, the following areas were identified for review and in-depth investiga-tions were performed:

o Support displacement, o Out-of-plane support design criteria, o Welded pipe attachments, o Valve/operator assembly modeling, o Base plates, o Load definition, and o Pipe clamp design.From this review, EOS Nuclear concluded that the large-bore pipe hanger criteria and procedures used at WNP-2 were for the most part technically acceptable and in accordance with the standards used in the nuclear in-dustry.Ma)or areas of concern were: o The method used for modeling valve masses in piping analyses, and o The design, qualification, and documentation of welded pipe attachments.

Since this review, these areas of concern among others of lass signifi-cance, have be n resolved.The specifics of the in-depth reviews are provided in the EDS Nuclear Report (01-0740-1101). 17-E.Bechtel Engine ring Management Group The Bechtel Engineering Management Group is a branch of the Supply System WNP-2, Project Engineering organization and provides staff support.The role of this group is to assist the Supply System in ensuring that all to-go engineering has been identified and to ensure engineering ap-proaches to specific issues, primarily NRC and industry concerns, are technically sound.In addition, specific areas of design, selected on the basis of history, and magnitude of concern are reviewed in-depth by this group to ensure technical adequacy.The Bechtel Engineering Manage-ment Group has a high degree of technical expertise with a number of years of, recent nuclear experience.

Refer to Table 3.In addition, the group has a direct interface, which is exercised frequently, with Bechtel staff support in their home office (San Franc'sco).

This provides con-tinuous input to the group of recent licensing positions, NRC actions and concerns, and changes in design methodology as they develop within Bechtel.Early in Bechtel's involvem nt on WNP-2, a list of to-go or potent'al to-go enginee ing items was developed.

Three principal sources were used for this list: 1)Burns and Roe and Supply System lists of remaining engineering activities; 2)Bechtel's Phase I Study of the WNP-2 Project;and 3)Bechtel's experience on other nuclear projects.The list is con-tinually evolving as new items are identified and existing items are re-viewed.Currently there are approximately 320 issues on the list with eighty percent (80X)of the entries having been assessed.Attachment.

13 is an index of these items.Attachment 14 provides typical examples of the Bechtel Fngineering Managem nt Assessment Form which is being com-pleted for each of the items on the list.The initial assessment is not a technical adequacy review, but rather it is an assessment to determine if Burns and Roe has recognized the task or problem and has a program in-place on WNP-2 to address it on a schedule compatible with construc-tion completion.

In addition to the initial assessments, as mentioned above, certain areas have been reviewed for technical approach and technical adequacy of the.existing design.In-depth design reviews are conducted based on Bechtel Engineering Management judgement of where the probability of design defi-ciencies are most likely.These areas are determined from Bechtel pre-vious experience, industry, and NRC problem areas (IE Bulletins, Problem Alerts, etc.)and where design changes are being made.The in-depth review areas include: o Small-bore pipe and hanger design, o, Under grounded conditions on high resistance systems, o Air line pressure drop to MSRV accumulators, o Fire protection requirements to meet Appendix R, (:.~

o Radiation shielding analysis, o Fatigue evaluation of MSRV, o Main steam turbine trip, o.Annulus pressurization piping analysis, o Hydrodynamic load application methodologies, o Large-bore stress analysis on selected areas (LPCS, etc.), o Hydrogen detonation effects on piping stress analysis, o Zero period acceleration effects, o Oynamic anchor movements, o, Raceway layout and cable presentation on'drawings, o Connection diagrams and scheme drawings (computerized cable schedules), o Cable separation, o Soil compaction, and o AC motor control center circuit voltage drop studies.A summary of the type of detailed review performed on two of the above subjects's provided in Attachments 15 and 16.In addition, from the various reviews, assessments, and inputs from Becht 1 experience, a number of design areas have been influenced/revised to varying degrees.The major areas are list d in Attachment 17;some overlap exists with the listing above.Bechtel is currently initiating a program for the Supply System to review ASMF Code piping/hanger designs.This rev'will look at a sample of pipe and hanger design calculations in detail by use of a documented checklist and is designed to give the Supply System a high degree of con-fidence in the technical adequacy and completeness of the design in this area.The checklists and governing procedure are provided as Attachments 18 and 19.Supply.System engine rs participate in.this review.-S-19>>

~gO TABLE 1 BURNS'AND ROE EQUALITY ASSURANCE AUDITS MNP-2 PROSPECT ENGINEERING AUDIT NO., DATE AREA REVIEWED BR81-5 BR81.-4 BR81-ls BR81-2 BR81-1 7/81 7/81 4/8T 2/81 1/81 Home Office Site and Richland Office Home Office (stress only)Home Office Site and Richland Office BR80-8/9 BR80-6/7 BR80-1S BR80-3.BR80-1/2 9/80 7/80 4/80 2/80 1/80 Home Office Site Site (Field Engineering)

Home Office Site BR79-8/9 BR79-6/7 BR79-4/5 BR79-1/2 7/79 7/79 3/79 1/79'ome Office Site Site Home Office BR78-11/12 BR78-8 BR78-6/7'R78-3/4 BR78-1 11/78 8/78 8/78 4/78 1/78 Site Home Office Site Site Home Office BR77-10 BR77-8 BR77-5 BR77-2 10/77 9/77 3/77 2/77 Site Home Office Site Home Office TABLE 1 (cont,)BR76-11 BR76-2S BR76-7 BR76-5 BR76-1 10/76 9/76 7/76 3/76 1/76 Site Home Office.Home Office Site Home Office BR75-8 BR75-2S BR75-1S BR75-3 8/75 8/75 7/75 2/75 Home Office Home Office Home Office Home Office No.1-74 10/74 Home Office 8/73 5/73 2/73 Home Office Home Office Home Office 11/72 4/72 Home Office Home Office 8/71 Home Office TABLE 2 SUPPLY SYSTEM SYSTEM DESIGN REVIEWS SYSTEM TITLE al ing tchgear Main and Exhaust Steam Extraction Steam and Heater Vents Condensate and Feedwater Heater Orains Miscellaneous Orains, Vents and Se Circulating Water Plant Service Water Control and Service Air Gas and Air Removal Auxiliary and Process Steam PlantMakeup Water Treatment Oemineralized Water Reactor Core Isolation Cooling High Pressure Core Spray Low Pressure Core Spray Residual Heat Removal Standby Liquid Control Reactor Water Cleanup Standby Service Water Reactor Building Closed Cooling Fuel Pool Cooling and Cleanup Condensate Supply Nuclear Boiler-Main Steam Condensate Oemineralization Off Gas Primary Containment Cooling.Standby Gas Treatment Reactor Building HVAC Radwaste Building HVAC Containment Atmosphere Control Miscellaneous HVAC Miscellaneous HVAC Control and Swi

0:0 Co W TABLE 3 BECHTEL ENGINEERING MANAGEMENT GROUP EXPERIENCE No.Engineers'otal Years Average Years~Ei~E Pipe/Hangers/Stress Mechanical/Nuclear 23 Electrical 56 19 Instrumentation 41 , Project Engineering Management 22 Total 15 226 15

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, FBP.MrfRAM3 VM CQPSES TD ELUH&il&03 I aaww SUBJECT cRPLcm H.K, Iwc:>>Z.Philipp StrMling/S.George aava".!.O.2COG-OQ Mashin ton PuMic Power Supply System Hanford Nuclear Proiec".-Ilo;2 Engineering Audit Ho.3 AJ Piehn TA Hendrich on db A t chnica'.adit of ice Proje t Zn-incoring wo I-covering the"Drywell Cooling System" was conducted by the Power"-ngineering Division.The audit was conducted in acco dance with T>P='-S r uality Assuranc Procedur 280-9-4.8 R v.O,-."th the ecce tion th-t no procurement specifications were reviewed.The audited"'rateria3.s were: 1.BaR Calculat'ons Ho.9.22;00 of Title"P7ZcC-Dr~;e3.1 Cooling System".'i 2>>M DrHwin-"oo i>>5':3p Pevo2 of'itle Al)4)At Art Gvi<<>>ver (yq4>>s pgcqt CcoI 4 qe Sy tarn"."Flow Diagram-"eactor I'keT4 4<<m<<~a Tamest~4~M<<yc 4 oQ<<t4~The ollowing technical engineering doc"-n s wer.eviG.se"'nd referred to--ba is for evaluating the audit d materials:

I.'.4;PPSS"nginc ing Criteria Document for Hanford'ko.2 Station (Revision 4).2 Sect'on","-ragrmh 7.0:-ating, Vent'@ting"nd Air Conditio"..'..g' 2~7;PPSS P"AR Vo'ume 2 Addendum 9 a.Section 5.2.3.7"Prier n=g Cc.'f ainrcnt To~al E at'ng, Ventilating and Air Condit.oni g~yste.." b.Section 5.2.3 8"2 ir;"-~Containment Environmental Cond'io.-.s.

3.G.E.Doc~ent~2o.22A2715A, Dev.O"D ywell Coo'ng System" which was referenced in calcul~c.s.'so.9.22.00 Attachment I

To<J Philipp Page 2 9-26-74 The audited materials wore found to meet the requirements of the Znginee"ing Criteria Document and the PSAR.However, the following technical deficiencies were identified:

1.Calculations Eumber 9 22 00 Sheet l a.A list of the arr naement drawings used to perform the calculations is not included.b.The"closed cooling w" ter" tc peratu"c ente irg the co'1 is given as 105=-.4'o:;ever, on"hc.t 12 o"~use calcula-tions, the water temperature is shown to'-e 95c~.Sheet 3 a.The ource of'he 657,000 3tu/h heat eleased fr~the reactor pressure vessel should be idcnti'ed as"G.=.Document Zo.22A271&4, Bev.0" instead of"Received fro G E Sheet 6 ar In the table shown, the columns titled" ensible Heat p B<<1/Ll luis Sea o a~<<ec and A<<<<{tunnel.a g C<<'"-u~<<o/<<3o/should be marked"VOIQ" s'nce the alterna"e sche.=e in=hect".12 of these calculations is using 25K~S." b.The"Sc am Condit"'on" shown at the bottom of the hect, should b ma ted"VOID" since thi condition i describ d in the alternate scheme,"beet 13 of these calculacicns.

Sh~et 7 a.The entire sheet should be m"!ed"VQXD-Use.Alternate Scheme-Sheet 12".'hect 12 a.State the basis for using the constant"0.9G" to develop the"Air Quantity/Unit".

b.State the source of the 95 E.design temperature of supply water.iHote that in hect 1, of these calculation

, you use 105oP.entering water temperature.

Sheet 13 a The source of the 3.,126,000 Btu/h released to the drywell during"Scram Condition" is not stated.jO

), To: J, Philipo Page 3 9-26 74 Sheet li a.The"Units" for air flows and heat loads are not shown.Sheet L5 a The"475,000" fiaure listed as heat release in Zone 2B is hewn as 425,000 Stu/h in'"eet 6 of these calculations.

b.The air auantity"3370 C.H",'shown in the.middle sheet,"hould he"33, ac0 CZ"".c.Under the heading"Suaply to Zone 2C", the 27~.~as"Supply a'r te.-.,perature" is actually"The air erature rise".of the given t~J&om~~2 B~+8'w iTo.5'5" 3 Rev.2 a.ln Sheet l5 o=calculation No.9.22.00, the capacity of each of tho upper and lower level cooling units i c-l-c'=Late"a-e"2,C30 C~~".Hcweve+in 3~~~Qwa Rev.2, th c"pacity of each of t!ie Lower l vel coc3.ing units, at hign=an speed, is indicated to be 36, 50 C:.."..and the capacity o each of tl e up"er level caoling uni=s is x.ndicat d to be 3=,000 C=i'.Stat:e th""=" an nor the diffe ence.

Q Og S~>>ge~~~~2 5'TNP-2 TEC$INICAL ENGINEERING AUDIT AUDIT NO.1 Revised: 12/17/81.Engineering Discipline Audited Sub ect Date of Audit Civil Reactor Building Foundation Mat development and final design 12/29/72 Electr ica 1 Auxiliary Power Trans formers Calculations 8/13/73 HVAC None Performed Instrumentation Control Valve Sizing C~lculations 11/9/72 Mechanical Turbine Generator Steam Bypass System and associated Relief Valve Augmented Bypass (REVAB)System 6 Sizing 1/16/73 Nuclear Fuel Pool Cooling and Clean-up System-Sizing, Mater Quality and Pump capacities 2/2/73 Stress Hain Steam and Reactor Feedwater Piping Flow Calculations 12/29/72 WNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.2 Page 2 Cont'd on 3 Date Engineering Discipline Audited Sub ect Date of Audit Civil Spray Ponds and Standby Service Water Pump House 12/10/73 Electiical None Performed fDJAC Reactor Building, Reactor Building Sump Exhaust, and Standby Gas Treatment HVAC Calculations 1/16/74 Instrumentation Control Valve and Instrumentation and Control Board Specification

-Contract 42 and 59 respectively 1/22/74 Mechanical Condenser and Auxiliaries Interfaces 1/21/74 Nuclear Solid Radwaste System 2/6/74 Stress Containment Penetration Design Loads 12/27/73'-

HNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.3 Page 3 Cont'd on 4 Date 9/17/80 Engineering Discipline Audited Sub ect Date of Audit Civil Reactor Building Roof Structural Steel 3/22/76 Electrical Separation of Electrical Circuits 10/7/74 ED1AC Drywell Coqling System 9/26/74 Instrumentation Instrumentation and Controls Compliance with AEC Regulatory Guides 10/15/74 Mechanical Pipe Stress/Mechanical Engineering Interface Data Traceabil ity 4/28/75 Nuclear Reactor Building Closed Cooling Hater System ll/14/74 Stress (See Mechanical)

HNP-2 THCIINICAL ENGINEERING AUDIT AUDIT NO.76-3 page 4 Cont'd on 5 Date 9/17/80 Engineering Discipline Audited Sub ect Date of Audit Civil Turbine Generator mat and walls, Reactor building mat 5/14/76 Electr ica'1 Calculations performed for the Reactor building and the Turbine Generator building 4/6/76 EIVAC Diesel Generator building HVAC System 2/10/76 Instrumentation Instrumentation and Control Spec.2808-92, Section 50A 8/2 3/77 Hech an ica 1 Calculations for the Turbine Generator building 4/2 3/76 Nuclear Standby service water system 5/14/76'~Stress Safety Related pi"'ng (Interim Analyses)-0 2/8/~8 LltlP-2 TECHNICAL, ENGINEERING AUDIT nnnxT so.76-6 Page 5 Cont'on 6 Date 9/17/80 Engineer ing Discipline Audited Sub ect Date of Audit Civil Electrical Sensitivity studies for Reactor Building soil/structure interaction element seismic analysis (Parametric Studies)Certify compliance with 10CFR50,Appendix A,Criterion 17 nd Regulatory Guide 1.32 with regard to power provisions f the main one-line diagram.Reliability of the diesel ineceenerarn

.a d i x'r n r e 12/28/77 7/2/76 kIVAC Standby gas.treatment system 2/4/77 Xnstrumentat ion Instrumentation and Control Specification 3808-92, Section 50B.8/26/77 Mechanical Circulating water system 1/28/77 Nuclear Nuclear resin, sludge and concentrate handling 9/23/76 Stress Primary containment vessel 2/23/77 HNP-2 TECIINICAL ENGINEERING AUDIT AUDIT NO.Page 6 Cont'd on 7 Date 9 17 80 Engineering Discipline Audited Civil Sub ect'urbine Building steel bents;crane griders Turbine Generator Pedestal Date of Audit 10/11/76 Electr ical Determine the reliability of the standby service water system.12/7/76 flVAC Containment.

atmosphere control system 2/14/77 Instrumentation Project Flow Calculations 10/21/76 Mechanical Condensate and feedwater system, extraction steam and heater vents, water drain system-reactor feed pump turbine drain., 12/2/76 Nuclear Fuel Pool Cooling and Cleanup System 3/25/77 Stress Piping Stress'nal~-

'-s ll/11

p i~)L'/NP-.2 TECHNICAL ENGINEERING AUDIT AUDI'1'O.'6-12 page7 Cont'd on 8 pate9/17/80 Engineering Discipline Audited Sub'ect Date of Audit Civil Downcomer Bracing 2/11/77 Electr ical Certify the compliance with Regulatory Guide 1.75 of associated circuits..12/21/76$91AC Primary containment ccoling and purging system 9/2 1/77 Instrumentation Instrumentation and Control Specification 280&-92, Section 52C 9/6/77 Mechanical Plant service water system description 11/28/77 Nuclear Control Rod Drive System 4/6/77 Stress Pipe rupture criteria document 6/23/77 WNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.77~Page 8 Cont'd on 9 Date9 17 80 Engineering Discipline Audited Sub ect Date of Audit Civil Miscellaneous civil/structural calculations

'6/16/77 Electr ical Examine several electrical calculations and their adherence with project procedures 2/5/77 tNAC.Miscellaneous HVAC safety related calculations 6/30/77 Instrumentation Miscellaneous Ins trumentation calculations 6/24/77 Mechanical Miscellaneous Mechanical calculations 6/28/77 Nuclear Not performed-.;.Stress Calculation No.8~"'.91i Thermal Growth of Sacrificial Shiel'Il 7/6/77 Wtl P-2 TECilNTCAI ENGINEERING AUDIT AUDXT NO.77-6 Page 9 Cont'd on 10 Date 9 17 80 Engineering Discipline Audi ted Sub'ect Date of Audit Civil Calculation of seismic input loads forNSSS Evaluation by General Electric Company.12/28/77 Electr ical Electrical aspects of sequential loading of the diesel generator when operating under total loss of off-site power conditions 11/16/77 BVAC Reactor building safety related calculation 9.21.00 4/12/7 8 Instrumentation Instrumentation and Control, Specification 2808-57 11/11/78 Hechanical Plant makeup water system Drawing 516 Revision 7 2/2 3/7 8 Nuclear Emergency core cooling systems (ECCS)3/1/78 Stress Off-gas system 3/5/80 WNP-2 TECflNICAL ENGINEERING AUDIT AUDIT NO.Page 10 Cont'd on ll Date 9/17/80 Engineering Discipline Audited Sub ect Date of Aud it Civil Calculations of loads on.submerged structures To Be Performed Electrical Calculations to the sizing of batteries, battery chargers and inverters 1/8/79 I)VAC BVAC off-gas charcoal absorber vault 10/19/79 Instrumentation Instrumentation and Control Specification 2808-42-(Control Valves)6/9/80 Mechanical Main and exhaust steam systems 3/11/80 Nuclear Nuclear steam supply system 5/15/79~S tress Reactor Water, Clear-~system 3/14/80 NNP-2 TECHNICAL ENGINEERING AUDIT auoxv Ho.~8~4 page ll Cont'd on 12 Date 9/17/80 Engineering Discipline Audited Sub ect Date of Audit Civil Reactor Pressure Vessel cap space frame 11/7/79 Electr ical Diesel generator start-up provisions for loss of off-site power and accident conditions 1/8/79 HVAC Radwaste building HVAC system 2/13/80 Instrumentation Instrumentation and Control-Specification 2808-42 6/9/80 Mechanical Extraction piping systems 4/10/80 Nuclear Condensate supply system 5/9/79 Stress Nuclear steam supply system 3/25/80 WNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.79-13 page 12 Cont'd on 13'Rll2laa-Engineer ing Discipline Audited Sub ect Date of Audit Civil"Roof Survival for probable maximum precipitation ponding" 7/9/79 Electr ical Security system, calculations 5/22/79 BVAC Control Room Habitability 6/24/80 Instrumentation Instrumentation and Contiol Specification 2808-42A (Control Valves)6/9/80 Hechanical Turbine and extraction steam piping drainage 4/15/80 Nuclear Reactor building closed cooling Mater 5/9/79 Stress Turbine building~~tems'0 lw page 13 Cont'd on 14 MNP-2 TECHNICAL ENGINEERING AUDIT AUDZT NO.79 Engineering Discipline Audited Sub'ect Date of Audit Civil Hain Security guard house 0 6/19/80 Electrical Protection of electrical auxiliary systems and proposed reloy setting 12/17/79 WfAC Containment purge isolation/vacuum breaking system 6/5/80 Instrumentation Instrumentation and Control Specification 2808-42 (Control Valves)6/9/80 Mechanical Plant service water system 5/1/80 Nuclear Off-gas system 2/26/80 Stress Turbine building and containment piping 5/1/80 MNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.BR81-8 page 14 Con t'on 15 Jam/Engineering Discipline Audited Sub'ect Date of Audit"Civil Pipe Hanger Support Expansion Bolts 6/10/81 Electr ical Addition of third non-safety related battery to the D-C distribution system.3/27/81 HVAC Construction Potable Hater Fire Protection System 5/15/81 Instrumentation 1.Relocation

.o f Ins trument Rack No.10.2.Replacement'f Rotameters with Orifice Plates on the Stand-By Service Water System.4/24/81 Hechanical Haste Transfer System 6/3/81 Nuclear I Standby Service Water System 5/22/81 Stress Standby Service Hater System Pipe Supports 6/3/81.~",

0@.page 15 Final HNP-2 TECHNICAL ENGINEERING AUDIT AUDIT NO.81-9 Engineering Discipline Audited Suh ect Date of Audit Civil Electr ical Retag of RPS Cables (Task 53410)10/21/81 HVAC Containment Inerting System Tie-in's to Penetrations 10/15/81 Instrumentation Evaluation of Instrumentation Reliability (Task 53420)9/24/81 Mechanical Conformance to HNP-2 Procedure INNP-2-)12, Rev.3 and Project Management Instructions IPMl 4-4, Rev.7 and PMl 4-4.1, Rev.2 10/21/81 Nuclear Reactor and Radwaste Building closed Cooling Hater System 10/8/&1 Stress Reactor Building closed Cooling Hater System rO 0 gO TG': i3 8.Jones R.White Z..Rhymes Office oE the@s.M.Z za File-T.Hendrickson db QUALITY ASSURANCE ENGINEERING AUDIT CHECKLIST Form BR 8402 Sheet.1 or 8 Date 4 19 INSTRUCTION>>

I The Chic Quali y Assuranc Eng newill'dicate in the'pace below, the specific areas to be audited, who shall perform the audit, ary assisting personnel, the completion date and all other instructions required.An audit of the WPPSS Hanford No.2 Project will be performed in the ax as of Criterion TV, Procurement Document Contxol and Criterion VI, Document Control;the week or April 30, 1973.'he audit te'am leader will be K.Lish assisted by N.Jones.(WORK ORDER CHARGE SHALL BE TO: 2808-08)'OMPLETION DATE INSTRUCTION II ChieC Qual'ty Assurance Enginee" The audit team, guided by the information above, will audit tne aesigrated sect'on.They wi'l aevelop a meno-randum type report.A copy of the rcport and this form will be clipped together to form the completed report to be submitted to the Chief Quality Assurance Engineer.Assess tne effectiveness of the procedures applicable to the area(s)audited.cUs L,I s'ssUnhiic y3 Attachment 3 IJ(IL Page 1 of 3 5/30/73 WPPSS HANFORD NO.2 PROJECT PROJECT ENGXNEERZNG AUDXT REPORT CRZTERZON ZV-Procurement Document Control Pze ace: Procu ement documents were examined in order to verify that performance of engineering and QA review/appzoval was in accordance with applicable project engineering procedu es.The areas of;bid evaluations, contractor approvals, change notices, dzawings and assoc'ated records were also examined for proper review/approval.

, 1.Document: Fmdmgs.Specification 2808-16"Condensate Filter Demineralizez System" a.Change o ders to the speci ication were issued by memorandum.

However, no receipt was specified to assure that the change orders were received.b.Procedure E-24 zecruizes change orders to be sent to the contractor/client in triplicate.

They have only been sent in duplica e.c.The numbering of change orde s was not in agreement with procedures.

d.Procedu e E-24 recrui es, as a minima, Qua'ity Plan I and ZZ-specifications to be routed to the lead QA enginee" and the OA group for review and approval.L was found that some Class ZZ specifications have not been approved by, the,QA gzoup.2.Document: Drawing A506, Rev.3 Fingings: Drawing marked"information", dated ll/12/73 and signed.Engineering dict not have a procedu e that de ines/controis a drawing indent."fied as information".'.

Document: Specification 2808-43"Standard Casting o-Forged Steel Valves" copy number 2 of bid review routing sheet.Findings: The supervising engineer signed routing sheet on line designated or the QA supervising

'engineer.

This was done because tne routing sheet does not provide space for the supervising engineer's signature.

?age 2 of 3 5/30/73 03 Document: 'indings: Speci ication 2808-31"Overhead Traveling Cranes" This is a cuality Class I specification which was re-viewed by QA but not appxoved by QA as required per E-24 paragraph 7>.,5.2.CRITERION VI Document Control Preface: Documents were chosen for review of traceability from a revision to a change notice in order to verify implementation of changes in accordance with applicable Project Engineering Proceduxes.

5.Document: Drawing A506"Ground Floor Plan", Rev.B, was traced back to PCN 4145 dated 1/17/73 whi.ch initi.ated the change to Rev.A.e Findings: a.No signatures of approval in the title block by squad Leader and designer nor where the initials oz the cognizant engineer indicated in the release block prior to issuance of drawing.b.No sign-ozf of PCN status log indicating"work complete" as required per E-15 paragraph 6.5.c.PCN Completion Form not available as required pe" E-15 paragraph 6.6 and 6.6.1.d.Approvals, Item 7 o PCN, not signed off as equi ed per E-15 paragrapn 6.2.1.~e.Manhour estimate, Item 6 of PCN, sign-ofzs of various disciplines, as indi,cated by an z symbol, have not been completed prior to release.Engineering stated that pro-cedures stipulated that zor th's type of drawing no signa-tures wexe required.No procedures were produced to support.this statement.

0-6.Document: Findings: Dxawing S-H053"Study-Circulating Water Pump Hose" (Bid copy)a.Procedure E-7 paragraph 4-1 states that a minimum of 3 signatures a e required on tne drawing.The required signatures were verified.No discrepancy.

.b.A printed statement above the title box, on the pro-cedure<indicates that there evists a revision dat d 7/12/72 over the orig'nal release dated 12/16/71.There were no revision letters or numbers listed in the revision box nor was there any discription change to reflect the indicated revision of 7/12/72.A PCN to reflect this change could Page 3 oz 3 5/30/73 not be located.A lead engineer verbally indicated the nonexistance of a revised issue and concurred that the revisal notice, should be deleted from all drawings./'~7.Document: Findings: Drawing 223-3"Study-Cooling Towe-Basins" (Bid copy)a.The drawing has been signed-off by design and the cognizant engineer,.however, the squad leader's signature was not annotated as required per E-7 paragraph 4-1.b.Prefix, Section letters and study numbers, as rem.ired per E-3 paragraph 3-1 and 3-2, were not in title box o the drawing.c.The drawing number used for identification is a speci-fication number which is not in accordance with the p oce-dure.Engineering stated that it is the practice, in some instances, that specification numbers be placed on drawings to support actual specifications.

Ho p ocedure was available to support this statement.

8.Document: Drawing M608"Weld End Details" Rev.2 (Bid copy)Findings: Drawing status is revision 2 as indicated on print dated 1/19/73.Project engineering' si.gn-of is dated 7/20/72 and the cognizant engineer's sign-off i.s da ed 4/12/73.All title blocks and evision columns a"e comple"e, how-eve, there was no PCH's ava'lable to substantiate authori;.'~

za ion of revisions 1 or 2.The validity of the drawing revisions could not be veri ied due to the lack of PCH's and associated documents as required pe E-'5.I 9.Document: Findings: Specification 2808-51"Batteries and Battery Charges".The bidding documents, plans and specifications were checked for approval of client in accordance with engineering, procedure E-24, paragraph 7.6.9 and 7.6.10.a.'he bid issue date of specification was prior to approval of client as indicated on bid issue approval sheet.b.Specification 2808-51 was also checked to verify that distribution of deviations/changes to Project SAR/ER and client approva'etters was made as required per E-17 parag aph 6.1.6 and 7.2.3.'There was no evidence that distribution of the client approval letter was made to the various disciplines examined.Summary e In the reaudit of tne above findings each of the areas which the findings cove-wil'1 be included plus interfacing areas wnicn in luenced the findings.Q Pro j ect WPPSS/MNP-2 P)VJ<P af Facility/Function Audited H.O./A Per owned by C.Roemer.Page 1 of 4 En ineering Audit No.BR81-5 Rapt t Data 7/20/81 Audit Date~76 to~79 1.PURPOSE The purpose of this audit was to evaluate Project quality Assurance/

Project Engineering compliance with the quality Assurance Program;as prescribed by the identified criteria of 1OCFRSQ, Appendix B, and applicable project instructions or procedures.

In addition, the audit scope was to include the review of corrective actions taken against previous audit findings.BR81-2, Finding No.1 Management Assessment Audit, Finding No.38 11.CONTACTS*R.Snaith*G.Satir'.Baker<<M;Kahn<<J.Blas 0.Moshier P.Stadelman Senior Project Engineer Project Engineer Project Engineer Assistant Project Engineer Project gA Manager QA Engineer gA Engineer*Exit Meeting Attende s (7/8/81)I II.AUDIT SURGERY This audit resulted in the issue of three (3)new findings and the closeout of findings from previous audit BR81-2 and the 1979 Man-agement Assessment Audit.Details of audit coverage achieved are provided under the appropriate criterion listed below.Criterion I-Organization The draft copy of Project's update of the Project Plan (Rev.9)contains the updated Organization Charts which appear to reflect both Home Office and Site organizations.

This area is considered satisfactory.

BR8461 Attachment 4

AUDIT REPORT page 2~g 4 pzg j erat, WPPSS/WNP 2 Audit: No.8R81-5 Criterion II-guality Assurance Program Except for the findings issued against specific elements of the gA Program, Project's compliance is considered satisfactory.

Training records related to the items listed were reviewed and the area is considered satisfac ory.It is recommended, however, that the training matrix be updated to reflect the overall current status of training activity.WNP-2-E-010 (Rev.4), Calculations Engineering Standard P015104Gl Engineering Standard P015105Gl Engineering Standard C015104G2 NOTE:.Above areas covered by gA Department sponsored training sessions on July 1-2, 1981.All disciplines represented; fifty-eight attendees.

WNP-2-ED-004 (Rev.0), Engineering Hol d Criterion III-Design Control A review of Project's performance relative to the listed items was accomplished.

Except for the items cited as deficient, this area is considered satisfactory.

Area'eviewed Documents Calculations reviewed Electrical Discipline included microfilm 2.01.01 activity (WNP-2-038/2) 2.01.02 2.01.06 2.01.07 Mechanical Discipline 4.25.06 4.25.08 4.99.01 Evaluation/Comments Satisfactory Sati sf actory Civil Discipline 6.18.02 6.18.03 6.39.01 Satisfactory BR84089 (2/15/78)

AUDIT REPORT age 3 oZ 4 pgog cog MPPSS/WNP-2 Audi<No.SR81-5 Area Reviewed'pecification Engineering Criteria Oocument, Rev.10 Oocuments Nuclear Oiscipline 5.17.11 5.17.14 5.17.24 5.18.01'.18.06 5.18.07 5.18.08 Thermal Oiscipl inc TI2.01 T12.02 T12.03+TI2.09 2808-28 Rev.I, 3/31/81 Centrifugal Fans and Essential Fan Coil Units Section H Technical Standards Applicabili y List Criteria Advance Changes-Electrical 5/12/81-Hechanical 2/26/81-Civil/Structural 4/I/81 Eva1 u ati on/Commen ts Satisfactory Unsati sf acto ry See gAFR No.I and RENRKS information (3)pertinent to all calculations.

Satisfactory (MPPSS Transmittal)

HYAC modified to Change Order EH draft.Satisfactory Criterion lY-Procurement Oocument Control Criterion YII-Control of Purchased Material, Equipment, 8 Services Area Reviewed Prepurchased Oocumentati on Oeficiencies Spec/Contract 2808-18 2808-24 2808-428 Evaluation/Comments Unsatisfactory See gAFR No.2.BR84 08 9 (2/15/7 8)

AUDIT REPORT Page 4 oZ 4 Pro j eot WPPSS/WNP-2 Audit No.BR81-5 I Criterion XV-Nonconforming Materials,.

Parts, or Components Area Reviewed Information Evaluation/Commonts Contract Waiver Requests The CWR Log appears to reflect Unsatisfactory a number of blank areas;seven See gAFR No.3.(7)in 1979 and two (2)in 1980.The issue and/or cancel status of the CWRs (gAFR No.3)listed were indeterminate.

The listed, dispositioned CWRs for contract C-12409 are con-sideredd satisfactory.

W-132 W-134 W-136 W-147 W-133 W-135 W-145 W<<149 W-150 It is recommended that Project review other contract/CWR files to assure the deficiency is not generic.Criterion XVII-gA Records The examination of various records related to the engineering stan-dards and procedures employed during this audit were appropriately filed and maintained.

This area is considered satisfactory.

Criterion XVIII-Audits Audit Follow-up:

Satisfactory Audit Status-BR81-2, Finding No.1 Closed-MAA (1979, Finding No.38 Closed Procedure WNP-2-EO-010 (Rev.5)provides all necessary correc-tive actions to satisfy and close the finding.I V.RECOMMENDATIONS Included in the gAFR information and within this report;as neces-sary.CR:map G~w=c-~~BR84089 (2/15/78)

JProg ect MPPSS MNP-2 Pacility/r unction Audited STATEHEHT, OP RE UZ~NTS BURNS AND ROSe INC~e C2~gaCuN~ANO CONRTltQ~99%

ee QUALITY AUDIT FIHDIiVG REPORT ,Audit No, aR.BR81-5 Sindine I'at 9 10CFR50/B, Criterion III, Cesign Control;as contained therein.Project Instruction MNP-2-EH10 (Rev.5), Calculations; as contained therein.FZNOLHG Thensa1 CaIcuIaticn TI2.09 Is an unapproved calculat1cn.The caIcuIaticn, hcwever, Is being readied for mfcrofilming and reflects two annotations which appear to warrant voiding of the calculation.

See the Remarks below and Finding attachment.

E'LCJhh:"" QUALITY ASSURANCE RECOKKHDATION 6 Receipt Acknowledged u-It is recommended that Project review the calculation and provide a determination con-cerning its status., CORRECTIVE ACTION Taken Q Proposed Q Scheduled Completion Date ll/l/8 Engineering will review Me ca2.cula~~on, determine the s atus, and make the calculation acceptable as a"final calculation.

jr Corrective Action Assigned to R<ondrasek Cognizant Manager (y~(A~M Proposed Corrective Action l.Acceptable-pending verification Q 2.Unaccep table.Cl Signature/date Corrective Act'on Verification 1.Acceptabl.e-finding closed C3 2.Ineffective/Incomplete-fling open Q Signature/date asKIRKs 1.Per the originator's statement, the effort was aborted 8/11/75.2.Calculation Sheet 0, dated 1/20/77, also reflects a statement wherein Calculation T12.09 not used by Project at this date, 1/20/77.3.This calculation and others reviewed (see report)do not reflect the calculation date or the checker's function.FINDING CLASSIFICATION Inadequate Proc./Instr./Guide/Plan C3 ifoncompliance to Proc./Znstr./Guide/Plan System Deficiency Personnel Error CI Instr./Proc./Di-ection Reauired Qx Ineffective Corrective Act'on Q HURNS'AND RC7K, INC NNOINSCBtS AND CONSTll VCTOltS QUALITY AUDIT FINDING REPORT Project WPPSS/WNP<<Z Facility/Function Audited H.O.OA Enoineerino STAT~OF REOUIRE."KHTS Audit No.BR Bl"~Finding 2 of 3 10CFR50/B, Criterion Y, Ins.ructions, Procedures, and Drawings;as contained therein.Project gA activity relative to the Prepurchased Document Deficiency List is not covered by BSR project instructions and/or procedures.

Oriainal Sianed UALITT ASSURANCE RECOMHENDATION It is recommended that Project provide a project instruction covering this area.CORRECTIV:" ACTION Taken Q Proposed g Scheduled Complecioa Date (~1~Project Management will'ssue a project instmction covering the Prepurchased Document Deficiency List.Corrective Action Assigned to J.Blas Cognizant Manager Pro osed Corrective Action l.Acceptable-pending verification Q 2.Uaaccep table C3 Signature/date Corrective Action Verif ication l.Acceptable-f inding closed Cl 2.Inef f ective/Incomplete-f indiag open Q Signature/dace hPPSS PNI 5-o (Rev.3), Documentation Deficiencies of Prepurchased Equipment, is cur-rently employed.as a guideline to the effort.FINDING CLASSIFICATION Inadequate Proc./Instz./Guide/Plan C3 Noncompliance to Proc./Instr./Guide/Plan Q System Deficiency 0 Personnel Error Cl Iastz./Proc./Direction Required Q Ineffective Corzective Action Q ra B URNS AND ROSe WC RacggggSCltS ANCS COSSSTRVCTOltS

.iProgect Pacility/Punction Audited QUALITY AUDIT FINDING REPORT Audit.No.BR 81-5 Egnggng~eg~STATEMENT OP RE UIR12KNTS Af'"'%~M~10CFR50/8, Criterion XV, Nonconforming Materials, Parts, or Components; as contained therein.Prospect-Instruction MNP-2-023 (Rev.1), Contractor Waiver Requests;as contained therein.Project's CMR Log of activity contains a number of blank areas;identified*

below.Endetemfnate was whether or not a CMR was issued against the number or the item was cancel 1 ed.Original Signed Issued by m~Date OUALITT ASSURANCE RECOAAENDATIOH

.lt is recomended that Project review the areas cited and determine whether or not out-standing CMRs exist which were not inputted to the control system or cancelled.

CORRECTIVE ACTION Taken Q Proposed g Scneduled Completion Datel2/l/81 Project Management, with the assistanc o=the Group Superviso s, w'll review the status of the"blank" CNR's to ensure that the log is complete.Corrective Action Assigned to<-Kahn/G-S~Cegn'anr-Manager e Proposed Cor ective Action l.Acceptable-peading verification Q 2.Uaacceptable C3 Signature/date Corrective Action Verification l.Acceptable>>finding closed Cl 2.Iaaf f ective/Incomplete-finding open Signature/date REMARKS*Contract C-12409 1979: M-12, W-17, M-18, M-19, M-21, M-36, and W-60 1980: M-130 and M-151 PINDQfG CLASS IPICATION inadequate Proc./Instr./Guide/Plan Q.foncompliance to Proc./Instr./Guide/P'an Q System Defic"ency 8 Personnel Error Cl Instr./Proc./Direction Required QX Ineffective Corrective Action Q

(~(e ATTACHXF.i' SPECZK DESKS BEV~f SDR SO\RKSXDUAZi HEAT B~~QVAL SYSTEM%%GPSS NUCLKM PRQJ" CT NO 2 Pehxua~27,'981 Prepared by H'tCg5gddg.

Approved.by~

The Residual Heat Removal System (RHR)des'gn was reviewed fo con once to the input docume..s 1'sted on Attachment 1.The specific output documents reviewed fo conformance to cr'te ia are<is ed in At achmen 2.All equ'd process crite a" have been met.The rev'ew covered only those'tems that a=e within the Bu~s and, Roe scope of desicn.Pipe support wo k and the con'~tion o" hydrodynamic loads from suppression pool discha=ges are not complete;finaL system w~~down has not yet been pe omed.A c6eck or confo~.ce to G=se'sm'c cr'ria shou'd be per owed as part c""e final s-ess analysis work subseq en to"".e waM down.=<<quipment sta~-uo and valve opening items in"'xe RHR we e checked and a"e analy'callv satisfac o~.~t is recommended that all equipment sta t-up and valve pening items for the system be verified-by fieLd test.*The term"process cr'ter'a" is interp eted to mean the aspec s of desig'n depicted on flow diagrams such as flows>pressu=es, temperatures, etc.

03~~SPZCZPXC CQKL~iiTS The following are specific comments: 1 Note 12 of&PQZD, input item 7"$962%3, states Wat thermal expansion af water cantained in t..e pipel:ne between valves P-008 (RBR V 8)Nd r-009 (RBR V 9)should he considered.

Bowever, na calculations addressing this consideration cau14 he found.A~so, FK-215-8-2832 di=ects that a Wexmal relic valve he added between Wese valves to campZ,y with Note 12.Recommendation:

A calculamn should he made ta detexm-.re We a-ssu e inc=ease assoc ted.w't.'" the vo3.~et=c expansion of""e Cupped fla'd ax We case o" max'~um temperature ice=ease.A.Wexmal x'ief valve.should he added a the design d awings as per PHD-215-H-2832.

2.Hate 18 of K PsZD, input item 73l="96M, states adecpzate piping surface should he allowed far cooling Pater Keg Pznp CQ03 (RBR-P-3).The note also appea=s in Not 9 ox Bu..s sd Rae f'ow diag=aza, cu pu document N52L.Bawever, na c'c"'at'an add=essing this reau'e-ment cauld he faund Recommendation:

'A'alculation should he made ta estahlish Wat We heat load f am We Hater Z,eg Pump can he d'ss'ated through the cannecting piping sur ace shown on We design drawings.

3.'ote 4 of K P&XD, input item 733=-961AD, s ates that temporary s"=ainer screens should be provided on the suction s'de of all pumps.Burns and Roe flow diag am,.output document 8523., does no show such a straine for.the Mate Leg Pump no does Mechanical Insta'lla~won Speci-fication 23.5 (output item 20)provide for the purchase the eof.Recommendation:

P ov'de for the pu chase, of the tempora~st=aine"or the Mate=Leg Pump and add to d s'gn.d'w'ngs.Temporary strainers in the suction of all pumps reepxi ed by Note 4 o GE Pa&, inpu" item 731=961AD, a e spec"'ed w pa ag aph 3.1.5.', page 15G-6 o Spec'at'on 215.Foweve r the po e'a,'-e e.iz3.p essu=e loading is not specif'ed..

Recommenda

'on: Perform calculations to determine the maximum potentia'ressu e loading on the conical st=ainez element and add this item to the requi=ements in Specification 215.5.Pa=agraph 4.2.2.11 o GZ input document, Design Spec.22A2817, s ates that each RHR Pump be equipped with a line to drain the leakoff rom the, shaft, seal to pe~" , measurement and visual inspection of any leakoff.These requi"ements have not been addressed.

Recommendation:

Provide faci'i":es for shaft Leakoff observation and measurement.

'aragraph 4.2.5.3.1 of K input doc.en 2~'QSL7 sta es that suction piping f~m the suppression pool be designed so that when any one suet'on s-ainer's 50$clogged, Axe minimum iPSB is provided ta RHR pumps du ing XPCX or Containment CooLing Operation.

'Calcu1ation 5.17.9, Sheet E-9 does not account for pressu e dip~Jr=ough suction strainer at 50%clogged condit'on.

The e a=e two 100%strainers wt'ch make the clogged cond'tion negl'gible.

Recommendation:

Add clogged coadi+'on to calcs.fo cord purposes.7.Paragraph 4 5.2 of~input documen 2~817Av stat s that valve F038 (~-RV-36)be sized to maintain up-st=eam pressure at.75 psig and L0%accumulation.

however, Table 11C, page LSG-7l o" Specifica"'on>>5

'-co=ec ly specifies the set pressu=e at L25 psig.Recommendat'n:

Spec'f'c cion 215 should be cor=ected.

1 8..Table 4.3-3 on page 4.3-6 of projec document"PLant Oesign Assessment Repor or SRV and LOCA" reports

'Mt 24" RHR'AH'uction lines in De supp ession pool have, not yet been proven acceptable to wiDstand the loads due to LOCK downcome discharges.

The analysis of these mes is in prog ess.Recommendation:

Add the results to Table 4.3-3 when the analys's has.dete~ed an accep~le cond'tion and, if necessary as detemined by the analys', e oute""e suc'on laes or the design d~w~9 Note 11 of&P&ZD, inpu item 731E96M~, sures that valves F088 (RKL-RV-88K, 3&C)shall be 1" relief valves.Page 156-71, Table 11C of Specifica'or.215 and ou pu drawing M521 spec'fy 3/4" si.=e.¹co~endation:

Gus'~the 3/4" s'.10 When the emergency d'esel, generator i.s ope a~parallel with the no~preferred powe sou-ce for routine exerc.sing of the diesel<the 5iVT swi~ge?r short.ci cuit rating given in calcu3.ations 2.03.10 and 2.03.LL could be exceeded This could occu when the RHR's in ope ation.T~cond'on can be avoided if the diesel gene am is exerc'sed in other elec ical operating modes whi.ch are identified in calcs.2.03.10 and 2.03.11.Howeve , the design documents for cons"action do not convey the ope ating rest=ictions to assure that the SRV sw" tchgea-rating is not exceeded.'n addition, there are no alarms provided in the-des'gn to alert the operators if the prose=ibed, ope aMq mode is attempted.

Recommendation:

The design documents should describe the diesel generator testing limitations.

Also, ala~should be added.11.PCH 7081 addresses rest=iction orifices in the~Sys em to prevent runout of the RER Pumps.Calculations for the orMices couM not be found.A2.so, no p ovision fo pu=chase nor inclusion on the-design drawing could be found Recommendation:

Xmplement the"Qi to prov" de the rest=iction or'" ces a d add them to the des'gn draw" zgs.12.Pa~g ash 4.2.1.5 o=GZŽpu docile=22%2817 s t s that the RBR System piping and.components shaL,1 be designed to withstand the ther~A, cycling eÃperiencecK M the various operatiorml

~des.T"e numbe s of thermal'.cycles for design a e given in pa agraphs 4.1.Z.3, 4.1.3.2, 4.1.4.4 and 4.1.5.7.Zn addition to these cycling xecui"ements, the system des'gn sha11.make allowance"or pqessure and thermal cyc3.ing facto s related.to plant standup and shutdown.Calculations addressing these requirements could not be fou.".d.

Recommendation:

Per orm the the~analyses and implement the results as may be necessary.

13.Paragraph 4.2.1.4 of GZ input document 22A2817 sites that hydraulic shock calculations should be m~corporated in the component design to ensu=e hyd aulic balance and system stability.

However, no calculations add essmg this reauirement could be found,.Recommenda

'on: Perform the hydraulic shock calculations and implement the results as may be necessa~.

ATTACHHMT 2 Ql72PUT MC~iTS 1 2 0 3 0 8.9.~l: l~13.15.16.L7.18.19.20.21 MS21, Rev 25 5-17 19 N567 Rev 6A H569g Rev L9 8570, Rev 12 K57L, Rev 10 X572, Rev 10 E70L>Rev LSÃ70Z, Rev 14 i%703 p i%704~i%705, M706, i%707 p.i4708, K709, 8710 i Rev 12 Rev 16 Rev 14 Rev 23 Rev 11 Rev.19 Rev 23 Rev 3 a~on 6 Piping ConMmtte s Plo~D'ag-am RHR Sys~P=essure Deep CalczzlaMon Gene a1 Ar angement:, Plan ELev.422'-3" 441'-0" and 444'-0 Gene~aL-Az-angemenh, Plan ELev.522'nd 548'-0".Genem.L Ar angemenh, Plan ELev.572'-0" and 606'-10 L/2" Genezal Ar angemen s, Section"LQ-LO" Gene"al Ar angements, Sec'on"8-8" If9 9 ll Plans, Sec'ons and De~ts=lev.422'tas, Sec>>" c" s and De a='E'v.444'nd 441,'lans, Sec"'ons and Details=Lev..471'lans, Sec"'on and Dehails Eley.522'tas, Sec on" and De~its Elev 548'lans, Sects,ons and Oedai's, E'ev.572'artial Plans Section and De~s Sections and DeMits P~al Plans and Sec"'ons Spec.2808-35 H"sceLLaneons Pumps Spec.2808-41 AGB Znctea Valves Spec.2808-69 Tes~te Check Vatves Spec.2808-215 iitechanicaL Emx'mene Zns aLL Spec.2808-42A Kisce>>aneous Consol VaLves and Accessor's BURNS AND ROE, INC.DESlGN VERIFlCATION CHECKLIST prajecat~tz rc'e'!t: 0 f'.'7<<i h'e Oesign Verilicztion Plan Item Numbur ltein fieing'Verified I.."'."i'i<ri.'r--.s CY'r;F'..~Sheet t of'Na.1.D QUESTlON'Vfere the fallowing inputs correctly selected and incorporated inta designs Basic functians at each structure, system and companent.

Verifier's Finding, initials and Gate~\1n4 Performance requirements such as capacity, rating, system output.Codes.standards, anil reguiatory requirements including the applicable issue andiar aildcnda.Oesign conditions such as pressure, temperature, fluid chemistry and voltage.Loads such as seismic, wind, thermal and dynamic.1.7 aper:tidn such"pre ur.o, ten;perature, humidi".f, cc-.osivene-, site elevation, wind direction, nuclear radiatian, electramaanetic radiatian and duration af exposure.Interlace requirements incluaina deiinitian ot the functional and physical interfaces involving structures, systems and comoonents.

1atenal requirements including sucn items as compatibility, electrical insulation aroaerties.

arotective coatina and corrosion resistance.

llnstp~i Q~)w eence esf~'~n I~e.i see/7 5 IIV!p 2 I~I//'"'l'.1ecnanicai requirements sucn as viorauon, stress, siiacx ana reaction forces.tructural requirements covering sucn ite...s as equipment roundatianS and pipe suaparts Hydraulic requirements sucn as puinp net positive suctian heads (NFSH), allowable aressura drops.and allowable fluid velocities.

j N P.~g/.r ee:~~-~1.12 1.13 1.17 Chemistry requirements such as provisions far sampling and limitatiahs an water chemistrv.

Electrical requirements sucn as source oi power, voltage, raceway re uirements.

electricai insulatian and motor reauirements.

Layout and arrangement requirements Operational requirements under various conditians.

such as piant startup, normal plant operation, plant shutdevn, plant emergency aperation, special or infrequent operation, and system abnormal ar emergency operation.

Instrumentation and control requirements including indicating instru-ments, controls and alarms reauired for aperation, testing, ano mainten-ance.Other requirements sucii as the type af instrument, installed spares, range af measurements.

and location of indication should also be inciuded.Access and administrative control requirements tor plant security.Redundancy, diversity and separation requirements oi structures, systems and comaonents.

frrure em"-rs rcrpnrcnre:res~use:ensures.

sys.ems cnrr cnrnppn"~rs, including a defiilition of those events and accidents which they must be deigned to tvitiistanil.'E>>

~"': i f fp i'e'.f-'.*wel Qg.r.Checklist questions that du nut apply to the item being verified shall be noted as"NA", nat applicable.

Pueeey t:atoi iu(ci BURNS AND ROE, INC.DESlGN VERlF ICATION CHECKLIST Vie.No:-+<<-~~P)oi~t Ocsign Vcriiimu>>)i>

Plan iicfn Number 1~Iten Being VcrHicd Sheet 2 of 120 127 S.0 8.0 7.0 GUESTlQN Test requirements inc!uuing in giant tests, and uie conditians unaer which they will be performed.

Accessibility, maiiit.nance, repair and insarvica inspectian requirements for tha plant including the canditians under which them will ba perfarmed.

rsannei requirements ana iimitauans inciuaing the quaiiiicatian and number af personnel availaaie far plant aperation, maintenance.

testing and inspection and permissabte persannel radiation expasura for specified areas and canditians.

Transportability requir ments such as size and snippmg weignt, limitations.

I.C.C.regulaticns.

Fire pratectian or resistance requirements.

Handling, storage and shipping requirements.

ther requirements to prevent unaue risk to tha neaitll and sa ety at the aublic.Materials, precedes, parts and equipment suitable far applicatian.

atety r quirements tor pravenung personnel injury inc!uoing such items as radiation hazards, rowricting the usa ai dangerous materials, escape arovisions from enclosures, and craundino of electrical systems.Are assumotions necessary to per!arm tna design aativity adequately described and rector able?Vlhere necessary, are the assumptions identified for subsea ent re verifications when the detailed design activities ara ccnioiated?

Are the apprapriate quality and quality assurance requirementsspecified?

Are the applicable codes, standaras and reauiatary requirements including issue and addenda properly identified and ara their requirements far design inet?Have applicable canstructian and operating experience been considered?

Have the design interface requirements been satisfied?

Vlas an appropriate design mathad used?Verifier's Finding Initials and Oata P.A~Les>>>>)t~Ss>>cc)>>lo(<<r>>s)~.)2.I o>>rr<<<Sb(i'>>~8.0 S.0 10.0 11.0 Is the autput reasanable campared ta inputs?Are the saecilied parts, equipment, and processes suitable for the required aouiication?

Are the spec!he!I materiais compatible with eacii other aiia the design enviranmental conditions ta which the material will be exnosed?Have arlequatc nrainterance features and requirements been speciiied?

~v)Q ChecMist questians that do nat apply ta the item being verified shall be noted as"NA", not appliable.

'!.0.Mo.~I'~'t t-prefect Design Ve.ification Plan Item Number BURNS AND ROE, INC.DESIGN VERIFICATION CHECKLIST i.!H P-W Sheet>of ,item Being Verified~~i r~" S i-K ts.a QUESTION Are accessioiiity anri other design provisions adequate lor performance of needed maintenance and reoair?Has adequate accessiu>>ity ueen provioeu to perrorm tne inservice inspection exoected to be required durino the plant lite?Has the design properly consioered radiation exposure to the puolic and plant personnei?

Are the acceptance cnteria incorporated in the design documents sufficient to allow verification that design requirements have been satisfactorily accomoiished?

Have acequate pre-operauonai ano suosequent periooic test require-ments been aopropriately specified?

Are adequate nanoling, storago, cieaning ano snipping requirements specified?

Verifier's Finding Initials and Date fd~rf r/i rr.~V~j)r 4!ri/: e)B.O Are adequate identification requirements specified'?

Are requirements for recoro preparation, review, approval, retention, etc.,'adequately specified?

20$Are the necessary su pporung caiculations completeo, cnecked and approved?5 g jPgr (:.apl&G Verifier for all items not initialed above (i<I&/Date Checldist questions that do not apply to the item being verified shall be noted as"NA", not applicable.

Form Co157toGt'

~)Fi~di n>6, FINDING 3 F~indi n Note 4 of GE PAID, input item 731E961AD, states that temporary strainer screens should be provided on the suction side of'll pumps.Burns and Roe flow diagram, output document M521, does not show such a strainer for the Water Leg Pump nor does Mechanical Installation Specification 215 (outpu.item 20)provide for the purchase thereor.Nature of Concern Temporary strainers are used in suction lines of pumps during initial system test runs in order to collect any debris which otherwise might be flushed into the pump, so that possible pump damage is prevented.

The concern here is that by not using these temporary startup strainers for the water leg pump, the pump might suffer damage from debris which otherwise would be collected in the temporary straine~.I Findin Evaluation It cannot be said that any damage or component failure would be expected if no startup-strainers are used.However, it is good practice to use the straihers.

Whether the water leg pumps should be included in this practice is a question which can best be answered by field expertise.

Comparing the data of the water leg pump and the system pumps, it appears highly unlikely that a strainer on the water leg pump will collect any debris at all.Since this f nding does not impact plant safety, it has beeniudged to be not safety significant.

During startup testing oi the water leg pump, its capability to fulfill its function will be verified.The strainer protects the pump during flushing and startup testing but is removed after the system has been shown by test to meet its design function.While the safety of the plant is not affected by the pre-sence or absence of a strainer (water leg pump system will, in any case, pass startup test prior to operation phase), a change has been made to include the strainer during startup".sting, Safet Si nificance The strainers are for temporary use during flushing and startup testi ng, and their presence or absence is not safety significant.

SDR-80-6, FINDING 4 Findin<i Temporary strainers in the suction of all pumps required by Note 4 of GE PIlID input item 731E961AD, are specified in paragraph 3.1.5.1, page 15G-6 of Speci-fication 215.However, the potential differential pressure loading is not specified.

Nature of Concern The concern here is the amount of differential pressure caused by the temporary strainer fluid resistance.

This pressure differential decreases the available net positive suction head of the pump.In an extreme case, pump cavitation might be envisioned.

Finding Evaluation Strainers for this temporary application are selected such that the percentage decrease in flow area is not excessive.

Good engineering judgment in strainer sizing combined with good system design, where an adequate margin in the available net positive suction head is assured, make it unnecessary to perform hydraulic analysis on these strainers.

The temporary strainers are selected to have a low head lass relative to NPSH requi rements.Even if pump cavitation should occur during initial test runs, the strainer would be removed and either cleaned or replaced.Safet Significance After flushing and testing of the system is completed, all temporary strainers are removed.They are not used for normal system operation.

For that reason and those discussed above, this finding is not safety significant; SOR-80-6, FINDING 5 Findin Paragraph 4.2.2.11 of GE input documents, Design Spec.ZZA2817, states that each RHR Pump be equipped with a line to drain the leakoff from the shaft seal to permit measurement and visual inspection'f any leakoff.These requirements have not been addressed.

Nature of Concern The concern here is the same as in Finding 6 of SOR-80-5.The RHR pumps are equipped with a mechanical seal, and they are vertically mounted, just like the LPCS and the HPCS pumps.Findin Evaluation The same evaluation as in Finding'of SDR-80-5 applies.Safet Significance This finding is not safety significant

{Reference SDR-80-5, Finding 6 evaluation).

SDR-80-6, FINDING 6 Finding Paragraph 4.2.5.3.1 of GE input document 22A2817 states that suction piping from the suppression pool be designed so that when any one suction strainer is 505 clogged, the minimum NPSH is provided to RHR pumps during LPCI or Containment Cooling Operation.

Calculation 5.17.9, Sheet 8-9 does not account for pressure drop through suction strainer at 505 clogged condition.

There are two 100$strainers which make the clogged condition negligible.

Nature of Concern The concern here is the same as in Finding 8 of SDR-80-5.Findino Evaluation Calculation 5.17.9 uses one unclogged 1005 strainer which is equivalent to two 50ll clogged strainers.

Safet Si nificance Calculation 5.17.9 is correct as is, and this finding has no safety significarce.

~3;~Findin SDR-80-6, FINDING 7 Paragraph 4.5.2 of GE input document 22A2817AY states that valve F036 (RHR-RV-36) be sized to maintain upstream pressure at 75 psig and 10Ãaccumulation.

However, Table 11C, page 15G-71 of Specification 215 incorrectly specifies the set pressure at 125 psig.Nature of Concern This finding applies to the steam condensing mode of the RHR system.RHR-RV-36 relieves condensate from both RHR heat exchangers into an 8.0 inch line, where-the condensate flashes and is routed to the suppression pool where it again con-denses.RHR-RV-36 will actuate if 1)the steam condensing mode is being used, and 2)one of the level control valves (RHR-LCV-65A or RHR-LCY-658) fails open.In that case, the relief valve protects the condensate piping from overpressuri-zation.The concern here is that the relief valve setpoint could mistakenly be set higher than the design pressure of the piping.Findin Evaluation O.The design pressure for the tube side of the RHR heat exchangers is 150 osig.The design pressure for the piping is 125 psig.The correct setpoint for the,relief valve is 75 psig, and the certified vendor drawing reflects 75 psig for the valve supplied.Safet Significance This finding is not safety significant.

GRAFT SDR-80-6, FiNDING 8~Findin Table 4.3-3 on page 4.3-6 of project document"Plant Design Assessment Report-,or SRV and LOCA" reports that 24" RHR'AB'uction lines in the suppression pool have not yet been proven acceptable to withstand the loads due to LOCA down-comer discharges.

The analysis of these lines is in progress.Nature of Concern The concern here is about lack of completed stress analysis of the RHR suction lines under conditions of high downcomer discharges.

Finding Evaluation This fi nding simply indicates that the desian is stil'.-in prooress, and'tress analysis is presently being performed.

The entire issue of containment hydro-dynamic loads was'.dentified several years ago as a 10 CFR 50.55(e)deficiency, and the overriding issue is safety significant.

The issue is being addressed in the Design Assessment Report and no design changes are expected.Safety Significance This finding in itself is not safety significant, since i.merely points out hat analyses are underway to demonstrate adeauacy./

SDR-80-6, FtNOING 9 Fi ndi n<i Note 11 of GE P&ID, input item 731E961AD, states that valves F088 (RHR-RY-88A, B,&C)shall be 1" relief valves.Page 15G-71, Table 11C of Specification 215 and output drawing M521 specify 3/4" size.Nature, of Concern RHR-RV-88A, RHR-RY-88B, and RHR-RV-88C are for overpressure protection of the pump suction lines in case sufficient backleakage occurs through checkvalves RHR-Y-31A, RHR-V-318, and RHR-V-31C.

However, pressurization can occur only when suction valves RHR-V-4A, RHR-Y-4B, and RHR-V-4C are closed.These suction valves are motor actuated gate valves which are normally open.In loops A and B they would be closed when the shutdown cooling mode is being used, which is relatively infrequent.

The concern here is that the 0.75 inch relief valve might not provide sufficient relieving capacity, whereas the 1.0 inch valve would.Findin Evaluation The concern about possible insufficient relieving capacity is unfounded since the backleakage through the checkvalves is very small.Calculation 5.17.17 estimates this backflow at 180 cm3/hr, which is so small that even a smaller size relief valve would be suf icient.Safet Si nificance There is no safety signi<icance to this finding.

SDR-80-6, FINDING 10 DRAFT~Find in When the emergency diesel generator is operating in parallel with the normal preferred power source for routine exercising of the diesel, the 5KV switchgear short circuit rating given in calculations 2.03.10 and 2.03.11 could be exceeded.This could occur when the RHR is in operation.

This condition can be avoided if the diesel generator is exercised in other electrical operating modes which are identified in calculations 2.03.10 and 2.03.3,1.However, the design documents for construction do not convey the operating restrictions to assure that the 5.0 KY switchgear rating is not exceeded.In addition, there are no alarms provided in the design to alert the operators if the prescribed operating mode is attempted.

Nature of Concern This concern is identical to the one'aised in Finding 1 of SDR-80-8, and it is discussed there.

SDR-80-6, FINOING 11~Findin PCN 7081 addresses restriction orifices in the RHR system to prevent runout of the RHR pumps.Calculations for the orifices could not be found.Also, no provision for purchase nor inclusion on the design drawing could be found.Nature of Concern The concern here is that the restricting orifices might not be properly sized, might not be included on design documents, and/or might not be installed.

Findin Evaluation It has been found on some systems at MNP-2 that conservative pump sizing has led to excess capability.

This finding comments on an item which, at the time, was in the design process.Calculation 5.17.29 has since been performed.

In cases where conditions may lead to pump runout or flow balancing problems during system lineup and startup testing, it is normal to take measures such as orificing or throttling of the flow.Test procedures result in the identification and correction of any runout conditions.

Safet Si nificance The RHR system will be tested and proper flow rates established during startup testing.=The lack of orifice calculations at the'oint in, design noted in the finding is not safety significant because the test program would assure adequate system function and, in fact, this is one of the purposes of the test program.

SDR-80-6, FINDING 12 I Fi ndi na Paragraph 4.2.1.5 of GE input document 22A2817 states that the RHR system piping and components shall be designed to withstand the thermal cycling experienced in the various operational modes.The numbers of thermal cycles for design are given in paragraphs 4.1.2.3, 4.1.3.2, 4.1.4.4 and 4.1;5.7.In addition to these cycling requirements, the system design shall amke allowance for pressure and thermal cycling factors related to plant startup and shutdown.Calculations addressing these requirements could not be found.Nature of Concern The concern here is that thermal fatigue calculations were not available to the reviewer.Findin Evaluation This fi nding comments on an item which is still in the normal design process.Stress cycling fatigue calculations are being performed, and will be included in the stress report on Class 1 systems that has not been filed yet.The certified stress report, a document normally completed just prior to operation, will address thermal cycling stresses, and will verify adequacy of Class 1 systems from this standpoint.

Safet Significance This finding occurred because the reviewer asked for calculations which, in the normal design process, may be performed at a later point in time.This finding is, therefore, not safety significant.

-SDR-80-6, FENDING 13 Findin Paragraph 4.2.1.4 of GE-input document 22A2817 states that hydraulic shock calculations should be incorporated in the component design to ensure hydraulic balance and system stability.

However, no calculations addressing this requirement could be found.Nature of Concern The concern here is that hydraulic shocks (waterhammer) might occur in the-system which have not been analyzed, so that unexpected system damage could resul t.Findin Evaluation This item is presently being'resolved.

'rovisions in the design make it very unlikely that hydraulic shock could'cause system disabling damage.Reasons for this are: (1)there are no fast moving valves in the system, and (2)the design objective of the water leg pump is to keep the.system filled at all times for the purpose of precluding hydraulic shock.General Electric suggests calculations but they are not a specific requirement.

Stress calculations do address valve closing times in critical areas.1n addition, exercising of the system during pre-operational and operational testing sill identify any tendencies-toward hydraulic shock and their causes.Safet Si nificance Considering the precautions that have been taken ard the testing programs that lie ahead for the system, this finding is not considered to be safety significant.

Co ATTACHMENT 7 Page 1 of 7 SLNFORO 2 SOP INTERFACE REYI&NCL,EAR MILER SYSTEM~>>C,>>>>'~p.~v', j>>Has'the afr supply to the HSIV's and SRV's.been specified to Neet the requfrasents af the Plant Afr Specification?

2.Are the pneumatfc lfnes and ffttfngs between the SRV actuators and accumulators flexible to ace~date the Notion of the aafn steaw lines relative to the accuwulatars?.

3'.Oo the check valves on the SRV and HSIY accuaulator fnlet lfnes have.resflfent seats and are they spring, laaded?4.Is each NSIY acc~lator capacity 3S gallons, Nfnfwum?S.Are the SRV accveulators 10 gallon capacity for the relief function and 42'gallons for the AOS function?6.Are the teeperature eleeents fn the SRV discharge lfne specified to be 3 to 6 feet froo the valve body?7.Are the.steaa lfne drains capable of equalizing pressure across the NSIV's prior to restar t follawfng steaa line isolation?

S.Is the condensing chamber 821-0002 center line elevatfon'specified to be 20" 1" above the vessel head nozzel flange face?9.Are the center line elevatians of condensing chaaler 821 0004 A-Oa 1 1/2" relatfve to the centerline of the vessel nozzle with a slope to place the chamber about 3 feet froa the nozzle.10.Are the electric circuits for the outboard HSIY protected against downstream breaks as required by the Electrical Equfpoent Separation Safeguard System design Specification?

ll.Are the AOS valve solenoid circuits protected against get fopfngeaent fram~sea)1 HPCS injection line break?12.Is the pneveatfc supply 1fne froa each accuaulator to the safety/relief valve 10 feet aaxfe~equivalent length and 1 1/4 inch afnfaa nowfnal pipe size?~~AFQ:cas/SHS 10/a/?9 Page 2 of 7 HANFORO 2 BOP INTERFACE REYIEV HIGH PRESSURE CORE SPRAY SYSTEH l.Are HPCS pump E22-C001 nozzle loads within specff1ed limits?2.Have thc,HPCS System environmental requirements been adequately considered in the design of the.equipment areas?3.Have line losses plus elevation rises plus reactor pressure been determined to be less than the pump TDH values specified on the process diagram?4.Is restricting orifice E22-D002 sized to simplify pre-operational test sizing (slightly smaller restriction diameter)and to eeet the requirements of the process diagram?5.Is the suppression pool suction strainer sized consistent wfth the requirements fn the design specfffcatfon2 6.Are the suction lines (suppression pool and condensate storage)sized to provide the NPSH specified on the process diagram?7.Are the condensate storage tanks, condensate supply linc, and level transfer instrumcntatfon arranged so that the minimum condensatc water storage reserve is available to the HPCS System?8.Are the flushing connections arranged close to the isolation valves to maximfzc the flushing volume?Is the"water leg puay" (E22-C003) designed to operate post L'OCA as required by the design specfffcat1on?

~J AFD:cas/6H2 10/4/79*

Page 3 of 7 HAHFORO 2 SOP 1NTERFACE REV?Bf RHR SYSTEH l.Adequacy of RHR pump HPSH should be evaluated at condition of SO%plugged suction strainer, and of that specified,in system design specification (see Table.i for paragraph number).g.Suction strainer mesh should be sized so as to eliminate foreign particlesof sufficient size to clog the containment sp~ay nozzles or suppression pool spray nozzles.3.Suction strafners and pool return lines should be arranged for uniform pool cool fng, 4.Stroke times of LPCl injection valve(s)-and shutdern isolation valve(s)should be.~fthfn time specified in system design spec.data sheet (Table I).5.Vere fn$ectfon valves specified to open against max.hP (vessel pressure-minus pump shutoff head minus elevation difference between min.pool level and valve, or as specified in system design spec.data sheet)?6.Are stcan relief valves si-cd for the thc maximum credible failure of the steam supply system?7.Mater~eight of both shutdown loop should be~ithin the maximum specified in the process diagram.(Table I)8.Do RHR equipment areas eeet Electrical-and Hechanical Separation requirements?

AFO: cas/6H6 10/4/79 wiPlgT Page 4 of 7 HAHFORO 2 MP INTERFACE'REVIBI REACTOR CORE ISOLATION COOLING SYSTEM-0 Has the minimum HPSH been satisfied from both condensate storage tank and suppression pool for all modes on the process diagram?2.Are line losses+elevation rises+reactor pressure within total puap dynamic pump head values (both high 4 low head values)2 3.Has the 15 psi prcssure drop between the reactor vessel and'the RCIC turbine been evaluated for modes A 4 B on the process diagram?i.Has back pressure at turbine exhaust been specified not to exceed process diagram value starting with pool pressure and working back to turbine considering line losses?S.Are"all" components of the RCIC System analyzed to be category I seismic except condensate storage tank?6.Are steam supply and exhaust lines sloped as indicated to prevent~ater hammer damage on fast start?7.Has a vertical hold down restraint been supplied to.prcvcnt)inc aovcmcnt on Tb.Exhaust considering 20 psi unbalanced pressure?8.Have the pump minimum flow bypass valves been specified to open and close in required time against full prcssure?9.Have the RCIC environmental requirements been considered in the design of the equipment areas?IO.Can RCIC start up and deliver rated flow independent of AC power?~~AFD: cas/6H1 10/a/79 jO.

Page 5 of 7 HAHFORO 2 SOP INTERFACE REVI&UN PRESSURE CORE SPRAY SYSTEM Are the suction strainers and suction piping sized such that the required NPSH~ill be provided to the LPCS puwps under all process dfagraa conditions even&en the strafners are 50K plugged?Is the LPCS suction strafner aesh sized so as to prevent foreign particles oi'ufffcfent size to enter the suction piping and plug the LPCS cyclone separator oriffces?3.Goes the.LPCS line-ffll systee functfon before and after a LOCA?4.@as the fn)ectfon valve.bought to the speed requfreoents of the system data sheet?S.Qo all LPCS components 4 piping Neet Sefsafc category 1 requfreoents?

4.Have envfrorusental requfreaents been accounted for fn the area of the LPCS equi peent?AFO: cas/6H?10/a/79 Page 6 of 7 HANFORD 2 BOP INTERFACE REVIEW OFFCAS SYSTEH 1.Are all process drains routed back to the cain condenser (by gravity flow for preheater, recoebfner, and condenser) with nonoally operat-ing drains 2",ainfam and incorporating a strainer, trap and trap bypass?2.For the loop seals (ff any), what are the provfsfons for non-siphoning, flushing, and blow out protection and are they tall enough for their particular purpose?3.Does the appropriate piping class extend to the first root valve on process drains and to the exit of the H analyzers, and where,$f ,anywhere, on the process.was the classfffcktfon changed because L/O c 7.0?4.How do you insure that the requfred dilution steaN fs always supplied to the SDAE train and that isolation will occur on low dilution flow?5.Does the valving sequences used to switch preheater reccebiner condenser trains allow for steae warning of standby train before SwitChOver and air purging Of ShutdOwn train after SwitChOver?

S.Have any provisions been lade such as color coding to signify which pipes and equfpnent possibly contain detonable aixtures?AFO: cas: at/SH3 10/8/79 Page 7 of 7 HAHFORD 2 SOP IHTKRFACE, REYIEW EHYIROHHKHTAL SPKCIF ICATIOH I'hat)s the h)ghest kntogratod,radiation dose and eax3am temperature at the RHR Puap Hotor that occurs during the fu11 shutdcnm period'.foll~tng the rec)rculatfon line break OBA.t.%et{s the aax)mn Caaperature at the RCIC Turb)ne speed controller

$f there$s a loss ot HVAC~n the RCIC)o requ)red to operate?AFO: cas/6H4 10/4/79

.0 WASHINGTON PUBLIC POWER SUPPLY SYSTEM ENGINEERING DESIGN REVIEW CHECKLIST PROJECT NO..SPECIf ICATION NO.TITLE I REVIEWED SY A.Design Requirements 1.Applicable sections of PSAR are: DATE i~~,i r.ra r, r 2.Does the specification properly cover the following items: a).NSSS imposed requirements?

b)AEC Regulatory Requirements?

c)State and other regulatory requirements'?

3.Has suitable information been provided by the A/E to support selection and sizing of equipment?

4.Are system isolation points adequate and accessible?

5.Is operator information sufficient locally?6.Is operator information sufficient remotely?7.Have precautions been taken to minimize the spread of contamination?

Operation (1aintenance 8.Is shield~ng adequate?9.Is accessibility adequate for the needs of radioactive maintenance?

ATTACHMENT 8 EXHIBIT 4-8.3 (page I of 6)(Rev.I, April I, 1975) 10.Does equipment have unnecessary traps for the concentration of radioactive material?.~11.Does equipment have necessary vents, drains, make-up supplies, etc.for radioactive service?sw~'.-'12.Are necessary controls.provided?lf.'Are.numeric'al..requirements reasonable?(Where suitable, perform simpl ified check"cal'culations) 14.15.16.17.18.19.20.21.22.Are interfaces with other systems proper?Are safety and relief provisions adequate?Is there adequate redundancy and separation?

Are redundant systems, protection devices, alarms, or adequate monitoring instrumentation incorporated in the design, where re-quired for safe operation and/or shutdown of the plant?Is identification adequate?Are necessary interlocks specified?

Are provisions made for in-service inspection?

Are the construction features suitable or the service , contemplated?

Is scheduling reasonable?

~23.Are special tools adequately specified?

24're installation requirements stated?25.Have instrumentation data and control functions been adequately and sufficiently provided to assure equipment integrity, as well as~efficient and safe operation?

26.27.28.29.30;Are circuits with maintained contacts utilized to prevent drop out of motors on voltage dips or momentary loss of voltage?Are the sizes, ratings, capacities of components, motors, fuses, wires, relays, etc., adequate to carry the burden imposed?Are cables and conductors terminated and identified correctly?

Are sensors selected to meet specified accuracy, reproducibility, operational limits, drift (time effect), response time, sensitivity and minimum output?Do sensors and associated equipment have adequate noise suppression circuits to meet computer input requirements?

ATTACHMENT 8 EXHIBIT 4-8.3 (page 2 of 6)(Rev.I, April I, 1975) 31.Do power supplies for I 8 C systems meet r'equirements to IEEE Criteria for Class IE Electrical Systems for Nuclear Power Generating Stations?32.Are all instrumentation wiring and components grounded according to the approved grounding scheme to minimize noise pickup?33.Are the loading, stress, strength, and structural design require-ments reasonable?

\34.Is the layout adequate for accommodation of equipment?

~A a)'.Is, lay-down area provided for disassembly?

Is clearance available for shaft removal or tube pull?~~~so~35.'Oo relevant:.'structural components contain provisions required by"-:pi ping"and eq'ui pmen't?a)Openings"Targe dnough go pass equipment?

b)Provision for personnel access?c)Support pads, anchor bolts, dowels?d)Box-ou ts, s 1 eeves, or penetr ati ons?e)Embedments in concrete for support or anchor?B.Code Requirements Have proper codes been specified and are'they consistent with PSAR Section 3.2?2.Are proper revisions specified?

3.Are specified requirements consistent with industry standard practices?

4.Ooes the document conform with applicable IEEE standards?

5.Ooes all protection system instrumentation conform to the requir e-ments to iEEE d279?ATTACHMENT 8 EXHIBIT 4-8.3 (page 3 of 6)(Rev.I, April I, I975)

C.Classification'f Characteristics I'.Are seismic requirements correct and in agreement with PSAR Section 3.2?;0 2.Are electrical requirements correct?3.Is the equipment clearly identified as to its guality Class 3?4.Are the safety and quality classifications correct and consistent with the ANS Safety Class and USAEC Regulatory Guide 1.26, guality Group, as listed in PSAR Tables 3.2-1 and 3.3-2?~~":-"'".'Are v.eports requirements correct?5~(4~D.Materials Have the proper materials been selected and the appropriate code references (e.g., ASME Section II or ASTM)stated?I'2.3~~1 C'fl 8 t Are the materials specified adequate for radiation resistance?

Are the materials adequate for corrosion resistance and/or minimum contribution.to radioactivation?

~I., Are points, and:coatings adequate?4'4.Q~l ATTACHMENT 8 EXHIBIT 4-8.3 (page 4 of 6)(Rev.1, April I, 1975)

E.Testing 1.Are required tests specified?

2.Are test tolerances and limits given?3.Are provisions made for in-service testing?4.Are provisions made for witnessing tests?4 h F.Welding 1.Are welding requirements stated?2.Are acceptance standards given?3.Is proper welding"boiler plate" referenced and attached?ATTACHMENT 8 EXHI 8 IT 4-8.3 (page 5 o f 6)(Rev.I, April I, 1975)

G.Part Identification and Serialization 2.3.Is equipment marking specified?

Are spare parts requirements included?Are code stamps required where appropriate?

4.Is terminology and item identification consistent and correct?~ll~~tA 4~, i;c H.Preservation, Packaging, and Handling l.Is proper cleaning"boiler plate" referenced and attached?2.Are cleanliness classes specified properly?3.Is proper packaging"boiler plate" referenced and attached?4.Are special cleaning, packaging, etc.requirements needed?ATTACHMENT 8 EXHIBIT 4-8.3 (page 6 of 6)(Rev.1, April 1, 1975)

WASHINGTON PUBLIC POWER SUPPLY SYSTEll NUCLEAR PRCUECT NO.COhIMEVT I RESOLUTION FORhl COKIIENTS ON: LKTTEII NO.PAGE OF OATE WASHINGTON PUBLIC POWER SUPPLY SYSTEhl ARCHITECT ENGINEER WPPSS PANIC COkllCNTS ACCCPT'5 5't g4 S I 64 r'I~!.r'4 C aCASOV ACCCPT llCJCCT Wt 6 1 6 Aev.1 ATTAOIHEHT, 9 EXIIIBIT PHP 4-8.4 (Rev.0, Hay 17, 1974)

QO ATTACHMENT 10 PE 1 ot 5 N BUf QNC ClCS DtC NTN~~r SNKN!Qfmeces,%25.Nev.15*"..-.--"--...-...-'-=.'=:'.::--

I...'8 520-525.Rev.0 and Rev.l'-.:-':.'::::

5519 SWSTa 5(55)AN4 15(RT)':-~+".;.5"ice'(N)for valve RCC-MY<8 ches e res should be rav)aed to s~the canal.a,, C<,~8~hen velv~71Aand 7" t and 7"", 8 ae)nter locked~1th the an contn1s x$th an auto s o,cm,on the 1ogfc d)agrm(r or f1'agnus 1:~,~~1('~'t (',"'r,'Xt r

~~tape 4 of 4~~~Qeector Sufldfny Closed Cool)te Motor BectHcal/tCC Prabless (cont)'Q'Talve CC V-101 closes on hfgh radfat)on s)anal to shut the" surge tank atmiospherfc vent.Th)e protect)ve funcf ton)s','-,--'~-'-,-.;-

bypassed due to the p)p)np des)gn of an open funnel overflow The Enyfneerfny Crater)a Oocument states that the ,--.-i.-:

-'..=.,:;-'-,';-:-.-:...-

ataospher)c vents shall be closed and the tank vented to the".'..",".:"=."-:.-.'=""-,'-'.,'-':=:-

redwaste systeIe upon rad)at)on s)anal.Thfs des)gn~ufre-.:-.,:.-.'.-'='-.-.':.--.=.--.-

.:.-'.~:-;.~;

%Nit fs not fllplmentedg please corrects~,,*"~,~~,'~,~+'<~,, W<~'.,~.'"~,"".'.';'",'.,~...~~.':.'-"~""'.",-4.Valves RCC V-N.8, C have an analog pos)t)on readout that=serves no useful purpose, The valve c)rcu)t w)11 only aller, fu11 open-full close operatfon.

The analog posftfon fndfca-t)on should be reoved.Rasolu)on: 'W~.--,".',-,.'.-',:.'-...

'.-.--.: '-.'-.'--.~'-:-:.,:-,...~e;-.;-::..

';,.~.The loqfc dfayraji shows valve RCC-VAO as hav)ny a second pa)r"-';:.-:...of fndscatfng lfghts at board S.Thfs)snot shown on the EQ.

~~~age c or 4 Neaetor Sufldfng gosed~lf~>.."-.:~':-:.-'.Neeirfeal/ECC Pre44ms (conc j~'~~~~~~The~c dfagms do-not shar switch actfon, f.e.sprfng return~'>'.w'*I'~~~,$,'e'ee'" 1 N..-...,.:,;',,..-.t.,;~~dasfgn iCandard symbols ari'not befng follerect for Ch~..;..-;,,::."--.;..:.'-,.-"..dfagram., ere are three dfffarlnt symbols show for the same-,.-"-"-"--=-'"'" t'cordfn to 1'f~ccordfng to fnformatfon recefved durfng the prevfous revfew,"';.:.";"'"='"--

""'standard fndustry practfce For fnstnee t fd tf-,.:-',:,.',;..::-..;-:.:

ffcatfon.The fndust~practfce', on.".;:,'v.r, Jgi-.p ce't<<1 g l ered corrlctly".'-: """'at on of flee er level tran'"-;=.--:-:=';-.";:.

-.mfttar usfng a dfffersn'tfal pressure method of measurerant fs not, I~tfal passu~transmfttar

~o P~Q~Nasu~d va 1 rl~tandard fndustn'dIntfrfcatfon 15 Ro':: ':::: """"":-.tter.Thfs fs explafned and documantad fn LSA sta d rd grap.Z.Z (Instrument Symbols 4 ldentf ffcatfon).

848 rrect the errors and fmplement the fadust~sCa~~~~"l'>'+~~'i'y~,-'",x?n;,.:

-.'.5..:;"".'j~,.:.:.'44 t

,.':;,': 'Rwctor tuf14fno C1osed Coo1fne Sacer:.I1ectrfcal/QC hob1aa (cont.f IV ,-;-.':"-;,:;

9.A fa1so 1'ressure a1arm Q11 sound each Cf th RPCCM..-"..-;.:,-'-:--",-'..:."',='-:.;--.

=;='-.-":":-;:-;',"=:."~i;,.'"...systeNI fs started up.Puttfny a 52/a contacC bebw Ch-"",=::-,',;:-"';l"'.=,':pres ure serf Cch and the 63X re1ay and usfng a Cfear de1ay'.-.-.-',,;=",,-;":

';...-i'."::""".-.-"..'".-.,'-:.-'::

p ckup on re1ag 63X/RCC-PS)A e511 rectffy thfs desfgn-~:-.;::,g;

='-":."(sobIm

'he fatso dfagrsa does not show the slam Satan-'.=."-';;-"':=':"'.-',,-,-'-"'.'ek fifth puap startfny as shoe on the ED.(f518 sh t 3 R2)'-':-:-'-;=-':::"':.'=-:.",:."".

~,'..'.."-,-~".-,<..'~~..:.';~.:-::".:.~e.~'~h A t~*" s e~s~

Gg WhS HLV CTON PUBLIC POWER SUPPLY SY~I DC8/DCR/D(8 CHECKLhT AC NO WN Ng C:<<0<<ENI<<CA NO W<<fSS OCSION CHAN4C OE5I4NATION EN4INEERINO REVIEW AOO ITIONSIOCLCTIONS Ot5CRISC WHY THC CHANOC IS NCCCSSARYI lt Ow TO MCCT LICtHSIIKS RCOVIRCMOrt%

TO<<IECT COM<<IITTCO STANOAROLTO SATI5fY OTHtll CONTRACT COMMITMCNT5o 555CNTIAL TO COMfLCTC fROICCTe ETCS L SSBSBN (MAR RATIvc occcllfTICN, 5 owoMISSICN fkoM 4RIOIHALfEAHs ANo SftclflcATICNW RtotSICN foR 5fCCIfIC RCASON, CT+L HAS THE CHAHat cctrl 5 VVSICAu.v Rcvlcwco IN THc flcLOI L IS THE SCO ft 4 f THIS CHANC 5 CON<<LETC 54 ALL Af f CCT'EO TC CHKICAl OOC'4 M 5 NTS ARE I 4 EN r I f I EO I YCS HO 0 CI C3 Cl l5 THIS CHAHOC NECESSARY fOR EITHER INITIAL fLANT ofcRACI4TY OR 4CENSIHOI ra IS THC SUSJCCT CHAHOC A TCCHN I CALLY 5ATISf VICTORY SOLUTION TO THI5 f R OS LEM1 L IS AOOTT14NAL tCHHICAL REVIEW RtOVI CEO SY OIL 4CEHSIINL OKRATIONS OR 5TARTUfr L ARC AIC MAHHOVRS 45TCO*NO RCA5ONASLCS Ia.CONCI.VSION Of ENCINCERHIO RCVICW Q AAKOVCO Q OISAfMOVEO ACTION TAKtN)W<<w<<O A~I<<W~I'I<I A VI Wino NOIW EA EQiIBIT I (SHEE.1 Ce 2)ATTACHMENT ll 5-111~SIO.j YO.1 PAGE 16 CF 21 PAC.

CONSTRUCTION RCVICW ICONSTRUCTION CONTRACTS ONI TI YCS No L RC4UIRCD 5TART OATt POR WORK DOC5 THC COMPLCTION OATC INOICATCD ON PCNIPCR SUPPORT THC CON5TRUCTIOH SCHCOVLCI Q P L CAN WORK SC PCRPORMCO CONCVRRCNTLY WITH OTHtR CONTRACT WORK SNTHOVT IMPACT DN Q Q OVCRALI CONTRACT COMPLCTIONI L HAS THC PROPtR CONTRACTOR%

CCCN SCLCCTCD TODD THC CNAN4tD WON KI Q Q Ir NO.AoomONAL DAYS ARC C5TDIATtD TO OC RCOVIRCO L CONCLVSION OP CONSTRUCTION RCVICW Q APPROVCO Q DICApptovco ACTION TAKCNs ONS RV IQN SNC H CORI AAC r OMINOIe%AIIUN RLVISN L IS THC PROPOSCD CHAHOC WITHIN'TNC 4CHCRAL 5COPC OP TNC LISTCD CONTRACTSI I RANOC CSTIMATC CIVCN POR THC PROPO5CD CHAN4C 5 IAIC AND CONTRACTOR COSTS)Q~VHO5 POR TNC PROPOSCD CMAN4C PROM AHTICIPATtD CHANOCS 5 CONTDI4CHCY 5 L AMOVNT OP PVNO5 RCMAININO IN ANTIC IPATCD CNANOC5 5 5, COHCLUSION OP CONTRACT ADMHII5TRATION RCVICW CONTINOCNCY 5 P APPROVCD ACTION TAKCNs Q OISAppRovco A A MINI RATI 4 APPROVCDs I N IN IN M,l N RU ON II R EXHZBIT I (S~2 CP 2)PiiP 5-111 REVISICR1 YO.f, PAGE 17 OF 2i

AllACHMENT 12 1 af2 OQ, Date: Tot

Subject:

Reference:

1HTiR 0FF ICE MEÃ08A'N0UQ

.WASHINGTON PUBUC POWER SUP.LY SYSTEM C3 EDC SNP-2'I EIXl V?NP-Si5 Cl Admin HIe HL Bennett RL Besser GW Brastad BM Boyum WG Conn EA Fredenburg DL Gano RE Green'AH Hol le AN Kugler GR Lawrence FE Maddy QA Ogawa DC Timmins MF hliitala IA Rodriquez KDC/lb EAF/lb November 8, 1978 DISTR j BUTION KD Cowan, Project Engineering Manager,'NP-2 PROCEDURE FOR AUDITING AE CONFORMANCE TO CRITERIA FOR WPPSS APPRONL OF DESIGN CHANGFS ME Witherspoon IOM, dated May 17, 1978 same subject This instruction supersedes the Reference.

Tne procedure transmitted by the Reference is voided.This change in procedure should cut down on the amount of paperwork being distributed and routed.All design changes shall continue.o be reviewed from the standpoint of cost, schedule, and technical adequacy.Cognizant engineers have a responsibility to cull changes which are not in the best interests of the Supply System regardless of whether or not WPPSS site approval is required.CONCURRENCE:

.N, Kugler Effective immediat ly, all PCN's and PED's which are determined by the AE and the Burns and Roe Technical Support group to not require approval by the MPPSS Site organization shall be reviewed by cognizant engineers for compliance with the criteria contained in Exhibit I of PMP 5-111-1.This reivew shall be evidenced by completing the attached form.The design change document with review form attached wi 11 be routed, and filed by Irma Rodriquez.

RFI's will be routed for information only since any design changes resulting from RFI's will be issued and reviewed as'ED's.W.G.CON~KD":c".h WF 102 82 ATTACHMENT 12 20f 2 PCN PED Evaluation of Comoliance with WPPSS Review Criteria Date to Peviewer WPPSS Review.Criteria (from PMP 5-111-1): 1)Deviation from commitments in SAR, ER, EFSEC.*')Deviation from design criteria or fran applicable codes and standards.

(3)Change in safe y or quality classifications (4)Sacrifice of operability or maintainability (5)Estimated engineering and capital construction costs exceed S50,000.(6)New Work (See 8-21-78 IOM from WG Conn)'*Refer to WPBR-78-274, dated 4-13-78 Based on criteria above,'WPPSS review is not.required.Based on criteria above, WPPSS review is.equired.;~REVIEWER: DATE:

MASTER LIST tSJOR ENGINEERING TASKS TO PLANT COMPLETION

~O Page 1 of ll January 25, 1982 ITEM I NO.I DESCRIPTION"INDICATES DUPLICATE ITEM I RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDENT I-COMPLETE FIED I I I I I.I I I lb lc le I POST TMI ENGINEERING I CONTROL ROOM DESIGN REVIEW AND CHANGES PLANT SHIELDING-II.B-2 I POST ACCIDENT SAMPLING I CONTAINMENT INERTING I PERFORMANCE TESTING OF SAFETY RELIEF VALVES I I I-I CAREY I 7-23-81 I YES I NO.I S-I JOHNSON I 8-,10-81 I YES I NO-I CAREY 12-15-81 I YES I YES 8.'-I.";.-/--JOHNSON I 8-04-81 I YES I No I I BOSTRTOM I 5-81 I YES I NO I SRV POSITION INDICATION I CAREY 0%44k YES I ae'r~"=I RCIC LEAK DETECTION LOGIC (Ilk.3.15)

REDUCE CHALLENGES To SRV's I CAREY 8-04-81 I NO I YES I I amasQlisN i-z7-VP Ne I'~I I MODIFICATION OF ADS LOGIC I CAREY I 8-05-81 No I No I lk lm ln lo I RESTART OF CORE SPRAY h LPCS ON LOW LEVEL I QUALIFICATImt OF ADS ACCW ATORS ll.k3.28 I TECHNICAL SUPPORT CENTER I DEGRADED CORE ACCIDENT I RADIATION SOURCE CONTROL I RCIC SWITCHOVER I TDAS (TMI h NON"TMI ASPECTS)I CAREY e-o5-el No I No I ROGOZA 11-6-81 NO I YES'WILSEY 8-20-81 YES YES I I JottNSON I 8-17-81 I No I NO I JOHNsoN 8-18-81 I No I No I Jot tNsoN 8-lo-el I No I No CAREY I 8-10-81 I YES I YES PROGRAM CENTRAL PROCESS COMPUTER (TDAS I CAREY I I i~I~.~Jl tlat"~I a C 6 MASTER LIST MAJOR ENGINEERING TASKS To PLANT COMPLETION Pagi 2 of ll.January 25, 1982 ITEM I NO.I DESCRIPTION RESPONSIBLE ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDEN TI-COMPLETE FIED I 2 I PIPE BREAK MISSILE EVALUATION 3-I POTENTIAL CHANGE IN SEISMIC GROUND MOTION 4 I ATWS 5 I ENVIRONMENTAL QUALIFICATIONS 6 I CVRP-ANNULUS PRESSURIZATON JOt tNSON I 8-27-81 I JOHNSON I 12-23-80 I S.JOHNSON I 6-09-81 I THAKUR I 8-10-81 I I BOSTROM I 5-81 I YES I YES I No I YES I VES I VES I VES I I YES I YES I Y e.s 7 I SITE ENGINEERING PIPE SUPPORT DESIGN PROGRAM I SKINNER I 8-06-81 I YES I No I 8 I-CONTRACT 215 LG.DIA.PIPING SYS.DESIGN (NPS PIPING)I HAYNES I 7-81 VES I NO I 9 I SQRT EVALUATION 10 I AS BUILT PROGRAM LG.DIAMETER PIPING BOS TRON I 7-81 I YES I No I I RLF.ITEt4 5 I ON MASTER ILIST I I 11 I FIRE PROTECTION 12 I CVRP-CHUGGING LOAD DEFINITION 13 I IE BULLETIN 79-02 14 I ULTIMATE HEAT SINK 15 DELETED-FLEXIBLE CONDUIT PROBLEM CAREY/ROGOZAI5-28/8-03-Bll I BOSTROM I 8-14-81 I SKINNER I 7-O6-81 I I POWELL I 8-03-81 I THAKUR I 8-19-81 I YES I No I VES I I NO I NO I YES I YES I NO I NO I 16 I CVRP-FATIGUE EVALUATION SRV LINES FTC.I BOSTROM I 5-81 I YES I YES I e 17 I CVRP" CONDENSATION OSCILLATION LOAD DEFINITION I BOSTROM I 8-14-81.I VES I NO I 18 I PIPING CLASS 1 STRESS REPORTS I HAYNES I 7-81'YES I No I 19 SEISMIC CATEGORY I PIPING FINAL CALC.(NON-CLASS 1)I HAYNES I 7-81 I YES I YES I 20 I EQUIPMENT NOZZLE LOADS 21 I NRC QUESTION 130.48'EISMIC fKTHODS 22 I POSSIBLE-VALVE MODELING PROBLEM I HAYNES 7-81 I JOHNSON I 12-16-81 I HAYNES 7-81 YES I NO I No I NO I YES No

~tSSTER LIST MAJOR ENGINEERING TASKS TO PLANT COMPLETION Page f ll January 25, 1982 ITEH I NO.I DESCRIPTION l RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.IDENTI-FIED COMPLETE FOLLOW-UP ACTION 23 I QUALITY CLASS II ITEMS IN SEISMIC I AREAS(ttECHANICAL) l BOSTROH Ill-02-81-NO NO 24 25 26 27 28 29 30 31 32 33 35 36 37 40 41 42 I RIGIO CONDUIT CLAW'DEQUACY I CVRP-SUPPRESSION POOL TEt4'ERATURE LIMITS I SMALL DIAt~ER PIPING AS-BUILT EVALUATION I VOLCANIC EVENT EVALUATION I CVRP-DESIGN ASSESSMENT REPORT REVISIONS I RHR TRANSIENT ANALYSIS I RCIC MOISTURE CARRYOVER PROBLEH l TURBINE TRIP ANALYSIS I CVRP-VACUUM BREAKER CYCLING PROBLEH I RIGID SWAY STRUT PROBLEH I CVRP-NSSS EVALUATION I SRV LINE TRANSIENT ANALYSES STANDBY SERVICE WATER PUMP thOTOR I CVRP-FUNCTIONAL CAPABILITY EVALUATION I MOD.OF DRAINS TO HS AND FtN TRAPS I REVIEW h HOD.TO RADWASTE CONTROL PANELS t CVRP-IN PLANT SRV TESTING I FUEL POOL COOLING UPGRADE t MISCELI ANEOUS LICENSING ISSUES I THAKUR 8-03-81 I JOHNSON 8-10-81 I HAYNES I 7-81 I WILSEY 8-06-81 I BOSTROM I 8-06-81 I HAYNES 7-81 I J.ROGOZA 8-03-81 I HAYNES I 7-81 I J.ROGOZA I 8-04-81 I SKINNER I 6-29-81 I HAYNES I 7-81 I HAYNES 7-81 I TtlAKUR I 8-05-81 I HAYNES 7-81 I ROGOZA HA WHEN 12-17<<81 I BOSTROH l 5-81 I JOHNSON l 8-26-81 I JOHNSON 8-26-81 NO YES YES YES NO NO I YES YES NO YES YES YES YES YES YES YES NO NO YES YES YES YES YES YES s-5-PZ.PREPARE PROCESS DIAGRAHS FOR FLOW AND TEMP.INFO.ROGOZA 8-05-81 NO 44 I SACRIFICIAL SHIELD HALL I HILSEY I 11-17-81 NO NO 45 I DELETED-PERSONNEL ACCESS CAPACITY IN GUARD HOUSE I CAREY'2-14-81 tQSTER LIST MA30R ENGINEERING TASKS To PLANT Cot%'LETION Page 4 of ll january 25, 1982 ITEM I No.I DESCRIPTION RESPONSIBLE ENGINEER ENGR.ASSESSMENT SCHEDULE DATE I AVAIL.FOLLOW-UP ACTION IDENT I-COMPLETE FIED I 46 I RIGID CONDUIT TO SWITCHGEAR 47 I COMPLETE TECHNICAL SPECIFICATIONS 48 I LOOSE PARTS MONITORING EQUIPMENT Tlml<UR I IAWKEN I 8-19-81 I12-15-81 Ilo-12-81 No I No I YES I YES YES No I S-s-vz, 49-I DELETED-INSERVICE INSPECTION

-SEE ITEM 144 I 50 I CONTAINMENT INTEGRATED LEAK RATE TEST I WILSEY I 10-30-Sl vEs I YES 51 I FENCING CONTRACT 52 I PAVING AND GRADING CONTRACT 53 I SOLID RADWASTE SYSTEM 30tkNSON I12-23-81 I POWELL I~g~Mt<s<g I12-28-81 YES I vEs I DELETED-SECURITY-LIGHTING CAREY I12-15-81 vEs I No JO}NSON 56 I RPS-MG SETS I TINKUR 55 I AUTOMATIC WETWELL SPRAY/DRYWELL FLOOR BYPASS LEAKAGE I I12-16-81 I 8-06-81 No I No I No 57 RFW PUMP VORTEX STRAIGHTENERS I ROGOZA 58 I CONTROL ROOM VENTILATION ROGOZA lll-9-01 YES I No 59 I DELETED-SEWAGE TREATMENT PLANT WILSEY Ill-18-81 No I 60 I POTABLE WATER/FIRE PROTECTION SYSTEM (FPS)BUILDING I J.ROGOZA I 3-25-80 61 DELETED-NEW DC BATTERY SYSTEM TllAKUR I 8-14-Sl No 62 I DELETED-GE SEPERATION CHANGES THAKUR I 11-3-81 YES I YES 63 QA VAULT MODIFICATIONS DELETED-QC UPGRADE OF 10" WILSEY BOSTROM Ill-17-81 I 8-19-81 No I No I No No 65 I PIPING WITH INSUFFICIENTLY THICK WALLS I BOSTROM I 5-81 No I YES 66 I DELETED-CIRC.

WTR PIPE Ec PLENN LEAK.UNDER T/G FLOORI WILSEY Ill-17-81 No I 67 I TG MISSILES AND ISI 68 I PIPE NOTION NONITORINO SYSTEM~I S,~~~I WILSEY I BOSTROM llo-30-81 5-01~4 vEs I No YES No (y-ttASTER LIST MAJOR ENGINEERING TASKS TO PLANT COMPLETION Page 5 of ll january 25, 1982 ITEM NO.DESCRIPTION RESPONSIBLE ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.IDENTI-FIED COMPLETE I FOLLOW-UP ACTI CONDENSATE IN-LINE RESERVOIR FOR HPCS AND RCIC~I S.JOHNSON 6-09-81 70 71 72 CVRP-SASS I CLASS lE EQUIPtKNT LIST ELECTRICAL EQUIPMENT TAGGING BOSTROM I 8-17-81 t t0 THAKUR I 8-07-81 I YES Tt tAKUR I 9-17-81 I t@NO YES 73 DELETED-lhISCELLANEOUS SECURITY SYSTEH CHANGES REF.ITEM 114 Ott THE MASTER LIST 74 75 76 DRAWING INDEX OF DEVICES ELECTRICAL (DIODE)PAOGAAht I DELETED-VENDOR DRAWING UPDATE PROGRAM SUPERVISED WIRING Tl tAKUR 8-07-81 NO ttAWKEN I 12-15-81 NO THAKUR I 9-03-81 I NO NO YES 77 I VIBRATION MONITORING I BOSTROH 5-81 I NO YES 78 TORNADO/DUCTWORK PROBLEH (SEE WPBR-81>>39)

I POWELL I I 79 80 81 I EOF I SIMULATOR I EMERGENCY PLAN CAAEY)2-zv-Sl I es HAWKEN 10-05-81 I NO CAAEY I l-2-t2 YES Yes 82 I DELETED-CONTRACT 2 (GE)ADMIN.(TECH.INTERFACE)

I GIUSTI I I 83 DELETED-CONTRACT AOHIN.PREPURCHASED CONTRACTS'GIUSTI 84 I SYSTEM DESCRIPTIONS I WILSEY 11-16-81 I NO YES 85 86 87 88 I MASTER DOCUMENTS LIST EWD's TEN CYCLE SEIShtIC CRITERIA I STRUCTURAL STEEL CRACKING I GIUSTI I I THAKUR I POWELL I POWELL 8-13-81 I NO YES 89 (DELETED-SINGLE FAILURE OF REMOTE AIR INTAKE VALVES I CAAEY 12-18-81 90 RHR DIFFERENTIALS STEAM CONDENSING JOHNSON~~~r ITEM I No.I DESCRIPTION t@STER LIST MAJOR ENGINEERING TASKS TO PLANT Cot1PLETION I RESPONSIBLE

-ASSESSMENT I ENGINEER.-DATE ENGR.SCHEDULE AVAIL.Page 6 of ll January 25, 1982 FOLLOW-UP ACTION IDENTI-COMPLETE FIED I 91-I RCC HEAT EXCHANGER DIFFERENTIALS.

92 I SUMPS IN ECCS'UMP ROOM 93 I SECONDARY CONTAINMENT PRESSURIZATION-94 I HSRV PIPING ISI 95 I FUNCTIONALITY OF ISOLATION VALVES 96 I JET It@'INGEMENT MSRV's JOHNSON I ROGOZA I WILSEY I12-23 I HAYNES I JoteSON I 7-81 I BOSTROM I 6-81 No NO YES YES No I YES.97 I DELETED-WETWELL COATING ABOVE WATER LEVEL.-I 98 I NON-CLASS IE COttDUITS I TRAYS IN CLASS I AREA I WILSEY THAKUR lll-17-81 I 8-19-81 NO NO YES 99 I DELETED:-CONTROL ROOM INFILTRATION THRU HVAC'ROGOZA 100 I SBGT INFILTRATION TEST 101 HYDROGEN MIXING 102 I CRD DISCHARGE VOLUME DESIGN 103 I HOT RRC TEST VS.INITIAL VIBRATION TEST'1O4 I OOYN CODE ANA1 YSIS 105 I MASS ENERGY STUDIES I.Jot lNSON JOHNSON I'JOHNSON I JOHNSON JOHNSON I WILSEY ll2-23-81 I 8-11-81 I 8-11-81 I 8-21-81 NO I YES YES 106 I DELETED-RCIC I HPCS TRANSFER-SAME AS ITEH 69 I 107 I STRESS CORROSION CRACKING 108 I CONTAINMENT BUCKLING ANALYSIS I ROGOZA I POWELL 109 I DELETED-CONTAINMENT INERTING-COVERED BY ITEH ld I 110 I REG.GUIDE 1.47 PANEL DESIGN CAREY I 7-23-81 YES NO ill STATION BLACKOUT 112 I LUBE OIL CONSUMPTION OF DGS Q PLAGGE I'OGOZA ll2-3-81 0 t tASTER LIST MA30R ENGINEERING TASKS TO PLANT COMPLETION Page 7 ot'l january 25, 1982 ITEM I NO.I DESCRIPTION RESPONSIBLE ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOH-UP ACTION IDENTI-COMPLETE FIED 113 114 POST ACCIDENT MONITORING INSTRUMENTATION R.G.1.97 SECURITY-t<ISC.

ITEMS INCLUDING SECURITY LIGHTING I CAREY CAREY 7-29-81 I YES I YES I~3 I 12-15-81 I YES I No I 115 I BINGHAM AMt tENDMENT S.JOHNSON I 6-09-81 I.No 116 117 DELETED-CONSTRUCTION QUALITY DELETED-PROVIDE 2ND LVL OF UNDERVOLTAGE PROTECTION HILSEY THAKUR I 11-16-81 I No I No I I 10-29-81 I No I No--I 118 ll9 120 121 SITE ACCEPTANCE TESTS FOR DIESEL GENERATORS (PSB-2)I ROGOZA I EVALUATE CONTAINMENT ELECTRICAL PENETRATIONS FOR I SINGLE FAILURE VULNERABILITY (PSB-3)THAKUR I JUSTIFY THERtQL OVERLOAD MARGIN FOR MOTORS (PSB-5)I PLAGGE I PUMP AND VALVE OPERABILITY'EMONSTRATE BY I I TEST OR ANALYSIS (MEB-6)I HILSEY I Ill-9-81 Ilo-12-81 I I NO YES NO I No I 122 123 I REQUIRE INDICATION OF NRC CONCURRENCE HITH 9+QS~W I I HNP-2 SEPARATION CRITERIA (ICSB-2)I HAHKEN I UPGRADING OF RCIC SYSTEM INCLUDING AUTOSTART(ICSB-7)

I ROGOZA I I12-21-81 No I YES I W->-E2 124 I DETECTION OF INTERSYSTEM LEAKAGE (RSB-5)I HILSEY 125 I RCIC PUtk'UCTION (RSB-6)I ROGOZA 126 SHUTDOHN UNINTENTIONALLY OF THE RCIC SYSTEM (RSB-7)I CAREY-I 8-06-81 NO I No 127 128 CATEGORIZATION OF VALVES HHICH ISOLATE RHR I FROM REACTOR COOLANT SYSTEM (RSB-9)AVAILABLE NET POSITIVE SUCTION tlEAD (RSB-10)I JottNSON Jot tNSON I 10-02-81 No NO I 8-25-81 I NO I NO I 129 I OPERATILITY OF ECCS PUMPS (RSB-14)I JOHNSON I 8-25-81 No I No I 130 131 ADDITIONAL LOCAL BREAK SPECTRUM I POHELL I DIVERSION OF LOH PRESSURE COOLANT INJECTION SYSTEM I HILSEY I I 132 USE OF NON-RELIABLE EQUIPMENT.

IN ANTICIPATED OPERATIONAL TRANSIENTS

~~':~I-': "., I';: JOHNSON I 10-02-81'o No I~"\

6 htASTER LIST HAJOR ENGINEERING TASl(S To PLANT COMPLETION Page 8 of ll January 25, 1982 ITEM I NO.I DESCRIPTION RESPONSIBLE ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDEN TI-Cot%'LETE FIED 133 I PEACH BOTTOM TURBINE TRIP TESTS D4 I MINIMUM CRITICAL POWER RATIO 135 I GEXL CORRELATION 136 I STABILITY EVALUATION 137 I EXEMPTIONS FROM APPENDIX G TO 10CFR50 D8 I EXEMPTIONS FROM APPENDIX H TO 10CFR50 JOttNSON I WILSEY I JOHNSON I Jol]NSON I JottNSON I JOttNSON I 8-21-81 No 139 I CONTAINMENT PURGE SYSTEH AND ISOLATION I 140 I CohtBUSTIBLE GAS CONTROL JOHNSON JOHNSON I12-23-81 I 8-11-81 141 I ALARA 142 I DELETED-TDAS REF.ITEM 1'43 I DELETED-INSTRUhtENT SETPOINT I JottNSON HN EN I 8-10-81 ll2-17-81 No YES YES 144 I INSERVICE INSPECTION 145 I SUPPRESSION POOL HIXING 146 I BOP SEPARATION CRITERIA SKINNER I 11-11-81 Tt tRKUR I 8-13-81 REF.ITEM 25I ON htASTER YES ILIST YES YES 147 I CONDUIT TAGGING 148 I DELETED-VOLTAGE DROP-CASES 149 I ELECTRIC RACEWAY PROXIMITY TO HOT PIPE 150 I DELETED-RCC HEAT'EXCH.

DIFFER.-SAME AS ITEM 91 I Tl IAKUR TttAKUR TltAKUR I 8-13-81 ll2-4-81 I 8-07-81 NO YES YES 151-I TERMINATION DOCUMENT PGCC 152 ITT HYOROMOTERS NOT QUALIFIED I MAW EN I 8-19-81 Ilo-13-81 YES 153 I'OUBLE LOADED CLAMPS 154 I SPENT FUEL RACK VENTING REF.ITEM 115lON MASTER LIST I REF.ITEH lll46 ON MASTERI LIST~(~!!(!!=,~~(~

MASTER LIST MAJOR ENGINEERING TASKS TO PLANT COMPLETION Page t'l January 25, 1982 ITEth NO.DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SO{EDULE AVAIL.IDENTI-FIED COMPLETE I FOLLOW-UP ACTION 155 LEAKAGE HITIGATION SUMP IN R.B.I ROGOZA I I I 156.I DELETED-EQUIP.QUALIFICATIONS

-SNK AS ITEM 5 I I I-.I 157 158 159 160 161 162 163 I CONTROL ROOM HABITABILITY I SAFETY PARAMETERS DISPLAY CONSOLE I PENETRATION ANALYSIS (SHIELDING)

I DELETED-ANALYSIS OF CLASS 1 SMALL 0 PIPING I SYSTEM-SAME AS ITEH 19 I ASHE SECTION III N STAMP CERTIFICATION I DELETED-LITIGATION 206 215 INSTRUMENT LIST UPDATE I ROGOZA I I I CAREY'12-16-81 YES I YES I JOHNSON I BOSTROH I 8-05-81 I NO I NO HILSEY I 12-28-81 NO I NO CAREY 7-29-81 I NO I 164 T.F.II CONTRACTOR TASK GROUP (TASK 0107)I GIUSTI I I 165 166 CONTRACT 218 RETROFIT (TASK 0117)I STEAH DRAIN AND CONDENSATE (TASK 1190)I TINKUR BOSTROM 11-02-81 YES I NO 167 I VENT ANO DRAIN REVIBl TASK 1210)BOSTROM I 8-06-81 I YES I NO 168 I CONTRACT 217 REVIEH CON'tENTS (TASK 1280)I ROGOZA I 169 170 OFF-GAS HOLDUP LINE NELDS (TASK l330)PIPE DEFECT REMOVAL (TASK 1350)SAME AS ITEM 65 I BOSTROM I 8-06-81 I YES I NO I I 171 I CLASS 1E LIST (TASK 1560)I REF.ITEM 7ll ON MASTER ILIST I 172 I PCN 6779-HSLC RO(SICAL SEPARATION (TASK 1580)I THAKUR I 9-D-81 I NO I NO 173 174 175 RADIAL BEAM SUPPORT ATTACHMENTS (TASK 1660)I WILSEY 11-12-81 I NO I NO I PRIMARY CONTAINMENT VESSEL ATTACtlhtENT (TASK 1670)I SKINNER 9-29-81 I NO I NO'PACE VIOLATION FOR CONCRETE INSERTS (TASK 1680)I SKINNER I 8-14-81 I YES I NO 176 AS-BUILT REVISIONS OTHER CONTRACTS (TASK 1700)I P v BOST ROM 8<<19-81 YES I NO.'

.~hQSTER LIST MAJOR ENGINEERING TASKS TO PLANT COMPLETION Page of ll January 25, 1982~j g ITEM I NO.I DESCRIPTION i RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.'CHEDULE AVAIL.FOLLOW-UP ACTION IDENT I-COMPLETE FIED I 177'CADWELD EVALUATION (TASK 1780)I QUALITY CLASS II ENGINEERING VERIFICATION OF 178 I PIPING AND SUPPORTS (TASK 1810)179 I QUALITY CLASS I AS BUILT SUPPORTS (TASK 1820)(,WILSEY l 11-12-81 I YES l NO SKINNER 7-30-81 YES I REF.ITEM 10)ON MASTER)LIST 180 j AS BUILT LARGE BORE HANGER DETAILS (TASK 1860)I REF.ITEM 182(183 ON MASITER LIST M200 GEOMETRY REVIEW, DW ANALYSIS, AND NPS ANALYSIS 181 REVIEW (TASK 1910)t HAYNES 7-81 YES.NO'182 I HANGER DESIGN ANO DRAFTING I REVIEW AND DRAFTING OF WBG LARGE BORE HANGER 183 j ISO'S (TASK 1950)SKINNER I 7-31-81 I YES YES SKINNER I 7-31-81 I-YES I YES)REVIEW AND APPROVAL OF CONTRACT 220 SMALL BORE 184 I STRESS REPORT (TASK 2000)I I HAYNES 7-81 YES NO 185 I PCN 6859 REVIEW CLASS lE CABLE (TASK 1590)186 I REVIEW INSTRUMENT DRAWINGS (TASK 1620)I REACTOR BUILDING, INSIDE CONTAINMENT HANGER 187"t STUDY (TASK 2030)188 I CALCULATION REVIEW (TASK 2040)THAKUR l 9-18-81 I YES I YES HAWKEN.)10-19-81 I YES I YES I-" I SKINNER l 8-03-81 NO I NO BOSTROM.t 8-19-81 I YES I NO l s-3-sZ 189 I PENETRATION SEALING/FIRE BARRIER.(TASK 3020)I PLAGGE l10-07-81 l NO j NO 190 t EMBEDDED PLATES (TASK 3030)I POWELL I I I 191 I HEAT TRACING (TASK 3130)l PLAGGE I 11-20-81 I YES (NO 192 I CONTRACT 206 CLOSE OUT (TASK 3170)I WILSEY I 12-21-81 l NO I YES 193 I VERIFY AND UPDATE HANGER GRID DRAWINGS (TASK 3210)I SKINNER j 8-07-81 1 NO j NO 194)SUPPORT OF TEMP.WETWELL FLUSH.RING (TASK 3220)I 195)'213A TASK FORCE II TEAM (TASK 3230)SKINNER I 8-04-81 I NO l NO WILSEY I 8-20-81 I NO I NO 4 O.MASTER LIST MAJOR ENGINEERING TASKS TO PLANT COMPLETION Page ll of ll, january 25, 1982.>>ITEM I NO.DESCRIPTION

)RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDENT I-COMPLETE FIED I I NEW LOADS/DEFLECTIONS IMPACT ON HANGER DESIGN 196 I (TASK 3290)197 I LUBRITE PLATES (TASK 3300)SKINNER 8-13-81.YES NO I SKINNER 8-0-81 YES I NO I 198.I PIPE WHIP RESTRAINT ANALYSIS (TASK 3370)I HAYNES I 8-81 I YES I YES I 199 I TSW CAVITATION RESOLUTION (TASK 3520)I WILSEY I 11-25>>81 I NO I NO: I 200 I ENGINEERING INVESTIGATION OF LOCAL BEARING STRESS I SKINNER I 8-26-81 I YES I NO I 201 I NJREG-0612 CONT.OF HEAVY LOADS AT NUCLEAR PWR PLANTS I JOHNSON 12-23-81 YES I NO I I ITEM I NO.IDESCRIPTION I MASTER LIST MAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL I RESPONSIBLE ASSESSMENT I ENGINEER DATE ENGR.SCHEDULE AVAIL., Page 1 of g January 25, 1982 FOLLOW-UP ACTION IDENTI-COMPLETE FIED I 1001 I MISSILE h HIGH BKRGY INPACT BREAK 1002 I FIRE PROTECTION EVALUATION 1003 I PIPE ANCHORS TO SLEEVES 1004 I VOLTAGE DROP CALCULATIONS 1005 I ELECTRICAL RACEWAY PROXIHITY TO HOT PIPE 1006 I TRAY COVERS 1007 I BOLTING HATERIALS (ASME III)I REF.ITEH 2 I ON MASTER ILIST I I REF.ITEM ll I ON MASTER ILIST I I SKINNER I 8-18-81 I YES I NO I REF.ITEM 148I ON HASTER ILIST I I REF.ITEM 149I ON MASTER ILIST I I REF.ITEM 1095 ON THIS LIST I BOSTROM I 7-81 I NO I NO 1008 I CABLE SEPARATION PER lEEE-384 h REG G.1.75 I REF.ITEH 122I ON HASTER ILIST I 1009 I THI HYDROGEN VENTING I.REF.ITEH ld I ON MASTER ILIST I 1010 I ELECTRICAL PENETRATION OVERLOAD/REG GUIDE 1.63 I WILSEY I 1-28-81 I NO I NO 1011 I MAIN STEAM LINE FLUED HEAD TO HSIV I HAYNES I 8-81 I YES I YES 1012 I VENDOR PANELS 1013 I SUPPORT-DESIGN CRITERIA VS AS-BUILTS 1014 I ALARA REVIEW 1015 I SEAL INJECTION FOR RECIRCULATING P04 I.REF.ITEM 1025 ON MASTER LIST I SKINNER 8-17-81 I YES I REF.ITEH 141l ON MASTER ILIST I WILSEY 1-28-81 NO NO 1016 1017 WESTINQSUSE LIHITS OF LOW NA IN HS SPRAY POND EFFICIENCY I WISLEY I 1-28-81 I NO I NO I REF.ITEM 14 I ON MASTER ILIST I 1018 I SEISMIC ANALYSIS 1019 I'AVING ANO GRADING 1020 I ELECTRICAL CONDUIT SUPPORTS I REF.ITEH 3 I ON MASTER-ILIST I REF.ITEH 52 I ON MASTER LIST I I THAKUR I I 1021 I CONTROL ROOM FLOOR REF;ITEH 1119 ON THIS LIST 1022 1023 TORNADO DESIGN INCLUDING INTERNAL COMPARTMENT I POWELL'I I PENETRATION h BLOCKOUT SEALING""...--".I,REF.ITEH 189I ON HASTER ILIST 102!-.~TEGRATED LEAK RATE TEST h STRUCTURAL INTEGRITY f~REF.ITEH 5D ON MASTER LIST 102 ENDOR DRANINO AS-DDELTS"':"'"'NAN<EN J9-21.81'f NO'YES I'-'/1 e:!TEH NO.DESCRIPTION lQSTER LIST h/AJQR ENGINEERING TASKS BROUGHT UP.BY BECHTEL I RESPONSIBLE ASSESSMENT EN INEER DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACT!0 IDENTI-FIED COMPLETE I ,rage 2 or$January 25, 1982 1026 1027 W ILSEY I 7-10-81 I NO I NO I SEISMIC MONITORING INSTRUhfENTAT ION: I I ELFCTRICAL SUPPORTS-BASE PLATE ANCHORS I THAK~R I I 1028 TURBINE LUBE OIL FLUSH WILSEY 10-29-81 I NO I NO 1029 I FUEL POOL LINER CLEANING 30HNSON I 8-11-81 I NO I.YES 1030 I INSTALLATION OF FUEL TRACKS 30HNSON'8-12-81 I NO I NO I I I~\INQTE: ITEMS 1031 THRU 1092 FROM"PHASE 1 STUDY ITEMS" I I I I I I I 1031 1032 I DRAWING CONTROL SPECIFICATION CONTROL I SEAMANS I 8-27-81 I NO I YES SEAHANS'8-27-81 I NO I YES 1033 I CORRESPONDENCE CONTROL SEAhNNS)12-2-81 I NO YES 1034 1035 I VENDOR PRINT CONTROL I MICROFILM PROGRAM SEAMANS.--~>."'I s I<I SEAMAN S)12-8-81 NO I NO 1036 I RECORDS TURNOVER SEAMANS I 8<<27-81 I NO I YES 1037 I CONTRACTOR STICK FILES SEAMANS.';-c,-~~I 0 I 6 1038 I PED PROCESSING SEAl4lNS I 8-27-81 I NO I NO 1039 1040 I ENGR.PLANNING AND CONTROL THI-HODIFICATIONS WILSEY 12-22-81 I NO I NO I REF.ITEH 1 ON HASTER ILIST-I 1041 I PAVING h GRADING I REF.ITEH 52 I ON MASTER LIST I 1042 I SEISMIC QUALIFICATION OF ELECT CONDUIT CLAhPS-)REF.ITEH 24 ON MASTER ILIST 1043 I 1044 1045 1046 INTERNAL COHPARThlENT TORNADO DESIGN PENETRATION SEALS ESR REVIEW OF SMALL PIPE HANGER DESIGN LOADS OUTSIDE CONTAINlKNT DUE TO HYDRODYNAMIC REF.ITEH 1022 ON THIS LIST I REF.ITEH 189)ON MASTER ILIST)SKINNER 8-07-81 NO I NO BOST ROM 8-14-81 I NO I 1047 hlFFD FAR MARTFR FAIITP nnPII>%wT nrccPchlPP

/TcT ht I vms~rr r,~:

@HASTER LIST HAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL Page of g January 25, 1982 ITEM I NO.I DESCRIPTION I RESPONSIBLE I ENGINEER ENGR.ASSESSMENT I SCHEDULE DATE I AVAIL.IDENTI-FIED Coh/PLETE FOLLOW-UP ACTION 1048 I NEED FOR FLOW DIAGRAMS I REF.ITEH 43 I ON hQSTER ILIST 1049.I PRE-OP PROCEDURE REVIEW 1050 I REVIEW OUTSTANDING PURCHASE ORDERS 1051 I PIPE BREAK HAZARD ANALYSIS I WILSEY I I POWELL I REF-ITEJI 2 I ON htASTER ILIST 1052 I MONITOR ENGR.BACKLOG OF RFI/NCR/CAR WILSEY I12-22-81 NO 1053 I ALARA I REF.ITEM 141I ON MASTER ILIST 1054 ISI I REF.ITEM 144I ON MASTER ILIST 1O55 I NEW LOADS 1056 I EQUIPMENT NOZZLE LOADS I REF.ITEM 17 I ON MASTER I REF.ITEM 20 I ON MASTER ILIST ILIST 1057 1058 AS-BUILT PROGRAM FOR PIPE HANGER STRESS I RFI TURNAROUND TIHE I REF.ITEH 179I ON MASTER BOSTROM I a-k'ILIST 1059 I SEISMIC CATEGORY II OVER I I REF ITEH 23 I ON hNSTER ILIST lO6O I REVIEW STATUS AND USE OF MODEL BOSTROM I 8-21-81 No 1061 I CROSS REF.ON ELEC.DWGS.IS LACKING INCL.DCL h TCL I TH AKUR I 12-9-81 I NO 1062 I CONTROL OF RACEWAY AND CABLE SCHEDULE 1063 I SWITCHGEAR WITH RIDGID RACEWAY CONNECTIONS 1064 I SEISMIC CATEGORY 1 CONDUIT SUPPORTS THAKUR I 12-10-81 I REF ITEH 46 I ON MASTER I TttAKUR I I NO ILIST 1065 I LIGHTING FIXTURES IN SEISMIC CATEGORY 1 AREAS I REF.ITEH 98 I ON tQSTER ILIST 1066 I SEPARATION 1067 I ENVIRONMENTAL QUALIFICATIONS I REF.ITEH 122I ON HASTER I REF.ITEM 5 I ON HASTER ILIST ILIST 1068 I SEISMIC QUALIFICATIONS I REF.ITEM 5 I ON MASTER ILIST 1069 I HOV OVERLOAD PROTECTION REF.ITEM 120 ON MASTER LIST I 1070 I FIRE PROTECTION I REF.ITEM ll I ON hNSTER ILIST 107)"WTTERY TESTING AND MAINTENANCE 107 DUNDANT CLASS lE OVERLOAD PROTECTION NO'TINKUR I 11-10-81 REF.ITEth 119 ON hNSTER LIST I 0~)tQSTER LIST MAJOR ENGINEERING TASKS BROUGHT-UP BY BECHTEL@0 Page 4 of$January 25, 1982 ITEM I NO.I DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT.

DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTIO IDENT I-COMPLETE FIED 1073 1074.I LOGIC DIAGRAMS FOR ELEC.SYSTEMS INCOMPLETE INSTRUMENT LIST THAKUR Ill-12-81 I NO I NO I REF.ITEM 163 ON HASTER LIST I 1075 I INSTRUMENT ANALOG MIRING HAWKEN 9-21-81 I NO I NO 1076 I INSTRUMENT LINE INTERFERENCE CARE Y I 12-15-81 I NO I NO'077 I CONTROL ROOM CHANGES 1078 I BOUNDARY ANCHORS SEISMIC II TO I 1079 I AS BUILT PIPING HANGER PROGRAM 1080 I HYDRODYNAMIC LOADS H AWK EN I 12-15-81 I YES I YES SKI tOER I 8-05-81 I NO I YES I REF.ITEth 179I 180 10 ON HIASTEI)LISTI I REF.ITEM 6 I16 19 ON HASITER LIST I 1081 1082 I 1083 I PIPING LOADS ON EQUIPMENT NOZZLES COtPLIANCE HITH R.G.1.68 h 1.68.1 FIELD INTERFERENCE DESIGN PROBLBIS I REF.ITEH 20 I ON HASTER ILIST I I REF.ITEM 77I ON HASTER ILIST I I HAYNES I 8-81 I NO I YES 1084 I PIPE HININN 1'IALL REQUIREMENTS 1085 I ATHS 1086 I ALARA I REF.ITEH 65 I ON HASTER ILIST I I REF.ITEH 4 I ON MASTER ILIST I I REF.ITEM 141I ON HASTER ILIST I 1087 I ISI I REF.ITEM 144l ON MASTER ILIST I 1088 I LICENSING STATUS 1089 I POST TMI I REF.ITEH 42 I ON HASTER ILIST I I REF.ITEM 1 I ON HASTER LIST I 1090 I I.E.BULLETINS AND CIRCULARS JOtlNSON I 8-25-81 I NO I NO 1091 I FIRE PROTECTION 1092 I SECURITY 1093 I FLOODING 1094 I BLOCK HALLS I REF.ITEM ll I ON HASTER LIST I REF.ITEM 114l ON HASTER ILIST I I ROGOZA-I I WILSEY.I 12-1-81 I NO I NO 1095 I CABLE DERATING BEACUSE OF TRAY INSUL.AT PENETRA.ETCI TtNKUR.11-5-81 NO I YES 1096 CABLE SEPARATION INSIDE CABINETS THAKUR I 11-17-81 I YES I YES 1097 I TMI HYDROGEN VENTING I REF.ITEH ldl ON MASTER ILIST

-tQSTER LIST MAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL January 25, 1982 ITEM I NO.I DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDEN TI-COMPLETE FIED 1098 I PLATFORM ANCHORS WITH PIPE ATTACHED TO PLATFORMS I SKINNER 8-19-81 I No No 1099 OVALITY OF PIPE I BOSTROM 7-81 I No 1100 I RADIOGRAPHS B31.1 PIP.h REWK.(ENGLERT SEE TASK 1220)I BOSTROM 8-o7-el I.No 1101 I CONTROL ROOM CEILING REWORK (MEAD FREDENBURG)

I POWELL 1102 I RWCU(REACTOR WTR'CLEANUP)

PIPE CHNG.(GRINDEL MCKINEY)I BOSTROM 8-24-81 I NO 8-10-81 No No I PWR (PIP WHIP RESTRAINT)

CLEARANCE MONITORING)

I I 1103 I (FREDENBURG GRANINNI)I REF.ITEM 68I ON MASTER ILIST 1104 CONTROL RM.FIRE PROTECTION (SONI BURSZTEIN)

I ROGOZA I REACTOR PROTECTION SYS.MOTOR GEN.SET BARRIERS I 1105 I (FREDENBURG GRANINNI)I POWELL I REACTOR FEED WATER PUMPS VORTEX STRAIGHTNESS 1106 I (KUGLER POPLARCZYK SCHLOSSER)

WILSEY: 1107 I STANDBY GAS TREAT.LEAK TEST (BENNETT POPLARCZYK)

I WILSEY 1108 POTABLE WTR/FIRE PROT.SYS BLDG.(FREDENBURG ENGLERT)l ROGOZA 1109 I CABLE INVENTORY DISCREPANCIES BURSZTEIN)

-'THAKUR 9-18-81 I NO NO 1110 I QA VAULT MODS (BAHL ENGLERT)llll I CONTROL Roots HVAC MODS.'REF.ITEM 63 I ON htASTER ILIST I ROCOZA INCORRECT INSTALLATION IN EXTRACTION h HEATER DRAIN I 1112 I PIPING (SCHLOSSER)

I BOSTROM, 8-19-81 NO I No.I 1113 I REWORK CONCRETE EQUIP.PADS (L.GOOD)1114 I CONTROL Root<CLASS 1 CHILLERS PEISTRUP 1115 TURBINE DRAIN (RIFAEY)1116 I STRUCTURAL STEEL IN CONTAINMENT I POWELL I ROGOZA I REF.ITEM 166I ON MASTER ILIST ,.I POWELL 1117 I SRV-TWO PHASE FLOW-DISCHARGE LINE DESIGN I REF.ITEM lel 1118:.TURBINE BUILDING DESIGN SUITABLE FOR EARTH AKE" I POWELL I 1 ON MASTER I LIST

~HASTER LIST MAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL Page 6 of g January 25, 1982 ITEH I No.I DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.IDENTI-FIED COMPLETE I FOLLOW-UP ACTION 1119 I CONTROL ROOM BUILT UP FLOOR hSDIFICATIONS I WILSEY 1120 I POTENTIAL DEFECTS IN THE MAIN STEAM.CONDENSOR TUBES I ROGOZA lll-30-81 111-20-81 NO I No I YES 1121 1122 1123 1124 I PROBABILITY RISK ANALYSIS (FAILURE MODES EFFECTS)I I THI TASK-PLANT SAFETY PARAMETER DISPLAY CONSOLE I THI TASK-REACTOR COOLANT SYSTEM VENTS TMI TASK-DEDICATED HYDROGEN PEtKTRATIONS I Jot lNSON CAREY JOHNSON JOHNSON 8-18-81 I 10-06-81 I 8-18-81.I 8-18-81 NO I YES I>>o I No No NO 1125 I THI TASK-CONTAINMENT ISOLATION DEPENDABILITY I HAWHEN, I12-16-81>>0 I YES 1126 1127 TMI TASK-ACCIDENT-MONITORING INSTRUhtENTATION I THI TASK-INSTR'OR DETECTS OF INADEgUATE CORE-COOLI HAWKEN HAWKEN I 9-21-81 12-15-81 No I YES I YES YES I s-~-sz pZ 1128 1129 I TMI TASK-REVIEW ESF VALVES TMI TASK-HPCI AND RCIC INITIATION LEVELS I HAWKEN HAWKEN 9-22-81 I 9-22-81 No I No I YES YES I 5'-~-g z.1130 I THI TASK-SPACE COOLING FOR HPCI h RCIC SYSTEMS I ROGOZA 1131 1132 1133 I 1D4 THI TASK-EFFECT OF LOSS OF AC POWER To PUMP SEALS I THI TASK-CMM(N REF.LEVELS FOR VESSEL LEVEL I THI TASK-SHALL BREAK LOCA METHODS THE TASK-PLANT SPECIFIC SB LOCA METHODS THAKUR KAWKEN BOSTROH BOSTROH Ill-6-81 I 12-15-81 I 8-06-81 I 8-06-81 NO I YES I YES I YES I NO YES I c-.~-.>z 1135 THI TASK-EVALUATE TRANSIENTS WITH SINGLE FAILURE I-BOSTROH I 8-06-81 YES I No 1136 1137 1DB I THI TASK-HANUAL DEPRESSURIZATION TMI TASK-MICHELSON CONCERNS THI TASK-OPERATIONAL SUPPORT CENTER I HAWKEt(JOtNSON WILSEY I 9/22/81 I 8-18-81 NO I YES 1139 1140 I THI TASK-84ERGENCY OPERATIONS FACILITY TMI TASK-PRIMARY COOLANT OUTSIDE CONTAINhKNT I REF.ITEM 79 ON MASTER ROGOZA ILIST I 1141 1142 2 RADIATION MONITORING THI TASK-CONTROL ROOM HABITABILITY PTPF RAFAIC Th)~i AAth flTc~lhnr r Mn>nil.1lcnprnc I HAt EN ROGOZA I12<<15-81 YES I NO 9 MASTER LIST MAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL g Page'January 25, 1982 ITEM I NO.I DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT DATE ENGR.SCHEDULE AVAIL.FOLLOW-UP ACTION IDENT I-COMPLETE FIED I 1144 I BASE PLATE GROUTING QUALITY WILSEY I12-23-81 NO 1145 I GE MEASUREMENTS OF CORE SUPPORT STRUCTURE IN RPV I WILSEY I 8-31-81 NO YES 1146 I HIGH DENSITY FUEL RACK VENTING JOHNSON I 7-30-81 NO 1147 AIR SUPPLY LINE TO MSRV FITTING PROBLEM WILSEY I 8-03-81 1148 I WELDED ATTACHMENTS ON PIPING 1149 I RESTRAINT FLEXIBILITY ON PIPING ANALYSIS I HAYNES I HAYNES I 8-81 I 8-81 YES YES YES 1150 I FAULTED END MOVEMENT INCLUDED RESTRAINT LOADING I)IAYNES.I 8-81 YES 1151 I MULTI-DIRECTIONAL LOADS DN PIPE CLAh)PS SKINNER I 0-17-81 YES 1152 I OPERATIONAL TRANSIENT LOADS ON PIPING/SUPPORTS I HAYNES I 8-81 YES 1153 I ANCHOR BOLT SPACING PROBLEM I REF.ITEM 17I5 ON MASTER ILIST 1154 I HYDROGEN DETONATIONS IN OFFGAS PIPING I BOSTROM I 8-04-81 YES 1155 I ZPA (ZERO PERIOD ACCELERATION)

I HAYNES I 8-81 YES 1156 I STATE OF WASHINGTON INVOLVEMENT IN CODE ITEMS I BOSTROM I 8-03-81 1157 I MAIN STEAM MINIMNt WALL PROBLEM BOSTROM I 8-04-81 1158 SOCKET WELD INSERTION h GRINDING PREP.PROBLEh)S I BOSTROM I 8-04-81 1159 DRAWING H-501-PIPING h HANGER INSTALLATION I HAYNES I 8-81 1160 I DYNAMIC MOVEMENT EFFECTS ON SPRING HANGER DESIGN I HAYNES 8-81 NO YES 1161 I NPS BENDING PROCEDURE BOSTROM I 8-19-81 1162 I CONDENSOR SEISMIC SHEAR LUG DISCREPANCY I WILSEY I 8-27-81 NO 1163 EXCESSIVE ROOM TEMPERATURES I ROCOZA 1164 I POOR WORKMANSHIP BY PUMP MANUFACTURERS I WILSEY I 9-05-81 NO 1165 I LOAD CAPAICITY DATA SHEETS SKINNER I10-09-81 YES 1166 I VALVE END WELD AND SOCKET WELD REQUIREMENTS

'.I BOSTROM REOPERATIONAL TESTING PRIOR TO CODE STAMPING ('OSTROM CABLE SHORTAGE AND DELAYS IN SHIPMENT I THAKUR llO-23-81 Ill-3-81 ill-23-81 NO NO NO MASTER LIST MAJOR ENGINEERING TASKS BROUGHT UP BY BECHTEL Page 8 January 25, 1982 ITEM NO.DESCRIPTION I RESPONSIBLE I ENGINEER ASSESSMENT OATE ENGR.SCHEOULE AVAIL.IOENTI-FIEO COMPLETE I FOLLOW-UP ACTION ll69 I HANGIT 1170 I SWAGE NIPPLES 1171 I JOHNSON CONTROL STRESS ANALYSIS 1172 I CROHS WATERHAMMER I HAYNES HAYNES I HAYNES I HAYNES 1-82 I 1-82 I 1-82 1-82 NO I NO NO I YES YES I YES YES I YES GAcl f73 ISc(s~c C cc.DC Pl IAJC SCTEfh 0)O Rap I ASS A)o I pJo Qo I Mo 117 D Fr us I OS pjo I' Ce BECHTEL ENGINEERIHG.

MANAGEMENT ASSESSMENT TasK/ITEM TITLE: ZOA~/mc.aw Err 8 5CZZ>HS GATE OF ASSESSMEHT

'/8 Bl BY

REFERENCES:

MASTER TASK LIST HQ./OOQ BURNS B ROE TASK OR ACTIVITY NO~5Z 07iiER: r-BC'3/l SCHEDULE AVAILABLE SCHEDULE.E CONTROL NO.5 VSTWW'ONTACTS:

BURNS B ROE-AAIA&gg OZ ygoCB C AVP~i~SUPPLY SYSTEM-.BACKGROUND:

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beg)-ACTION TO-GO: p"/C>orrvC~gE,p/Zu g y 5 year ZWS g~S/S.Oar//CZP 4~tr'/sou'4 Y Cr~z<r~Co/GrmC>HeCW~~~rV~~/Q HOAGY.BECHTEL ASSESSMENT:

ZEU/E~g+gS-B>v/C/A'C PENT/POPc'O~/~ger K.p-~&A7-E 5/OM Wp A'OO/'/E=r'CarrDM R<PU/'R~D 70 g/&C~/=Z5 r~/r Cr OF 5F)dcfCD.g~~rnrrHH~BECHTEL FOLLOW-UP REQUIRED-ACTION TRACKING: YES NO FOLLOW-UP DATE;ATTACHMENT 14 LIST HO./5703 Page'.1 of 3

(-BECHTEL EHG IHEER I tilG HANAGE 1EttT'ASSESSIMEHT DATE OF ASS ESSHEHT I/-4-F/BY U rood'azS;TASK/ITE i TITLE: PdgcjFlc87/Prl op'p gccdntaL<7oW REFEREHCES:

tQSTER TASK LIST NO.BURNS 8 ROE TASK OR ACTIVITY NO.OTHER: M k.3.ZF C&dZEQ-4 78/3 SCHEDULE AVAILABLE rt/c7 SCHEDULE CONTROL NO.CONTACTS: BURIIS A ROE-S.RIRVEIY'TIIPLL/MELC SUPPLY SYSTEtl-BACRGROURD:

<<ps PIC-IIIcdLFPr IO'S VALVES ETCI gEEIIIRECI vc PEI FoI-ed jcII7C 7 IN/5 FOIL/Od O'VS'PF 7EE IOCC IOErdr.CVEEccr 7 IVR 5IIPPLII co~~a sp'em.pwoVcozs o~sY 9o Say-opz~~riuc>

czpRau/Tp'.

ACTION TO-DATE: ng g gZC'am<~/iu'DED

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'gobi/cEpg Loig Dcs/cgA(cn~ocRL'cV CTIOH TO-GO: 'Be~I'Si<<IO pa<p~~c.p'IN'rgb OEG'/CeN'Rc

/Sic gZD EYING PRIIYL/'ilESIIL-0 g/pR psst'o EE dPIOFIrEIOr.

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COOI,AC-, BAR)SITE&OE6 Co LIST HO, d k'age 2 of.3 BECHTEL ENGIiNEERING DATE OF ASSESSMENT B-'I"l-H L MANAGEMENT ASSESSMENT TASK/ITEi~l TITLE: t jP, P-

REFERENCES:

HASTER TASK LIST BURNS 5 ROE-TASK OTHER: BY BO~iOAl SP~SS L n~n CO~ESZ~~~~~

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T'0'V HMF'v'h4 t:-A.Q~u.wC.EY

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~O MF U.~~i b3 H 2 i<CC BAH&.kSZM,C~%~i h'<<VZ:C<MR3M VAHW~~~C-.

~C>in xw~ACTION 70-GO-KJ~i S~&WE ZU.(Vl QP PG'5Ol V A.CU.KK~PARK~WwDM Z R'TC>Q K CHUM G~~&m 2 8 PP~K C~C)~l'lUMN'Ll l O KaD>~~S,R.~~NAKE wYZO m M.mM c BECHTEL ASSESSMENT:

~~~HE.U.5~, T4Z>-M.~RC3CO~CW~G~UPc~UK

~HM%~W ZCIW i i~t~.CQ~&~i~tL~t=

INLt=t LIO~>+I=ZMAE1.I WY TR'L/c1ZTFv'HE EYZ5~xC KEY'Zk C~~~iHc2W~i~COXPr~i~~~WW E KQ.GD CQPAE~HMM~

lM~i~OD~~I't M HE N C&VM.R.~~MC~

T~Q D+l~~~QU.K~PTWWi i~~~Y u WH~~~=~&M YWKC3M AAA W.P.~AD E~G,W~C la&~K.C U 9.W~&lC mama~C.~S~~.BECHTEL FOLLOW-UP RE UIRED: ACTION TRACKING: YES NO K FOLLOW-UP DATE: LIST NO.++Page.'3 of 3 0 0 t ATTACHMENT 15 SMALL-BORE PIPING ANALYSIS FOR HYOROOYNAMIC LOAOS Bechtel Engineering Management Group (BEMG)identified the need for Gilbert/Commonwealth (G/C)to prepare a design guide for hydrodynamic affected small bore piping systems in the drywell.l The design guide was issued by G/C and reviewed by.BEMG for technical adequacy.2

'he zesults-of this review indi-cated several significant findings affecting the design of the piping and pipe suoports.The findings were correlated and all analyses utilizing the.ncn-conservative analytical approaches were reperformed to a r vised design guide that adequately addressed.

the findings.SCOPE ANO METHOOOLOGY:

The G/C'esign Guide (GC-0000-24) contained a sample calculation illustrating the procedure to be used for hydrodynamic analysis.This sample, calculation utilized the T PIPE computer code and represented a complete piping stress analysis calculation.

Pipe support design was not in-cluded, in the design guide or the review.The sample'alculation that BEMG analyzed was a 3/4 inch vent line from RRC-V-67B to an EDR drain header as depicted on isometrics RRC 1550-1,-2,-3, and-4.Input data was provided by Burns and Roe via the 208 Contract Soeci-fication and applicable Project Engineering Oirectives (PEDs).The BEMG re-view utilized the input data and isometric drawing to duplicate the sample calculation using the Bechtel inhouse piping analysis computer code ME101.The ME101 analysis was performed for two cases: the first being to simply duplicate the G/C (T PIPE)analysis, and the second incorporating revised analytical aoproaches to demonstrate the effects of employing methodologies that adequately addressed the design requirement's for piping stress analysis.The first analysis confirmed the results of the sample calculation.

However, the second analysis clearly indicated certain deficiencies in the G/C method-ology and resulting non-conservative results.RESOLUTION OF FINDINGS: G/C Procedure 0000-24 was revised to incorporate cor-rected methodologies and to also address the findings of a subsequent audit conducted by Burns and Roe Engineering.

>The BEMG design review together with G/C and Burns and Roe t chnical audits have provided assurance that Gilbert/Commonwealth has adequately addressed the design requirements for small piping analysis subjected to hydrodynamic loads.1BEC'HNP2-81-0061, 4/28/81 2BECWNP2-81-0085, 6/5/81~BR Audit No.B/R-5-81-1, 11/12/81 Page 1 of 1

0 A.E;;0 CO ATTACHMENT 16 AC MOTOR CONTROL CENTER CONTROL CIRCUIT VOLTAGE CROP STUDIES A study was performed to determine whether the circuits were adequately de-signed so that motor starters would pull-in for all anticipat d conditions.

Generic calculations were made to determine actual maximums allowable circuit length for various circuit configurations.

Specific drawings were reviewed to determine circuit lengths and connected loads.The drawings were compared with actual field hardware to ensure accuracy.Some drawing discreoancies were discovered.

It became apparent from the study that the voltage drop pro-blem could actually be realized on some WP-2 circuits.The Burns and Roe calculations were reviewed to assure that they were complete and did include the effects of main bus voltage variations, control power transformer impedance, considered all auxiliary loads such as lights and re-lays, etc., which may also be powered during the circuit operation.

The findings of the Bechtel study were discussed with Burns and Roe and the Supply System.They reviewed the findings and agreed with the conclusions.

Burns and Roe is now investigating to determine the extent of the problem based on the as-built conditions.

This problem has been reported as a poten-tial lOCFR50.55(e) item to the NRC.The number of actual deficiencies appears to be very limited.Page 1 of 1 j,-0 ATTACl+1ENT 17 AREAS WHERE WNP-2 DESIGN WAS INFLUENCED BY BECHTEL REVIEWS SYSTEMS 1.HPCS/RCIC Switchover (Eli,minating Loops)o Original design required"loops" and separate instrument standpipes for HPCS and RCIC suction lines.o Bechtel questioned if adequate water suoply to eliminate loops was available and if combined instrument standpipes for both systems could be used.o Burns and Roe recalculated supply, eliminated loops, and combinedstandpipes.

2.Off Gas Line (Detonation Pressure)Bechtel had studied this problem extensively and provided assistance to expedite the calculations.

Fire Protection o Use of'SI Thermo-Lag in place of Kaowool to wrap cable trays/conduit (ampacity derating, construction cost, and schedule, space restrictions) and assistance regarding the Thermo-Lag Test Program.o Initiated contact with the NRC to clarify 3-hour fire barrier option in Appendix"R", which also led to possible exemption ror omitting sprinkler systems in low fire load areas.o Application of Thermo-Lag coating on entire length of raceway sup-port members.4.P netration Sealing o'xisting design specification was lacking for today'material availability, i.e., non-toxic materials.

o Provided input/recommendations for specification improvement.

5.Vacuum Breaker Cycling Test Program o Assisting in coordination of Mark II Owner's test program admin-istered by San Francisco Home Office Limerick projects.Page 1 of 4 6.HVAC o Identified need to conduct control room pressurization test per SRP 6.4.Assisted in specifying instrumentation required.~r o Verified that ductwork leak integrity testing by contractors during balancing was adequate.C1VIL 1.Spray Pond Leakage Fix o Recommended approach for repairing expansion joints, waterseal dam-age was identified and materials recommended.

2.Spray Pond Vortex Breaker Design o Indentified vortexing as potential problem on siphon line connecting spray ponds.o Burns and Roe generated a vortex breaker design.Soil Canpaction Approach o'uestionable records and compaction practices existed.Critiqued test program to verify past work.o Scope'd areas where Class I backfill was required.o Recommended backfill lifts/restrictions to assure compaction.

4.Structural Steel in the Drywell.~o Provided team leader for resolution of deficiencies.

o Salvaged significant amount of existing work through engineering and docunentation review.Established-baseline documentation.

o Established evaluation criteria and acceptance base.o Established direction for repair of 5.Containm nt Vessel Pressure Test remaining items.o Eliminated need'for a second containment.

structural, integrity test of o Processed code case through ASME Code Committee to support this pos ition.Page 2 of 4 PIPING AND HANGERS l.Identification of piping requiring transient analysis;2.Refinements in steam-hammer analysis and identification of analytical

'eficiencies.(Main steam lines for turbine trip.)3.Delineation of pipe and hanger as-built requirements.

.4.Refined stress"methodologies:

Z ro oeriod acceleration.(High frequency phenomenon for rigid systems.)Fifteen percent (15K)expansion/contraction in time/history analysis which reduced significantly their analytical and computer costs.o Faulted building movements.

o Incorrect stress intensification factors, should reduce hardware rework.5.6.o Inclusion and phasing of dynamic end movements.

o Off Gas system detonation effects on hangers.o Dynamic effects on spring hanger limits.o Selection and envelopment of response spectra.o Valve stem flexibility, operability, and pipe stress.o Oamoing being over-conservative.

Eliminating small-bore piping analysis deficiencies in Gilbert/Canmonwealth (G/C).Accelerat d schedule and provided engineering assistance on safety relief valve fatigue analysis.7.Assisted Burns and Roe in the formation of piping thermal expansion and steady state vibration testing program.'LECTR!CAL 1.Modified design to decrease voltage drop on the control circuits on a critical system.2.1nitiated a review of the plant electrical power distribution systems and potential FSAR violation which may cause damage to cable and equipment during specific modes of operation.

Page 3 of 4 Reviewed containment penetration protection o Standardization of backup protection fuse size.o The need for backup protection for MCC control circuitswere shown as not being necessary.

,~Page 4 of 4 Cl

~~ATTACHMENT l 8 PART I\ff~1tffff PIPE SUPPORT REVIEW FOR COMPLETENESS AND ADEqUACY WP-2'Review By: 'ate:-::-'The purpose fs to review six major areas as follows: Oa 1.Design Specification and Codes in Compliance with Project FSAR.2.Design and Calculation Standards.

3.Computer Programs Used.Procedure and Control.'4'.,':.'!5.Review oi'esfgn and Calculation.

!rdfnation, Review and Inte&ace Procedure with other ups such as Stress and Civil/Structural.

~~!.0*"

t~PIPE SUPPORT REVIEM FOR CONPLETENESS AND ADEQUACY CHECKLIST 81 DESIGN SPEC., CODES 8 STANDARDS'roject~MNP~2\Review By: Date: Sht.No: Hanger No: C3 QC-I C3 QC-II Code E Class Stress iso/Rev: Data Point: Item No." Name of Document Document No.&Rev.YES NO Compliance with FSAR ASME Code B31.1 Code 3.Cl~VI Cl'cn Large.Pi pe Small Pipe 6.Drawing Standard 7.LCDs 8.Catalogs Small Pipe Support Manual~~

PIPE SUPPORT REVIEM FOR COMPLETENESS AND ADEQUACY CHECKLIST 82 REVIEW,.,OF DESIGN AND CALCULATION.

.Prospect: MNP;.Z., Revfew By: Date: Sht..No: lof 2 C f4'-'anger No:.;.E3 qc-i 0 qc-rr Code 5 Class'tress fso/Rev: Data Pofnt: , Item"'o.3.4.8.0'escrfptfon Design vs.Verifed Load , Frfc"ion Force Considered a..Me1d Allowable b.Shear Stress Allowable c.Bending Stress Al 1owabl e d.Axfal Stress Allowable e.CEB Allowables Component Std Suppt.vs.Verfffed Design Load Meld Cal culatf on Structural Analysfs Base Plate Analysis'EB Analysfs Intermedf ate Plate Analysf s Adequate YES Remarks Meets 79-02 Requfr ements CHECKLIST¹2 Sheet 2 of 2 , Item No.Description Adequate Remarks 10.12 13.15;16.17.18.19.20.21.23.24.25.26.27.28.29.Special Clamp Special Component Deflection Check Status A'-Buf1tlF.W.

Det.Final As-Built Minimum Weld Skewed Weld More Force Component Considered due to Swing of Assembly Load Combination or Worst Load Justfffcatfon Proper application of Component Proper Typical Number Called Out Proper appl fcatfon of Typical Interpretatf on of Computer results Torsion Stress Check Buckling Check Embedment Capacities Check Pipe Support Drawings Hanger Mark-up Dwg.Hydro Load (Flush)Jurisdictional Boundaries

,

4'I fl J I~~'I I'.."-'rodeot

'NP-'2 PIPE SUPPORT REVIEM.FOR COMPLETENFSS ANO AOEQUACY CHECKLIST f3: COMPUTER PROGRAMS Review By: Gate: Sht.-No: ';Item No..: Program ,." Name Gocumentati on per Spec..Chief Engr's Approval For Use Meeting Project Criteria Remrks l~tJ 2o.fl,~STRUOL ANSYS 3.*OTHER PROJECT COMPUTER'ROGRAMS I t g I'I~~,~

'4 h")eh eehhhhh h hhh elh hh W w e~eh hh*'PIPE SUPPORT REYIEW FOR COMPLETENESS AND ADEQUACY CHECKLIST P4: PROCEDURE 5 CONTROL pro j ect WNP 2 Review By: Date: Sht.No: 1 of 2 Individuals Contacted:

TitIe: Item No.Description Meets Appl i cable Project Procedure YES System'Adequate Remarks h 2.Isometric Control a.5.6.7.8.9~10.Load..Defi.

Sht.control Retention/Storage Civil Review Stress Review Pipe Support dwg.control Pipe Supports Calc.Control Revision Work"Hold" Control SE1.3-7 e wl Sheet No.2 of 2 CHECKLIST 8'4~Item, No., 12.-"13.Descri,ption Civil a Layout dwg.Control.Small Pipe Support Cycle Other discipline drawing control ,'YES NO Meets AppIicable Project Procedure YES NO System Adequate Remarks 14.18.19..Outstanding Doc.Complete PED FRPED RFI NCR PRR Documentation of Coriwnication Valve Support and Inter-face with Valve Vendor Nuclear Class I Melding Embedment Program SSM.Cont.Shell, Block Mall, etc, attachment control PIPE SUPPORT REVIEW FOR COMPLETENESS AND ADEQUACY CHECKLIST g5 COORDINATION WITH OTHER GROUPS Project: WNP-2 Review By: Date: Sht.No: Group Stress&Civil Stress Item No.2.3.Description Pipe Support dwg.review and comment compliance When hangers moved mote than allowable YES NO Adequacy Remarks Stress Stress Stress Stress Stress Civil 4.5.6..7.9.10.Size of snubber changed Lubrite Plate req'uirement Integral'art design of Nuclear Class I Non-standard integral part design for critical pipe support Anchor/reinforcement pad requirement Embedment Special Steel requirement Civil 12.Block Wall ATTACHMENT 18 PART II STRESS ANALYSIS REVIEM FOR COMPLETENESS ANO AOE(jUACY Prefect Name:~wm-~Stress Cal c No: Review By: Oate: The purpose is to review six major areas as follows: I.Oesign Specification and Codes in compliance with Project FSAR.2.Oesign and Calculation Standards.

3.Computer Programs used.4.Analytical Methodologies.

5.Calculation Oocumentation and Traceability.

6.Coordination, Review and Interface Procedure with other disciplines (Pipe Support, Civil/Structural, Mechanical and Construction).

F'roject Name: MNP-2 Stress Calc.No.: Code/Class:

REFERENCE DATA CHECKL IST 8y e Date: STATUS INPUT DATA INPUT DATA DESCRIPTION O I a Cl)O 0)0 O S 4 O 07 CJ O S 4 CJ 0 I CJ O CJ O C tV lO S QJ W 4 Ci 0 O 5 CP E Cl 5 tO 4 E O~r O 4J Q th UJ W O 5 O O REFERENCE DOCUMENTS COMMENTS xxixx x(xix a~b.C.d~e.a~k.m.n.0~q.Desian Soec.Fl ia ram P ID Desian Guide/Procedure Svstem Isometric Thermal Modes (TEP)Response S ectra Curves 1 Seismic OBE 8 SSE 2 Hvdrodvnamic Forcina Functions Histoarams Pi ina Index 1 Pioina Class Sheets 2 Class Summar Va ve Information Mei ht 5 Lenath 0 erator Mt.5 C.G.f of Tooworks Acce eration Allowable Restraint Information 1 Location 2 Orientation 3 Flexibilit 4 Additional Weiaht din Movem nt Data 1 Sei smi c 2 H drod namic 3 Process Pioin tauloment rawlnas Nozz e owab es Comouter Code and Rev.Veri ication Date Load Combinations Insulation Weiahts 1 Pioe 2 , Valve, Flanges Tech Nemo 1257, Rev.0 215 Spec Section 158 Tech M m r (o PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST project:~~~~Calc.No.: Code/Class:

By: I Date: DESCRIPTION CHECK REMARKS 1.0 MODELING: Are there any special modeling techniques used (equipment flexibility, expansion joints, valves, etc.)1.2 Are the proper stress intensi-fication factors or stress indices used.Ref FSAR 3.7.2.3.2 1.3 Does the code employ a geometry/closure check.0-1.4 1.5 1.6 Is the correct pipe material, thickness, 00, modulus of elasticity and allowable stress used.Are branch connections identi-fied and is there a criteria'or including/excluding connected piping in the model.Does the piping model terminate at full (six way)anchors.If not, is i t acceptable.

Ref FSAR 3.9.3.1.19.5 Ref Tech Memo 1267, Rev.0 Ref FSAR 3.7.2.8 8 3.7.3.13 2.0 THERMAL ANALYSIS 2.1 2.2 Are the analyzed thermal modes in agreement with the flow diagram or mechanical group's mark-up.Are the correct thermal'xpan-sion coefficients used..2.3 2.4 Do anchor movements reflect vendor data and thermal modes.-Is the system ba1anced;no upward load on gravity supports greater than deadweight.

PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST Project: HNP-2 Gale.No.: By: I, Date: Code/Class:

DESCRIPTION CHECK REMARKS 2.5 Have clearances at wall and floor penetrations, and pipe whip restraints been checked.2.6 Are post LOCA temperature and pressure effects considered.

3.0 PRESSURE

5 DEADWEIGHT ANALYSIS 3.1 Do operating, design and peak pressures agree with the design spec.3.2 Are pipe, valve, specialties, contents and insulation weights correct.3.3 Are pipe support clamps and welded attachment weights included.Ref 215 Spec Section 158, 3.4 Ar e deadweight di spl acements excessive.

4.0 STATIC

SEISMIC ANAL'YSIS 4.1 Do the static acceleration factors agree with FSAR requirements.

4.2 If based on the system natural frequency, does it occur at or beyond the peak of the appli-,'able response spectrum curve.4.3 Are the calculated responses from the three components of acceleration combined correctly.

Ref FSAR 3.7.2.1.8.2 Ref FSAR 3.7.3.5 5.0 SPECTRAL ANALYSIS 5.1 The following load cases were analyzed using the response spectrum method:

PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST project:~~~Calc.No.: Code/Class:

OESCRIPTION CHECK By: I Oate: REMARKS 5.2 Are the latest revisions of the spectra curves used.Ref Tech Memo 1257, Rev.0 5.3 Are pipe restraint building attachment points properly identified.

5.4 5.5 5.6 5.7 5.8 Have the spectra been properly enveloped.

Are the correct damping ratios used per FSAR requirements.

Has the correct curve inter-polation method been selected.Ooes the cutoff frequency cover the peak accel eration.Ooes the number of modes solved extend to the cuto f frequency.

Are they acceptable.

Is zero period acceleration considered.

Ref FSAR 3.7.1.3 Ref Tech Memo 1226, Rev.2 5.9 5.10 Ooes the mass point spacing reflect the cutoff frequency.

Are at least two mass points located between two adjacent restraints acting along the same direction.

At least one between two restraints of different directions.

5.11 Are restraint flexibilities included.5.12 Are the extended yokes of motor, gear, air, or hydraulic operated valves modeled as flexible members having a natural frequency equal to that provided by the valve manufacturer.

PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST Project: Calc.No.: Code/Class:

WNP-2 By: I Date: DESCRIPTION CHECK REMARKS 5.13 5.14 Are modal responses combined per FSAR requirements.

Have dynamic displacements been checked at springs, penetrations and pipe whip restraints..

Ref FSAR 3.7.2.6 Ref FSAR 3.7.2.7 6.0 ANCHOR MOVEMENTS 6.1 The following events were considered for anchor movement analysis: Ref FSAR 3.7.2.1~7 6.2 Are support attachment points to the building correctly identified.

6.3 6.4 6.5 6.6 6.7 Are the anchor movements correct at each attachment point.Are the phase relationships correctly identified.

Are the inertial piping displacements considered in branch piping separately analyzed from the header.Are emergency or faulted anchor movements considered.

Are differential building movements considered.

7.0.SPECIAL ANALYSES 7.1 Have special analyses been performed (i.e., fast valve: transients, force or dis-placement time history, multiple response spectra, fatigue analysis, thermal transient analysis or wind loads).If yes, generate a separate check sheet.

'PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST-:.-project:~~Gale.No,.: Code/Class:

By: I Date: OESCRIPTION CHECK REMARKS 8.0 LOAD COMBINATIONS 5 EYALUATION 8.1 8.2 Are all the ooerating condi-tions and postulated events.for this system considered in this analysis.Are loads combined and evaluated per FSAR require-ments and within code allowables.

Ref Tech Memo 1226, Rev.2 Ref FSAR 3.9.3.1.1.7 Ref DAR 3.5.4.2 8.3 8.4 Are anchor movement moments properly included into Equation 9,-10, or 11.Has the thermal stress range and anchor movement stress, as necessary, been properly incorporated into Equation 10 or 11.8.5-Do inline anchors reflect the load from the other side of the system.0-8.6 8.7 8.8 8.9 8.10 8.11 Are positive and negative thermal loads tabulated on systems with more than one thermal operating mode.Are hydro loads tabulated for steam/air process lines requiring a hydrotest.

Are transient loads (valve closure/opening, relief valve thrust)considered as re-quired on certain systems.Are local stresses on the pipe due to welded support attachments considered.

Are flange loads evaluated properly.Is pipe bearing stress on rigid supports considered.

PIPING STRESS ANALYSIS INPUT AND OUTPUT CHECKLIST project: Gale.No.: Code/Class:

DESCRIPTION CHECK By: I.Date: REMARKS 8.12 Are fun'ctional capability requirements considered.

8.13 Are valve accelerations within allowables.

8.14 Are nozzle loads within allowables.

8.15 Are postulated pipe break locations correctly identified.

8.16 Are isolation valves properly evaluated against postulated pipe break loads.9.0 COMPUTER CODES 9.1 L'ist computer codes used for this calculation.

9.2 Does the computer code satisfy'he analytical requirements for seismic design.9.3 Has the computer code been, , verified per FSAR requirements.

10.0 DOCUMENTATION

-CALCULATION DE UAGY 5 COMPLETENESS

.2 Doe's the documentation"sub-stantiate the assumptions and analysis performed in the calculation.

Listdiscrepancies (if any).10.1 Do calculation design drawings reflect all outstanding documentation and/or later.revisions.

10 Ref Tech Memo 1240, Rev.1 Ref FSAR 3.7.2.1.8.2 Ref FSAR 3.12 PIPING STRESS ANAlYSIS INPUT AND OUTPUT CHECKLIST Project:~~~Ca1c.No.: Code/C1ass:

DESCRIPTION CHECK By: I Date: REHARKS 11.'0 CONCLUSIONS Ce VASEGNGTON PUBLIC POWER SUPPLY SYSTEM NNP-2 PHQ jE t'ai 3HSTRUCT I OH APPROVE t PROJECT MANAOCR TITLE I ASI'IE CODE D SIGN ASSURANCE REVIEN NO I RCVR PMI 6-7 RCSP ORONl PE O~1.0 PURPOSE AND SCOPE This procedure establishes the method used to evaluate the technical adequacy of specific ASME Code piping/hanger design work performed by external design organizations for the Supply System (Owner).The pur-pose of this evaluation is to provide assurance that the design work meets the technical intent of the applicable ASME Code.The scope of this procedure describes the activities of the Owner or his agent from the identification of the intent to perform an ASME Code design assurance review, the performance of the review and the resolu-tion of any findings.This design review does not replace any of the existing contractually or Code imposed design reviews.This design review will be used by the Owner to establish a high level of confidence in the technical adequacy and completeness of the'designs.2.0 DEFINITIONS 2.1 ASME Code Pi in/Hanger Desi n Assurance Review-A documented eva uation by a qualified review team in accordance with written procedures or checklists to verify, by examination and evaluation o, objective evidence, that ASME code design is being or has been satisfactorily performed.

3.0 PROCEDURE

Resoonsibi1 i t Action Ploject Engineering (PE)Manager Identifies the need for.an ASME Code pip-ing/hanger design assurance review..2 In cooperation with other management and organizations as appropriate, designates a review team leader and a review team.The members of the team shall meet the qualification requirements specified in Attachment 5.1.)Review Team CSPKCTIVC QATCR.3 Determines the scope of the specific review and establishes the schedule and the plans for performance of the review.Identifies additional review team members if required.SVPKRSCQCS ISSVC QATCQt QVAI ITY APPCCTINGA WP 16S nn New YCS NO ATTACHMENT 19 PAOC OI 1 4 PNI 6-7 Rev.0 3.0 PROCEDURE (Cont.)R Review Team Action NOTE: The plan shall be prepared in written form consisting of procedures, instructions, checklists or other documents as appropriate to the needs of the specific review.e Review Team Leader.3 Drafts letter to the design organization to be reviewed advising of the schedule and scope of the review, documentation and per-sonnel to be made available, and requesting any documentation or information needed prior to the review, PE Manager Review Team Review Team Leader.5.6.7 Officially approves review plan and schedule.Transmits the review notification letter to the design organization to be reviewed.Neets for prereview briefings, as necessary, to review available pertinent documentation, to prepare checklists and to make any other preparations necessary for the review.At the location of ihe design organization, conducts introductory interviews at first meeting;introduces review team members;chairs initial meeting and provides coor dina-tion of overall review.Review Team.8 Determines if the necessary personnel and documentation from the design organization are readily available to provide assistance and information for the review.Identifies additional personnel and documentation needed in areas of concern.Conducts review.Review Team Leader.10 Reconvenes, as necessary, to summarize and review findings.Prepares agenda for exit meeting.Chairs exit meeting with design organization.

NOTE: Results, conclusions or findings dis-cussed at the exit meeting should be presented as preliminary with the understanding that they are subject to change'.Page 2 of 4 Io PMI 6-7 Rev..0 3.0 PROCEDURE (Cont.)Revi ew Team Leader PE Manager Action.12 Requests comnents and/or coomitments from.reviewed design organization as appropriate.

.13 Holds a post review meeting at the Supply System to identify any problem areas and design discrepancies and to determine rec-ommended corrective,and follow-up action..14 Prepares, signs and dates a review report, including a recommended schedule for accomp-lishing corrective action and follow-up items, if any..15 Reviews findings and recommended corrective actions.

4.0 REFERENCES

.16 Decides what corrective actions to take, i f any.4.1 ASME Boiler Im Pressure Vessel Code,Section III, Division 1, Sub-sections NA, NB, NC, NO and NF, Edition and Addenda as applicable to the component whose design is to be reviewed.5.0 AT i ACHMENTS 5.1 gualification Requirements for ASME Code Piping/Hanger Design Assur-ance Review Team Members Page 3 of 4 PMI'6-7 Rev.0 QUAL'IFICATION REQUIREMENTS FOR ASME CODE P'IPING/HANGER DESIGN ASSURANCE REVIEW TEAM MEMBERS 1.0 SCOPE This attachment presents minimum requirements for the qualification of personnel selected to perform ASME Code piping/hanger design assurance reviews for the Supply System.g<<TO One or more qualified team members shall be selected by the Review Team-Leader to perform an ASME Code piping/hanger design assurance review.The qualifications of each team members shall be evaluated prior to their assignment to a team and shall be summarized in the final report.2.1 A team members shall have not less than four years of active engi-neering experience.

C 2.2 A team member shall be experienced in the applicable field of design and analysis and in the application of the requirements o Section III.In.particular, the member shall be knowledgeable of the applicable portions of Subsection NA, General Requirements, and shall have a working knowledge of Section III requirements for design, including pertinent materials requirements.

2.3 A team leader shall meet the minimum qualifications of a team mem-ber and shall also have demonstrated ability to organize and plan the work of technical teams and to effectively interface with or-ganizations outside the Supply System.The team leader shall also have a working knowledge of the contractual requirements between the Supply System and the design organization as pertinent to Code design work.2.4 Personnel not meeting the above requirements may be utilized on a team for training provided their work is reviewed by a qualified team member.Page 4 of 4 Attachment

5.1 APPENDIX

C APPENDIX C WNP-2 QUALITY ASSURANCE The purpose of&is Appendix is to describe the activities conducted by the Supply System Quality Assurance (QA)Program which confirm the qual-ity of the safety-related aspects of WNP-2.The Supply System is ult'-mately responsible for quality in all phases of the design, pracurement, construction, testing, and operations of WNP-2.The Supply System QA Program addresses the 18 criteria-or" Appendix 8 to lGCFR50, applicable ANSI QA standards, and other NRC, Federal, and State quality-related re-quirements.

Accordingly, the, QA programs of the suppli rs and contrac-'ors involved with the ASME Code and safety components are required to adhere to the applicable Appendix S and ASME Code requirements.

Further, Supply System QA reviews and approves such supplier and contractor QA Programs (including the Architect Engineer, Construction Manager, and NSSS supplier)prior to award.The Supply System Project QA Manager di-rects the QA activities r lated to the design, procurement, and construc-tion of WNP-2.The Supply System QA organization is independent of the engineering, construction, and operations organizations; has the freedom to identify quality problems, and directly reports to senior management.

At WNP-2, the QA Program is implemented through i'our organizations.

They-are: 1)the Supply System, 2)Burns and Roe, 3)Bechtel, and 4)site contractors and subcontractors.(Ref r to Figure 1.)The site contrac-tors and subcontractors are responsible f'r implementing their approved QA programs." Each contractor has a QA and Quality Control (QC)func-tion.First-line verirication of construction quality is performed by these organizations.

Becht 1, as Construction Manager, provides second level QA/QC surveillance and audits of cor,tractor activities.

Burns and Roe QA at the WNP-2 site performs surveillances on theiz engineering ac-tivities and audits on their engineering subcontractors.

Supply Syst m Project QA overviews Burns and Roe and Bechtel by surveillance.

Add-itionally, Supply System QA performs surveillances of other contractor activities to determine the effectiveness of'he Bechtel QA Program.The Supply System, Bechtel, and Burns and Roe Corporate QA organizations per-form management audits on the site act'ities of their respective organizations.

A'.Organization 1.Supply System Project Quality Assurance a.Staff 1 Manager 2 Supervisors 1 Staff Assistant 10 Senior QA Engineer 1 QA Engine r I 1 Analyst 2 Secretaries 8 MemOers b.Credentials/Experience 1.Nuclear Industry<1 1-5 5-10 10-15 15-20>20 (a)Years/personnel (typical)1(a)5(a)5 2 2 1 2.Quality Assurance<1 1-5 5-10.10-15 15-20>20 3 7 5 1 0 0 3.College Oegrees 4, Professional Engineer Registrations 5.AWS Certified-C Manager QA Engineers Secretar Me ers b.Experience

-Nuclear/Quality Assurance 2.Burns and Roe Engineering Quality Assurance a.'tare 1~5 1 1-5 5-10 10>>15 15-20%20 0 3 1 1 1 3.Bechtel Power Corporation Quality Assurance a.Stai'f'.BQA 1 Manager 6 Auditors 3 Auditors in Training 4 Clerical I'2.BQC 1 Manager 26 Supervisors 141 Inspectors 22 Clerical 190 Members b.Credentials/Experience l.BQA Nuclear Industry 1-5 5-10 10-15 15-20>20 5 2 1 0 2 2.SQA Nuclear Quality Assurance 1-5 5-10 10-15 15-20 020 5 2 1 0 2-C B.Responsibilities Tha following paragraphs focus on the responsibilities and activities of i!the WNP-2 QA organization since the restart of Quality Class I work in June 1981.The entire WNP-2 QA Program was extensively reviewed and mod-ified during the Restart Program (July 1980 to June 1981)as described in Appendix D to strengthen management control of the Project and improve implementation by the site contractors of the Project QA Program comait-ments.Appendix E summarizes the Quality Verification Program which has been implemented to assure that quality concerns for hardware installed prior to July 1980 are identified and corrected.

1.Supply System Project QA The responsibilities of Supply System Project QA include: Veri fy implementation of the design and construction QA programs, Perform overview of the Architect Engineer, Construction Man-ager, contractors, and other project organizations (excluding Operations) by surveillance, Report significant, adverse quality conditions to the Supply System WNP-2 Program Dir ctor and Director of Quality Assurance, Tssue Stop Work Orders as necessary, Interface with the NRC, R gion Y, to resolve identified items of noncompliance and/or concerns, and o Review Construction Management and contractor records in sup-,'ort of System Turnover.The responsibilities of the departments within Supply System Project QA include: a.Quality Engineering Personnel within this department perform surveillances of'he Architect Engineer, Construction Manager, contractors, and other project (excluding Operations) organizations to verify compliance with the Supply System QA program requirements.

Personnel within this department also prepare, track, and eval-uate Surveillance Quality Action Requests (SQARs), Quality Finding Reports (QFRs), and Corrective Action Requests (CARs).SQARs identify a deficiency of minor significance.

A CAR identifies a deficiency of major significance

'or breakdown in an organization's QA program.The Management

'CAR is a Supply System document used to notify an organization's Corporate man-agement of a major, significant breakdown in a site organiza-tion's QA program.'FRs.identify both minor and major defi-ciencies found during an audit.-C When Project or Corporate QA identifies a deficiency within one.of the site organizations, a SQAR, QFR, or CAR (or equivalent document if identified by Burns and Roe,QA or Bechtel QA/QC)is issued to document the deficiency.

Each deficiency document requires corrective action for the identified deficiency and gives a date for compliance.

Upon completion of the corrective action, a re-audit or re-surveillance is performed to ensure the correctiv'e action has been adequately completed.

Since June 1981, this department has performed:

o Sixty six surveillances of Bechtel resulting in fifty SQARs and t n CARs, o Three audits of Bechtel resulting in twenty one findings (20 minor, 1 major), o Twelve surveillances of the Burns and Roe site and Richland offices resulting in four SQARs and one CAR, o One audit of the Burns and Roe sit organization resulting in a single, minor audit finding, o Eight surveillances of WNP-2 Supply System organizations resulting in two SQARs.and three CARs, and o Three audits of WNP-2 Supply System organizations result-ing in twenty four minor audit findings.ln addition, since Dune 1981, the Supply System Corporat QA organization has performed one audit of the Burns and Roe New York office resulting in fourteen findings (7 major, 7 minor).Over the history of the WNP-2 Project, there have been a total of twenty three audits of the Burns and Roe organization by the Supply System.Recently, Project QA has assessed the findings on Bechtel as Systems-Completion Contractor and as the Construction Manage-ment QA organization.

The trends indicat a need to improve procedure implementation and to properly carry out the in-process QC surveillance and inspection activities.

Recognizing the quality history of WNP-2, the late stage at which Bechtel entered the scene, and the trend indications, the Supply System has taken the following steps to enhance the effectiveness of the WNP-2 Project QA surveillance program.o Assigned Corporate QA the total responsibility for site audits.This change will permit the WNP-2 Project QA organization to focus on in-process surveillances.

o WNP-2 Project QA has replaced four of the individuals in the group responsible for in-process surveillances with more experienced Senior QA engineers from WNP-l.-C-5-October 1982, Rev.1 o The program for surveillance of in-process construction has been revised to: Provide for the performance of in-depth, limited-scope and unscheduled surveillances.

In-depth sur-veillances will be performed to provide a comprehen-sive analysis of the capability of a specific func-tion to yield quality work.The plan requires the performance of about five in-depth surveillances per month.Limited-scope surveillances will be used to provide routine overview of ongoing work and unsche-duled surveillances will be performed to cover speci-fic problem areas as they arise.Increase the number of surveillances from the average of about 9 per month since June 1981 to 12 or more per month.Focus the surveillances on areas of complex or crit-ical work and in areas where adverse trends are indi-cated based on the analysis of trend reports and cur-rent problem areas.o Added special surveillance programs in two areas.These surveillances are scheduled separately f rom the routine surveillances, and are used to assess critical or complex work.RPV hydro preparation and performance.

This included the contractor and Bechtel work in preparation for RPV hydro, the identification and review of documen-tation for components within the hydro boundary and the performance of the hydro.Documentation review and turnover process.This in-cludes the review of the documentation by the con-tractors prior to their document turnover to Bechtel plus the Bechtel document review and processing in support of system turnover and contract closeout activities.

b.Quality Compliance Personnel within this department retrieve and revi w quality documentation for prepurchased and inactive site contracts, review quality documentation on a sample basis for Construction Management and active site contractors, support the Quality Verification Program by contract review, and support the System Turnover process.-C-6-October 1982, Rev.1 These responsibilities are implemented as follows: Prepurchased

-Review quality docunentation, obtain resol-ution of.discrepancies, and suoply information for con-tract close-out,'I Turnover-Review quality documentation through a sampling of turnover packages and assist Construction Management to retrieve missing documentation and carr ct deficiencies, o Quality Verification Program-Review inactive site con-tracts to identify and resolve document deficiencies, o Systems-Revi w and approve Supply System specifications and purchase r quisitions; prepar, review, and approve QA orogzam procedures; or pare changes to and maintain th QA section of'th FSAR;and coordinate supplier and bid eval-uations, and Project'A Library-Control specifications for construc-tion contracts; collect and have available cod s, stand-ards, and procedur s for use by sit personnel; and ensure training has be n performed for QA.c.Supply System Pxoject QA Staff The Project QA staff tracks the xesolution of 10CFR50.55(e) and 1OCFR Part 21 items, trends deficiencies, and preoar s r oorts for management on quality trends and deficiency backlogs.In addition, the, staff working in conjunction with the other de-partments p rforms revi ws of quality documents, orocedux s, Project Management Instructions (FMIs), etc.d.Stop'>fork Act vity The Project QA, Construction, and Engineering Managers have xezcised stop work authority as d fined in WI 4-13.2.Nhen work is not'n conformance with th quality requirements, a Quality Enforcement Action is initiated.

Conditions which do not comply with technical and/or quality requiz ments, and for which one of.the following apply, are consid r d severe de f iciencies:

October 1982, Rev.1

0 I o Fabrication, construction, or testing deficiencies, which'represent a loss of safety function or integrity-of a sys-tem or component, or o A breakdown.in management or procedural controls evidenced by deficiencies in several areas of the QA program re-quirements and/or 10CFR50, Appendix B criteria.When such a deficiency is identified, issuance of a MCAR, CAR, or Stop Work Order is r quired by the Project Managemen't In-structions.

When a valid reason exists for stopping work, a~written directive is issued in the form of'Stop Work Order (SWO).The activities associated with the SWO are monitored to assure that conditions of the SWO are'being met.Lifting of a SWO is initiated by a letter signed by Project Management after.appropriate action has been taken and-verified.

This includes the elimination of the basic discrepancy and the steps taken to'revent recurrence.

Limited resumption of work has in some instances been allowed (e.g., SWO No.9)provided the condi-tions,of release were documented and fulfilled prior to start of work.Since 197S, there have been fifteen (15)'top Work Orders issued at WNP-2..(Refer to Attachment 1.)2.Burns and Roe Engineering Quality Assurance (EQA)Their major responsibilities include: Surveillance and audits of Burns and Roe enginee ing at the Richland and site offices to assure that the engine ring's performed in accordance with project policies, progr'ams, ozo-cedures, and instructions, o Preparation of reports of quality assurance activities at the Richland and site offices, o Performance of audits of engineering subcontractors, o Review safety-related equipment and construction specifications for quality requirements, o Prepare and/or review project instructions and procedures and their revisions to assure compliance with the QA program re-quirements, and o Investigate and report quality matters as requested by Burns and Roe Corporate Engine ring or QA.The Burns and Roe EQA organization was formed in Duly 1980, after a project reorganization which assigned the responsibility for con-struction surveillance to Bechtel.Since then, EQA has performed ninety two surveillances of the Richland and'AP-2 site offices.They have performed thr'ee audits of the Richland and WNP-2 site of-fices resulting in six minor findings.-C From 1971 to February 1982, the Burns and Roe Corporate office has performed eighty audits, which included the New York, Richland and WNP-2 site offices.These audits resulted in a total of 235 findings.3.Bechtel Power Corporation QA/QC a.Bechtel QA assumed responsibility for Construction Management QA activities June 1, 1981.Their major responsibilities include: o Perform audits of Bechtel and contractor/subcontractor site activities, o Stop work as required, o Track, status, and ensure timely resolution of NRC inspec-tion findings, o Track, status, and trend nonconformance reports, and o Verify that Bechtel functions in support of system turn-over are complete and satisfactory.

From June 1, 1981, to March 31, 1982, BQA performed eleven audits of site contractor activities resulting in forty five minor findings, and eight aud'ts of Bechtel internal activi-ties, resulting in twenty four minor findings.Bechtel Cor-porate (San Fransico)QA performed four audits on their WNP-2-~QA Program, which resulted in fifty two minor findings.b.Bechtel QC assuned responsibility for Construction Management" Quality Control activities June 1, 1981.Their major responsi;bilities include: o Perform QC surveillance of site contractor and subcontrac-tor activities, o Perform"first line" QC inspection of Bechtel activities as Systems-Completion Contractor, o Perform documentation reviews of active site contractor submittals, and o Review contractor, subcontractor, and Bechtel QC programs and procedures.

-C Since June 1, 1981, BQC has performed the following surveillances:

'Contractor No.Surveillances No.Oeviations 210A 213B 215 216 217 218 219 220 221A 234 215-103 215-103A F003 2 285 401 157 344 153 513 182 165 225 198 10 24 36 4 61 19 29 5 10 58 12 16 37 6 0 0 0 0 4.Audit and Surveillance Schedules (1982)In order to provide insight into the ongoing WNP-2 QA activities, the audit and surveillance schedules for 1982 are discussed below: a.Audits 2.3.Supply System-The Project QA schedule is broken down into four quart rs and gives the audited organization, audit t am members, scope of the audit and schedule dates.(Refer to Attachment 2.)It should be noted that Corporate QA was assigned total responsibility for the performanc of site audits effec-tive June 1, 1982.This will permit Project QA to focus on in-orocess surveillances.

Burns and Roe-The EQA schedul has two areas, Burns and Roe subcontractors and technical audits.It lists the audited organization and the month the audit is to be per-formed.(Refer to Attachment 3.)Bechtel Power Corporation

-Bechtel QA has established an audit schedule for 1982 (ref r to Attachment 4).The mas-ter.audit plan has three sections: audit area/audit scope, master audit plan schedule (yearly), and the QA Quarterly Audit Schedule.The yearly schedule identifies the quarter the audit is to be performed and the quarterly schedule identifies the date for the audit.-C b.Surveillanc s~~l.Supply System-Project QA establishes a surveillance schedule based on a six month tim frame (refer to Attach-mo nt 5).The published schedule only reflects scheduled audits to ensure coverage of the surveilled areas.Un-scheduled surveillances are posted on the master schedule to.show all surveillances performed for the six month period.2.Burns and Roe-EQA establishes a monthly surveillance schedule (refer to Attachment 6)which includes the person responsible for performing the surveillance and the sur-veillance scope.3.Bechtel Power Corporation

-Bechtel QC inspectors perform daily surveillanc s which are not formally scheduled.

At the end of each day, the QC inspectors file a surveillance report docunenting their activities for that day and any deviations noted.

C.Management Support The previous paragraphs described the structure and activities of the WNP-2 QA organization and provided evidence of the capability and effec-tiveness of this organization to identify problems and initiate action to resolve them.The key'emaining factor is management support to ensur resolution of the problems identified by QA, and follow-up to ensure im-plementation and to preclude recurrence.

Since the stop work in July 1980, a number'f actions have'been taken to strengthen the overall man-agement control at WNP-2, including Project QA.Some of these actions were: 0 Restart Program-The Restart.Program provided a complete re-review of the contractors/subcontractors, Construction Management, and Supply System management control processes.

Quality procedures were" revised'to strengthen acceptance criteria and to assure compliance with SAR requirements.

New trainingprograms were implemented to improve the overall quality of QA and QC personnel.

o Management Reporting-Routine reporting systems were instituted for site deficiencies, such as NCRs, CARs, audit findi'ngs, and op n sur-.veillances.

These reports provide to Project Management, on a monthly basis, the total nuaber of open deficiencies in each cat-egory, and aging data to permit management assessment of the time-liness of corr ctive actions.o Management Quality Awareness-Ourfng-th'e Restart and Quality Veri-fication Programs, Supply System management became acutely aware of the'ack'of management attention to previously identified quality problems.The direct result o f this enhanced awareness was in-cr ased management involvement in the resolution of quality concerns and a mor rigorous reporting and assessment system for qual'ty is-sues.Management involvement in these issues is the principal rea-son for the dramatic reduction in the overall deficiency backlog for WNP-2 to date.o Reduction of Backlog (refer to Figure 2): NRC Inspection Items-NRC inspection itens numbered 55 in June 1980, reached a peak of 127 in April 1981 as a result of pro-blems identified during the Restart Program, and have been r-duced to 51 items of which 26 have been submitted to the NRC.This is a 60K reduction.

Corrective Action Requests-CARs numbered 22 in June 1980,.reached a peak of 59 in March 1981, and have been reduced to eight as of March 1982.This is an 87K reduction.

Quality Finding Reports-QFRs numbered 102 in June 1980, reached a peak of 113 in February 1981, and have been reduced to 41 as of March 1982.This is a 63X reduction.

10CFR50.55(e)

Items-10CFR50.55(e) items numoered 28 in dune 1980, reached a peak in August 1980, ahd have been reduced to 3 in March 1982.This is a 90K reduction.

Project Reorganization

-The WNP-2 project reorganization included bringing Bechtel Power Corporation in as the Construction Manager with responsibility for surveillance of the site contractor QA/QC programs.o Action Tracking System-A computer program was implemented to track and ensure NRC commitments are completed in a timely manner.o Quality Hotline-A telephone service was implemented to provide any site employee conf idential access to Supply System management on issues related to qualify.o Quality Awareness Program-A program was implemented to enhance feedback of quality problems from other Supply System projects.:-C

'UPTSS~TS Qoh vX94r&r~n YS DOORS DU~S SOE DO)tS OFFICE AHA~I~I hU IT MPPSS PRO)ECT Q,h, DURltS C ROE Et)GI))EEAItIG (SITE)I 1)RUl SUllVE SO+Et)GI))SERI))G SUE~)TRhCTORS ill DUAl)S hltD AOE Tt)PflOVIDE hUl)IT St)PPOAT TO DECIITEt, TO PERFORM AUDITS OF COltSTAUCTIOll CO)tTRhC!O)t Et)GI))EEAI))G FUI)CTIO)t.

SIIX~smaaaos llPPSS N~iVNMWR lIII WIIIIIIS gjgg QQQ Cet)TAhCIuR Figure 1 i JCe F"'I CORRECTIVE ACTIOtl REQUESTS 100 90 80 70 60 50 40-30-20 10 30 34 48 49 44 45 46 59 53 48 45,.32 28 25 2 19 12 10 8 June 80 Sept.80 Dec.80 Harch 81 June.81 Sept.&1 Dec.81 Harch 82 Figure 2 Page 1 of 4 NRC INSPECTION

SUMMARY

130 120 110 100 90 80 70 60 55 50 40 30 20 10 56 96 106 107 114.114 122 122 109 104 66 60 66 71 78 78 52 51 June 80 Sept.80 Dec.80 March 81 June Sl Sept.81 Dec.81 March 82 Figurr." Page.~4 QUALlTY FINDlNG REPORTS 120 110 100 90-80 70 60 50 40 30 20 10 110 90 89 8 0 100 110"3 98 90 89 60 44 41 832 45 48 41 46 June 80 Sept.80 Dec.80 Har.ch 81 June 81 Sept.81 Dec.81 Harch 82 Figure 2 Page 3 of 4 lOCFR50.55(e) 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12-10 8 6'2 31 31" 23 23 20 0 26 23 25 20 19 20]9 13 4 June 80 Sept.80 Dec.80 March 81 June 81 Sept.81 Oec.81 Harch 82 Pagl 4 STOP WORK ORDER f SUBJECT STOP WORK/COllTROL SUll4ARY CONTRACT DATE IMPOSED CONDITIONS OF RELEASE DATE LIFTED CONNENTS 001 002 003 004 Impraper assembly of the sacrificial shield wall;concrete void problems;visually re]ectable welds and related repaIr problems.r Stop all work relating to concrete and grouting installation.

218-F/L 215-ING 220-JCI 215 WBG 1I-21-79 II-21-79 11-2I-79 01-18-t8 a.Reinspections and quality records 001 incompleted and all problems identified.

b.A comprehensive corrective action plan (which includes design chang and rationale for acceptance of non-reinspectiable work)wIDbe de-veloped and submitted to the tlRC In an Interm 50.55(e)report.The resumetIon of work was contingent upon tlRC review of the associated corrective action plan.To assure control of Concrete and Grout placeaent.

contractqr was required to: a.Audit related activities to assur compliance to contract requIre-ments~b.Accomplish work with trained personnel In accordance with ap-proved procedures.(I.e,MP-7 R.S)c.Resolve CAR's 1427 5 1430 to sat-Isfaction of the Owner.12-11-81 1-23-81 12-03-81 01-31-80 Actions Complete Actions Complete Stop work relating to field instal-)ation of t)C-I materials due to field drawing discrepancies 5 drawing con-trol problems.220-JCI 03-28-80 Resumption was contingent upon Owner verifIcation of: a.Drawings corrected of discrepanc-Ies.b.Drawing control system capable of maintaining up-to-date copies in the field.04-09-80 Actions Verlfie I'omplete ht tactttttetlf.

]Page 1 of g STOP WOR CONTROL SINIART 510P WORK ORDER l SOBJECT COIITRACT Stop design and installation activi t-215-WBG lcs associated with qC-I Small Sore Piping, due to lack of adequate design control.DATE IIIPOSED 04-18-80 CONDITIONS OF RELEASE A/E revise specification to change design responsibility for S.S.Pipe.'the reason for this change in resp-onsibility was to resolve several Identified problems.Actions Included: a.Establish an engineering organiza-tion responsible for the design of AS<IE piping systems.b.Implement a design control prograi which satisfies the quality req-uirements of NSI II45.2.c.Perform a anre rigorous design analysis ln an effort to minim-Ize construction changes to pre-sently Installed piping systems.d.Provide engineering certification that the design calculations com-ply with design criteria and ref l lect as-bull t drawing conf lgura>>tion In accordance with IE Sul'let-In 79-14.DATE LIFTED 06-03-81 COOIEII TS Responsibility assigned to Gilbert/Common-wealth'Inc.

Actions Complete 007 St~instalhtioncfcaHcs associated with 218-F/L Power Generation Control Complex (PGCC In Control Room.05-23-80 Contractor to proceed with PGCC,rout-Ing verification with approved Work Procedures and Project Engineering Directives (PED's)W-218-E-3064 6 2967.02-12-SlActions Complete Stop work associated with Arc Stikcs on Large and Small Bore Ilangers.The inspection activities related to procedures pertinent to the acceptance of Arc Strikes on hanger or structural material.was stopped because proced-ures allowed arc.strikes while the specification did not.215-WBG 07-17-80 The Project prepared criteria on arc strikes and required the contractor to Incorporate the Information Into I ts applicable procedures.

Evidence was required of the contractor that It trained craftsmen and Q.C.Inspectors to these procedures.

06-03-81 Actions Complet Attarlu'IIOTIt

'1 STOP MOR COIITROL SHOIARY STOP WORK ORDER f SUBJECT COIITRACT DATE IIIPOSEO DATE L IFTED COlgIEHTS Stop Mork of all site I1C-I work due to the inadequacy of work control and quality assurance systems at MAP-2.lit Cons t.ite Cont 213A-PIN 215-WBG 216-TMC 217-SAS 218-F/L 219-08C 220-JCI 221A-PTL 210-PKS 234-OBC 07-17-80 Restart activities included re-evalu-ation of the related work methods, controls, and standards of performance Installation of safety significant items hare been reviewed and systems to control future work are inplace.The following quality related programs/areas were upgraded: a.qualification and Training b.Contractor Mork Procedures c.Detailed Mork Planning d.Responsibility and Account-ability for work e.Documentation of completed work f.Feedback Systems within the Project and Contractor organ-izations.See Below 04-01-81 06-03-81 04-13-81 05-15-81 04-02-81 04-14-81 02-1'1-81 05-12-81 05-21-81 04-20-81 Activities completed.

009-A Stop all quality Class I, ll, 6 G work activities not previously stopped by Stop Work Order f009.Examples of work stopped included: preparing new work packages, issuing new Purchase Orders, subcontractor installations, issuin materials document review.215-MBG 08-22-80 Detailed instructions regarding speci f ic activities to enable lifting the stop work were provided to the con-tractor.Some of these activities were: a.I1A Program review of all deficiency documents.

b.Audit Evaluation of Procu ement P m.01-9-81 Activities completed.

010 Stop work involving Installation and purchasina nf Power Piping Sway Brace Brackets, due to discovery of defect-ive welding.213A-PDN 6 2 I 5-MBG 08-13-80 The required actions taken by contracis 213A 6 215 were: a.Identification of how many items were purchsed.installed and in stock.b.Field inspection of all hanger de-signs which utilized rigid sway struts.c.Significant findings reported.d.Repairs made as directed by A/E.(see Page 4)(see Page 4)Attacllent 1 Page 3 of 5.,

STOP MDRK/COttTROL SUIHARY STOP MORK ORDER I 010 continued:

SUBJECT Power Piping Sway Brace Brackets;CONTRACT 213A-PN d 215-MBG DATE IIIPOSEO (see Page 3)COttDITIOttS OF RELEASE Corrective actions taken by the h/E: a.Results oF a test program indicat-ed that it was necessary to derate the design load allowable.

b.Review of al I existing Installed designs which utilized size 15, 20, 25, 8 40 rigid sway struts.DATE LIFTED 05-04-81 6 07-31-81 COt HEtt TS Activities Complete 011 8 012 Cease all installation of seam welded pipe and fittings associated with NRC-I Bulletin 79-03A due to longitudinal weld defects)n ASIIE Sh-312.Type 304 Stainless Steel Pipe.215 MBG 6 2I3A-PN 09-04-80 Actions to assure safety reulrements:

a.Complete a review of contractor material lists for use of Sh-312 or A-312, Type 300 series fusion welded pipe.b.Identify where material was used.c.Prepare instruction to etch(where applicable).

d.Record status of etching S results 01-12-82'8 06-18-82 Act I v I t ies-Complete Owner-Furnished Pipe Ithlp Restraints for the Contalenent Ory Mell (Leckenby C-90 PMR's).215-MBG I I-21-79 Corrective Actions included: a.Examination of quality records associated with the restraints.

b.Submittal of corrective action plan to thb ttRC.c.Records suspected of being fraud-ulent were to be collected and retained in a secured area.05-13-80 173 Pipe Mhlp Restraints were affected.ActtonsCompiete Stop work of activities performed by GEIASE and Brand Itanford Co.These companies were subcontractors forMBG.215-MBG 06-24-80 Actions taken to restart activities were: a.Doth Subcontractors were retained under direct contract to the Owner.bi Both Subcontractors were required to comply with Owner tL Bechtel qh Program.: 09-24-81'this item was reiolved during corrective act-ion for SM0-009.Action Complete A*",ment 1 PaL of 5 STOP WORK/COIITROL SQgIARY STOP WORK ORDER I SOME CT Falsification of Docmnentation related to welding on pipe supports and piping.COllTRACT DATE IIIPOSED 215-WDG 03-02-78-CONDITIORS OF RELEASE The corrective action parameters req-uired to have been implemented before resuaytion of work were: a.Recall all Class 1 pipe and pipe support document packages and place under WPPSS/BAR control.b.Constitute a Joint WPPSS/BAR spec-ially trained team to review these records for irregularities utiliz-ing specific guidelines provided.c.Prepare for WPPSS/BAR approval, a procedure for the control of weld documentation packages, both pipe and pipe supports.d.Upgrade and iaylement the weld filler material control system.e.Provide training to all personnel Involved in welding for the im-.plementation of the upgraded weld filler material control system and the documentation package control procedure.

DATE LIFTED 03-09-78 COlNEMTS 59 suspect pack ages were re-.viewed and dis-positioned.

Work completed March 19, 1978, Actions complete AttachDlent l Page 5 of 5

,0[C 1st Quarter 1982 ORGAN I ZAT I ON AUDIT TEAH SCOPE PROJECT EQUALITY ASSURANCE AUDIT SCHEDULE IlNP-2 SCIIEDULE LICEK BEGINNING~98&<rough Approved~[~

Page~eP~ACTUAL DATE(S).REISRKS'upply System and*D.Leslie J.Weers Overal 1 Control of Reverifica-tion Pro-grams 1/1/82 1/11/02 WNP2-82-1 1/11-15/82 No Findings Issued.Bechtel D.Leslie (As Bechtel Team Hember)Participate in Bechtel Internal Audit of Procurement 5 Haterials Hana ement 2/9/82 2/19/82 IIP2-82-2 2/22-26/82 Joint Audit.Bechtel to lead.6 Findings Issued.Bechtel to close.Supply System Haterials Hanage-ment*D.Leslie C.Park G.Baker Supply Sys-tem Haterial Control 2/26/82 3/8/82 NNP2-82-3 3/15-26/82 12 Findings.;Report To Be Issued.~Audit Team Leade 2nd Quarter 1982 PROJECT QUALITY ASSURANCE'UOIt 5CIIEDULE WHP-2 Rev.No.1 Date hprQ 2~gl82 g gag leigh APProved~~ahnso Page~ef~ORGANIZATION AUDIT TElN SCOPE SCIIEDULE IIEEK BEGINNING ACTUAL DATE(S)REHARKS.Burns and Roe, Inc Supply System Project Engineerie Burns and Roe, Inc Bechtel*J.Reiten TBD*D.Leslie TBD*J.Reiten TBD D.Leslie (As Bechtel Team Hember)ocument ontrol esign and Specifica-tion Review RI QA ro gram everifica-tion Johnson ontrols 4/2/82 4/19/82 4/23/82 5/10/82 5/7/82 5/24/82 6/4/82 6/21/82 WNP2-82-4 WNP2-82-5 WHP2-82-6 WNP2-82-7 Joint Audit.Bechtel to lead.*Audit-Leader 3rd and 4th Quarters 1982 PROJECT QUALITY ASSURAttCE AUDIT ScttEDULE}tttP-2 Rav.<Io.~o2-By~C.O.y+, Appravad~Jo so Page 3 of 3 ORGAtt I ZAT I OH AUDIT TEAti SCOPE.SCltEDULE{ttEEK BEGINNING M1EY KO Ot.ACTUAL DATE(S)REt tARKS Bechtel Burns and Roe, In*J.Reiten TOD Design Control J.Reiten Contractor (As Bechtel Rti)Control 6/10/02 7/5/82 7/16/02 0/2/82 HNP2-82-8 ItttP2-82-9 Joint Audit.'ecl>tel to lead.Bechtel*D.Leslie TBD Bechtel Receipt In-spection and Storage 9/3/02 9/20/02 ttNP2-82-10 Oechtel J.Reiten (As Bechtel Tlt)Bechtel fire Protection 9/17/82 10/4/02 tlNP2-02-11

'oint Audit.Bechtel to lead.Supply System Oechtel*D.Leslie TOD*J.Reiten TBD Records ttanagement QA Program 10/15/02 ll/1/02 ll/19/02 12/6/02 NIP2-82-12 WNP2-82-13

~Audit Team Leadei 0 C' Attachment 3 1982'UDIT SCHEDULE Rev.1 3/22/BZ BSR Contractors Gilbert/Commonwealth EOS Nuclear Audit Dates 2/16-19/82 and 8/10-12/82 3/16-18/82 and 9/14-16/82 Contract Numbers 210 213 215 216 217 218 220 Months May March May June June April April and Nov'ember and September and November and December and December and October.'and October NOTE: Technical audits are to include the following disciplines as applicable

-Civil, Electrical, HVAC, I 5 C;Mechanical, Nuclear and Stress.

CO (22~)P PIIOJCCY HAMC 14631 QUALITY ASSURANCE MASTER AUDIT PLAN 4)-.IIKlfl~lOH NO~sar~ov 23'O, AUDIT Ah@A AlJDIT SCOPC COHThOL DOCUMENTS 1.0 Organization

• (NgAN Section 1 No.7)Evaluate the project's compliance with the require-ment for an organization chart showing key quality related positions.

Organization

• Evaluate the project manager's compliance with the requirements for an organization chaI't showing key quality related positions.

N(AN Section I, No.7 1.2 Construction Organization

• Evaluation of the project field construction managers compliance with the requirements for an organization chart showing key field and quality related positions.

MNP-2, B(AN Section 1, 1.7.6.1*Not included in project audit program.This area t~be covered by management audits, and monitored by projects.Sf P.20010 Attachment 4 Page l of 34 I'l 0 J C C T H A M'K~HP 14631 1t QUALITY ASSUIIANCE MASTEll AUDIT PI.AN ne VICIOH HO I'AOK~O$'HOr AV DIT A)ISA AI)DIY$COI'K COHTIIOI.DOCUMVH)5 1.3 Q.C.Construction Quality Control Manual*.Evaluation of.construction QC compliance to the re-quirements for preparation, approval and control of the CQCM.CQCM, Section 1, 5.0-5.&1.4 Project Construction Work-Plan/Procedures*

Evaluation of construction compliance to the require-ments for preparation approval and control of work plan/procedures.

WP/P-1$1.5 1.5 Quality Program Oocuments*

Review of quality program procedures and I'IIanuals for maintenance of updated content of assigned copies issued by Bechtel departments.

NQAM, Section 0, No.3 NQNi, SEction IV, No.1 i Yr Van)O Attachme Page 2 o).~

rgf'~ci<<")rnoIccT II*aas WNP 2 14631 IOS NUWSan 0 IlUALITY ASSUIIANCE MASTL'H AUDIT PLAN IICV ISION NO FAGC oF NO AUDIT ANCA AUDIT score coNTnoI.DocuaocNTs tlanagment

'Corrective Action Report Control*Evaluation of project manager and manager of engineer ing compliance to the requirements for review)ng, evaluating and controlling t1CARS.H(AH, Section Y, No.4 1.8 Housekeeping*

Evaluation of construction compliance to the require-ments for housekeeping.)lP/P-III'f P 2007Q Attachment 4 Page 3 Of~34 IIAr~s I~gjj~tE<Ls~ss-p MHP-2 thOJRCT HAMC joo HUMsih~14631.QUALITY ASSURANCE MASTER AUDIT PLAN hCVI~IOH HO~aaa~o~~HOi hVDIT AhCA hVDIT SCOPE I COHTHOI DOCUMKHTS 2.0 Indoctrination and training (HQAN Section V, Ho.3)Evaluation of construction compliance u>ith the projects indoctrination and training program.2;1 Project construction indoctrination and training Evaluation of construction and construction quality control compliance to the requirements for orien-tation, indoctrination, and training.CQCH,Section II HQAN,Section V, Ho.3 BQAN,Section II, 2.7.1.1 Reg.Guide 1.50 Rev.1 007-SFP 2 hment 4 P[I MAt.~

SgC"-rllOJ CCT NAMC JOO NUMSKh 14631 QUALITY ASSURANCE MASTER AUDIT PLAN hCVICION NO r*OC+Or 2.3 No+AUDIT AhCA AUDI Y IICDr C CDNThol.OOCUMCNYC 3.0 Construction document control Evaluation of project construction compliance with (H(AH,Section II, Ho.II)requirements for the control of project constructio design document control, and request for informatioI s 3.1 Design document distribution and control Evaluation of project construction compliance with the requirements for: Field control and distribution of design documents.

Preparation, processing, and control of reques for inforIIIation.(RFI)'N(AN,Section II, No.II 8(AN,Section VI W P Section VI II 5FP 20M0 Attachment 4 Page 5 of 34 I~IE]fEE LI~E<.: Wr<P-Z rhosaCT NAMC JOS HUIIICh 14631 I.QUALITY ASSUIIANCE MASTEII AIIDIT PLAN hCVI~IOH HO~ass<>3'v NO, AUDIT AHCA AUDIT score COHThOL DOCUMCNTS 4.0 Q.A.Record retention (NQAN,Section V, No.7)Evaluation of requirements for collecting, evaluat-ing, storing, and maintaining quality assurance records'Project quality control.reco'rds Evaluation of project construction Q.C.compliance to the requirements for establishing facilities and filing systems for retention of quality control records.(Record retrievability may be included in audits of other construction areas.)HQN,Section V, No.7 CQAN,Section VII NP/P,Section II oro-SFP 20 ,1 I~,~c(;A lent 4 Page 6 4 I~r e I I I I I I I I I I I~I e'e I I I I I r I I I I'~I r I I I I I I~I r I I~e I I I I I I I I e I I r I I~~~I I I I I~I~I I'I~I~I I I I e~I I I I I I I I I I I~~I I I'I I~I e I, I I I 1'I I I I~I I I II rl I e I~Ill I I I I~~I I III I~I~e aeII el I e I I I I I I'I~r I I~I I e I I'I I 8ECH MNP-2 rROZCCT NAMC QUALITY ASS 0 RANGE MASTER AUDIT PLAN RCVI5ION NO 5 toom~~~~NO+5.4 AUDlT ARCA l Bechtel Construction comple-tion of HCC Powers Installation AUDIT 5COlIL'erify Bechtel Construction compliance to completed installation and"as-building." CONTROL DOCUMCNT5 Applicable contract specifi-cations, PED's, Drawings, QCI's, QCIR's, Spec 215 CQCH NL$I~(5..5'.6 Bechtel Construction CRD Installation Bechtel Construction Small-Bore and Large-Bore Hydro-static Testing e to the G.E.ce to Verify Bechtel Construction Complianc Installation Requirements defined by 74 Crr:I r<E bar,,(.ago,.fflrlr/~$6/ASS S/'ri~ku~+o+.'CoafMaF O4,/'f,>*-.rlgur+Au/f>><</C~Crm~e Cf C.S P/r f/kr~r.u J/f~($P5A C~CC/l/gory 54 P/~('~,$,5/>>~'C'Oaf~/.yy)Refi~recC~C(OSlrrC~/l 5<Jr~/.<fy>P<~A<<l

>4 ( PHOJSCT HAMS JOA HUMSSh DUALITY ASSURANCE MASTER AUDIT PLAN O~hSVI~IOH NO 0 PADS Or 9 23 NO>>AUDIT AhSA AUDIT ICOPS CONThOL DOCUMSNTI 6.0 Nonconformance control (NOAH,Section IV, No.4).Evaluation of construction compliance to the require-ments for identification, control, and disposition of nonconforming materials, parts, or components.

6.1 Processing

and disposition of nonconforming items.Evaluation of construction compliance to the require-ments for proper preparation of NCR forms;NCR logg>>>>ing, control of NCR tags, segregated storage pract-ices, NCR disposition.

reinspection and acceptance, corrective action to prevent recurring nonconform-ances;and control on installation of nonconforming items.NOAH,Section IV,-No.4 CQCN,-Section IV B(AN, Section 15 5FP 20020 Attachment 4 Page 9 of Q4

[gf.EGjI~E MNP-2)OI NUSIOCII GUA1lTY ASSURANCE MASTER AUDIT PLAN IICVI~ION NO I'AOC.OP NO, AUDIT AIICA AUDI'T ICOPC CONTIIOL DOCUMCNTS 7.0 Control of measuring and test ing equipment.(NOAH-Section

!V, No.5)Evaluation of construction compliance to the require ments for control of measuring and testing equipment 7.1 Control of measuring and testing equipment Evaluation of quality control compliance to the requirements for the control of measuring and testin equipment used in construction activities, including evaluation and control of non-Bechtel calibration services to,the purchase order and material requisi-tion requirements.

NOAH, Section IY, No.5 BLAH, Section 12 CQCH, VI, 6.0 10$FP.100.hment 4

)L>~I~.p thOJCCT NALIC 14631~~O.UAt lTY ASSUBAMCE MASTER AUDIT PLAN g IICV IDION NO I'AOE~oP 23 NO, AUOJT AhCA AUOIT NCOI'C 4 CONThOL OOCUMCNTN 8.0 Haterial receiving, inspec-tion, storage handling, and maintenance control.(NQNl Section IV, Ho.2)Evaluation of--construction conformance to the re-quirements for material receiving inspection, storage handling and maintenance control.8.1 Haterial receiving inspectio storage, and maintenance control.Evaluation of construction conformance to the re-quirements for receiving and inspecting material, reviewing vendor documentation; material storage conditions; and maintenance operations and records.BQAH,Section VII 7.6, Sec.1 CQCH,Section III 4.0 GwrVp-4 5F p 20010 httactunent 4 Paqe ll of R (g)0,.E)~gjf!~~NOJCCT Nh&C XOC NuuICN 14631 OUALlTY ASSU RANCE MASTER AUDIT PLAN NCVNNON NO PAOC OP'No AUDIT hi%CA huotT SCOrC CONTNOL DOCVMCNTS 9.0 Field procurement control (NQN Section III, Ho.2)Evaluation of construction compliance to the re-quirements for field procurement.

9.1 Field

procurement control Evaluation of construction compliance to the re-quirements for field procurement.

OQN4,Section IV CQCN,Section V WP/P, Section 12 1 5p p.l0010 h hment 4/MAP Page le 4 t (I~It;II Pho3CCZ IIhMC W P"2 JOh NUMOSII 14631 GUALITYiASSURANCE MASTER AUDIT PLAN IILV I~IOII IIO 13 23 s a ac oi NO hUOIV hIICh hUOll'COPC COHTIIOI.OOCUMKNTN 10.0 Contractor control (NQAN IV, No.7)Evaluation of the contractor compliance to his quality assurance program and/or control document requirements.

10.1 NOE contractor control Evaluation of the NDE contractor compliance to his quality assurance program and/or control document requirements.

BQAM, 759 CQCH;Section 9 WP/P, No.12 1!10.2 Elec.contractor control Evaluation of the elec.contractor compliance to his quality assurance program and/or control document requirements.

Spec.218 BQAN,78 9 CQCN, Section 9 10.3 Coating and painting contractor control Evaluation of the coating and painting contractor compliance to his quality assurance program and/or document requirements.

Spec.219, 234 BQAN,7&9 CQCN, Section 9 P/4~o~', 10.4~5FP.20010 I Instrumentation contractor control Evaluation of the instrumentation contractor com-pliance to his quality assurance program and/or control document requirements.

Attaclwent 4 Spec.220 BQAI<, 7 8 9 CQCN, Section 9 Page 18 of 34 6~gjj~1$<PIIOJCCT HAMS lOO HUMICII 14631 QUALITY ASSUIIAIIICE MASTER AUDIT PLAN 0 II@V IDION HO~ase ol HOe 10.5 AUDIT AIIL'A HVAC&plumbing contractor control AUDIT I COP'C Evaluation of the llhtAC and plumbing contractor compliance to his quality assurance program and/or control document requirements.

e CONTIIOI DOCUMENTS Spec.216 BQAN, 7 CQCN, Section 9 10.6 Concrete&grouting contractor control Evaluation of the concrete&grouting contractor, compliance to his quality assurance program and/or control document requirement.

Spec.215 BQAM, 7 CQCN, Section 9 PP~10.7 Mechanical contractor control Evaluation of the mechanical contractor, compl~ance

'p to his quality assurance program and/or control document requirement.

SFP 20 nrot, I~~~chment 4 gage 14 oi.~

I ,gt of HNP-2 I'IIOJCCT NAMC JOa NUI4$Ch 1463 1 GUALiTY ASSURANCE MASTER AUDIT PLAil~hKVISIOH HO 5~*oa or 15: 23 NO AUOIT ANCA AUOIT SCOPC CONTNOL OOCUMCHTS 10.8 Architect Construction Contractor Control Evaluation of the architect contractor compl iance to hi s quality assurance program and/or control document requirements'pec.

210 BQAN,7 C C)1 Sect 9.'P P o 12 10'Primary Containment Vessel Retrofit, Construction Contractor Control Evaluation of the primary containment vessel and re Spec.213~213(LCA)trofi t contractor compliance to his qual ity assur-BQN, 7 ance program and/or control document requirements.

CQCH, Section 9!p fP-, 10.10 Fire Protection Contractor Control Eval uati on of the Fire Protection Contractor compliance to hi s qual i ty assurance program and/or control document requirements.

Spec 217 BQAM 7 CQCH, Section 9 p/Q-~10~11 Testing Laboratory Contractor Control Evaluation of the testing laboratories contractor compliance to hi s quality assurance program and/or control document requi rements~Spec 221, 221 A BQAN 7 CQCH, Section 9 QFP-20fl70 Attachment 4 Page l 5 of 34 Mar-a l[s~g (pMi(gt rhp f cc7 H/Ma 14631 JOO HUMSCh QUALITY ABSUBANCE MASTEH AUDlT PLAN hC V HHOH HO raoc J6 or g$.How AUDIT llhCA AUDIT score COHThDL OOCUMCHTS 11.0 Control special process (tiQAN IV, B)Evaluation of construction compliance to the re-quirements for special process control..Welding and nondestructive examination control.Post weld heat treatment and filler metal control.Evaluation of construction compliance with the re-quirements of quality control and documentation for welding, post weld heat treatment, filler metal'ontrol, and nondestructive examination for ASNE Code,Section III application.

BQAN, 9 CQCN III, 7.1.2 SWP/P, Wl 11.2 ASNE Code stamping*control Evaluation of project compliance with the require-ments'of code.authorization, inspection and code'ymbol stamping.BQAN, 19 BQAN, 7 5FP QP010 I'1 hment 4 Page 16 L Mar~a l I lF<(If~L~~: rIIOJCCT HAMC JOO HUIS'CS 14631 QUALITY ASSURANCE MASTER AUDIT PLAN~IKVIIIOH No rAoc+7 oy g3 NO duo>r esca AV Ql'f NcorK covveoc.oocvaecNva 12.0 Inspection plans and records (N(AN,Section IV, No.3&7)Evaluation of construction conformance to the re-quirements for-inspection, and inspection records.12.1 Inspection plan&records Evaluation of construction conformance to the re-O(NI,Section X quirements for preparing, processing, revising, and CgCN,Section III, Page 8 controlling field inspection records, I sfr I~20070 Attachment 4 Page 17 of 44 rIIOIccT NAIAC for NUMrCII QUALITY ASSURANCE MASTER AUDIT PLAN IIC VISION HO tAOK OP 18 NO, AUDIT AIICA AUDIT r COP'C CONTIIOI DOCUIACCITr 13.0 Systems completion and veri-fication Evaluation of conformance to procedures for reveri-fication of completed safety-related work.tlVI-Ol Rev.0 13.1 Oechtel systems completion and verification Evaluation of construction and quality control con-formance to procedures for systems completion and verification of past work.i%2 Electrical contractor veri-fication activities Evaluation of contractor conformance to procedures for ver ification of past work.13.3 Instrumentation contractor verification activities Evaluation of contractor conformance to procedures for verification of past work.13.4 HVAC and plumbing contractor verification activities Evaluation of contractor conformance to procedures for verification of past work.>0 (SFP 100'lwent 4 pygmy$6 OI eai.a I IloiaCT IIAua'tP JDII NUMIISII GUALlTY ASSURANCE MASTER AUDIT PLAN~NCVIIION N'O~sac ow~19 Now AUDIT ABACA AUDIT IICOFC CONTIIOL OOCUMCNTI 13.5 13.6 13.7 13.8 13.9 Coating and painting contrac tor verification activities Architect Construction Contractor verification Activities Primary Containment Vessel contractor verification activities Fire Protection contractor verification activities Hechanical Contractor verification activities Evaluation of coating 8 painting contractor confor-mance to procedures for verification of past work.Evaluation of the architect contruction contractor for conformance to procedures for verification to past work.Evaluation of the primary containment vessel contractor for conformance to procedures for verification to past work.Evaluation of the Fire Protection Contractor-for conformance to Procedures for verification to past work.Evaluation of the Hechanical Contractor for conformance to procedures for verification to past work QVI-01 Rev.0 QVI-01 Specification 210.SWP/P-G14,15 BQAH Sec.7 CQCH Sec.IX QVI-01 Specification 213 SWP/P-G14, 15 BQAH Sec.7 CQCH Sec.IX QVI-01 Specification 217 SWP/P-G14, 15 BQAH Sec.7 CQCH Sec.IX QVI-01 Specification 215 SWP/P-G 14, 15 BQAH Sec.7 CQCH Sec.IX SFP 20070 Attachment 4 Page 19 of 34 Ls~<<g 0~g'j72~tlaoJccT HAMK 14631 JOS HUM~Cgg DUALITY ASSUIIANCE MASTEII AUDIT PLAN tlCV I%ION HO 20 23 A K>>Ol HO, AUDIT AllCA AUDIT alCOPC COHTIIOL OOCUMCHTI 14.0 Fire protection system (NQAN, Section 0, No.5)'Evaluation of conformance to procedures for comple-tion of fire protection system.14.1 Bechtel-fire protection system completion Evaluation of construction and.quality control'conformance to procedures for system completion of fire protection system.PQAN, C-3, C-4, C-12 CQCN, Sec.III, Sec.IX SNP/P-G-3 5f P 20010'~~ltment 4 Page 20 e~

IIIgff LI~I.IIIIOJCCT HAMC 0 QUALITY ASSUIIAMCE MASTER AUDIT PLAN HLVIsIo~~O,0 FAOC OF 22 23 HOi AUOIT*Ilm,'A AUOIT NCOI'II COHTIIOI.DOCUI4LHTS 15.0 Seismic II/I quality assurance program (N(AH, Sec.6, No.6)Evaluation of conformance to procedures for comple-tion of seismic II/I.15.1 Dechtel II/I system comple-tionn Evaluation of construction and quality control conformance to procedures for system.completion relative to seismic II/I items.PgAH, C-3, C-4, C-12, C-5 CqCH, Sec.III, SEc.IX I~20010 SFP Attachment 4 Page 21 of 3Q s~<<'"~ROICCT NAMC Jos NUMscR 14631 QUALITY ASSURANCE MASTER AUDIT PLAN REVISION NO PAOC~OF~NO 16.0 16.1 AUDIT ARCA Sacrificial shield wall void repair.(NQAH Section IV No.8)NS-1 Material-Sacrificial shield wall void application contractor.

AUDIT SCOPC Evaluatioh of conformance to procedures for control of special processes.

Evaluation of the sacrificial shield wall applica-.tion contractor (subcontractor to the 215 contract)for compliance to his quality assurance program 8 documented process control requirements.

CONTIIOI.DOCUMCNTS Specification 215 BQAM 7 MP/P, No.'12 CQCH Section 9 17.0 Fire protection subcontracto electrical subcontractor to fire protection contractor, (NQAM, Section 0, No.5)Evaluation of the fire protection contractor for compliance to his quality assurance program and/or control document requirements.

17.1 Electrical installation of fire protection system.Evaluation of the fire protection electrical in-stallation contractor (subcontractor to the 217 contract)for compliance to his quality assurance program and/or control document requirements.

Spec.217 BQAH 7 CQCH Section 9 1&.1 Inprocess and final inspec-tion control of the piping insulation contractor.

1810.<Piping, control of insulatio contractor.(NQAH Section IV No.7)Evaluation of the pipe insulation contractor for compliance to his quality assurance program and/or control document requirements.

Evaluation of the piping insulation contractor (subcontractor to the 215 contract)for compliance to his quality assurance program and/or control document requirements.

Spec.215 BQAH 7 CQCH Sec.9;WP/P No.12~'achment 4 Page 22 I'~MAi-c o ,~ROiSCT RAM'NP-2~4 QUALITY ASSUBANCE MASTEB AUDIT PLAN RS',VISIOII HO 4 rACa~OV Q~IO AUDIT ARCA AUDIT SCOCL'CONTROI.DOCUMKIITS 19.0 19.1 Electrical Contractor contro of subcontractor.(NQAH IV No.7)Control of the subcontractor for the balance of plant power generation control complex.Evaluation of the contractor compliance to his quality assurance program and/or control document requirements.

Evaluation of the BOP, PGCC contractor for com-pliance to his quality assurance program 8 docu-ment requirements.

Spec.218 BQAM 7";;WP/P No.12 CQCH Section 9 20.1 Bechtel Construction PGCC.Completion Veri fy Bechtel Cons truction compliance to Bechtel Procedures and to requirements provided by GE-NEBO Applicable Contract Spec cations, GE documents CQCH II QCI's, QCIR's BQAH Sec.10 S F P.20810 Attachment 4 Page 23 of 34 MA~-A LKOKHD AUOIT SCHKOULKO AUDIT PKRI ORMKD AUDIT CLO5KO~ROJKCT HAMK JOb HUMbKR GUALlTY ASBUAANCE MASTER AUDlT PLAN SCl)EDULE RKVISIOH HO ooo~oo HO.It+2.I 2 2~I 2 2 i I 2 2 It I 2 I It I 2 3 I It 2 2 2 I~2 2 2.1 3.1 4.1 5.1 5.2 5.3 5.4 5.5 6.1 MAP 2 LKCKI!AUDIT SCNKOULKD 0, AUDIT PKRPDRMKD AUDIT CLDSKD 6 PROJKCT NAMC Ioo NUMSKR 14631 I O.UALlTY ASSURANCE.MASTER AUDlT PlAN SCHEDULE RKVISIDN NO am~os~NO I t 2 i I t 2 i I I 2 I 2 2 i I I~2~IS 2)4 7.1 8.1 9.1 10.1 2 j g+10.2 10.3 10.4 10.5 ,0 O 10.6 SFP 20873 MAP LKOKND AVOIT SCNKOULCD AUDIT PKRFORMKD AVOIT CLOSKO~ROJCCT NAMC JOS NUMSCR QUALITY ASSURANCE MASTER AUDIT PLAN SCHEDULE RKVISION NO 3 5 aa al NO.I 981 I 2 3~2 3~I9 I9 t 3 I9 l9 4 I 2 I9~I t l9 3.3~0.7 Oa8 Oa9 0.10 0.11 7.1.2,i MAF 3 LCGg I AUOIT CCIIKOULCO

~, Pgyfl AUOIT tCRYORMCO AUOIT CLOSCO~RO>CCT NAMC IOO NUMQcR 14631 O.UALITY ASSURANCE iNASTEH AUDIT PLAN SCHEDUL'E RCVISION NO PAOC ap I 5 NO, Is~2 I S.Q3 I 2 S 4 I 2 S IS IS IS 4 I 2 IS t 13.2 13.3 13.4 13.5" 13.6*137*13.8*13.9 14.1 SF P-20813.*Hew M A II LKOEND AUDIT SCHEDULED AUOIT rKRrORMKD AUDIT CLONEO PROJECT NAME JOI NUMBER 14631 O.UAt.(TY ASStj BAtIICE MASTER AUDIT PNN SCHEOtjt.E II K V I S I 4 N NO 2 5 rAOK Or Now I t S e I t S~IS~I~-82 le+3 S~I t S t I I~I t S I t S IS 15.1 16.1 18.1 19.1 20.1 5.6 A A I'II<a 1 I'i~~

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0 APPENDIX D

/I APPBlDIX 0 RESTART PROGRAM The purpose of the Restart Program was to assure that risk of additional con-struction quality problans was minimal prior to releasing a contractor to r-sume construction on Quality Class I (QC-I)or Seismic Category I (SC-I)work.The program was applied to all sit contractors performing QC-I or SC-I work.The scope of the program summarized below is described in detail in Attachment I to thi's Appendix.The program included the following tasks.

Reduction of Non-Contractor Backlog This task focused on the methods used by project and corporate organiza-tions to resolve problems and to respond to requests for information and direction from contractors and external agencies.The purpose was to reduce the backlog of outstanding problems and improve response time.The specific areas addressed were: o Nonconformance Reports, o Physical implemntation of engineering dir ction, o.Quality assurance audits, o Corrective Action Requests, o Quality assurance surveillances, o NRC Inspection Items, o 10CFR50.55(e) reports, o Startup Problem Reports, o Oocunentation receipt by the Supply System, o Request for Information (RFI)processing, o IE Bulletins, Circulars, and Information Notices, o Major engineering problems, o Corporate audit findings, and o Master Work List.;0 This task resulted in a number of specific actions which have succeeded in reducing the backlog of PEDs, RFIs, NCRs, and SPRs from about 3,100 to 1,000 (refer to Figures 1 and 2)and contributed to the reduction of oth r backlogs as discussed later.r-0 B.Specification Reconciliation This task included a review of the..construction specifications to assure that they complied with the FSAR commitments, development and issuance of an updated"list of effective pages" for each contract specification, and a review by the contractor to assure that his issue of the specifica-'ion was current and complete.The specification/FSAR review resulted in four changes to the FSAR and approximately 20 changes to various sections oi the specifications.

The procedures used to control the specification/

FSAR review and a typical transmittal showing the feedback to the proce-dure review process (Section 0 of this Appendix)is included, as Attach-ment 2.-0 C.Deficiency Review This review covered the full range of deficiency documents (e.g., Noncon-formance Reports, Corrective Action Requests, Quality Audit Findings, NRC Inspection Items, 10CFR50.55(e), and 10CFR Part 21 items).All open de-ficiencies were identified (listed)and reviewed for trends that were indicative of programmatic problems.Programmatic problems detected in these reviews were fed back through the QA program to assure that correc-tive action was implemented to preclude recurrence and to evaluate the impact on prior work.In addition, for NRC Inspection Items, 10CFR50.55(e), and 10CFR Part 21 items, a matrix showing the action taken to close each item was prepared and an evaluation was performed to assure that subsequent procedure revisions had not invalidated the previous cor-rective action.Finally, all open deficiencies were resolved by closure, carrying the resolution to the point where craft work was required for closure;or evaluation, which determined that the existing status did not impact restart of QC-I/SC-I construction.

In the latter case, this usually involved having an approved corrective action plan in-place so that the assessment of the impact on restart of construction could be performed.

The primary benefits were a substantial reduction of the backlog of open deficiency documents (ref r to Figure 2 of Appendix C), feedback of pro-grammatic problems to strengthen'he QA programs, management systems and work procedures, and the development of a more effective system to moni-tor and manage the size of the backlog of open deficienci s.-0 0.Procedure Revie'w'The primary focus of this task was to assure that the construction con-tractors'A, QC, and work procedur s complied with.the specifications, codes and standards, were internally consistent, and incorporated ade-quate controls to preclude recurrence of past problems.The r view pro-cess worked in both directions, and in a number of cases, changes were made to clarify or corzect project.instructions.

or the specifications.

The completion of the specification/FSAR and deficiency reviews provided a baseline from which the procedure reviews were performed.

The proce-dure reviews were conducted in several stages with formal transmittal and response to review ccmnents.'n those cases where revisions had been made in response to the defi-ciency reviews or other inputs, the procedure was first'reviewed and ap-proved within the contractor's organization.

It was then reviewed for approval by Burns and Roe and the Supply System Restart Task Team as-signed to that contract.The Task Team exercised the Owner's QA approval authority for procedures and was responsible for tracking the resolution of outstanding comments.

E.Training and Personnel Qualification Reviews This review included the procedures that control personnel qualification and training requirements, and audits of the implementation of these re-quirements.

The scope covered QA/QC personnel, NDE personnel, welders, and engineering/supervisory personnel.

ln general, few problems were encountered in those areas where job descriptions and qualification re-quirements are well standardized (e.g., NDE personnel and welders).The primary benefits from this review were clarification and strengthening of the qualification requirements in the QA/QC and engineering areas, in-creased emphasis on the qualifications and training of key personnel, and an independent verification that the personnel involved in the work to be restarted were qualified and had been trained to the revised program.-D F.Management Systems Review Work process flow diagrams were developed by the four major contractors (mechanical, electrical, HVAC, and IhC)to assist in the identification of problem areas and the development of corrective action.The scope of these reviews concerned all phases of the contractor's program, from work planning, processing of engineering direction, and material acquisition, through construction, inspection, problem resolution, and docum ntation review.The main benefit was the broad overview of.the program structure which highlighted interface problems and adverse procedural interactions. 7-G.Corrective Action i The corrective action process which took place during the Restart Program involved two major thrusts.One activity was directed at the identifica-tion and resolution of generic problems that were impacting work in major hardware areas or the dispositioning of multiple defects.Examples of these problems ar the dispositioning of weld defects in sway brace brackets procurred from several vendors, and the development of more ef-fective criteria for the inspection and resolution of arc strikes.Since many of.these items were contained in the backlog of deficiency documents and the engineering backlog, the performance of this task was one of the key factors in the reduction of the backlogs.The other activity of the corrective action process is less visible, but was equally effective.

This was the feedback between the reviews de-scribed above.This feedback process is depicted in the flowchart in Attachment 1.The principal result of this feedback was iterative revi w and revision of the QA, QC, and work procedures.

The primary driving orc s for these iterations were the output from the deficiency reviews, the resolution of the generic problems, and the management system reviews.-0 H.Evaluation The evaluation encompassed the collection, review, assessment, and docu-.mentation of the results of the various Restart Program tasks.The eval-uation was done by.Supply System task teams using formal procedures and checklists to assure that the main elenents of each task were complete and satisfied the program requirements.

The task t ams conducting the evaluation were independent of the organizations responsible for perform-ing the work.They had the authority to reject the work submitted and exercised this authority frequently.

Additionally, a review was per-formed by WNP-2 Project QA of the Restart Program documentat'cn assembled by the Task Team.The review by Project QA was not limited to the docu-mentation, but included-checks of contractor records and interviews of contractor personnel to verify the validity of the conclusions developed by the task teams.These reviews did generate additional findings which required resolution.

The results of the Project QA reviews and the re-solution of their findings are part of the Restart, Program record.-0 I.Independent Review r The last step prior to the release of a contractor was a review of the Restart Program results for that contractor by a team composed of senior~Corporate QA and Engineering personnel who were not involved in the Re-start Program and who were organizationally independent of the WNP-2 Pro-ject.A copy of the results of the Restart Program reviews was also pro-vided to the NRC Resident Inspector concurrent with the Supply Syst m's independent review process.The findings of the independent review team and their resolution were also provided to the NRC Resident Inspector.

-D r5rrr 55 55>Ski>$555 rrrr rrrr re~~~,rr i'~r r M~HW r r r~~~r rr csea r 55 rr~I SSUE NSS L 1 x~8~~~

-0 P 4o

1900 1700 LEGfttD:--TOTAL DOCUt'tent)

EttGIttEERlttG DO ITS BACKLOG-1981 8 1982 ACTUAL BACKLOG EAv.'..EEK DY DOCUtlEttT TYPE PA KL06---FPED's-.PEP'8 gQ'I I-CR-RFI's 2900 2700 1600 1500.1400 1300 1200-g 1100 1000 W 900 800 I@I 700 8 600 500-400 300 200 100-0~~~~4~~~~TAL ED-'s 0's I'R's R's-RFI OCUl EttT.I>>ACKL~>>>>e>>~~~~~~~~~~~~~~~0~~i~yy~~~~~~~~o~~~~~~~2500 2300 2100 1900 1700 1500 o l300 1]00 o a 900 700 500 300 100 0 198l CI IA M Ql N O'Ch O ID N PI W rI rI O O O w rw I~~O N CU~I IA O4 cv N~N N~I p C4 I I 1982 CA r N N PW Attachment 1 WASHVfGTON PUBLIC POSER SUPPLY SYSTEM P JT-01 IICV PIO REVERIFICAT10N tNSTRUCTtOH RESTART ACTIVITIES SCOPE'.0 PUIIPOSK CIPFCCTIVC OAT'C 12/29/80 QUALITY AIt CC~1 NO Q YC5 L:HO The purpose of this instruction fs to delineate the total scope of all activities requfred prfor to authorizing the restart of a specific ccmaodfty of quality Class I/quality Class II Seismic Category I work.This fnstruction also assigns the responsibility by Project organfzation for performance.

2.0 OEFINITIONS

3.0 OISCUSSION

Tne activftfes required to restart work on ccnmodities (priorities established on reference 4.3)are derived from ccmmi&ents of Reference 4.1 and further described in Reference<.2.Additionally, there are several actfvftfes which must be per.ormed to fulfill the intent of the camaftments made in Reference 4.1 but are not specifically identified.

The activities of Attac!ment 5.'re a compilation of all known items~hich will be required to satisfy Owne.canaitments.

These activities will be performed in accordanc wi h th ited instruction and by those assigned responsibility in order to standardize methods, coordinate the total project ef ort ynd minimize duplications.

4.0 REr"RBCoD 4.1 MPPSS Ietter, G0-2-80-153, dated July 17, 1480-response to NRC 10CFR50.=-4(f).

4.2 Plan, WP-2 Restart of Safety Related Work, dated Oecember 17, 79K (Rev.1)4.3 Restart Level 3 Cctrmodfty Priority Schedule.5.0 ATTACHMENTS 5.1.Restart Actfvfties

5.2 Standard

Restart Flow Oiagram, Oated Oecember 10, 1980 (Rev.2)5.3 Plan, MNP-2 Restart of Safety Related Work, dated Oec aber 17, HK (Rev.1)A&ISOV CD WAI ISO 5UPCPI5COC5 I55UCI PJT-01 Revision 0!I PAOC DIP~1 REVERIFICATION PROGRAH ACTIVITES (PllASE I-RESTART))REFERENCE"STANDARD RESTART FLOW DIAGRAH" (ATTACHHEHT 5.2)ACTIVITY 1.Current Baseline Specification.

a.Provide Baseline Specification.

b.Ensure Baseline Specification Compliance w/FSAR.c.Hodify Baseline Specification/FSAR as Required.2.Deficiency Review.a.Provide Listing of 50.55(e)s, Part 21s, Open HRC Findings and Closed (since 1977)HRC Findings.b.Analyze List (para.2.a.)in Conjunction with All Open CARs, (AFRs, HCRs, IRs and RFls for-Program/System Failures and Provide Recommended Corrective Action(s).

c.Review E Approve Analysis and Recommended Corrective Action(s).

d.Verify that Corrective Action s)have been Incorporated in Applicable Specification(s

, Procedure(s) and/or Hanagement System.3.Corrective Action.a.Provide Construction Sequence/Priorities/

Detailed Schedules to Identify that Specific Work to Comnence upon Authorization to Restart.INSTRUCTION P JT-06 P JT-07 PJT-00 RESPOHS IB IL ITY BN Engr., Cont.Project Engr.BKR Eng., Proj.Engr.P.I).A.Contractor R,P.R.P.C.H.1 Page 2 os ACTIVITY 0)INSTRUCTION RESPONS I OIL ITY d.e, go Identify and List Non-Contractor Deficiency Backlog that Constrains Restart of Work and Provide for Disposition in Accordance with the Restart Schedule.Review Deficiency List (par.2.a., 2.b.)in conjunction with Construction Sequence (par.3.a.)and Establish a Priority for Dispositloo of All Open Deficiencies.

Disposition Deficiencies in Accordance with the Established Priorities

'(par.3.b.)(Hinimum Acceptable Criteria is the Deficiency Backlog Reduction to Support One Honth's Mork and Scheduled Disposition of the Balance to Sustain Project Remobilizatlon).

Review Deficiency Disposition (par 3.c.)and Identify any Requirements for Specification Hodification,-

Procedure Revision and/or Hanagement System Revision.Review and Document the Effects of Deficiency Disposition on Restart (Including Haterial Availability and Long Lead Items)and Adjust Construction Sequence (par 3.a.).as Required.Verify that Identified Chanqes/Revisions (par 3.d.)have been Incorporated in Applicable Specification(s), Procedure(s) and/or Hanagement System.PJT-0$Engr., P.Q.A.Contractor Contractor, BN Engr., Project Engr., Project Hgmt., P.Q.A., C.H.R.P.C.H., Contractor R.P.4.Procedure Review.=PJT-05 a.b.c List and Submit all Procedure(s) by Con~oodit.y.

Review Procedures to Current Specification (Par.1.)Deficiency Review (Par.2.)and Corrective Action (Par.3.)and Submit Resolved Comments to Contractor.

Revise Procedure(s) as Required.Approve Procedures.

Contractor R.P., BER Engr.Contractor R.P., BN Engr.Page 3 of 12 ACTIVITY INSTRUCT IOt]RESPONSIBILITY 5.Personnel I)ual if ication.aO b.Co Submit Hames and Resumes of gA, l)C, Engineering and Supervisory Personnel to be Trained as Required by Approved Training Program/Procedures.

Review and Approve.Authorize Training.Contractor R.P.C.H.6.Management Systems (Applicable Only to Contracts 215, 2)6, 218 Ec 22D).a.b.Submit Management System to Include those Requirements Identified in the Deficiency Review (par.2.)and Corrective Action (par.3.).Review and Approve.Contractor P.H.7,.Evaluati on.aO b.co Document an Evaluation of the Adequacy of R.P.Performance of Reviews and Actions Accomplished.(pars.1., 2., 4., and 5.)Document the Effect of Restart on Reinspection (Reverification Program-Phase II).Provide a Declarative Statement Attesting that Restart of Work will have a Minimal Risk of guality Problems.Contractor,-

C.H.Contractor, R.P.8.Ftn'al a.Review and Approval.Prepare a Fina)Document Package that Demonstrates Satisfactory Completion of All Restart Requirements.(par.1.thru 6.)R.P./0 Page4 of~

ACTIVITY b.Conduct an Independent Review of Restart Activities to Provide an Objective Evaluation that the Req<<lrements of the"PLAN WNP-2 Restart of Safety Related Mark" have been Adequately Accomplished.

9.Restart and Mork Surveillance Program.a.Prepare Mork Surveillance Plan and Identify Applicable Work llold Points.b.Issue to the Contractor a Conditional Authorization to Restart Subject to the P.Q.A.Surveillance Plan and llold Points.INSTRUCTION RESPONS IO IL I TY Supply System Hgmt.Comnittee P.Q.A.P.H.c.Commence Work.d.Perform Surveillance in Accordance with Plan.e.Identify Additional Revisions to Specifications, Procedures and/or Hanagements Systems as Applicable and Assess the Adequacy of Training Programs.f.Initiate, Implement and/or Incorporate those Findings Identified

{par.9.e.)to Include Retraining as Necessary.

g.Issue to the Contractor an Unconditional Release to Restart.Contractor P.Q.A.P.Q.A.Contractor P.H.

Rev.0 7/31/80<<vs~12/17/80'0 MNP-2-RESTART OF SALTY RELATED HORK APPROVAL G.I.Me11s R.N.Fo1ey A.N.Sas ry R.T.Johnson M.C.Bibb Ci Page 6 of 12 Rev.I 12/17/80 TASK II/PHASE I SURGERY O.I In order to resume any work stopped by Stop Mark Order No.009,'review will he.conducted tc assure that contractor quality controls are ef ective and that any rMumption af work would have minimal risk of quality problems and would not preclude r inspection af pas work.This~ufmoent applies to all can-tractars responsible for Quality Class I cr Quality Class II Seismic Ca~~cry.I work.The lfst of actfcns which must.he taken before r lease for any work activity for any contractor fs included as Attachment I.A tachment II identffies the additional requirements which mus he applied ta Contract 215 fndivfdual work acti vf tf es prf or tc resumption of work.The attached restart plan is ta he cansfde~as Phase I of Ne overall revie~effor., which was c~i d to in he 1QCFR50.54(f) r sponse ta NRC (1 t~r G02-80-153).The plan attached her in addr sses only those ac ivities necessary ta restar work.It involves the apaoin nant of a Rest r Cacrdinator for each contract, in A~wc.'nnent I.This individual will be the cental pain of ccm-munication with the contractor as it r lates ta the r start program.Mark which will he r viewed and assessed are smnarized as ollcws: Procedure status and adequacy of proc dur~uiremen~~.

to specifica-'on and SARs.Adequacy of perscnnel qualification and training programs.Analysis of deficiencies (IRs, RFIs, NCR, QAFR, CAR's SQ.Sa(e)s, Part 21 and NRC findings.)

Oeficfency backlog reduction in accordance wi'i priorities of cans~ec-tion canpletion plan.Results of the review will be assessed and if controls are de~ed adequat, work may restart.Corrective ac ian measures will he stipulated, as appro-pRate.Upon verification that the carrec ive acticn measur s have been implement d, the can~icwr will be authorized to commence work subject ta a Ccndi icnal Release for Restart.Ouring the period of Conditional Release foi Restart, work activities wf.ll be subjected ta a surveillance program established and adminis-tered by the Pro)ect QA Oepa~nt.An Uncanditional Release for Restart will be issued contingent upon the Contractor's demons ratian of the adequacy of all controls/procedures affecting the work.Upon ccmpletfon of the review associated with Phase I the designated team will then initiate Phase II of the review plan which will verify ie adequacy of ccmplet d work.An action plan, schedule, team leaders, and team members are presently heing identified.

Page 7 of 12 12/17/80 TASK II/PHASE I I.List the following types of safety significant work which was supped as a resul of SMO 89.A.Safety function-Quality Class I/Seismic Class I and Quality Class II/Seismic Class I.Construe ion II.The ini ial prioritized list of contractor work activities to be reviewed wi'll be provided.Subsequent 1'sts will be added as needed.III.Iden ify and obtain resolution of can.actors'oncerns which cauld affect restart of safety significant work (e.g., NCR dispositions, approved drawings, procedure convent and resolution/approval).

Meetings with the contractor, conducting-interviews and requesting writtm responses fram the contractor by the Project organization will be utilized to identify can ractars'oncerns.

IY.Evaluate can.rac.ors'urrent work and inspection controls ta assure that quality controls are effec.ive and adequate for the specific work activi y being consider d.A.-Proc dures associated with the contral of work being evaluated shall be lis d and will be associated with De following applicable areas.Mat rial control, ma rial receiving and traceability.

Mark procedures Inspection procedures Document control Design Change control Special processes NCRs, RFIs, CARs Quali fi cation/traing procedures B.Procedures will be reviewed for: Proper approval authority status Incorporation of applicable SAR, speci ication,'code and standards requirement Qualification of welding and special processes A program to provide positive control of the work C.Review of personnel qualification and training programs shall include: Qualifications for QA/QC, Engineering

&supervisory personnel Construe ion Constructi on Contractor RP (Task Porc..x RP (Task'orce II)RP (Task Force II)Page 8 af 12 Task II/Phase I Rev.I 12/17/80 I Y.C.continued gualificatfans of NGK persannel Training programs for craft personnel gualf icatfon requirment of welders Q.Oacumantation

~0e1eta (Oocumentatfon review wf1 1 be accamplfshed under the scape of Task Force II, Phase II).K.Geffciencies

{IRs, RFIs, NCRs, gAFRs, CARs, SQ.SS(e)s, Part ZXs and HRC ,fndings)shall be analyzed tc determine (ff applicable):

Programatic failure of management controls Recommended corrective actions Resalutfons required to support construe"fon priorities F.Sample Reinspec ion Gelete (Reinspection of comp eeet work will be acccm-plish d unde..he sc"pe of Task Force II, Phase II).Resaonsibf 1 it RP (Task Force II)Cantractcr, Construc-tion, RP (Task Force II)Y""valuatior, af Rmwr Ac ivities to Provide: A.Identify ar a(s)where restart of work wauld pre-clude r inspec ion af previausly ins 11 d work.If r star af work would not preclude reinspec.'on of previously fnswlled wark, this condition shall be sc documental.

B.Geclaratfve statanent attesting that Res art of work will have a mfnfmal risk of quality problems.C.Oocumen ed evaluation of the per ormance a=the ac.fvitfes described in IV.Contractor, Cans ruc-ti an Ccntrac~ur, RP{Task Farce II)gA VI.The fallowing fnformtfon shall be compiled and pro-vided tc the independent review team, identified in VII below ta assfs in determining if work shauld be 1~star~ed'.Results of the activfties performed in IV.B.Results of the activities performed in V.RP (Task For e II)~'age 9 of 12 Task II/Phase I VII.For the work activities identified from II above, an independent review shall be conducted to provide an objec.ive evaluation of all safety significant work activities to be restarted.

This review will continue until terminated by approval of the MNP-2 Project Nanager and MNP-2 Program Director.The Independent Review Team will be comprised of senior management personnel not presently assigned to the MNP-2 Project.Prior to restart:.of work, the resul.s of the inde-pendent review will be forwarded to the WNP-2 Program Director for hfs disposition.

This review shall: A.Determine that the assessment,"restart of work will have minimal risk of quality problems", has been adequately performed.

B.Determine that the assessment,"r'estar of work will not preclude reinspection of previously insulled work which falls under the requirements of the reverification program (Phase IT)", has been adequately per ormed.G.Determine that.he evaluation performed in IY above did no identi y any areas which were not in full compliance with the identified requir~ments.Mhere deficiencies were identified, appro-priate restrictions will be imposed on the work activi.y.D.Determine that identified conditions which repre-sent a generic problem with the overall manage-ment control system are corrected and verified as being adequate.Rev.I L2/'17I BO (~t Independent Review Team Independen Revie~Team:0 VIII.Upon Conditional Release for Restart, gA surveillance gA will be conducted on the cowedity activity.Projec (}uality Assurance will establish a Surveillance Plan and identify work hold points.The surveillance results will be documented on prepared check lists.These results will be analyzed to determine any necessary corrective actions to management controls, procedures or training.Unconditional Release for Restart will be contingent upon a demonstrated ade-quacy of the work controls and where identified, the implementation and verification of any corrective actions.Page 10 of 12 ATTACHMENT II Rev.I 12/17/SO 215-AOOI i TONAL ACTIONS (1)Review.select&work processes and sfmp1ify work procedur s (Rei'.80.54(f)letter-Attachment 5)~Hangers 11 Sore (2)Revfew and upgrade work planning: Ensure'availability of approved procefures Ensure adequate trafning of all personnel Ensure avaflabflt y of material fn compliance with speci f-.cations Establish-performance accountability Establish performance indicators and monitoring system Establish productivity measurement sys m-(3)Reduce backlogs and es ablish controls to provide timely resolution of the following:

RFI's IR/NCR's..CAR's Audit Findings Transmf ttal s (4)Review and upgrade the training program.Train personnel to new training program r~ufrements hefor r sumption of a==ected work.(5)Secure r lease of Stop Mork Oirectfve rom MNP-2 program Ofr~or and NRC Region Y.Page ll of 12 r;Ci

~~ltleir LORE~t (O>>ORT(STAND"-RD RESTART FLOE DIAGRAM~Rss IR~le(RD SR>>I~(f(RD tl~a(%lll OR Er(oo~ccr>>er ll LV/RL Tt n El(or(~Rf(ERK la Lrr/SCL Tt Tl K'lrl Coot>>R~r>>sar LR K fn renrl ES stl OCTO(e R>>TR ha'1~tr>>'rs CO>>e 1 It (OCLL.D F00-H.4 I n(~>>o(lec~4" ri X CVl RI>>4(I SRET te tt~n RRE~tl Isa>>R KR C>>W.lct(OL laR>>iea ,~I ln RES (>>~4 f 4~TOT~ill>>RL~>>cs/Rro/s II It laR Rl R4O/I RtlaeCL T>>ei n 4(TR R>>(ITIC'I SDIIRLI(ct

~(>>CR.O>>ltn Crt/IC(T t(DR RQ OD G CR lL.SI~ER(ncs~4 th~TT lt IR>>O~CDRCT(tt LT(D lt I'I~r(KK Tt n>>W(t IR" c(e>>(C((tCI r/er sn Tf n El ecnr(n Oe 4 (ll It L'(ID COVLETE~(O TfRI>>1't I,'1 tl nn, Ll Tt I~~~~CR (KTD 41441 RIRRRRS il KCOT>>rn ell>>lfhl(R~LR(RRl~4 r a EE>>-~~P ll PR I~R coro/Rc, 4~L>>kl 1~C(O(r Lair>>.1'I'>>R/R>>~cnnn CDL(ir>>or tr(R>>nose faa~r f>>r~Ec>>re I Eri RRtn~RD(RL ntll K(LD KTRVS~sa~>>PRE 4 f1 4D~Ta Lnt 11 ll(at tlr h NR Crh ann 4: CO.CDI S(RI It(f COCnel'lf ORe RC Ref/nr rce 4/s i fr~lrt, t/KR/lrt COTIKTIR LETRI a I fr(CI Cf~nfatf ll Ri(irnl lrs e lrtlnt K~IIRT l ll IERnn OVT, tW, CEW I.~RLS IRRR Cs>>RKT(R~rf(E nxro>>rs.4 Le>>EI~R (asia CO(RETCH rl mr sr e(e(>>R RR Ill(~Tn Kfrn ltl ee n a/tRNC Or lire(l/itl Oi>>II rutnn 0 i(a(in R>>TIKI'I:ei'((R (OII~(RKS 1 r>>aR 4ncuK(n K (SERI Or~tl (tVL etl>>(IKRS I I I Irri Sn(re>>R(IR I (r(CI 4Ã(i(1 wr nn>>'\I>>R>>t ((4 RrlT 4 (O EDC sall TI I IR>>nrrn RL(t>>TRn~(ERIL ca to KK I C>>KCJCKS tr Il~Ol Kll>>n P~OK5 tp F'El osvln ftih(n oot>>>>ttet~IcIE(s/SORTS E(R ln N nl KT(lfi I rn ar>>oct Tl EI lnirf~Kr't\RIL Ki CO>>LE(I Ell C>>R 44 nlfll E tr trt nz E(nr IES (CCE~STONO RQTARl'Xf'//

0 tLRQI~en RR>>R>>>>el np o>>R r DIE>>(Vr~I Page 12 of 12'I

0 Ok P>~JL5'9 SASHWGTON PUBLlC POSER SUPPLY SY~at REVERIFICATION lHSTRUCTIOH P JT-06 ACV NC4 CPIcCCTIVC OATC l.-l.s-a1 QVALITV AIcI'CCTP04 QX vCS Q Ico REIflEA OF SAR'E UIREMEIVTS I.O PURiOSc The purpase af this instructfan fs to delineate those responsibilities rec ssary to assure adequate review of SAR r~ufrements to be included in contractors specfff catfcns.2.0 OEFINITIONS None 3.0 INSTRUCTION

~tB Reverification Pr agram Engine r'.ng The"NOTE" refers to noi confirming infomation within the SAR.The specifications were.reviewed against the SAR design requirements.

ActIcc 1.Suhnfts priority lis af ccnstructfcn activities to Engine ring.2.Receives lfs and if r~ufred adds addftfcnaI actfvft es that they have specific knowledge af.3., For each construction activity, rev.'ews the latest antencntent of the FSAR and the SCV t.QG for approved commitments and fills aut an"Activity/Ccmmi nent Checklis"" (At achment 5.2)and verifies the anencntent number used on attachnent 5.4.The cctnnf&ent colImtn mus identify the requirenents such that specification ccmplfance can be evaluated.

In general, the identification of a speci ic cade/standard/gufde with revision will be sufficient.

'Ahere a cctnnf&ent fs not to a cade/standard/guide, the detailed cctnni nent mus be entered.NOTE: Ccneftments relative to desian and/or test prcgran are not a part of this review.AftflOV CO w&I 44 ATTACHMENT 2 YACC Ct P JT-06 Rev.2 4.Reviews each comitment against the latest specification as defined by the current List of Effective Pages (LEP)and Specification Control Log (SCL)identifies the dates of the LEP and SCL on attachment 5.4.Determines compliance/

non>>compliance'.

Prepares RFI/SCN in accordance with references 4.1 and 4.2 as appropriate for non-complying items.Fills out Commitment Specification Checklist" (Attachment 5.3)and verifies the LEP and SCL used on attachment 5.4.Engineering Review Coordinator Reve ification Program Supervisor/Team Leade~5.Submits completed forms at achments 5.2, 5.3 and 5.4 and copies of RFI's and SCN's to Engineering Review Coordinator.

6.After approval submits 1 (one)copy of all itans in 5 above and any pertinent correspondence to Reverification Program Phase I Supervisor.

7.Reviews Comnent Specification Checklist and other information submit ed in 3.6 above evaluates effect on Procedure Review and Restart.

4.0 REFERENCES

4.1 S and R PIP MNP-2-012 Request or Information (RFI)4.2 EOP-8.3 Review and Approval of SAR Amendments

5.0 ATTACHMENTS

5.1 FSAR Review Flow Chart 5.2 Activity/Ceanitment Checklist 5.3 Commi~ent/S ecification Checklist P 5.4 FSAR/SPEC Review, Verification of Amendments and Revisions Used.Page2 of 7 Q~

CONSTRUCTION ACTIVITY FEAR PARAeuuH(S)

COPt~ii BA'(S)RFfiFA VS SPKIFICATTCNS ANO uaNaZS (Pm S)CONAITMENT IN SPECIFICATION LOG RP/ISK: SPECIFICATION RFI FSAR-SCN Page 3 of 7 I

PJT-06 Rev.2;~RESTART P ROGRAi4I FSAR SPECIFICATION REVIEW VERIFICATION OF AMENDMENTS AND REVISIONS USED Amendment No.11 of the WNP-2 FSAR was used for the Activity/Commi tment rev'ew.The Commitment/Specification Review for Contract included a check against the List of E-,-,ective Pages (LEP)dated and a review of PED's listed in the SPecification Control Log (SCL)dated REVIEWER: DATED: Page 6 of 7.I-~

WASHINGTON PUBLIC H)%:-R SUPPLY SYSTEM Da~e:@~~up~/'g/g~/

Subject:

+~gIggrs~+in accordance with PJT-06, Rev.1, attached are: Activity/Commitment checklists, and 2, Comitment/Speci=ication ch cklists 3.P.ri 9'MP-4/4 SCH~g-3>7.gZB S-4O R.Grant, Reverification Program Phase Supervisor H.F.'Aiitala, Engi.ne ring R view Coordinator, VHP-2: RESTART OF SAFE-RELATED liQRK~F AR/SPECiFiCATION R"=ViBf..coy':,oorTv.

u'a.r~" Ak'z PrP~2"DCYihi 1/4 C~ZDCmPEDC ViN.'i 5 QAdmia Fie MG Conn wc A Cygelran-9OaA F.Gamer val OK Earle RN Foley AH Kugler GT Harper-904A RT Johns" n-9i7B Nh Sastry-90iA hF'.tiita-a s=(2)p=(1)iirtl/Ib=or the subject commodity.

Th Activity/Co

-.itment checklis-s ar provideo so that the co,";i;.nts c n be correlat d.o the Cori tr..ent/Speci-i cat;on checklists.

i'here a checklist indicates that th sp c'=.ication is in com-p 1 i ance wi th the FSAR co-.i i tment, no=ur ther action s recui red.if the specification is not in compliance, then th RFi re=erenc'd shall be incorporated and procedures shall be reviewed to ensure corplianc>>i h the FS'R conmitment.

in.hose cases where the co~ii~i,ent is changed by the SCl<reiereficed, tne cnange shall be reviewe n det~rmine its effect on the orocedures.

Any proc-dure a-.-ecteo s.all nc'e r le sed 0 consi uction until the SCH has been aoproved.tiFM:cd Page 7 of 7

.Cg AP P END I X E 1 1.I I 1~

APPENOIX E NORMAL PLANT VERIFICATION ACTIVITIES The purpose of this Appendix is to discuss the normal verification activities.

used to confirm the adequacy of: o Construction, o Functional performance of components, systems, and structures, and o'overning docunents used to implement the plant-operating enevelope.

The in-process design controls and design verification used to ensur an ade-quate.design are discussed in Appendix A and further confirmed by the tech-nical reviews addressed in Appendix B.Oue to the construction quality problems experienced earlier in the history of WNP-2, the Quality Verification Program (QVP)was implemented.

This program, although not a normal construction activity, is discussed here because through the implementation of the QVP, the Quality Class (QC)I and/or Seismic Cate-gory (SC)I construction prior to July 1980 will be upgraded or confirmed to be acceptabl.The ongoing quality controls are then used to maintain an ade-quat 1 vel of construction quality.The discussions on P rformance and Operating Envelope Verification are used to tie in the standard testing program and procedural controls and operating limits that bring the plant from the construction phase to commerc'al opera ion.

A.Construction Verification l.Quality Verification Program As the Restart Program activities were drawing to a close and prior to the time contractors were released to resume construction of safety-related work, BPC was engaged as the Construction Manager/Systems-Completion Contractor.

In planning for the evaluation of the adequacy of prior work accomplished by activ site contractors, the Supply System integrated its reinspection activities with Bechtel's Systems-Completion Plan.Provisions were included in the normal verification process for reverification of work already com-pleted and accepted.The Quality Verification Program is designed to verify the adequacy of safety-related work completed prior to the July 1980 stop work.This program, which is described in detail in Attachment 1 of this Appendix, has thre major elements: o Systems Completion

-which covers work performed by active site contractors, o Prepurchase and Inactive Contracts-which covers long-lead hardware purchased by the Supply System, and work performed by site contracts that are already closed, and o Soecial Tasks-which includ: Review of deficiency docum nts for proper disposition, Analysis of personnel qualifications gathered from other reviews and reinspections, and Receiving reinspections to determine the adequacy of past.receiving programs.The Quality Verification Program provides for a random, sample (min-imum 10X)reinspection of hardware that has already been completed, inspected and accepted, and review of supporting quality documenta-tion.Deficiencies identified in these reviews and reinspections

'are reported and corrected in accordance with approved project pro--cedures.The completion of the review and reinspection activiti s of the QVP are coupled with the Systems-Completion Plan.As such, this program will function in parallel to construction completion on a system-by-system basis (system turnover).

Attachment 2 identifies the individual system turnover dates projected at this time, and therefore includes the schedule for performance and completion of the Quality Verification Program.

Another consideration in establishing confidence in the quality of the work in-place is recognition of special investigation and rework programs.The existence of such programs is a positive indication that the hardware or work items have received adequate attention to design, function, quality, and performance.

The Quality Verifica-tion Program takes credit, as appropriate, for these other reinspec-tion activities'and rework programs air ady performed or under way.A list of examples is provided below, with a bri f statement de-scribing the scope of each activity: o Backfill Testing The failure of contractor documentation to fully support the in-place densities of soil backfill placement led to a special t sting program developed by Burns and Roe.The results indi-cate that QC-I.backfill is acceptable and no rework is necessary.

o Sacrifical Shield Wall Investigation and Repair Oeficiencies identified in the welding, shielding, and material traceability of this structure, installed by the mechanical contractor,.

were extensively investigated by the Supply System and Burns and Roe.Inspections and tests were performed by independent personnel, and repair work was performed oy the on-site contractor and Bechtel.Results are recorded in a ccm-pl te engine ring report.o Rework of Pipe Whip Restra'nts A review of contractor r cords by Pro'ect-QA revea'ed a numb r of deficiencies, which ultimately resulted in 100K NOE of"he pipe whip restraints provided oy a contractor.

Correc" ive action to resolve the fabrication problems continues at this time;all PWRs are being remanufactured or repaired.Results of the investigation and evaluation are recorded in an engine-ering report.o Control Room Cabling As a result of'oncerns, questions arose relative to cable sep-aration in the control room.A sample inspection program to verify routing and separation of cables has been initiated by the electrical contractor.

Bechtel QC and the Quality Verifi-cation Program are monitoring this work.o Weld Radiograph Review In late 1981, a sample review of weld radiographs was conducted as a part of the reverification f fort on the PzoJect.The results indicated a need to re-examine all radiographs of ASM'ield welds completed by the mechanical contractor (approxi-mately-2,500), which is in progress at this time and is reg-ularly zeported as part of the Quality Verification Program.

o Work Smart (~This program was initiated in 1979 to resolve construction

~,~interference problems with large-bore pipe supports in the mechanical contract.The work was typically performed by a team composed of a contractor field engineer, a Burns and Roe pipe support stress analyst and draf tsmen, and craf tsmen.While originally designed as a time-saving action, this program resulted in less conflicts in the construction, less rework, and a higher quality installation.

o Grout Testing All grouting under QC-I and SC-I quipment and hanger base plates is currently under revi w.A sampling program of micro-coring and testing has been developed by Burns and Roe to de-termine the quality of grout used throughout the Project.An-other program for the orderly replacement of deficient grout is being developed at this time.2.Ongoing Construction The Restart Program should be viewed as providing a"fresh start" in the context of the basic program, procedures, etc., and the reduc-.tion of the backlog of unresolv d problems.However, a number of additional actions were taken to assure effective follow-through on the implementation of the new program and prompt corrective action in response to new problems as they occur.in addition, a number of organizational and contract realignm nt changes were made to.'trengthen management control of the Project.The benefits from the Restart Program, in conjunction with the follow-up and ongoing ac-'ivities discussed below, and the WNP-2 Quality Assurance Program.'-'refer to Appendix C)ensure that the in-process construction will be acceptable.

a~Strengthen Project Management Within the Supply System, the management of the construction projects was decentralized to provide stronger direction in the field.Each project now has a Program Director responsible for all design and construction activities at the site.Bechtel Power Corporation (BPC), with extensive experience in the nuclear power industry, has been engaged as the Construc-tion Manager and the Systems-Completion Contractor.

Prior to this change, the Supply System and Burns and Roe shared the construction management responsibilities.

As Construction Man-ager, BPC is responsible for the day-to-day managem nt of the on-site contractors.

In their role as Systems-Completion Con-tractor, BPC is responsible for construction completion of as-signed areas or systems, and for turnover of all systems to the Supply System.BPC is also, responsible for audit and surveil-lance of all site contractor QA programs and QA/QC activities Ce for their work as Systems-Completion Contractor.

The WNP-2 Project QA organization is responsible for audit and surveil-lance of the BPC QA/QC Program, including monitoring the eff c-tiveness of the BPC program of contractor audits and surveil-lances.In the fall of 1981, BPC was assigned the responsi-bility for construction completion of, all.the mechanical sys-tems at WNP-2..The role of Burns and Roe at the WNP-2 Project has been changed to provide undivided responsibility for engineering.

The de-sign activities, formerly conducted at the home office in New York, for the most part have been transferred to the Burns and Roe Richland office or to the-site organizations.

Technical authority for the mechanical, nuclear, electrical, and IAC dis-ciplines resides in the Richland office.Further, the Richland office staff includes former Supply System engineers who are familiar with the technical issues, the requirements of the Project, and Supply System operations.

Control of the Engineering and Quality Program Backlog A major emphasis of the Restart Program was the reduction of the backlog of unresolved engineering and quality probl ms.The Restart Program was highly successful in producing resolu-tion of many of the outstanding probl ms, but in most cases the'ctual correction of the defects could not be performed until after restart of construction since they r quired craft work.To assure effective management of this process, tracking sys-tems and processing goals were established which have proven very effective in maintaining control of backlog sine the Re-start Program.In addition, the resolution of reportable con-ditions (lOCFR50.55(e) and 10CFR Part 21)is now scheduled and tracked on a priority basis throughout the Project.Maintenance of Specifications and Procedures in Compliance with Licensing Requirements Burns and Roe instructions include as a specific checklist item the review of each Project Engine ring Oirectiv (engine ring directive to contractors) for conformance to the FSAR commit-ments.Changes to contractor procedures are reviewed by Bechtel and/or Burns and Roe to assure compliance with the specification.

In addition, when compl tion of the mechanical work scope was assigned to Bechtel, an extensive review was performed to assure that earlier commitments made in response to NRC Inspection Items had been carr'ied through into the Bechtel program.This review identified a number of actions which required follow-up by Bechtel and/or the Supply System to satisfy these commitments.

-E d.Improv'ng the Timeliness and Control of Engine ring Direction to the Field Many of the activities initiated under the Restart Program as-sociated with reduction of the non-contractor backlog have been continued and expanded to further improve the timeliness and control of engine ring direction to the field.Examples are: o A Burns and Roe Field Engineering group was established to provide quick engineering response to minor problems, inter f erences, etc.which occur during construction ac-tivities.These engineering resolutions are documented via the Field Resolution Project Engineering Directive (FRPED).The FRPED is checked by the appropriate disci-pline engineers (not in the field group)to assure the validity of the solution and potential impacts in other interfacing areas.This system has significantly reduced the response time for engineering answers to construction questions wh'e preserving the integrity of the design control.In an effort to reduce the administrative processing time required to revise specification pages, the active con-struction specifications have been put in a word processor system.In addition, Burns and Roe has established a tracking system to expedite specification release packages through the site engine ring groups to accelerate the is-suance of the revised specification pages.The mechanical soecification is being revised to consoli-dat QA requ'rements and clarify the technical require-ments.This effort will ensure that technical require-ments are more simply stated for the Systems Completion Contractor.

o Burns and R'oe engineering, design, and drafting groups are completing an effort to significantly reduce the volume of drawing changes remaining to be incorporated.

The volume of outstanding, authorized drawing changes (PEDs)has al-ready been reduced by over 60X.The object of this ac-tivity is to reduce the volume to less than four weeks backlog of drawing changes.This will result in improved drawings for use in the field and will help minimize docu-ment control system errors.o Burns and Roe has established internal methods and proce-dures for updating drawings which had been supplied by contractors and vendors whose contracts are now closed.These drawings will therefore be maintained current and assist in the control of design and construction.

-E o The Drawing Control Log (OCL)lists the Burns and Roe drawings which are issued for construction and authorized changes to those drawings which have not been incorpo-rated.The use of the DCL is becoming more efficient be-cause of the current program to incorporate PED changes into the drawings and thereby r duce the volume'of"open" PEDs."'"'.To assure that documents requiring a.Burns and Roe ze-sponse (e.g.,-Request For Information, Startup ProblemReport, transmittals, etc.)are answered in a more timely fashion, Burns and Roe Site Engineering has in operation a program which lists response requir d items by date.The Document Aging Report is also used-by the engineering groups to keep an active track of items which requir ex-tensive research, and therefore time, or are awaiting in-formation from an organization outside of Burns and Roe.The Bechtel'Systems-Completion Plan The Systems-Completion Plan is a method used by Bechtel for completion of QC-I and QC-II/SC-I systems.Concurrent with the performance of new work to effect systems completion, the plan integrates provisions for resolution and correction of discrep-ancies in both hardware and documentation, as well as verifica-tion.of a sample of previously completed and accepted saf ty-related work and accompanying documentation, which is discussed in the Quality Verification Program discussion.

It is utilized by BPC and other site contractors working under Bechtel Con-struction Management (CM)in compl ting safety-z lated systems.Bechtel verifies, using their total QA/QC Program and this plan, those portions of the systems to be comple".ed by Bechtel dir ctly.Portions of systems that ar completed by other con-tractors working under Bechtel CH are verified by those con-tractors using their Supply System approved QA/QC programs and this plan.The site contractors are und r surveillanc inspec-tion by Bechtel QC and auditing by Bechtel QA.These efforts are conducted under the Supply System's overall administration and direction.

Figure l of this Appendix illustrat s a~flow diagram for the verification proc ss.It should be noted that BPC has successfully used similar plans in the completion stages of other nuclear power plant projects.-E B.Performance Verification 1.Purpose Performance Verification is the industry established and carefully structured process by which WNP-2 will be taken from completion of the construction phase to commercial operation.

This verification of proper functional performance includes not only the plant sys-tems, components, and structures, but also the plant operational procedures and personnel.

The end result of the Performance Verifi-cation is the demonstration that the plant, staff and procedures meet governing regulatory requirements and are integrated to achieve safe and reliable operation.

Performance Verification is accomplished by testing in a time pro-ven, logical sequence (refer to Figure 2 of this Appendix)which extends over a wide range of normal operating and transi nt events.Systems, structures, and components will be tested to ensure that functional design requirem nts are m t.2.Scope The specific scope of Performance Verification includes testing to: o Ensure that the plant systems and components are designed and constructed to allow preoperational and power ascension testing, o Demonstrate the functional capability of structures, compon-ents, and systems to meet performance requirements, o Effect fuel loading in a safe manner, o Demonstrate that the plant adequately performs under normal operation and a wide range of abnormal/transient conditions, o Evaluate and demonstrate, to the extent possible, plant opera-ting procedures to provide assurance that the operating plant staff is knowledgeable about the plant and procedur s and is fully prepared to operate the facility in a safe manner, and o Bring the plant to rated capacity and sustained power operation.

3.Requirements Performance Verification is modeled aft r and mee s the same regula-tory requirements as numerous, previous General Electric Boiling Water Reactor Test Programs.The plant will be tested and operated und r the requirements of 10CFR50 and the WN?-2 Plant Technical Specifications.

Following fuel load, WNP-2 will be operated in ac-cordance with Chapter 13 of the FSAR"Conduct of Operations".

Qual-ity Assurance for Performance Verification activities will be in accordance with Appendix B of 10CFR50, ANS 3.2"Administrative Con-trols and Quality Assurance for the Operational Phase of Nuclear.0-E Power Plants", and Chapter 17 of the'FSAR"Quality Assurance".

The personnel conducting Performance Verification will be qualified ac-cording to ANS 3.1"Standard for Selection, Qualification and Train-ing of Personnel for Nuclear Power:Plants" and Regulatory Guide 1.8"Personnel Selection and Training".

The test programs will be in accordance with the requirements of Regulatory Guide 1.68"Preoperational and Initial Startup Test Pro-grams for Water Cooled Power Reactors" and the General Electric BWR"Startup Test Specification".'he individual tests are discussed in detail in Chapter 14 of the FSAR.4.Method of Compliance The management organization from the Corporate Managing Oirector down to the Plant Manager and the Test and Startup Manager is illus-trated in Figures 3, 4, 5, and 6.A complete description of the organization, responsibilities, and personnel training program for the operating plant is provided in Chapter 13 of the FSAR.The t st programs are procedurally controlled by the Corporate level Test and Startup Program Manual for the system lineup and preopera-tional tests..The power ascension phase is implemented by the Plant Procedures Manual which contains 1400 to 1500 specific procedur s.It should be noted that Burns and Roe and Gen ral Electric, for their design responsibilities, r view and concur with the acceptance crit ria and test results from the system lineuo and preoperational test programs.In addition, General Electric is intimately involved in all aspects of the power ascension test phase, through th use of the GE Startup Test'peci ications and by review and concurrenc with the test procedures, including acceptance criteria, and the t st results.Further, prior to fuel load for the purooses of the NSSS scope, General Electric will perform their Operational Readi-ness Review.System Lineup Tests System lineup tests are the first group of tests after provi-sional acceptance of a system from the construction organiza-tion.These tests determine if the components which comprise a system function properly and, if not, identifies specific def'-ciencies for corrective action.In addition to generic tests to be used on all systems, there are also special tests to dem-onstrate specific functions.

Typical system lineup t sts generally include, but are not limited to, the following:

o Chemical cleaning and flushing of syst ms, tanks, and vessels, o Electrical equipment tests including energizing, checking grounds, relay checks, checking circuit breaker operation and controls, continuity checks, meg ger tests, phasing check, high potential measurements, and energizing of buses, o Initial adjustment and bumoing of motors, o Checking control and int rlock functions of instruments, relays, and control devices, o Calibrating instruments and checking or setting initial trip setpoints, o Pneumatic testing of instruments and service air systems and cleanout of lines, o Checking and adjusting of relief and safety valves, o Complete tests of safety-related, motor-operated valves including adjusting torque switches and limit switches, checking all interlocks and controls, measuring motor cur-rent and operating sp ed, and checking leak tightness of stem packing and valve seats during hydrotests, o Complete tests of HSSS control systems including checking all interlocks and controls, adjusting lim'switches, measuring operating speed, checking leak tightness of pnuematic operators, and checking for proper operation of controllers, pilot solenoids, etc., and o Other tests and verifications such as component leak inte-grity and vibration.

Refer to Table 1 of this Appendix for a list of system lineup tests.b.Preoperational Tests qO;~Preoperational testing is the testing of entire systems after formal system turnover from construction has occurred.The system must have either no deficiencies or only minor deficien-cies evaluated not to impact testing before turnover is com-pleted.Preoperational testing ensures that the system oper-ates properly and meets performance requirements in all re-spects, with the exception that heat transport systems cannot be tested for heat transfer capability.

Preoperational testing also demonstrates that the operating procedures are adequate to the extent they are reflected within the scope of these testing activities and gives operating per-sonnel training time on operating systems.Co The general objectives of preoperational tests are as follows: o Ensure that test acceptance criteria for system perform-ance are met, o Provide documentation of the':performance of safety-related equipment and systems, o Provide baseline test and operating data for=futur reference, o Run-in new equipment for a sufficient peziod so that de-sign, manufacturing, or installation defects are found, and o To the extent possible, ensure proper integrated operation of plant systems.Refer to Table 2 for a list of preoperational tests.c.Power Ascension Tests Power ascension testing begins after the preoperational t st phase has been completed.

The power-ascension phase begins with fuel loading and extends to comm rcial operation.

The tests (approximate3.y 43)conducted during this phase consist of major plant transi nts, stability tests, and tests wh'ch demon-strate correct performance of the nuclear boiler and numerous plant systems wh l at power.The power ascension t sts are performed in a structured se-quence starting with basic plant operating checks and building into more complex integrated plant performance testing as reac-tor power, and thereby t mperatures, pressures, and flow rat s are increased.

During this testing phase, plant operating per-sonnel will perform the testing, and plant operating procedures will be used for actions not covered directly by normal or spe-cial test procedures.

The plant will be operated in accordance with the Technical Specif'cations during this test phase.Table 3 lists the power ascension tests.d.Technical Specifications Upon receipt of the plant operating license, just prior to fuel load, the NRC issues the Technical Specifications which govern plant operation following that time.Technical Specifications are Appendix"A" to each production facility operating license issued by the NRC.Basically, Tech-nical Specifications are the NRC's requirements cov ring plant operating limits and surveillance testing to ensure that the lant is operated safely and within limits.Refer to Subsec-ion C of this Appendix for additional details.

5.Conclusion The Performance Verification activities comply with regulatory re-quirements, logical and time-proven industry startup experience, and Supply System Corporate policy.These activities will be completed by qualified personnel in accordance with Chapters 13, 14, and 17 of the FSAR, Corporate level and plant level procedure manuals, and the Technical Specifications.

Performance Verification, through the various testing phases, will ensure that WNP-2 will perform in accordance with the design and plant performance requirements during normal and abnormal operating conditions.

-E C.Operating Envelope Verification 1.Purpose The purpose of the Operating Envelope Verification is to ensur that the operating envelope, as defined in the Technical Specifications and implemented by the Plant Procedur s Manual, properly reflects the design, plant performance requirements, regulatory requirements, and industry experience.

2.Scope Operating Envelope Verification in the context of this report includes: o The process used to establish the NRC approved Technical Speci-fications, which govern plant activities after fuel load, and o The process used to establish the plant procedures which imple-ment the operational controls (Plant Procedures Manual).It is to be noted here that the Technical Specifications and the Plant Procedures Manual also govern the power ascension testing phase of Performance Verification.

In addition, the implementation of the Oo rating Envelope activities requires the establ'shment of an operating organization with quali-fied personnel capable of supporting the ooeration of WNP-2.Though this issue is briefly discussed her'n, th's document is not intend-"'d to be used to address organizational readin ss for operation.

3.Requirements The basic requirements associated with the operating envelope are provided in 1OCFR50.36"Technical Specifications", NUREG-0123, and through licensing commitments documented in the FSAR.Requirements relative to the operating personnel and organizational structure ar provided in regulatory guides, NUREQs, and ANSI/ANS standards.

The plant specific operating requirements are specified by the NRC in the operating license and the Technical Specifications for WNP-2.4.Method of Compliance a~Technical Specifications A violation of a Technical Specification condition or limit is a reportable occurence to the NRC;thus, considerable attention is focused on the preparation, review, and approval of this document to'ssure it correctly reflects the plant design and performance requirements, the regulatory requirements, and our commitment to operate the plant in'a safe and reliable manner.

The NRC uses a generic appro'ach to establish Technical Specifi-cations.This generic approach resulted in a standard document!~that is revised yearly (i.e., the Standard Technical Specifica-

.tions (STS)for BWRs).Implementation of the STS on a given plant is described in Attachment 3 to this Appendix.The STS document for BWRs is NUREG-0123 and has been revised five times since first incorporated in the license of Brunwick No.1 in September 1976.The STS has been refined considerably since=1976, but there still remain about 24 issues presently being discussed with the NRC by the BWR-5 Owner's Group (refer to examples in Attachment 4).WNP-2 personnel are actively in-volved in this group effort.The WNP-2 plant specific Technical Specifications (marked up STS-Rev.5)have been prepared in first draft and have been submitted to the NRC as described in Phase I in Attachment 3.General Electric and Burns and Roe are presently reviewing this first draft.Responsibility for preparation and processing of Technical Specifications rests with the plant Technical Staff, and the majority of the information in the first draft was as-sembled by plant technical personnel who are experienced in startup and surveillance testing of BWRs.In addition, associ-ation with other BWR-5s resulted in inclusion in the WNP-2 STS markup of information derived from their testing programs.The actual param ter values (instrument setpoints, flow rates, etc.)wer taken from Burns and Roe and General klectric design docum nts and fram-.the FSAR.Review and approval of the STS markup within the Supply System is performed by WNP-2 Project Engineering, the WNP-2 Plant Technical Manager, and by th Safety Engine ring Group Manager (refer to Attachment 5).Phase II of the STS process should begin in about six months.At that time, comments form General Electric, Burns and Roe, NRC, the Supply System, other BWR-5s, etc., will be incorpora-ted into the next draft (Draft No.2).This draft will then undergo review and approval by the Plant Technical Manager, the Safety Engine ring Group Manager, and the Systems Design Engi-neering group.This engineering group also performs the Re-quirements and Design Reverification.

Subsequently, the NRC/Supply System resolution meetings will commence.Refer to At-tachment 6.Technical Specification examples (ECCS and Administrative Con-trols)and a copy of 10CFR50.36 are provided as Attachment 7.There will be an overview of the Technical Specification pre-paration/review process by the Corporate Nuclear Safety Review Board.-E b.Plant Procedures Manual The Plant Procedures Manual contains the implementing proce-dures required by the Technical Specifications.

The plant pro-cedures are being developed-and refined based on a number of inputs: o Procedures from operating BWRs, o Technical Specifications, o BWR Owners'roup on Emergency Response Quid lines, o System lineup tests, o Preoperational tests, o Power ascension tests, o FSAR, o Washington State Site Certification Agreement and Permit, o Oesign specifications, o Operating experience reports, and o-Corporate policy, programs, and'procedures.

The plant operat'ng procedures are prepared and reviewed oy exoerienced plant staff members.They are also reviewed by the Plant Ooerations Committee (POC)which consists of the follow-ing personnel:

o Plant Manager, o Assistant Plant Manager, o Operations Manager, o Technical Manager, o Maintenance Manager, o Administrative Manager, o Plant QA Manager, and o Health Physics and Chemistry Manager.Upon resolution of all review comments, a plant procedure is approved by the Plant Manager.-E Co In addition, the functioning of POC is overviewed by the Cor-porate Nuclear Safety Revi w Board.The Plant Procedures Manual consists of 14 volumes including the emergency and security plan implementing procedures as listed in Figure 7.These procedures are specific to the WNP-2 facility and are the required and approved methods for opera-ting, monitoring, t sting, maintaining, and modifying WNP-2 equipment, systems, and facilities in accordance with the Tech-nical Specifications and other regulatory requirements.

The emergency plan implementing procedures integrate operational aspects to the Site Em rgency Plan.Corporate Support Programs and Procedures Programs and procedures generated by support organizations which are qualified for.use at WNP-2 include welding proce-dures, ISI, operations Quality Assurance, procurement, secu-rity, environmental monitoring, and the Emergency Response Pro-gram.All,safety affecting Corporate procedures used with the WNP-2 facility are approved by the WNP-2 Plant Operating Committee.

d.Organizational Structure and Operating Personnel The organizational structure of the Supply System and-the lines of r sponsibility for operation of WNP-2 ar established in accordance with NRC requirements and guidelines and industry experience.

In establishing the organizational structure the following were considered:

o Regulatory Guide 1.8,"Personnel Selection and Training", o Regulatory Guide 1.33,"Quality Assurance Program Require-ments (Operation)", o NUREG-0731 (Oraft),"Guidelines for Utility Management Structure and Technical Procedures", o NUREG/CR-1280,"Power Plant Staffing", o NUREG/CR-1656,"Utility Management and.Technical Resources", o ANSI/ANS-3.1,"Standard for Qualification and Training of Personnel for Nuclear Power Plants", o ANSI/ANS-3.2,"Administrative Controls and Quality-Assur-ance for the Operational Phase of Nuclear Power Plants", and o INRO guidelines on organizational structure and responsibilities.

r In addition, the qualifications, training, and experience for plant operations and support p rsonnel comply with regulatory requirements, ANSI standards, INPO recommendations, and TMI 1 ssons learned criteria.The plant training program and the qualification of key staff members-and operations personnel are discussed in Chapter 13 of the FSAR.Specific.responses to regulatory" issues on qualifications and training are addressed in Appendix B of the FSAR.Nuclear experience of the current WNP-2 plant technical and management staff exceeds 1100 man-years (refer to Figure 5).At full staffing, this number is expect d to incr ase markedly (refer to Figure 8).In addition, plant craft personnel have in excess of 517 man-years of nuclear experience.

The manner in which the plant organization is structured will ensure that sufficient personnel depth, diversity, and cap-ability exists to support the operation of NNP-2.The qualifi-cations and experience of the operating staff, combined with the review process for the Plant Procesures Manual, will ensure that the plant operating procedur s are adequate and will pro-perly implement the Technical Specifications.

Independent Reviews The Quality Assurance and Nucl ar Safety Assuranc organiza-tions will perform a spectrum of review functions relative to the operating plant.The Nuclear Safety Assurance organization:

under the Safety and Sec r'ty Directorate provides for inde-pendent-'iew of safet/'ssues>plant procedures test plans, safety performanc

, and plant"hanges, and coordinates/performs industry and WP-2 ooerating experier.ce evaluations.

The in-dustry experience review process is illustrated in Figure 9.Tne Nuclear Safety Assurance organization is discussed in FSAR Appendix 8, item I.B.1.2 (" Independent Safety Engineering Group"), and Chapter 13 of the FSAR.The Operational Quality Assuranc organization, under the Qual-ity Assurance Oirectorate, provides QA/QC services such as re-view of documents which affect plant safety, surveillance of plant activities, overview of the Inservice Inspection Program, and perform QC inspections.

The Operational Quality Assurance organization and their responsibilities are described in the Supply System Operational Quality Assurance Program Topical Report.A Plant Operating Review Committee and Corporate Nuclear Safety Review Board further.serve as line management and Corporate surveillance of nuclear safety, respectively.

-E 5.Conclusions WNP-2 operations will comply w'th: o NRC, Federal, and State requirements, o Industry experience, and o Corporate policy.The operation of WNP-2 will be performed and governed by: o NRC approved Technical Specifications, o FSAR requirements, o Approved plant procedures, and o Qualified, trained, and experienced personnel.

Plant procedures and operating staff are used in performing the power ascension testing programs.Thus, each is"verified" in con-junction with plant operations to assure that all are integrated, qualified, and provide for saf, reliable operation in accordance with the governing Technical Specifications.

-E-l8-SYSTEM'INEUP TESTING PROGRAM)Generic Tests on All S stems ITG Il I2 I3'TG Vl V2 Instrument and Control Test Guide Instrument Calibration Loop Checks t Instrument Removal 5 Installation Vibration Test Guide=Vibration Data Machinery Vibration Signature ETG Electrical Test Guide El Circuit Test Record (non-rotating equipment)

E2 Motor and Control Test Record E3 Motor Operated Valves E4 Crane Motor and Control Test EDS-1 thru EDS-31 (Electrical Data Sheets)FPI1 FPI2 FPI3 Flushing Program Requirements Cleaning Procedure Preparation Cleaning Procedure Implementation Ml M2 M3 M4 M5 M6 Pump Test Record Fan Test Record Compressor Test Record Air-Operated Valves Safe'ty and Relief Valve Operational Readiness Test Loose Locking Nut on Limitorque Valve Operators I Total approximately 60 tests o Examp1 es: a.S13.0-1 CRD Scram Discharge Volume Verification b.S58.0-2 Special Performance Test of>JNP-2 Ultimate Heat Sink (UHS)c.Sl.0-1 RPV Code Hydro Test Pressurization Procedure TABLE 1 QO PREOPERATIONAL TEST PROGRAM 1.2.3.5.6.7.8.9.10.11.12.13.14.15.16.17.18.19.20.21.22.23.24., 25.26.27.28'9.30.31.32.33.34.35.36.37.38.39.40.41.42.43.44.45.46.47.48.49.50.51.NUCLEAR BOILER REACTOR RECIRCULATION REACTOR WATER CLEANUP REMOTE SHUTDOWN REACTOR CORE ISOLATION COOLING HIGH PRESSURE CORE SPRAY-MECHANICAL HIGH PRESSURE CORE SPRAY-STANDBY ELECTRICAL HPCS 125 DIVISION 3 BATTERY LOW PRESSURE CORE SPRAY RESIDUAL HEAT REMOVAL STANDBY LIQUID CONTROL CLOSED COOLING WATER CONTROL ROD DRIVE-HYDRAULIC CONTROL ROD DRIVE-MANUAL CONTROL PROCESS COMPUTER REACTOR PROTECTION NEUTRON MONITORING TRAVERSING IN-CORE PROBE ROD WORTH MINIMIZER ROD SEQUENCE CONTROL LEAK DETECTION FUfL HANDLING&VfSSEL SERVICING EQUIPMEiNT CRD INSTALLATION EQUIPMENT (CRD-If)PRIMARY CONTAINMENT ATMOSPHERIC CONTROL PRIMARY CONTAINMENT COOLING PRIl1ARY CONTAINMENT INSTRUMENT AIR PRIMARY CONTAINMENT ATMOSPHERIC MONITORING LIQUID WASTE PROCESSING CHEMICAL WASTE PROCESSING SOLID WASTE PROCESSING RADIOACTIVE DRAINS&SUMPS PROCESS RADIATION MONITORiNG AREA RADIATION MONITORING ENVIRONS MONITORING FUEL POOL COOLING&CLEANUP.STANDBY GAS TREATMENT OFF-GAS 500/25KV DISTRIBUTION LOW VOLTAGE DISTRIBUTION INSTRUMENT POWER EMERGENCY LIGHTING STANDBY AC POWfR SYSTEM STANDBY AC POWER SYSTEMS DIVISION 2 MAIN TURBINE SYSTEMS 250V DC DISTRIBUTION 125V DC DISTRIBUTION 125V DC DISTRIBUTION 125V DC DISTRIBUTION 24V DC DISTRIBUTION EXCITATION

&VOLTAGE REGULATION GENERATOR HYDROGEN COOLING TABLE 2 GENERATOR HYDROGEN SEAL OIL GENERATOR HYDROGEN STORAGE&SUPPLY GENERATOR STATOR COOLING ISOLATED PHASE BUS DUCT COOLING TOWER MAKEUP CIRCULATING WATER PLANT SERVICE WATER STANDBY SERVICE WATER MAKEUP WATER TREATMENT DEMINERALIZED WATER STORAGE&TRANSFER POTABLE HOT&COLD WATER FIRE PROTECTION MAIN STEAM LINE ISOLATION VALVE LEAKAGE CONTROL MAIN STEAM SEALING STEAM CONDENSER AIR REMOVAL AUXILIARY STEAM CONDENSATE CONDENSATE STORAGE&TRANSFER CONDENSATE FILTER DEMINERALIZER REACTOR FEEDWATER REACTOR FEEDWATER CONTROLS HEATER VENTS&DRAINS TURBINE OIL PURIFICATION

&TRANSFER NON-RADIOACTIVE DRAINS&SUMPS CONTROL&SERVICE AIR PLANT COMMUNICATION REACTOR BUILDING HVAC REACTOR BUILDING EMERGENCY EQUIPMENT COOLING TURBINE BUILDING H&V CONTROL, CABLE&CRITICAL SWITCHGEAR.ROOMS HVAC RADWASTE BUILDING H&V STANDBY SERVICE WATER PUMPHOUSE H&V DIESEL GENERATOR BUILDING H&V SERVICE BUILDING H&V OFF-GAS VAULT HVAC SEISMIC MONITORING CIRCULATING WATER PUMPHOUSE H&V MAKEUP WATER PUMPHOUSE H&V COOLING TOWER ELECTRICAL BUILDING H&V METEROLOGICAL SYSTEM 52.53.54.55.56.57.58.59.60.61.62.63.64.65.66.67.68.69.70.71.72.73.74.75.76.77.78.79.80.81.82.83.84.85.86.87.88.89.90.91.92.93.94.95.96.'7.98.99.100.101.102.103.BASELINE RVICE INSPEC RVICE INSPEC TDAS SECURITY SYSTEM POWER DISTRIBUTION SECURITY SYSTEM CATHODIC PROTECTION PROCESS SAMPLING LOSS OF POWER&SAFETY TESTING RADIOACTIVE WASTE PROCESSING CONTROLLER DATA FOR THE FOLLOWING:

TION OF REACTOR VESSEL TION OF PUMPS AND VALVES'(IWP&IWV)TABLE 2 (cont.)SPECIAL TESTS 1)INSE 2)INSE CRANES&HOISTS REACTOR BUILDING CRANES PRIMARY CONTAINMENT INTEGRATED LEAK RATE TEST SECONDARY CONTAINMENT INTEGRATED LEAK RATE TEST POWER ASCENSION TEST PROGRAM OQ STI No.1 9 10 11 12 13 14 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Test Name 31 Loss of T-G Offsite Power 33 Orywell Piping Vibration 34 RPV Internals Vibration 35 Recirc.System Flow Ca'libration 36 Isolated Reactor S tabi 1 i ty 70 Reactor Water Cleanup System 71 Residual Heat Removal System 72 Orywell Atmosphere Cooling 73 Cooling Water System 74 Off Gas System, SPECIAL TESTS-Moderator Tem'perature Coefficient Measurement

-In-P 1 ant Sa f e ty-Re 1 i ef Valve Load Test-Ultimate Heat Sink Test-Sacrificial Shield Verification Tests-Loose Parts Monitoring Baseline Chemical 5 Radiochemical Radiation Measurements Fuel Loading Full Core Shutdown Margin CRD SRM Peri.5 Control Rod S'equence Rod Sequence Exchange Water Level Measurements IRM Performance LPRM Calibration APRM Calibration

.Process Computer RCIC Selected Process Temperatures System Expansion Core Power Oistribution Core Performance Electrical Output and Heat Rate~Core Power-Void Mode Response Pressure Regulator:

Setpoint Change Backup Regulator FW System: FW Pump Trip Water Level Setpoint Change Heat Loss Turbine Valve Surveillance MSIVs: Each Valve One Valve Full Isolation Relief Valves: Flow Oemonstration Turbine Stop Valve Trip 8 Generator Load Reflection Shutdown from Outside Control Room Recirculation Flow Control System Recirculation System: Trip One Pump Trip Two Pumps System Performance Non-Cavit, Verification TABLE 3

.~

VERI 1-"lCATIGM PRGCE88 I I ITCN Nof l1IIAlltO SUI tl It 1~A DDCVVINIIIIIW 001 I VDI~I~II IN~ICCEFIA~LC IDCUUENIAIIDT Aaaol Dl I AIR 0 ICCC~II~IC DOCUUEN1I1loa LAO I Ias~ALEE~I~IIVI IALLCDS I~I ITCNI INACCIISAILI 6 ICNIDlat Noall II At1011 fol c 0 N I I 0 v c I Nal tACtADC 1IIIVC I IaltCCIIDN tllal F01 NIIFICTI01 FIRFOIN'NDREF I ltNORC lao OC I t Fat I C I fl I 1 lasllll IIDII II DDCVVENIATIOV DII I 401 IIII CELVIFCCTION INTALIOAT CO~I I~I IV~~OCUVI~Tlffoa I C I 1 I~C C 1 ION DISCI.OICS IIARDNAAC DIICAI IIVCIE~UIO I I I I Ill I I DI 00 ITCNI ltsts~ISLE TIIIDOTV IIIICN I'ICN I loallCII1 la I'Ill I C 0~ACVitr DOCVUCNI~IIDN All~DDCUUCNIAIIDN IS ACCEFIAILC

~IILCCI SlNtlt~DR RE IV~tlCTIDN I II~I la I I IL I C~I 1 I 0 1 a E C I l'I I~UCCC Slt Vl FCOFOSII ACI1lttCIION UICRCAIE IANFLI IN~ttlto1N Vt QI~10 I~IN lflasttc'IION I a I I ALLA I ION Ia DDCVNINIAIIDN Is val Co~SCCI~DCUNERIAIIDR ll vasucctssrvl (aisle flalttl Wl It~It I~ACCttllllllff Ot NAOONlIC Aas~OCNNCRTATION TU Nof STSTCN I~I~IARTUt 101~Stlttlllloall I ITIN~IVttl IC1~DDCUUINIAIION QOQIO 11 Ualccftlllll IIIN vlCDRAECIL1 I a I I II I I 0 lllN I~101~CORRECIAILC

~I REVORK 01 AI~LACENCNI~OISIN AIFAOTAL V'cl~ISFIOITION tier Rtlt.~S~IO~~llllatlfl01 I UIC ADIOS~IIFOV'IIOR

~Rt till Ollto~ITION I'I I II ID C CDAACCllllC

~I ataoaa oa~CFLACCUINI 1'I~Clttlalg0 IDCNTVSIO Al A SIIVLT DF 11E SOLLOOIRO ACTlVITICONILL OC CRT tato 01 Ial Nllffa N01C UIIQl QI Qll 8 0 Q FlguVQ

'I I CONSTAUCTION MANAGEtllENT AAEA OF nESI'Owsl(3ILITY wASIIINGTow puoLIC powEA supl LY sYsTEM Al)EA oF nEsPowslolLI1 Y IPI1ovIDEs ovLnALL MRNAGEMENl.<<

IcoollDINATIUN oF cQNsTnUcTIow I AND TFCIINICAL DlnECTION OF<<CONSTAUCTION TESTING.I I I I cowsTnucTION pl IAsE I I I CONTAACTonS FINISII I coNsTnUGTIDN, MAINTAIN EOUIl'MENT, PEllFOHM I cowsTnlICT'low TEsTTNG AC1 I V IT IES.I I.'I I I I I I I SYSTEM L I W El/P Pl IASE PIIEOPEnATIONAL PI IASE STAI ITllP Pl lhsll Nl'~THS PEASONNEL.

I vLnFonM LINEuv AC rlVITIEs.r~OSg<(>C1 IOg MA WAG Erl Coon 0 IN Rl'E CO NTI 3 3ACTO I)ACTIVI I'IES I cowrnAcTons AsslsT LlWEUP ACl'IVITIES As Dll'IEcTED IIY wl'Pss.I I I I pnovlsloNAL ACCEPTANCF l wl'pss pEnsoNNEL pEAFonM TEsT AcTIvITIEs,=

MAINTAIN AND OPEllA1 E PLANT.COMMEnclAI.-

OPEAATION T U II N 0 II E II LOAD I UE WFI'SSE CALIQIIATES.

IIECIIECKS, TESTS, VEIIIFIES.

OFEIIATFS ANI'I MAINTAINS SYSTEM'.I Fl I cows INTEGnATED NISI I CONSTAUCTION SYS1 EM<<FIINCTI I llUCTION TESTING VElllFICR I'IUN TES1'IWG 1'LST AND STAIITUP PlloOAAM nlsE To POWEII whnnANTY DEMON-S'fl1 ATION P

tlANAGING DIRECTOR DEPUTY t1ANAGING DIRECTOR EQUALITY ASSURANCE DIRECTOR DIRECTOR OF PROJECTS BUSINESS PROGRAt1S DIRECTOR TECHNOLOGY DIRECTOR SAFETY AtlD SECURITY DIRECTOR POWER GENERATION DIRECTOR TREASURER PUBLIC AFFAIRS DIRECTOR WtlP-I PROGRAM DIRECTOR WNP-2 PROGRAM DIRECTOR WNP-3 PROGRAM DIRECTOR Figure 3 Ce 0 NASIIINGTON PUBLIC POQIEB SUPPLY SYSTEM POWEA GENERATION IIANFOIID/PACKWD.

GENEAATING PIIOL Gf Nf IIATION Sf AVICES GENf IIA1ION 1HAINING WNP-)/4 OPEAATIONS WNP.2 I'LANT WNP.3/6 PLAN1 Test 8 Startup APPAOVAL Ng~cF Actus OulECtalL tOwfll GCHBIAIION QAIt'igure 4 APPIIOVAL Io IW 0@le>v s~i~4uio ONEclun uAlf.CONCIIIlllf NCE M~1'c, C,P~5,(o'>(e-cONI'Alutu>ll I~ulhulu ui l)AI1 4;0 Ci PLANT lggC 53 Man-Years**

alP-2 PLAtiT HAtiAGEA ASSISTANT PLAtir HAtiAGER 21 Han-Years**

.ItiQUSTRIAL SAFETY SECRETARY 10 Han-Years**

~.HA ItlTEtiANCE HhtiAGER TRAI tiltiG HAtiAGER OPEBAT IOtiS HAtiAGER ADHI tiI STRATIOti HAtNGER TEOltiICAL

~NtiAGER ttP/CttEHISTAY

~NtiAGER 121 han-Years**

180 t5an-Years**

307 ttan-Years**

22 Han-Years**

169 Han-Years**

227 t1an-Years**

• NTRIXEO**tluclear Experience (1110 Total)'**Craft Experience of 517 Han-Years FIGURE 5

+r'~'I g+4~L-WASIIINGTON PuOLIC POWER SUPf LY SYSTENl 1'EST 8c STABTUP SYSTEMS 1UlNOVEfl TEST GAOUP TEST GAOUP TEST GAOUP u paavAL W~++~FIGURE 6 evnovAL iJ/A IIEVIIIYI'4 I I 1.hl IUII Il cowcunnEwcE.

~4m~w a s~.h..il-.I:llI t45All(Ill Ollli I'I j.)tilth'1AIC 1 A'~l' 1 ,2 3 5 6 7 9 10 11 12 13 14 ADMINISTRATIVE PROCEDURES SYSTPi OPERATING PROCEDURES GENERAL OPERATING PROCEDURES ABi'JORf'lAL CONDITION PROCEDURES EYiERGENCY OPERATING PROCEDURES FUEL HANDLING AND REFUELING SURVEILLANCE PROCEDURES OPERATING AND ENGINEERING TESTS iNUCLEAR PERFORNANCE EVALUATION NAI;ITEflANCE PROCEDURES HEALTH PHYSICS PROCEDURES CHEi'lI STRY PROCEDURES ENERGENCY PLAN If'1PLEf'EiNTING PROCEDURES SECURITY PLAN INPLEl'iENTIiNG PROCEDURES 65 70 9 192 14 19 135 48 27 251 115 337 96 35 TOTAL APPROXIMATELY

~1A00 FIGURE 7.

0 Oj WNP-2 PLANT OPERATIONS STAFFING Vi 3I n ten ance , inciudes: Supervision Electricians l8 C Technicians Mechanics.Technical incIudes: Supervision Ptaf1t Engineering ineering Reactor Eng HP/Chemistry includes: Supervision Technicians Administration Training Plant Management Operations includes: Supervision Shift Managers CR Supervisors, Shift Support Supervisors Reactor Operators Equipment Operators Manning at Vf NP-2 Fuel Load 3 7'i 3 6 6 6 t2 38 2S 3 is 230 FIGURE 8 j C4 INDUSTAIAI EXPERIENCE REVlEMf PLANT MANAGER ACTIOII 5 COMMITMENT'RACKING SYSTEM ACTION AECOMMEtIDATIONS CNSAQ SAFETY ENGINEEAING GROUP HP/CHEM ENGA.OTHER OPERATIONS MAIN)EttAtICE TECHNICAL SIGtllFICANT EVENTS NSAC/INPO OPERATING EXPERIENCE REVIEW GROUP LICENSEE EVENT REPORTS INSPECTIOtl AEPOATS I8 E BULLETINS, CIACULARS 8c NOTICES lO CFA 60.66(o)AEPOATS NPAOS IIOEA)GAOS NSIC VENDOR/tlSSS BULLETINS FIGURE 9 CO ATTACHMENT 1 MNP-2 PROJECT qUALITY VERIFICATION PROGRAM JUNE, 1981 REV.1, OECENBER 1981 MASHINGTON PUBLIC PO!HER SUPPLY SYSTEM Page 1 of 29 MANAGEMENT STAT&fENT QUALITY VERIFICATIDN PROGRAM The Special Projects Department (formerly Systems Turnover Group)has consoli--dated the activities resulting from Supply System commitments in letter G02-80-153, dated July 17, 1980.Most of these activities have been accom-plished prior to restart of the construction contractors, with the exception of verification of documentation and hardware-completed before July 1980.The plans for this work, the Quality Verification Program, are now ready and the activities are scheduled to begin.The guidelines in the RCSW manual, Volumes I and II, governed the work of the Restart P ogram and other activities.

Volume III has been created'to provide instructions for implementing the Quality Verification Program, and is being issued at this time.Volume I, containing internal administrative information for the Special Projects Department, is being revised to accommodate the program.(0 The Manager Construction Department, is hereby delegated the authority to develop, approve, and publish instructions to meet his goals and objectives in='his program.Concurrence must be obtained from all affected project organi-zations, including Project QA on quality related instructions, prior to publi-~cation.All project personnel are directed to implement this program by ensuring that Quality Verification Program objectives and activities are in-tegrated with the remaining work of the WNP-2 Project.Individual respon-siveness and personal commitments are necessary for the successful completion t of this program and this plant.Revision 1 December 4 1981 The first two paragraphs

'of this statement aze historically correct.The third pa~raph is revised to reflect the organizational changes acccmplished since the original document was published.

.G.Matlock Program Director, WNP-2 Ce Page 2 of 29 WP-2 PROSPECT-QJALITY VERIFICATION PROGRAM TABLE OF CQN~TS 1.0 INTRQGUCTION 1.1 S stems Completion

1.2 Preaurchase

and Inactive Site Contracts 1 2.0 ORC4NIZATIQN

2.1 Functions

2.2 Functional Resaonsibiiities

3.0 SYSTEMS

CCMPLETIQN REVIEWS 3.=1 Qocum nt Reviews 3.2~chare Reinsaection 4.0 HERJRC."iASE ANQ INACTIVE SITE CONTRACTS 4.1 Cccunent Reviews 4.2 Selection af Fardware for Reinsaectian 4.3~are Reinsaection

5.0 SPECIAL

TASKS 5.1 Ceficienc 5.1.1 5.1.2 5.1.3 Cocumentation Identification of Qocumentation Selection of Qacvnents for Review Oacunent Verification

5.2 Persarmel

t'ualificatians

5.3 Receivin

Insaectian

5.3.1 5o3a2

Stared Material Installed Material Fage 3 of 29

'NP-2 PROWCT-QUALITY VERIFICATION PROGRAM TABLE OF CONTENTS 6.0 S~LE (continued)

7.0 REPORTING

Figure 2-1 Figure 2-2 Figure 2-3 Figure 2-4 F'gur 5-1 Fig ur 6-1 LIST OF FIGLRES Quality Ver'ication Program Quality Verification Program Flow Diagram Quality Verification Program Organization Quality Class I Systems Completion Plan Flow Diagram Flow Diagram, Deficiency Oocunentation Review Quality Verification Program Schedule Attachment No.1 Attachment No.2A ATTAGAL ENTS QC-I Prepurchased/Closed contract Review Checklist Oocunent Eligibility Checklist (Sample)Attachment No.2B Document Review Checklist (Sample)Attachment No.5 Quality Class I Systems Completion Plan Page 4 of 29 WNP-2 PRO"ECT.QJALITY VERIFICATION PROGRAM Tee, 1981 l.0~~GCUCTION The Supply System has re>>examined its original response to the NRC'sÃ.54(f)letter af Xae 17, 1980, to determine the effect of recent chug<at the WNP-2 Project, such e, the transition fzcm bulk ccnstruc-tion to systems-ccmpletian construction and the engagement of Bechtel Power Corporation ta be the systen-ccmpletian contractor and construction manager.Alsa, as the Restart Program nears canpletion and results of'eviews and actions arising fram information acquired in that program became available, a reassessment of plans f'r verifying the quality af past work has been accomplished.

While the original objectives and poli-cies stated in the Supply System's response remain unchanged, the plan-ning of verif'icatian activities has evolved.This program description outlines the resulting plan for verif'ying that the quality of work al-ready in pLace at the WNP-2 Plant is acceptable.

Ta acccmplish the work of"His Program, procedures or instructions wiLL be prepared and impleInented by the WNP-2 Project.In the execution af the work, other lnspecticns and evaluations will be appropriately con-sider+1 for guidance w areas zequf,ring att nt'on, or f'r satisfying the program abjectives.

The scape of this program Caes not include the work of contractors and suppliers whose quality,assuzance programs have been reviewed by the NRC.The Supply System has identified three major activ'ties to be covered in its gua3~ty Yerificatian Program: 1.1 Systems Camoletian The'WNP-2 Plant has been scaped inta approximately LOO startup systems/facilities far the purpose of ccnCucting an orderly turnover of systems ta the Test and Staztup Oepaztment.

These systems have been priozi~~zed for turnover to Startup to support the Project schedule L.The primary goal of the systems ccmpletion effort is to ccmplete canstructian by startup system.Verification revie~of documenta-tion and reinspection of safety-related hardware within these sys-tms have been integrated with the Systens Ccmpleticn Program.'ine these investigations and the resolution of any discrepancies f'ound are a part of the construction ccmpleticn, this work, includ-ing verificatian, has been assigned to Bechtel in its role as systems-ccmpletion cantzactar and canstructian manager.However, the Supply System retains the ultimate review, approval, and dis-position responsibility.

1)As of M.y 1, 1981, three Startup Systems have been tumed aver to Test and Startup and the Supply Systen will be responsible for verification of these syst ms.All other systems and facilities will be turned over to the Supply System by BechteL in accordance with the.System Completion Program.Page 5 of 29

1.2 Preaurchase

and Inactive Site Contracts<Oacumentatian f'r safety-related hardware will be reviewed and an evaluation made of the need to perform sample hardware reinspection on a contract by contract basis.Verification on these contracts does not lend itself to systems-orientation, but, will be coordinated to make information available in support of the systems completion schedule.This work will be performed by the Supply System, with same reinspection activities assigned to Bechtel.The Supply System will review and report the results.1.3 Saecial Tasks Three special areas have been identi ied f'r verificatian which Co not lend themselves to systems-orientation and do not involve acti-vities in Sec.ion 1.2.These include: o Evaluation of personnel qualifications, which will be accom-plished by the Supply System, but will include revi ws by Eechtel.o Ceficiency document rev'ew, which will be performod by the Supply System.o Receiving inspection, which w" 1 b perfa~d by Eechte', and reviewed and approved by the Supply Systen.These tasks wil'e caa~nated with the systems campletian effort., 2.0 ORGANIZATION

2.1 Functions

The activities to be acccmplished in this program are more fully described in Sections 3 thxough 5 below.The activities are out-lined in Figures 2-1, and a QuaLity Verification Program Flow Oia-gram is shown in Figure 2-2.2.2 Functional Responsibility An organization chart is shown in Figure 2-3.The chart delineates overall functional responsibility for basic activities in the Qual-ity Ver'f'icat'on P."agmn.An exanqle of specially-assigned tasks f'r Bechtel's area of'erformance may include such docunentation reviews and/or hardware reinspections that would normally be accom-plished in an inactive cantract or pre-purchase contract review, but, are required at a specific time to support systems completion.

3.0 SYSTEMS

COMPLETION REVIEWS Safety-r&ated items within a startup system are identified on equipment'ists prepared for systems campletian.

Scoping drawings are used to establish the boundaries of'ach systen, and after transfer of'sys-tem, a walkdown is perf'ormed.

This process is described in the Page 6 of 29 OUALll Y VEAIF ICATION P I'IOG 0AM SYSTEMS COMPLETION JOE.PUACIIASED AND INACTIVE=SPECIAL TASKS a OA AECoADS AEVIEW IIAADWAAE AEINSPECTION QA fIECOADS fIEVIEW IIAADWABE.AEIIISPL'CTION DEFICIENCY e DOCUMENT AEVIEW PEASONNEL QUA LIP ICATIONS~AECEIVINCs

'NSPECTION Fiyira 2-1 QUALI7Y VEIIIFICATION PROGRAM FLOW DIAGRAM Ctl flltl CIA VIIICH aocla40 I~ITCHY'i)Calla l I I 4 IAIWAC'IOAV NAAOAAAI~IH&ICIION IAINIACIOIT UNEAIWACIWT NI Ca I I I I~lllavl DIIKNOCT~A 4 A I IN AC Iaaf II CCHlllalC IVVI N II~I CIAO I Aaa onaa~AOCCAttl~Vll tlai~IVAAC.044I 4 CAIWACIOOT 1 IANAIWAC~IOAV tlavvvai 0 ltl 4 ICA I TON alvaa CA I 4l ACIOA T 4 lAINIACIOAV

~ICNC'I AIAC~IN INN OCT alvavl~44A I W AC IW I~AltAAI Ica oa cAA ll Qi I HAC at Ioa I NICIHHO NatlctWA CAIWACIOAV CHB taltvatt4II Aaa vttc I Hl aocaalaI~alvaa 4 IAINI ACIOAT (A wIAIW AC INC T I Vl IICI I I al VVAI CIFH IAatl I IIIICII~tat I tlI I III~Il VlaltFAICAI Aaalvtl Qlt Qll~I Oll II HOAI Nt AC Ioav l~VAlOAVI Il ll Dl I FNIFV A Figuro 2-2.'

QUALITY VERIFICAT-ION PROGRAt1 ORGANIZATION PROGRAN DIRECTOR PHAGE R QUALITY ASSURAHCE ftAtNGER CottSTRUCTIOH HAttAGER EHGI tt EERI tfG DEPUTY PROGRAM DIRECTOR STARTUP 5 OPERATIONS QUALITY VERI F I CAT ION PROGRAH SPECIAL TASKS 8 lttSPECTIOHS OECIITEL COHSTR.tSttAGEHEHT SYSTEttS COttPLETIOH PROGRAN CottTROL 8 REPORTIttG DOCUHEttTATI ott: PRE-PURCtIASE AHD ItNCTIVE SITE CottTRACTS AUDIT AHD SURVEILLAHCE DESIGtt CONTROL EHCil HEERI ttG SUPPORT.ORIG l tNTOR DOCUl I E ttTATI OH AHD I ttSTALLATIOH ACTIVE SITE COttTRACTS:

HATER IAL IHSPE CTlott I ttSTALLAT lott VERI F I CATION SYSTEt ts CNIPLETIott Ass I GtIED TASKS SCOPIHG SYSTEH TESTS ACCEPTAHCE DATE Jl Ql APPROVED.~.~g DATE Quality Class I Systems Completian Plan (Attachment No.3), and flow dia-gram for the verif'cat'on process, Figure 2-4.3.1 Dacron nt Reviews" Documentation associated with each safety-r lated system/facility will be reviewed under this program.These r views will establish that the records meet specification, code, standard, and QA program requirements.

Deficiencies will be processed in accordance with Project-appraved procedures.

3.2 Hardware

Reinspection A sample of hardware and work activities will be selected for rein-spectian, such that the adequacy of the work end its associated re-cozds aze verif'ied.

The selection criteria for reinspection of'ork activities will be docun nted as.discussed in the Systans Completion Plan.The results f om the Restart and other.spec'al prog ams will b considered in establishing these criteria.4.0 FREPURCHAS" AND INACTIVE SITE CONTRACTS Most of the dacunentatian associated with prepurchase and inactive con-struction contracts has be n reviewed by the Supply System.Deficiencies identified in the review are being resolved.The Supply Sys em will con-tinue the document review zespcnsibA~ity for these cont:acts.

4,1 Document Rev'ws Donmntation Rev'ews associated with each saf'ety-related item will establish whether or not the records meet specificat'on, cade, and Supply System's QA program requirements.

Deficienc'es

'dentified in the review wii'e resolved in accordanc-with project procedures.

4.2 Selection

of Fardware for Reinspection The f'ollowing evaluation will be made an prepurchase and inactive site contracts ta determine the need for sample hardware reinspec-tion: o Were pr vious inspections or evaluations made by the Supply System/AE which would satisfy the objectives af'he Cuality Verification Program2 o What is status of dacumentation and problems mcauntered2 a Is the supplier an ASME certificate holdez2 o Does contractor have an NRC-reviewed gA pzagmn2 Vendor his-tory on prepurchased equipment?

Attachment 1 shows a review checklist for assembling the above information.

Page 10 of 29 C4 I Ifcii Nof i>>liliiee I Utti it 4~oocii>>iillaiio>>

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~ill Ve'liccceeaoil 6 IC>>coiNt SPNCS at'Noae Ios CONC IlUCIH>>i ii 0 ii toitaoc silloc~i>>ltICEICU tla>>l Soa INltccfioN

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QQ d ao1 ai~IiolteCEI40 ENVLLEOLE C~C lief LVI~C>>iils flf ION~tisltlcridN

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4.3 Pardwaze

Reinspection

-~If the results of the evaluation indicate a need for sample rein-spection, it will be performed by the Supply System or Bechtel.In general, the Supply System will perform reinspection of non-system related work, and Bechtel will perform inspections related to system completion.

Prepurchased equipment will also be checked for physical configuzation and obvious damage during system walkdown.Reinspections will be accomplished on a representative sample of-hardware, using an approved sanpling plan.If necessary, procedures will be consulted to guide the selection of inspection attribut s.If the results of the evaulation indicate that reinspection is not necessary, the basis for determining not to reinspect will be docunented.

5.0 SF CIAL TASKS Specific verification activities that are not compatible with the systems-oriented plan for completing construction will be acccmplished as separate tasks.These will be coordinated with Bechtel's activities so that equipment and its supporting documentation required within startup systems are available for~direly ac"eptance.

5.1 Cefic'encv

Oocum ntation Deficiency doc~ntation reviews will be accomplished to establish whether or not dispositions of non-ccnrormances, design changes, field change requests, and information r quests were made cor-rectly.These.revi,ews are not oriented to the systems approach.The review process described hereinafter is depic ed in Figure 5-1, Flow Diagran, Deficiency Docuaentation Review.Identification of Documentation-The following generic documents were identified as those which may need evaluation for correctness of disposition.

They are listed below with the specific documents that will be considered in the Quality Verification Program.o Non-Conformance Reports NCR, Non-Conformance Report{WPPSS/BhR).

~, inspection Report (Contracts 215, 218).ECAR, Engineering Corrective Action Report (Contract 213A).DR, Deficiency Report (Contract 216).Page 12 of 29 I' FLOW DIACiAAItJI.

DEFICIENCY DOCUMENTATION REVIEW NOT OCI OR~f LIUUIATE NOT OCU, Sf IS.I*REVIEW CANDIDATE APPLICASLE, 7 TAKE CUE OFT EON HEVIE W IDEN1IF V DOCULIE NTS DETEHUUIE CONTRACT, QUAL.CLASS IF VES,QETERLUNE SCOPE, AttLICASLE TO OVP OSIECTIVE S IF OCI OH OCU, SflLLUC I.QETE HUIUf IF DOCULIIN'r WAS Rf Vlf WED.IIV OTHE 4 tHOOllhll NOT APPLICAHLE, CAIIOIUAlf FON Nf VILW IF NO, QOCUIIENT IS CANDIDATE FOR REVIE W NOT USED FOR IO E URINE EHUIO QlftOSITION f LWUI ATE.NOT A REVIEW CANDIDATE.REVIEW SATISFACTORY REtORT Df I f HEINE IF~USED FOll EN Olllf f HUIO DUPO.Sf Lf CTED FOR IS Tf CUIIICAL ADEQUACY Hf VLE W INPUT TO tf NSONNE L QUALIFICATIONS REVIEW IF YES,SELECT NLVIEW SAlltlf 0 CP 4 a NOT lflfCTfD Nf VIEN WISATISFACTORV DETE IUNNE IS CAUSE,tREtARE NCR OR CAR, OICHEASE SAlll'Lf SISS Figllru 6-1 o Desion Chano s RCC, Request for Contract Change.CWR, Contract Waiver Request.ECN, Engineering Change Notice.PEO, Prospect Engineering Directive.

FRPEO, Field Resolution PEO.o Field Chanoe Reouests 5.1.2 RCC, Request for Contract Change.CWR, Contract'Waiver Request.ECN, Engineering Change Notice.FCR, Field Change Request (Contract 215).o Information Reouests RFI, Reouest for Information Selection of Documents for Review The use of the above documents will be revi wed to deter-mine the follcwing information, which wi>>ident'fy their eligibility for review in the Verification Program: o Qn what contracts were the docunents used'?o What was the purpose of the document'?

If used to obtain Engine ring disposition or dissemi-nate design resolution, document may'be selected for review.If not, it may be set aside.o When was docunent used':0 o Has document been included in review by another pro-grams If previously evaluated by another program, credit will be taken for that review, based on the following considerations:

Page 14 of 29 What was scope.of review'Determine that information obtained satisfies the obgective of the Verification Program.QO Who perf'ormed the review?Determine that the organization and/or personnel who perf'orned the review were appropriate for the review, and their revi w included criteria which would meet the verif'icat'cn abject'ves.

What is status of'he review?Determine the status and priority of the review f'r tmelinms with verificaticn chjec"'ves.

What az the results ai'he r view?Determine what corrective actions resulted frcm the review, and if'hey have been implemented.

What experience fram pr vicus review may be use-ful in verificaticn.

Attachment 2a shows a sample chart ta he used for assenbling the above information an all design-change documentation.

Tnis inf'ormaticn wiH~he evaluated to deternine further verificaticn by the Project.Similar matrix charts will be uti~~zed for Non-con-f'arnance Reports, Field Change Reques~, and Infarna-tian Requests.Document Ve ification Dccunents selected for review under this 9 ality Verifica-tian Program will he sarpled (1C randan sample)and r-viewed f'r carr ctness of'isposition.

The revie~wi3.1 be perf'ormed by personnel other than those who performed the.work associated with the dispositions described an the review dacunents.

Revie~criteria for the verif'ication prccess include: o Is an engineering dispasitian r quiz d to r solve the documented issue?o Is a design zesolutian described cn the dacunent?o Evidence af ccmpl'ance with appUcable ccdes, spec'-f'ications, standards, and SPR r quirements.

o In cases where ccmpliance is absent, adequate justi-fication f'r deviating.

o Evidenc that design change was performed by Engine zing personnel.

o Evidenc that the disposition was proper'y reviewed and approved.Page 19 of 29 Attachnent 2b shows a sample Oocument Review Check'ist to be used for recording the above information for all docu-ments reviewed.The results will be analyzed to determine if problems exist.Should this review result in discovery of significant problems in corzectness of disposition, a larger sample wiD be reviewed.A corrective action plan will be developed to resolve problems arising from the reviews...0~/One of the considerations in developing the corrective action plans is to evaluate whether problems arising out of previous dispositions could be related to personnel quaUfications.

If so, it may become necessary to in-itiate a review to verify personnel qualifications.

5.2 Personnel

Qualifications Personnel qualifications will be addressed in the Yerification P"o-gram by examinaticn of documents which identify complianc with spe-cific personnel requir ments, as a part of the scope of documenta-tion reviews discussed earlier in the plan.Also the sampling of work activities for reinspection unde the System Completion Plan will serve to illustrate whether or not sat'sfactory work was accomp" shed.by qual'fi d pe sonnel.Satisfactory re'nsp ction=e'-sults will provide a h'gh level of confidence that the part'cipants were qualified, including crafts n, Quality Control Inspectors, and NOE pe sonnel.Qualifications of enginee ing pe"sonnel will be conf" rmed by z view, of deficiency d'spositions d'scussed'in Section 5.1.*Review results will establish the actual performance of engineers and pzov:de con-fidence that the personnel responsible for engineering dispositions associated with the work were~alified.Contractor's engineering qualifications will be verified by similar methods, wherever contractors were charged with engineering respon-sibility.For example, where Inspection Reports noted discrepancies

, to be dispositioned by engineering personnel, these ar covered by Section 5.1;and in those very limited cases where design perfor-mance may not have been verified by Project Engineering activities, a program of review for evidence of contractor personnel qualifica-tions will be developed.

5.3 Receivin

Inspection Quality verification of past receiving inspections.

is divided be-tween material currently in storage, and material already.installed.

5.3.1.Stored Material Page 16 of'9 To gain a level-of confidence in the past receiving in-spection practices of the major active site contractors, Bechtel will direct repeat receiving inspections of ma-terial currently in storage and awaiting installation in System 58.The results of these inspections will be$1

5.3.1 Stored

Material (Cont'd.)5.3.2 analyzed to determine-if further reinspection of stored material is required prior to installation in other-systems.Also, results frcm reviews perforrad in the Restart Program will be ccnsiC zed in this determination.

installed Material 6.0 SCtKGULE Occurrent zev'ews and haz"ware rainspections

<<ill be uti1ized to determine the adequacy cf pr viously in-stalled material, as described in Section 3.0 of this Programs The Supply System intends to initiate the Quali.ty Verification Program by applying Systems Completion Plan to the first system to be transferred to Hecht 1 for ccmpletion, the Standby Service Water System (No.58).This affords the opportunity to evaluate details of both plans and to ad)ust them based cn experienc gained.Systems-ccmpletion reviews and r in-spections will begin cn System No.58, along with identificat'cn of sys-tem boundaries, configuzaticn verificaticn, etc., and continue cn a similar systems basis util constructicn has been zesuned on al'ystems.

Review of docunantation for precurchase contracts and inactive site cen-t adw is mde way and is being ac"cmpU.shed by Prospect Quality assur-ance as a part of their nozmaZ Occ~ntaticn Review Program.Reinspec-tions will be ccordinated with Bechtel's activiti s in systems ccmplet'cn.

Some of t e Cocuaentaticn views asscciat d with the spqcial tasks hav begun.Ccmpleticn of this work is expected to take up to several months, depending cn the actual embers of documents finally Cetezmined as review candidates frcm initial eligibility revie~s.The above activities are i'lustrated in the schedule shown in Figure 6-1, wnich is provided prior tc ccmaencement of the Prcgram for sccping dura-tions of the planned activities.

Ad)ustments to the schedul will be made after scme exper'ence has been acquired in the executicn cf the Pro-grGlll 7.0 RER3RTING Progress reporting of Quality Verification Program reviews will be in-cluded in the bi-monthly reports to the NRC, Region V.Oeficiencies identified, which meet the requirements of 10CFR 50.55(e)and/or Part 21, will be reported to the NRC in accordance with approved procedures.

Ott ers wiA~be sumarized in the bi-monthly r port.Page 17 of 29 ACTIVITIES 1981 1982'J J A S 0 N D J F H A H J J PROGRAH PLANNING SYSTEMS COMPLETION Adjust p'lans based on System 58 experience Information available from System 58 To construction completion PREPURCNASE 8 INACTIVE CONTRACT REVIEWS SPECIAL TASKS REPORTING (Oi-monthly)

~Task-completion reports V+V+qUALITY VERIFICATION PROGRAM SCHEDULE FIGURE 6-1 Cy Special reports will be prepared as appropriate at the conclusion of in-dividual tasks.Significant problems discovered during the Qua3;ity.Verificaticn Program will be evaluated and considered by the project management organization for appropriate action.Experience gained from this act'vity will be appropriately appUed to other Supply System projects.Page 19 of 29

-I PRE-PURCHASED/CLOSED CONTRACT REVl&Q=CKLHT:4 Reviewe s Date Contract No.Present Contract Status Description 1.Docunentation Status Percentage Results of Oocunentation Review 2.Determine Crit'ality/P=i ority Item'P 3.Determine Whethe" Othe" inspection or Evaluation Programs Satisfy Require-ments P 4.Determine Whether NRC Has Approved QA Program/NRC Vendor History 5.Determine Whether ASME Certificate Holder'.Make evaluation on above to determine feasability of further reinspection based on results of Ztems 1" thru 5 and make recommendation for Systems Turnover Management Approval.Approved by , Signature/Date ATTAQ+lENT NO.1 Page 20 of 29 (0

~,:DESIGN CHANGE OOQNENTS IIAS DOCUMENT BEEN REVINEO BY ANOTI.ER PROGRAM?DOC.TYPE CONTRACT PURPOSE WIIEN NIIAT CAUSED RE VIEW SCOPE OF-REVIBl ORGANIZATION STATUS PERFORMING

)OF RE VIEN RESULTS RCC I CWR e FRPEO Reviewer Date ATTACI INENT 2a SAMPLE DOCUHENT ELIGIBILITY CHECKLIST Approved Date QJALITY DEIFICATION PROGRAM OEF ICIENCY DOCUMENT REVIEW FORM WNP-2 PROSPECT Oocument Identification:

Is The Technical Disposition Acceptable'?

.Yes I Nol I Comments e Further Evaluations Reaui~Engineering Reviewer Special Projects Department Date Sheet 1 of ATTACHMENT NO.Z Page 22 of 29 (0 ATTAQ+IENT 3 TO QUALITYVERIFICATiON PROGRAM iiNP-2 QUALITY CLASS I SYST&6~PL TION PLAN 1.0~e 18, 1981.2.0 This plan describes the method to be used for completion of'uality Class I systems.Concurrent with the perfozmanc of new work to eff'ect systens ccmpleticn, the plan includes provisions fcr the resolution and cor e:-tion of past discrepencies in both hardware and dccunentaticn as well as verification of a selected sample of previously mnpleted and accepted safety-related work and acccmpanying dccuaentation.

This plan is de-signed to be responsive to NRC conc ms relative to verification of'ast work as set.f'orth in their 1OCFR90.94(f), Request Regarding Quality Assurance, dated Gwine 17, 1980.SCOPE/APPLICAB ILITY This plan w"1 be utDIzed by Bechtel and ether site c"ntzactors wozking under Becht 1 Ccnstructicn Management in ccmpl ting Quality Class I systems.Bechtel will ver'fy, using their total QA/QC prcgzam and this plan, those port'ons of th systems to be ccmpleted by B ht~diz ct'y.Portions of'he syst ms that are ccmpleted by other cont=ac'zs wczk'ng und r Becht'cnstruct'on Management will be verified by the other ccntractozs using the'" Supply-System-approved total QA/QC p cgzams and tnis clan.These other contractors will be under surveillance inspecticn by hechtel QC, auditing by Bechtel QA, and management by Bechtel Ccnstructicn.

The ef'f'orts of'oth Bechte3.and the other contractors involved In systems completion and verification will be conducted under the Supply Syst m's overa>>administration and direction.

Verificat'on activities described in this plan are fully applicable to Quality Class I Itans.Itens designated as Quality Class II, Seismic Class I are also Included in the verii'ication program, howeve, only those attributes important to structural.

integrity under seismic loading ar considered.

3.0 PREREQUISITIES

There are a number of'rerequisite activities which must be performed prior to begiming the verif'ication proc ss f'r system ccmpletion.

These prerequisites aze: A.Requirements f'ox the miniaam dccumntation ne ded to att st to the quality of past work perf'armed by the contractoxs and their sup-pliers and subcontractors shall be established.

The project contract specifications and other design docunents refe enced ATTAG+IENT 3 Page 23 or 29 B.C.in those specifications shall be used to determ'ne the min~qual-ity verification docvaentation requirements.

With this information, checklists shall be prepared and used as the basis for performing the'revi ws necessary to complete the document verification part of this plan.Design configuration control for each system to be complet d by>is plan shall be established.

The Architect/Engine r will provide the approved design configuration for each system to be completed by this plan.The design docunents (specifications, drawings)appli-cable to each system will be identified along with all outstanding technical changes such as~s, RFIs or CWRs which have not be n incorporated in the drawings and specifications.

A design change control system which assures that future changes are communicated to Bechtel in a timely manner will be maintained by the Architect/

Engineer throughout the systems ccmpletion process.The cognizant Quality Assurance organization w~~l identify, list and index by start-up system classification, all outstanding NRC, WPPSS/B&R and contractor discrepancy reports (NCRs, CARs, QAFs, IRs, etc.).iO O.The contractor quality verification documentation, including sup-pli r documentation for contractor purchased items, which has be n previously prepared and is stored in the contractor's vaults will be organizM, filed and indexed in a manner wh'ch will allow retr'eva-bil'ty for review to support the verification process by star-up system.It is not intended that this task include engine ring docmentation or such items as environmental qualifications, seismic qualifica-tion, performance its, etc.WFPSS/BE&engine ring will retain sole responsibility for obtaining and approving these kinds of documents.

4.0 SYSTEM

COMPLETIQN.

ANO VERIFICATION PRO~~System completion and verification will be accomplished simultaneously in the following steps.The numbers in parentheses correspond to those shown on the attached"QuaU.ty Class I Systems Ccmpletion Flow Diagram for WNP-2", Revision 1 (4-2-81).4.3.Each system will be walked down in accordance with an appropriate procedure to determine its present status of installation.

The approved design documents that establish current design configura-tion of the system will be used for reference.

The approved d sign documents will be those established in Prerequis't B, above.The walkdown will be a configuration and status check and not a detailed item by item inspection.

Missing as well as added items not shown in the design will be noted.Page 24 of 29 (0 The walkdawn will be perf'armed by Field Engineering with pazticipa-tian by Construction Quality Control.Results f cm this initiaL walkdawn wi>>be classified as follows:a.'It m installed in proper location and to correct configuration

(~)b;It m inst~~ed but damaged ar installed to the"'wrong location or configuration (4)c.Item,nct installed (2)Review Qacuaentaticn and Outstanding Oiscreaan Reaorts (5)Contractor instaLLation quality verif'icatian documentation and sup-plier dccumntatian for cantractoz puzchased itens will be reviewed by Construction Quality Control using the checklists developed in Prerequisite A, above.The docunentaticn is x vi wed to determine ccmplet ness and traceability but nat technicaL ccnhnt.Qutstanding d'screpancy r parts ar r vi wed by Canstzucticn Quality cantzoL and carrellated with the results of the docunentation re-view.Upcn canpletion of-the walkdown and this eview, the documen-tation and physicaL status of the system~iLL be known.Furca er processing ta effect systens ccmpleticn and vezif'ication

~iLL be cone as follows.Item Not Installed (2)Ccnstx'uction Quality Control prepar s an inspection plan and r cord (QCX/P)to cover inspection.of the cans ructicn act'vities"equized ta install the missing items.Before installing any missing it ms, cansideraticn is given to the accessibility fax zeinspecticn of'ther ccmpleted work in the sys~.Installation of missing itens may be worked an by Canstructicn at any time provided the nec ssary canstnNion procedure and QCI/IRs have been prepar d and Ccnstruc-tion Quality Ccntzol perf'ozms receiving, in-process and final in-'spection of'he items as def'ined in the QCI/IRs.If'he dccunentaticn r view identifies existing installaticn docu-mentation f'r items now f'cund to be not installed, such Cccumenta-ticn shall be voided foLLowing approved quality assuranc pra-cedures.Cocumntatian of the new work is x ferenc d ta the pr vious dacunentation that has be n voided.When materiaL required to ccmpLete the installation of'issing items is obtained by Bechtel fx'cm the Supply System or other sit can-tractors, Canstructicn Quality Control wi'1 perform xec iv'ng'n-specticn of such material prior to releasing it f'r use.Rec iving inspection includes review of'upplier documentation for ccmpLete>>ness, traceability and technical content.Page 25 of 29 4.4 Item Installed ta Correct Confiouratian/Sucolier Documentation Does Not Exist or Is Unacceotaole 6a)Gb.Construction Quality Control caordinat s with the Supply Syst m and other site cantractars, as applicable, to obtain supplier documenta-tion or to obtain corrections to supplier documentation when appro-priate justification exists.If acceptable documentation is ob-tained, the item is entered on a list of items that w~be subject to verification reinspection.

If acceptable dacvnentation cannot be obtained, a recommended dis-position is formulated and a NCR is prepare.The NH is submitt d to WFPSS/B&R far approval fo the disposition for repair" or"use-as-is" dispositions.

Item Installed to Correct Canficu:ation/Installat'on Ooca~entation Oaes Not Exist 6b)If the item is accessible, Canstruction Qual'ty Control issues a QCI/IR and reinspects the item.The canpleted QCI/IR is added to the record files as docunentation of the acceptability of the installation.

4.6 If the item is inaccessible for inspection, a reconmended disposi-tion is formulated and a NH is submitted ta WFPSS/BH fo" approval of the dispos'tion far n epairn or"use as is disposition Installed to Car"ect CanÃauraticn/Installat'on Docv~entation

's unacceptable Ba)4.7 Canstmction Qual'ty Cantral coordinates with the contractor who p rformed the instal'at'cn ta obtain carmctions to documentation when appropriate justification exists.If corrected docmentatian

's obtained, the item is entered on a list of items that will be sub-ject to verification reinspection.

If'cceptable documentation cannot be obtained, Construction Quality Control issues a QCI/IR and reinspects the item.The completed QCI/IR is added to the record files as documentation of.the accept-ability of the installation.

If the item is inac"essible for inspection, a reccmmended disposi-tion is formulated and an NCR is prepared.The NCR is submitted to.NPPSS/BhR for approval of the disposition for"repair" or"use-w-m" d'spcsi'on.Item Installed but to an Incorrect Configuration Damaoed or Has Other Obvious Discrepancies 4 27 Items in this category include those found on-the system wa3.kdown; those having outstanding discrepancy reports aga1nst them as identi-fied in Prerequisite C;and those found to be discrepant upon veri-fication reinspect1on of a selected sample of previously accepted~.work+Page 26 of 29 gO Approved dispositians are abt~~ed f'r itans with previously pre-pared, outstanding discrepancy reparts, (P oject NCRs, 1Rs, etc.).Qnce obtained, th approved cUspasitiara are wazked af'f.Construc-tion Quality Control performs inspection and dacunents repair, re-wo~ar zepLacement actions.Items.fcund to be discrepant frcm the system rialkdawn ox upcn verif'icaticn reinspection af pzeviausly accepted work are treated as'allows: a.If'he'tem was-finally accepted to the current'cfesign xequize-ments or if'he item was not f'inally accepted and cars;ot be caxxected by"rework" or"replacement", an NM is prepaxed with a reccnlnended cKspositicn.

The NCRs are submitted to NFPSS/BhR f'r approval of'repair" and"use>>as-is" cfispasitions.

b.If'he iten was not f'inally acc pted ta the current design re-quirements and is correctable by simple"rework" or"reolac-ment", Canstructian Quality Control prepares an inspection plan and record (QCI/D)to cover inspection or the construction activities required to correct the itm.Correction af dis-crepant items by"rework" ar"reolac ment" may be performed by Canstructicn at any twe provided t e nec ssary construction prccMures and QCI/LRs have be n pr oar d and Ccnstructian pra-c cures and'CI/iRs have be n pr=ar~and Ccnstxucticn Quality Ccnt=al performs r c'ing, in-o-ccess wd inal inspection of.the itans as defm>>ed'n the QCZ/=~s.4.8 Item Installed ta Correct Canficu ation/Dac mentation ls Acceptable (7)A sample of the hardware and acccmpanying Cacuaentatian f'r items in this cat gory wiLL be selected f'r re'nspect'an ancf review to ve ify their acceptability.

The sample siz and selection wi'L be made by Pie d Engine ring subject to rev'ew and approval by Quality Assur-anc.The rubber of items sampl d shall nat be's than 1G of the total nunber of items in this cat gory.The items selected f'r hardware reinspection and dccumentaticn re-view shall be those which past experienc dictates to be the anes most likely to ccntain discrepancies.

Crit ria to be used f'r smile selecticn are: ae b.Information provided by the Supply System frcm the results of their reviews of'he contractar's procedures and perscnnel q.elificatians ta ef ect restazt.Items~hich required the applicaticn of'pecial processes, speciaL equipment or complex procedures to prcduce an accept-able installation, e.g.pipe welding, heat treating, non-destructive examination; soils ccmpaction; grcuting and dry packing;cable rcuMg and separaticn; electricaL terminatians; application and testing or special coat'ngs;installation of conc ete expansion anchars;mechanical equipment alignment, etc.Page 27 of 29 c.Information cbtained fran he earli r sys em walkdowns and do-cumentation reviews which call into question the performanc of individual inspectors.

d.Critical'tems for which significant discrepancies will not be readily revealed by construction testing or pre-operational and start-up testing.e.NRC Bulletins (-The actual hardware reinspections and docuaentation reviews to ccm-plete the verification sample will be done by Construction Quality Ccntrol using inspection plans and document eview procedures (QCI/Ds).Nonconfo~i'ng itens revealed by these reinspections and r-views will be document d cn Nonconformance Reports.These NCRs will be summarizmf by Quality Assurance cn a semi monthly basis to support the Supply Syst m's reporting ccnmitments to the NRC.Results fran the hardware reinspections and docunentation reviews to satisfy the initial verification sample shall be reported by Con-struction Quality Control, evaluated by Field Engineering and re-vi wed and approve by Quality Assurance.

As a part of the'" evaluaticn, Field Engineering shall dete mine the need, if any, for further samp3'ng and selection of items for hardware re'nspect'on and dccumentat cn rev'ew.T¹need for further samp"ng and se'ec-tion, which may co as high as 1COX, w~be based upon the nature and nunber of discrepancies disclosed by the init'al and subsequent verification sample.Substant've disc." pane'es in suffic'ent num-bers to reveal a t end will req~>>additional sampling and selec-tion.Page 28 of 29 0'o~ogpg+55 o~o~0 e~I I'oOC'I~~~~~

0~

C!~'aten'/82 1 I=Instrmentation E=Electrical BAL=Balance System Number INTEGRATEO PROJECT SCHEOULE, REV.1 PROVISIONAL ACCEPTANCE ANO TURNOVER OATES Ti tie Abbrev.P/A Oate ATTAC MENT I Page 1 of ll T/0 Oate 1.1 Reactor Pressure Vessel System 1.2 Nuclear Boiler Instrumentation

3.0 Reactor

Recirculation System 4.1 Reactor Water.Cleanup P ip ing 4.2 Reactor Water Cleanup Filter/Oemineralizer

5.0 Remote

Shutdown System 1 Control 6.0 Reactor Core Isolation Cooling 7.1 High Pressure Core Spray-Mechanical 7.2-1 High Pressure Core Spray-Electrical (Package 1)7.2-2 High Pressure Core Spray-Electrical (Package 2)8.0 Low Pressure Core Spray System RPV NBI RRC RWCUP RWCUFD RSO RCIC'PCS-.H HPCS-E(1)HPCS-E(2)LPCS 7/26/82 P3)8/9/82 P4)2/14/83 P2I 5/31/82 I,E 6/21/82 I,E 6/21/82 BAL 8/16/82 P4 P4 I 6/7/82 E 6/28/82 BAL 8/30/82 P2)I 6/7/82 P2)E 6/28/82 P2)BAL 8/30/82 P/A'd E,'8/2/82 BAL 8/23/82 I 7/5/82 E 7/26/82 BAL 8/4/82 P/A'd (P3)8/2/82 P/A'd 3/1/83 3/14/83 I 1/31/83 2/21/83 2/21/83 2/28/83 3/28/83 9/6/82 2/28/83 1/17/83 8/30/82 014.1 Date: 4/20/82 I Instrumentation E~Electrical BAL Balance INTEGRATED PROJECT SCHEDULE, REV.l PROVISIONAL ACCEPTANCE ANO TURNOVER DATES I ATTACHMENT 1 Page 2 of 11 System Number 9.0 Residual Heat Removal System Ti tie RHR Abbrev.P/A Date P4)I 6/21/82 P4)E 6/28/82 P4)BAL 7/19/82 P5)I 6/21/82 P5)E 6/20/82 (P5)BAL 0/16/82 P6)I 6/21/02 P6)E 6/20/82 (P6)BAL 0/16/82 T/0 Date 1/31/83 I I I I 10.0 11.0 13.1 13.2 (14.0 15.0 16.1 16.2 16.3 17..0 18.1 Standby Liquid Control System Closed Cooling Water System Control Rod Drive-Hydraulic Control Control Rod Drive-Manual Control Process Computer Reactor Protection System Source Range Monitoring Intermediate Range Monitoring Average Power Range Honitoring Traversing Incore Probe System Rod Worth Hjnjmjzer SLC RCC CRD-H CRD-MC RPS SRH lRH APRM TIP (P2)7/19/82 E,I 7/5/02 BAL 8/30/02 P/A'd 5/10/82 P/A'd 10/4/82 I/10I83 1/10/83 1I10/83 3/14/83 P/A'd 9/27/02 4/25/03 4/11/03 2/14/03 TIO'd 2/21/03 6/20/83 6/20/03 4/25/03 6/27/83 T/0'd 014.2 Oak</20/82 I Instrunentation E Electrical BAL~Balance lNTEGRATED PRO 1ECT SCHEDULE, REV.l PROVlSlONAL ACCEPTANCE AND TURNOVER DATES ATTACHHENT l Page 3 of 11 System Number Title Abbrev.P/A Date T/0 Date 18.2 Rod Sequence Control System 19.0 Leak Detection'0.1 Fuel Handling and Vessel Service Equipment 20.2 22.0 CRO install ation Equipment Primary Containment Atmospheric Control System 33.0 34.0 Chemical Waste Processing System Solid Waste Processing System 35.0 Radi oac t i ve Drains and Sump s 23.0 Primary Containment Cooling System 24.0 Primary Containment 1nstrument Air 25.0 Primary Containment Atmospheric Honitoring System 31.1 Floor Drain Processing 31.2 Equipment Drain Processing RSCM FH 4 VSE CRO-1E CAC CRA CIA CHS FOR CMR RDS P/A'd 4/25/83 10/4/82 9/13/82 3/14/83 8/30/82 3/21/83 3/7/83 12/6/82 2/7/83 2/14/83 3/7/83 l,E 10/18/82 BAL 3/7/83 T/0 d 6/13/83 12/13/82 10/4/82 4/18/83 1/3/83 5/2/83 5/2/83 6/6/83 6/6/83 6/13/83 6/27/83 6/6/83 I 36.0 Process Radiation Honitoring System PRH (CONT RH)11/1/82 5/30/83 BAL 3/21/83 014.3 Oat-j: 4/20/82 I Instronentation E.Electrical BAL Balance INTEGRATED PROJECT SCIIEOULE, REV.I PROV ISIOtIAL ACCEPTANCE AIID TURNOVER DATES ATTACIIMENT 1 Page 4 of ll System Nosher Title Abbrev.P/A Date T/0 Date 37'.1 37.2 Area Radiation Monitors Environs Honitors (CONT RH}11/1/82 4/11/03 BAL 3/7/03 (CONT RH)11/1/82 4/11/03 BAL 3/7/03 38,.0 39.0 40.1 40.2 45.0 46:1-1 46.1-2 46.2-1 46.2-2 46.3 46.4-1 Fuel Pool Cooling and Cleanup System Standby Gas Treatment System Off Gas Processing Off Gas Refrigeration Supervisory Control System 500/25XV Distribution (Package 1)500/25KV Distribution (Package 2)230/115KV Distribution (Package 1)230/115KV Distribution (Package 2)6.9K Distribution 4;16KV Distribution (Package 1)FPC SGT OG-P OG-R 500/25KV (1)500/25KV (2)230/115KV (1)230/115KV (2)6.9KV 4.16XV (1)(P3)E, I 0/16/82 (P3)BAL 9/6/02 2/21/83 1/24/83 1/24/83 P/A'd 5/31/82 5/31/82 P/A'd P/Ald P/A'd P/A'd 1/10/03 4/4/03 3/21/83 3/21/0)T/0'd 6/20/02 6/20/02 7/18/83 7/18/83 7/10/03 7/18/03 014.4 Oaf (20/02 I Instrumentation E Electrical BAL Balance t INTEGRnTED PROJECT SCNEDULE, REV.l PROVISIONAL ACCEPTANCE ANO TURNOVER DATES AT~RENT l Page 5 of 11 System Number 46.4-2 46.4-3 46.5-1 46.5-2 46.5-3 46.5-4 46.5-5 46.5-6 46.5-7 46.6 46.7 46.8 47.1 47.2 Ti tie 4.16KV Distribution (Package 2)4.16KV Distribution (Package 3)480Y Distribution (Package 1)480V Distribution (Package 2)4&OV Distribution (Package 3)4&OY Distribution (Package 4)4&OV Distribution (Package 5)400V Distribution (Package 6)480V Distribution (Package 7)Low Voltage Distribution Instrunent Power Emergency Lighting Standby Diesel Generator Diesel Oil Storage and Transfer Abbrev.4.16KY (2)4.16KV (3)400V (1)4&OV (2)4&OV (3)40OV (4)480V (5)4OOV (6)4&OV (7)LY IP EL OG P/A Date P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/n d As required As required P/A'd As required BAL 7/5/02 BAL 7/5/02 T/0 Date 7/18/83 7/18/83 7/18/83 7/18/83 7/18/83 7/10/83 7/18/03 7/10/83 7/10/83 3/21/03 T/0'd 4/25/03 10/25/82 10/25/82 014.5 Date: 4/20/82 ATTACINENT l I.Instroaentation E Electr i ca 1 BAL Balance INTEGRATED PROJECT SCHEDULE, REV.1 PRQVISIONAL ACCEPTANCE AND TURNOVER DATES Page 6.of 11 I System Number Title Abbrev.P/A Date T/0 Date 50;1-1 50.1-2 250V OC Distribution (Package 1)250V DC Distribution (Package 2)50.2-1 125V Distribution (Package 1)30.2-2 l 50'.2-3 125V Distribution (Package 2)125V Distribution (Package.3) 48.1 Turbine and Accessories 48.2 OEH'Control 48.3 Turbine Lube Oil 48.4 Turbine Supervisory Instrumentation 49.0 Annuciator System DEH LO TSI P/A'd P4)5/17/82 P5)5/17/82 P/A'd P/A'd P/A'd 250VDC (l)P/A'd 250VOC (2)P/A'd 125VDC (1)P/A'd 125VDC (2)P/A'd 125VDC (3)P/A'd 10/4/82 7/12/82 7/12/82 7/12/82 10/18/82 5/2/83 5/2/83 1/3/83 5/2/83 4/18/83 50:.3 24V Distr ibution 51.1 Excitation and Voltage Regulation 51.2 Generator Hydrogen Cooling 51.3 Generator Hydrogen Seal Oil 24VDC E/R HC SO P/A'd 7/12/82 7/12/82 P/A'd 5/2/83 7/19/82 7/19/82 7/19/82 014.6 Date: '0/82 I Instrmentation E Electrical BAL Balance INTEGRATED PROJECT SCHEDULE, REV.1 PROVISIONAL ACCEPTANCE AND TURNOVER DATES ATTAin ENT l Page 7 of 11 System Number 51.4 51.5 51.6 56.1 56.2 57.0 58.0 Title Generator Hydrogen Storage and Supply Generator Stator Cooling Isolated Phase Bus Duct Cooling Tower Hakeup System Condenser Cooling Cooling Tower Plant Service Mater Standby Service Mater H2 STC BOC CT TSM Abbrev.P/A Date P/A'd P/A'd 5/31/82 P/A'd P/A'd P/A'd P/A'd P5)I,BAL 6/21/82 P6)I,BAL 7/5/82 P7)I,BAL 8/2/82 T/O.Date 7/5/82 T/0'd 6/28/82 5/17/82 5/3/82 T/0'd 11/29/82 3/21/83 59.1 59.2 60.0 61.0 62.1 62.2 Hakeup Mater Treatment Plant Hakeup Mater Treatment Chlorinator Demineralized Mater Storage and Transfer Potable Hot and Cold Water Fire Protection Water Turbine Building Deluge MT-P MT-C PM T-OEL P/A'd P/A'd P/A'd (P5)11/22/82 P/A'd P/A'd T/0'd T/0'd 6/6/83 12/13/82 7/19/82 7/19/8 014.7 Date;4/20/&2 I Instrmentation E;Electrical BAL: Balance INTEGRATED PRQJL'CT SCHEDULE, REY.l PROVISIONAL ACCEPl'ANCE AND TURNOVER DATES ATTACHMENT 1 Page 8 of 11 System Number 62.3 62.4 62.5 62.:.6 63;1 63;.2 64'.0 65';0 66 0 68:1 68;2\69.1 69;2 70.0 71.0 Title Radwaste Building Deluge Reactor Building Deluge Diesel-Generator Building Deluge Miscellaneous Fire Protection Main Steam Piping Main Steam Leakage Control Extraction Steam System Sealing Steam Condenser Air Removal Auxiliary Boiler Heating Steam Condensor Condensate Piping Condensate'Storage andTransfer Condensate Filter Demineralizer System Abbrev.M-OEL R-DEL 0-DEL MFP MSP MSLC SS AB HS CONOR CONDP CST CPR P/A Date P/A'd 5/31/82 P/A'd 6/28/82 (P2)7/19/82 5/2/83 (P3)11/29/82 P/A'd (P3)5/3/82 P/A'd P/A'd (P4)11/1/82 P/A'd P/A'd P/A'd T/0 Date 7/19/82 7/19/82 7/19/82 7/19/82 7/11/83 7/11/83 1/31/83 1/3/83 3/14/83 10/4/82 10/4/82 1/3/83 1/3/83 6/6/83 2/2&/83 014.8 D'at'20/82 I Instrunentation E Electrical BAL Balance 1NTEGRATED PROJECT SCIIEDULE, REV.1 PROV1SIONAl ACCEPTANCE AND TURNOVER DATES 0)ATl~aHENT 1 Page 9 of ll System NUmber'2.1 72.2 72.3 74.0 75.0 76.0 77.0 78.1 78.2 78.3 79.0 80.0 81.0 82.0 I 84.0 Title Feedwater Equipment Feedwater Turbines and Auxiliaries Feedwater Control Heater Vents and Drains Systems Turbine Oil Purification and Transfer Non-Radioactive Drains Sanitary Systems Control and Service Air Systan-Turbine Building Control and Service Air System-Radwaste Building Control and Service Air Systen-Reactor Building Plant Coomunication System Reactor Building HVAC System Reactor Building Emergency Cooling System Turbine Building HhV System Control, Cable, and Critical Switchgear Rooms HVAC System RFM Abbrev.RFWDT TMC HD TO ED/FD PSD CAS-T CAS-W CAS-R PCOH R-HN R-HVAC T-HQ CR-HVAC P/A Date (P5)8/30/82 P/A'd3/14/83 11/1/82 P/A d 7/4/83 11/15/82 P/A'd P/A'd (P3)4/4/83 8/2/82 7/19/82 9/13/82 6/14/82 5/17/82 T/0 Date 7/ll/83 5/2/83 6/27/83 4/11/83 ll/1/82 7/18/83 12/13/82 5/2/83 5/30/83 5/2/83 8/23/82 2/7/83 1/3/&3 8/9/82 10/4/82 014.9 D~ate: 4/20/82 I'nstrunentat Ion E Electrical BAL=Balance INTEGRATED PROJECT SCHEDULE, REV.1 PROVISIONAL ACCEPTANCE AND TURNOVER DATES ATTACHMENT I Page 10 of 11 System Number 85.1 85.2 87.0 88.'0 89.1 89.2 89.3 89.4 I 89.5 89.6 89.7 92.0 93.0 94.0 95.0 Ti tie Radwaste Building HUAC Radwaste Chilled Water Standby Service Mater Pumphouse HLV Diesel Generator Building HLV Service Building HVAC Service Building Heating Hot Mater System Service Building Chilled Mater System Mater Treatment HVAC Machine Shop HUAC Security Building HVAC Technical Support Center HVAC Off-Gas Vault HVAC Seismic Monitoring System Circulating Mater Pumphouse HLV Makeup Water Pumphouse HLU Abbrev.W-HVAC WCH SP-HLV 0-HLV S-HVAC SHIIW SCH WT-HVAC MS-HLV SB-HVAC TSC-HVAC 06-HVAC CP-HLV MP-IILV P/A Date P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd P/A'd 10/11/82 12/20/82 4/11/83 P/A'd T/0 Date 8/2/82 8/2/82 8/2/82 8/23/82 10/4/82 10/4/82 6/28/82 10/4/82 10/4/82 6/7/82 11/8/82 3/14/83 5/23/83 T/0'd T/0'd 014.10 O4te<20/82 I Instrumentation E Electrical BAL Balance O.INTEGRATED PROJECT SCHEDULE, REV.1 PROVISIONAL ACCEPTAttCE AttO TURNOVER DATES AT'i:.rlENT l Page ll of ll System Number Ti t,le Abbrev.P/A Date T/0 Date 96.0 Cooling Tower Electrical Building IMV 97.0 Heteorological System 101.0 I 1'02.0 Heat Tracing/Freeze Protection Power Plant Information Communications System 104.0 Security System 105.0.106.0~107.0.Cathodic Protection Process Samp1 ing Cranes and Hoists 108.0 109.0 Hi,scellaneous Equipment Facilities 110.0 Loose Part Detection 103.0 Transient Data Acquisition System (STARTAC)CT-HEY'T/FP PP ICS TDAS SEC CP PS/PSR HT-REACTOR HT-OTHER HE FAC LPD P/A'd P/A'd 11/15/82'/12/82 1/10/83 (P18)6/28/82 9/6/82 As required 8/2/82 As required As required As required Pl)1/3/83 P2)1/3/83 P3)1/3/83 T/0'd T/0'd 3/14/83 10/18/82 3/7/83 (Tl)5/31/8 (T2)8/30/8 10/4/82, 5/16/83 Il/16/82.8/1/83 9/5/83 9/5/83: I 3/7/83 1 II~-,~~.~

~tt'~Il ATTACHMENT 3 IMP LBIEHTATION The implementation of the STS on an-individual license application will proceed in three phases.The.major steps within each phase are indicated below.Phase E The applicant should;--1.Obtain copies of the STS from the LPM.2.Identify and mark.those specifications not required because of plant design or other factors.Specifications within this category should be retained in position within the document package for later review and discussion.

3.Identify those areas where specifications are required but are not provided in the STS.4.Provide the applicable values of the parameters and variables identified by blanks or parentheses in the STS.5.Provide the figures, graphs and other information required to complete the STS package.Phase II 1.The Commission s aff will review the information provided in the marked up STS package resuiting form the Phase I preparation.

2.An applicant/s aff meeting will be held to resolve noted differences of position and other related comments from the applicant, vendor and A.E.Phase III l.The Commission will provide a Proof and Review edition of the technical specification for final review by all parties based upon the resolution of comments and positions in Phase II.2.Final comments and corrections will be incorporated into the document as received.3.The Technical Specifications will be issued by the Commission as Appendix"A" of the Operating License.GE"STS 1 41 4-<<gs 1 C'*.C A~L'~;~7 q l,'$t~,I%~~~Q~

ATTACHMENT 4 3 EXAMPLES OF TECH SPEC ISSUES IDENTIFIED

~J'SSUE 1.Control Rod Operability 3/4.1.3.1 2.MSIY Leakage Rate 3/4.6.1.2 3.Recirculation Pump Operation.3/4.4.1.1 4.Main Turbine Bypass System 3/4.7.10 5.Snubbers 3/4.7.4 6.Control Rod Scram Accumulator 3/4.1.3.5 7.EOC-RPT Response Time 1.12 8.Operational Leakage 3/4.4.3.2 9.AC Power Source 3/4.8.1.1 CONCERN Provisions of specification 3.0.4 with regard to inoperable control rods do not reflect the conditions assumed in the FSAR transient and safety analysis The approach to establishment of STS allowable leakage limits for MSIV's vary from plant to plant Action statement requiring immediate scram on 1oss of both recirculation pumps imposes a transient on the plant not warranted by plant status Various options for appropriate action statements (such as MCPR penalty, 25/power derate)should be accepted as'generic resolution are available Existing surveillance requirements do not recognize the current plant design (primarily a large in reas.in number of snubbers installed)

While recognizing the automatic scram on low CRD pump discharge pressure is an acceptable resolution other options are being evaluated and may be presented.

on specific dockets Response time as presented in STS could be modified to reflect the parameters testable by standard method as previous submitted by LRG Clarification of valve isolation provisions of Action statment will faciliate uni form implementatic Action statements require high frequency (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />)disesel testing

/~a~.~~+V 1 PI I

~q ATTACHMENT 5 TECHNICAL SPECIFICATION SIGN-OFF SHEE~T..Tech.Spec..Section: 7

Subject:

'I~Lead Technical Reviewer: Mark-Up Due to Licensing:

The mark-ups should include a brief technical description of why the changes were made and a list of'"later"s to go in the OCI log.Lea i ecnns ca l eve ewer t s gr/c 4/8~ate M ger, avery~ng1neersng Group, WHP-2 dj g~Odte'ecnntca uperznt ndent fl'0 let Pl ate g*4~5>'~~I~g]~~~~~~J~A w~s~~'1 TECHNICAL SPECIFICATION GENERATION PROCESS ATTACHMENT 6 3 STANDARD TECH SPEC PLANT STAFF PROJECT ENGINEERING TECH SPEC OWNERSROUP..BURNS&ROE (B&R)'IN-2 1st DRAFT 2/1/82 OTHER BMR 5 TECHNICAL SPECS'ENERAL ELECTRIC.(GE)(1)TECH SPEC OWNERS'ROUP (1)PLANT WNP-2 2nd DRAFT.G E (2)B&R (3)SUPPLY SYSTEM DESIGN ENGINEERS (4)(())~(((2)~c%(g ((3)~(((4)~,WNP-2 3rd DRAFT (RESOLUTION WITH NRC)NRC PLANT STAFF SYSTEM DESIGN EN G INEERIN6'ROOF

&REVIEM WNP-2 No.1 SUBSEQUENT PROOF&REVIEWS WNP-2 LICENSE WITH TECHNICAL SPECIFICATIONS II~f*I~f 1 4 f~f>>V'4~4 1 VIVV+~~'~IV I 4 L~<<Vvv eec e I 4 ff I~', 4\~~II., rk L~4'I~I l~I I I>~il~V'I II~4 I~~l 1 e 4 V~nlv~~4 ff~'I~4~~V~I e~I'5~4 f.'I I~l V~~~~~~~~I,~I Il~el~V I r C 4 I~~b 3 b b r r ,..'-""".-'-;

3/4.5'ERGEHCY CORE COOLTNQ SYSTB6;:==':

,~~..""'=:-;;-..'."::,, 3/4.5.T ECCS OPERATING'-.~

-"'.~-'=-,~:.~~~,'.~..=."..='

'---'-:--".-

-".'-:.';IJMITINQ CONOITION FOR OPRRRTION.:--.'..-..;-':.=..-'.

..:..~-'.3.5.1 ECCS divisions l'and 3 and, the"automatic'depressurimtfon systea'::-=-;::"..':-:-":*AOS)shal1 be OPERABL.with::---'='-"'-:;,'.

';.;.;,...'...: ',;.-=:.-";,."'(.",.~.-,.-'.=."=,"".'~t.

~a.'-..': ECCS divf sion'1'onsisting:

of:;--.:-"'--':-'*"'

'-.-: "-"'-'-'-.-1..'The OPERABLE-1ow presiiirec'ore spraJJ (LPCS}mystes with a flew'=="=.'-

path capable of taking suction fr@a the suppression chaaber and transferring, the.,water through the spray sparger to-the reactor,".:-...".=.

l~lm 2." The OPERABLE 1ow.pressure=coolant fnjectfon (LPC?}" subsystem"A".of.,:...,..:::....'....:...the RHR systesi with a flow.path capable of taking suction fron-..---',.'-

the'apprasslan cbaiib4er end'sns(erring'the.aeter ta the r.esw cr".T.:-::"."~-:.=b.:::,::-'OCS:dfvI fasnmcakI tsfng f:a%'~~~~'"=:"-""~~'"-

"=~,.--,,-"'-.-..."-,="..: "-.:-.~-'~-..'-ll

.=.!TSC OP~LE'"low ps"ressure"cool'ant'in'jectf on:I(LPGA) suhsyrstenis"S",.:;-'-,-;;-"-.-

-"-...:"-..;--.".:..=,;~-:~:,"-.'..',,'"-":

and.t C""of=the; RHR system,=each with a flow;path capriole of taking'.=;::,:::."-:-:.;

."",=,:":..'.:-'"-.:.,-'-:;=':-.'.=

-.-.~,'~:=,.;::.';;:

';:-.SuCtiOn~'rthe".SuppreSSfOn'Caaber and tr'anSserring the Water,.-~=~~

'c.",,'CS dfvfsfonB-consfstfng.of.,&e'OPERABIZ high.pressure core spray."'.=."~(HPCS)system Nlth,a flow path'capable of taking suc ion'ree the,.----...=.-,'--'=,.-'uppression chamber and, transferring the water through, the spray: ,-'.".:..'

\APPUCABIUTY:

OPERATIONAL CQNOITION l;2" and 3".A~~4~,~~f rr>ne ss not required to-be OPERABLE when reactor steam dame pressure fs less than or equal to@003(psfg.

('See Special Tes'Exceptfon 3.10.6.i'HNP-2 r 4~I 3/4~1 44 p$$59S2 4 j'.:ra'r~HERGBfCY CORE COOLING SYSTBS-.":.~~..~.~~~,.~n.:,.=.~'=-'.~-.-::;

-'-.-UHITING CONDITION FOR.:OPERATION Continued)

.'V~,-":-"':.~~-.,-::-;;."'.'." For ECCS:division'1.," provided,+at.

ECCS divisions 2 and=3:are OPERABLE.,;.I C!'a'--=-'-'.'-",,:

.1.MiN;Me LPCS sys em inoperable, restore the inopar'able LPCS systai to OP~ICE tmtus within 7 days;F , 2.kith'LPCI subsystem"A",.inoperable, restore the inoperable LPCI.subsystem~

A to OPERABLf.ital+

within.7 days.-.3.Mith the LPCS system inoperable.and LPCI subsystem"A" inoperable,'

~'restdra~at 15'as'"'tIie in'oper+1'a'PCI subsystem"A" or'he inoga&hhle LPCS"System' QPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.r.,:-~4.,04emse,'e in.at'ees'.-,HOT'SHUTDO'4 within the next'12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hand.'in'COLD'SHUTDORJ within the Vol'lowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..'.~~7.=.~~','--~-"~-I+-~;.-:,=-..b..-For ECCS.division,Z;.::provided'CCS divisions 1 and'3 ara.OPERABL"":,.-.:..-.."...~.--..'.:.,=~-,,-..;.:.~'.-...:3'.-

-.....-Mih:QCI-subsystem".B" or.".C".,-inoperable-res ore>e inoperable'=.

-~=',,;..=,;

LPCIsubsystem:".B".cir"C";.m OPER&LE sw us th.7.da:=-.-'=-.'-'=i-,=;,.'.~~~-.:-"2-'".'.hht'h'r LPCI s'ubsystems""B""and"C".noperabl e;'ras zYre',it.1 east',:-.':."'=""";:,-~="-";-.

-'=:>-'--..the~noperable:LPCI subsys~"B" or"C" to OPERABLE-status.'-'--~:.::"='..

r J.-.:...-.'-

--.'=---'.3....Otherwise,':be i'n at 1'east, HOT SHUTDOWN wi iin da.next'12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s>;:=--.-~=:-'-"-

.'-and.in'.

COLO SHUTDQW within thIe,following 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s=':="."-.:-.:;:...;-c."'-For ECCS;division 3-.provided",that,ECCS.

divisions'1 and 2'and the..:---:..-..'.=1): Mith ECCS division 3 inoperable res+re the inoperable.

division"".".-.".'.."::='.-"=.

-ta: OPERABLE statu's'within'4.'days.

~~':2).Otherwish; be in at'leist;.HOT'SHUTDO!0 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.'nd'n CQL'O'SHUTDOWN within'he, fol3owing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.d.For ECCS divisions 1 and 2, proyided..that ECCS division 3 is OPERABLE: r~'.-1);Mith LPCI"suibsyrhi."A"'hand.'LPCI subsystem"B" or"C" inoper~:.;;-...'able, restore-'at'least,the.inop'errable LPCI subsystem"A" or the ,.inoperable'LPCI'subsystem"B" or"C" to OPERABLE status within~-" 72=hours~-'-r~'I*henever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDSOas required by this ACTION, maintaip.reactor coolant temperature

, as,low as practical by use'o'f a1ternala."4akt'emoval methods.~I'Ur I 4'/4 5.-2 81P-2 KB 03, 1982 r\~.~

ws~al~tO~4 EMERGENCY CORE COOLING SYSTBIS I LIMTING CONDITION FOR OPEStTNN Continued ATTACHMENT w aor@MINGwr ie w~L Nth one,.of.the,above requi,~d.:AgS.valves" inoperable, restore the inoperab7e hGS:valveQ gPERbBL'E.status within 14 days or be in at 1east HOT SHUTDOWN.,yjthin.theinext-E2'hours and reduce reactor stela.dome, pressure ta';;<+O~ps i g Hi.hi n-the next~24 hours..'-,:

-1 2.NN~cr more of'he above aequi.red AGS valves inoperable, be in at least HOT.SHUTDOWN, within-IZ hours and reduce reactor.stean dane pressure ta (+100+paid'ithin De next 2t haurs.r~E'-CI i d,ii.'k:i: i!I g.'alarm ins-~entaticn channel.incperabIe,.

per, cm Surveillance Requirement 4.5.1 a.I, a~I east.one~per.p24, hours.r.4th an ECCS headhr'delta P instrumentatioh charm~I inca'elle, restore the inoperable,cpynnel-to.OPERABLEr'ith5Zs W%7Z-hours or determine ECCS'header"."deltaocaltly at-Iea3t.'.once"per IZ hours;otherwise, declare~5e assccfated ECCS inoper~&le.

Vith the Surveilljn'c'e-kequ'ir'jument"of gpecfgMation 4.5.l.d.2 not performed at the r5quir'ed'interval due.to=low-r ac~r steam pressure, the prcvis~cns of.Specification 4;0.4 a~.not.ajplic'able provided, the appropriate

'surve'jul'ance js,performs within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressur'e is adequite to perform, the test.I\In the event"in"E8S'system is actuated and injects water into the Reactor Coolant System,,,a 5peci,aI.,Report"shaH;be prepared and sub" mitted to the.Ccagjssion.pursuant.;to.

Spqciificat'ion

6.9.2 within

90 days describirig

&e-.,ci,rcgms>ncaa,oit,the;;actuation, the total accumulated actuation cy'cles to date and..the;cu~nt value of the useage factor for each affected safety injection nozz1e whenever its value exceeds 0.70...,..., ,!, two-or more"fNR sub+jtems.true.

xnoper+I'e;.

if;:unable'o attain'OLO as required by this'ACTION,'" maintain reactor coolant temperature as rac ical by use of alternate heat removal methodsw~'}~V~W 3/4 5-3 PEB 01>882'h.Whenever SHUTDQN Icw as p ACTIQN: (Cantinued) 2)Nth the"LPCS"sg'stem'noperable and LPCI subsystems"B" or"C" inoperable, restqre.at:.leaNt ghe.inuper&le LPCS systei or the inoperable ILPZX,'sj6systttem

~lp or",.C'l-M'OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />." L 3)Otherwis'e', he'.i)i'at;le~~

HOT>,SHUTUOWN.i]thin the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLO SdUTGGQH within.the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />".e.For ECCS divisions I an'd 2, pnroyided that ECCS division 3's OPERABLE and divisions 1 and',2 ar'.,otherwi.se, OPERABLE:

r~I~I V 7~I~~~~r>>l l>>~" SURVEHLAHCE REGlJXREHEHTS J<<,r~r ATTACHMENT 7'.I vv r v s V V~>>~I~<<'~hh~h VW V~r~pl<<~>>l>>+>>V>>'ll I~l>>W...4.5.1.ECCS division 1, 2 and 3 shall be demonstrated OPERABLE by:.a.At least once per 31 days for the LPCS, LPCE and HPCS systems: 'l.",,Verifying that the.system"gp)'nf fram the pump discharge valve" to the system isolatian valve is filled with water.2.Penrfarm<<nca of a CHAHHEL"'FUNCTIONAL TEST of the:~~=~>>h<<>C hl ,:.)I.VI ll I: ".: I'-III'I"S al arm instrumentation; and b),.Ke+yr del&P;,ins'trument'ation.

h'.Vhkifinvg that each valv~, manual, power operated or automatic,..-$g.the.flow.path-that isi-not locked, sealed, or otherwise secured.."in position, is, in its correct position, I'.Verifing that,when testen'pursuant tn'SPecifica icn 4.0.5, each: s r t 1.LPCS pump develops a flaw of at least joe,~gpm against a teat 1ine-pressure.

greater.:.than cr equal tnlen>>1 psig.I" 2.IPCI-pump de claps-a total"-flaw af ht least P666 m against a tesc'line pressure greater than nr equal tn (-..)Psrg.~, 3, HPCS pung;devel cps a:fl reef w,at 1e st'-ast l-'-',-','"~,line',pressure greater~'or equal to" psig.-'c." For,%e'LPCS,.LPCX,,and HPCS systems)at",least once per 1S manWs: I 1.Performing,a,sy'sstem functional test:which includes simuVated automatic actuation of the system throughout its emergency.,operating.seqg~nce and veHfying"thit each automatic valve in'Iig"flaw p~,actuates to.its c,'orrict positi on.Actual'infj~iin of-gi*<1ant inta".the"reactor'essel may be excluded from this'test.~>>/~w~S I l~igss I e l~I~I l la>>Vea~~I'r I h f~V l~h I s\OP-2 K I I<<>a tvw" V l W I ,r 3/4 5-4 p~gyga2

~I~ATTACHMENT EHERCBICY CORE CDQUNC SYSTB6'URVHLLANCE REOUEREHEH7S CanNa~'e~+lg C ii MIAN~V W Clp~~cpa'4r~a~~RI'IV t Perforraing a'HANNEL CALIBRATION, of, the: llf*m Il'k:::fi11 1" 4, k~alarra.;ins4rumentatioa'hd':yeR~

tying"the:

')'igh pressure setpoint and the 1m'ressure set-poin4;of.='the':=

-=" ,-"~(a).-LECT>system to'be'<',psig and>psig, ,.respectively

<'-"='-2....-(g,&CI;.

subsystems to'0e'$400+psig and>~psig, respec ively.2)'>",;,~pressure.shQoint<'of,ttre HPCS system to be 50!b)Header del mzP:;inst~entation'and

'veri fying;the, setpoxnt,of the: '.I~'I~~~..: 1):-.LPCS: systaa and-LPCI subsystems'e

+'ggpsid-iQ').;HPCS'@s~

to"be~,+'$0;25gpsid less than..'-.the no@mal;indicated 3....Verifying that-.thew'uctioddoi"the+PCS-,system is (automati cally)tr,anqferrerL~Xrorrr-MN.coh8HRsate"storage tank'to the sup-,ression chambe'r.on'a condensate.storage

~klm water level.signal.art/orrm~pN&ion<

chaafb'en'tn gh@ater.1evel'ignal

..*~A d.At least once ger,']8,tmonthd for."'the'AQS:,'by".'"-

Perfprming

"~'system functfd551 testi&includes simulated automatiw jctuati'an of.-'the~Aei

'~rougiout its emergency operatigg sequence;r,but"~cMding fctuA'valve actuation.

2.Manually opening each AOS valve (~hen the'eactor steam dome, pressure is greater than or equal to-100 psig)and ob'serving

~at either.a)The control valve or bypass valve position responds.-accordingly, or HNP>>?b}c)There is a corresponding change C.cc,o~1+cal mrs~~aQ~~Zt~'i~W.~i~v~r~.3/4 5-6 r t 4 in the measured steam flow.g au~vM]u4~a~s~'-.4 gH 01882 k-~AQHINIFiiATiVE CONTROLS.ATTACHMENT 7 kk-PROMPT NOTXFLCATKH'VETCH-MB7TEN FOLLMJP~.<<k 6.9.1.8 The types of events listed be1taf:shall.+e..reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and canfirmdd by tele~gh,'miiTgram, or facsimile transmission ta the Girector of the Rygianal Officeq ar.:his designate no later than the first ,;,working Wy'followinq the,'e'vent, with.a>written:

fallowup report within 14 days..The.written followup".r'epart'iha11 iwcl:ude;-m-'a':minimum, a completed copy of a ,"-;licensee event rjy'ort,for'm.".,'.Tqfe~iqe provide'd Wn the licensee event reparform mhal1 be implemented, as neededk~additional narrative material to provide complete explanation af the circumstances surrounding the event.~i,.a;".Failure ef the reach'prateion: systeih or.other systems sublec ta"".-limiting st'ty system set its">;init'ice'he required protective i"-'u'nc ian 5y thetime.,g-jaanigred:.parameterreaches the setpaint speci-fied's"the'"1im'iting".safety, system.set lng'n the technical speci>ica-;;:.."-,-.'ticns~or.

Pailu~to, camplefy'he-requiAd protective function.i~-:.b:-Qperatibn'of'he unit or affected syitems-when any parameter or-operation subject to a limiting condition for operation is less conservative than the least conservative aspect af the limiting condition for operation established in the technical specifications.

k~c., Abnormal degradatian discavemd in fuel cladding, reactor coolant'ressur'e boundary,'or primary-cantainment.

I~'\....d;'.;Roc ivity ahomalies.

involving disagreement with the predicted value~~.....:of re'activity.'alance under steady state conditions during power opera-.=%ion greater than or.equal ta,;1~delta k/k;a calculated reactivity

'-balance'indi'cating'a SHUTDOWN MARGIN less conservative than specified.in the technical.

specifications; short-term reactivity increases that'car're'spond ta'".reactor period,.of:, less-than 5 seconds or, if subcritical';

'.W"unpl'armed r'eactiyibg,insertion of mare-'than 0.%delta k/k;ar-'ccurrence of any unp)armed,criticality..

k k k IV e.Failure orh malfunction of one;-or more components which prevents or~cauld-'prevhent,;

by itsel f, the-fulfillment of the functions'I require-ments of-system(s)used-ta cape with acCidents analyzed in the SAR."kh v k f.Personnel error, ar,.procedural inadequacy"Qhich prevents or could.prevent,-by'itself, the".ful'fGlient og,.-the func ionaT'-requirements of systems".'equired,ta'cope"yit5,accident&'analyze'd"'i'n the SAR.g.Conditions arising fram natural or man-made events that, as a direct result of the.ev~~quipe unit shutdown,'operation of safety.-'systems', or other,.protective

.-measures; required by technical speci'fications.

MNP-2 6-$'

ADMINISTRATIVE CONTROLS~~A~>>~~&a+>>>>~>>ATTAI:HMENT 7 C 0 1 PROMPT HOT FICATTOH MID WRITi74H"FGL'LOWP:(CaiIti'need)

.:-;;,.~q-.""..".-

• '4~h.Errors discovg,ed.irr)the'.transient cr"'Msdejt analyPes;,ar':

tn~Me methods used:for.~dh'.mtfai'y'ses as Mescr,"f5ed,in'he s~ty ana'lysis report or in.Qebases-;afar'rthe;tepini&1'sp'e'cffica.ians that have or cauld have pe~jkted;m8'c't'o't'cji'e'r'ati'on'"i.g~',.'manner Iless:rcanser'vative than assumed,jp'<Ne.'.angyse's.'-:

"'="""-.',"Z

..)~:o)u)g>>yl$)%4))gP>>to'l Performance of structures, systems~ap gampanents that requires remedial,a<ion.

pr~carr~iVe" me'Esures..to prevent'p'eration in a manner less conservative, than:;Resumed in'tlje agcideit ana>yses in the safety analysis repa~-or).,technicil""specifici6fons.ba>>esj,:

or discovery, during unit life of conditions';not"-'specifi~al'TyI considered'.,in the safety analysis-report or..technical speci i icat'fons that require remedial actian ar carrective measures to prevent tjte,existence or.development of an unsaf,e,~odi:ticn.;-"~

'.."." THiRTY DAY WRITi eH?SPORTS 6.9.1.9 The types ageve'nts li'sN'd belaw shall.'ba'tlie'ubjec"".of written report'o the Dire~~r cf the'Regional)Office witfiin thirty" d'ays of occurrence of the event.The wrii en report shall include, as a minimum,', a<completed copy of a licensee even" r part fcvp.".: I'n)or..'ation provide'd on he 1)censee event repor-.'arm sHali be supplement"ed,:

as.'~'ded, by addi jonah,gaprativp material pr.vide complete explanation of'-%e'ci'r.-'g@~ces.jurraunding,"Pe event.-" a.Reactor protec, ion,~ste5'br" injinkered,"'saf@.

faampg ins rument set~ings whic)1:are.-)

cond-u" b'e lWs'.'qadi)y'rvytjye~thanqthose esMlished by the technica1,-

specifiCltIIcns'ut ih>ch'do,a jgpjyyent the ful fillment of the func"ional.requftMetits"cf 4'ffec~d'-systems.

b.Conditions leeching to aper'Mian.>hh"d)grajtqd~ade;permit ed by a limiting concjgicn)fcrucp5rition or p$agt sou aawn required by a limiting cond~ion-"foe OperaPion'.--

c we>~~a>>o+Q~c.Observed.inadequacies).'i'n the" 8fjkementati"on of.administrative or proce-dural cantrc$p.,which Nr)eaten t'a"cause.gducticil..of-degree of redundancy providedinweac ar:pated&'on:Systems cf engineered safety eature systems V d.Abnormal degradat5in.'o'f

'"syst'gs'-othe/;tPpri'those,speci.fied in 6.9.1.8.c abave deigned"to<'conYa>7i"t'adi aactiye.materi al resul ting fram the fission process.(NP-2 6-17

)E.~gp, (>>VQ>>0'.-/t'<>>b<<1~4eq vrp V,~t e p4 PJ">>2~I CA~~'>>4I J>>J'$f 2)l(<SMi~>>9 0&>>!~hip~~~M~>4~5~>>'Q~Q~g, a.VW>%At>>ga>>>>j1'1r t*+'054%~'4 w~~'Q p,,lt, g'<4C'vms~s h pf?MN I>>'>>,y~'*~j>>4 1~Ct&4~l>>~>>, P~'phltA~t'dilW2 e~, ye~g>>g i,'s>>sr..t Ja'(p'"+S'>>cp i4>>>>l/%lpga,>>+>>*~ta~gyp, 4'vrn~y2~af vt'g~p~.I.'>>grit(,~i, y->>N Adrs>>purA40.

~ae'w ATTACHMENT 7 li 5'[M Title)~De the maintenance ind use of equipment taking into co the main e g into consideration the site c!I.a Mntained-in" Part 100 of (Aosec-,chapttr, the PropoSed facQity carr Para((raph:i,posed 4ocation" withaut undu y fram thy~estimates sufjygtted In..p+~Fh m 4n;aDJ?HOLQt

~SuDDlted Iru.the appHC2(tion for..q coagiuc[ion,;~

fse Pit>eseV.De-3~.19V0;Ss tuuend'e'd'at 40r'~~~~~r)radiried to reflect that'rac C Ii 5024 faauanc j of construction pirtnI!s.'

tu~ran au p't~g t"to'proceedwith.

construction bu pHed hQtIMy YQt.Of,ghe,~hgM

@'."not+bnstltute Commission aPProval OI formation re<jtilre'd'~.complete.the th s~ty~desrgn feature or appHcation and!supp'art"the.iestiarnqe SPeMa~dan urQCSP the aPPHCant SP>of a construction Per>>mit which,ap>>proves all prapasrrd dtsgn feattires.".pp~e the Comnission>>may issue a eddic--per'mIC'The aPPHcant.at his oPtion, tian Permit If<tKe-Corrmrjsqian fhrds.m th e t that (1)the amp)leant'has described'W~~an p~t" or,~the proposed design of thedacIHty.

In-thne, by amendment of.his construe:.tiori nrrjt.Th Cammissio may, tu teria for the design,~d has Identified" s~ctiori pe~<pro Isla s reqUIrirr the major features or components in: corporated therein for:the protection of the health and safety of the pubHc;, sech~d deveioPment Programs de-(2)such further'technical or design in'igned'o resolve safety questions.

formation as may be required ta.corn>>-*<c)" y'm~~@on p~bject-to the Hmitation that a Hcense can ressonablybeleftforla~cansid-authorieing oPeration of the faciHt, eration, wQ1 be'supPHed in the final wQ1 not:be-hsued fiy the Commiss safety analysh.report;

<3)?safety'fea-,untQ.

(1%the appH~t.ha s bmi~to the'tmmrhsian

'.bX'.)rmendment to quire research and devhl'opmefrt

~ye'." the apPH 40 4 he'mPlete Qm been described=by the'appHcant and the appHcant has identified.'and there Nll b condu~d, a~hatd and.d~.ed from time to tjme.and (2)the Com-velopment program reisonably de-'on-~fa'mrs" t t the f~d e 3 i g: pro<d e s~o~1 e associated with such features ar'cain ponents;and that-.(4)otIrr the bash f the foregoing, there:ls rea'sonable as-,',.'qsurance that.(f)such safety jueiieiphe

'~be m~actorQy~lv~.at" before the l,t td,t~d.f-the ap'.-,(S.-18iree.sat 955"-pHcation for campletian

'of, tion of the proposed faeQIty ind (Il)'1 PR co'c-'(39fe;",f)ec.'39,>993: 2'., a 30.1988;35 FR 5313.Mar(34 feVO;3S PR e644.Apr.35, 197(S 35 t~~'~~,PR31eel; Jl+IV, 1970)19'N.for any fact)it)p for arbicb a notice'af<a)Each appHcant for H N'W.for anr a cense au.p oual o-~aperation of a production or DubIIsbed on utQIzatiorr.facIHty'shall include In hh;.g.'.1-pp aPPHcatioh propasf!d technical specifi-332:~a pter I Nudear Regul catiorrs ln accordance with rrrents of this section.s>terrrent of the bases o: such specifications, other covering admlnhtrative cr also be included in the ap>spall not became parr, of.Specifications.(b)Each Hcense auth'!ion of a production or t cility of a type described 150.22 wQ1 include tech':!Ious.The technical spec!be derived from the anD~cation included in the sa-cport and amendmen~rsitted pursuant u 1 S0,:-aission may include su<tcchnical specifications ruhsion finds appropriate, (c)Technical speclfica dude items In"@he f ollowh (1)Safetp-J(urits, hu systeur sertirrps, arrd firn set!in ps.(I)(A)Safety)br.ar reactars are limi up process variabfe be necessary I integrity of ver,.of barriers which guard ag.cantroQed release of rat any safety lhnit is exceed mr shall be shut down.shall notify the Comm: the matter and record t the review, Including the condition and the basis action taken ta preclude Operation shall not be r authorised by the Camm (B)Safety limits for f iug plants are those b which She process mais maintained for adequat the aperation and whicl.exceeded in order to pro'ity of the physical sy.designed to guard again trolled release of radiaa safety Hmit for a fuel plant h exceeded, cor: shaH be taken as stated cal specification or the of the process, or the en required, shall be shut such action would furth margin of safety.The notif y the Commhsior.

matter end record the Q 1 nergy 1 site c...'pf this)can'4e pro-<risft to hUc;pUed Ld.V-'on re-L wdud.Me Pwc-oprtazely 1 const!->pUcaat)u royal of tue o.spe-~and<prior,'":.he-e to~true.ay con.'l!r a Ls~J3 be 1!cense Mion unitted kent to fina!)ns of 3t'Co-'f ic;a!umnce-of the y oper.m with.se ar.d)net tt 5318.ts>0;55 rse au.dcn.or La his';ATTACHf1ENT 7~A'~ii.i~"CIAO)A4Wltp

{:hcrpter I-Nuclear Regulatory Cornrn!ssion g 50,36 in accordance with the reqiQie;,c, regrew.!nclucUng.the'.cause of.the.con-of thrr section.A, s~aiy de!ops,.and thee basis for correl:tive

!:-..o.ent of;he bases or regons'ors

<<actEog~Wen to'pr'eclhdtc'keoccigejcq.

5 c.'".specifications.

other thah,tho'se>>;ffcoa

~on of-.tM~:process.-.or;.the

c: er'".g administrative contrite, shaH, ep(~rpcess'-has=b'circn shut'em;tr~"::=o be inc!uded ta the appUcation,'but emtion spall not".be:r'hsiuned un@'a!I-.".'..z>M not become p~of the'tec?Meal'.,"thd'~VjPby tht;Co&nuSsion".

"""'r elva lc)ns'=!=ach Ucense author~,gp'(,,"t7njj,foe>nuclear reactors are settings s::sn of a production or urgxattdh:w-~gqgtcutomatic-protertive de)flees.ielat-".-.'".:y of a ty~described in 150,2)og,:-:ed'ottthose v&ables having slghiff--'-50,22 weal include technical spec!flea-.,kyat,safety functions.

VFhere a Umit-,:!c.-a.he tee+weal speci'icatiora

+,ing'safety.system settin'!f)'li'sp4'cified'e

=erived from the analyses and:zeal-"*fo'Z'a~variable on whig@a safety.limit..~.""s;a:!on included in the safety analpS;has,Seen placed.the setting jhaH,be)o re-or..and" end ents thereto,'sub--".'hosen that automatic,'prot'ective,-".:e pursuant to$50.34.The Cafa;.actiorii~dg,correct the'abnormal.situa-,.-...:.z.~-'-5'!cn may L".elude such add1tit)ng",.

+on.blare a safety.'!pit'Is.".exceegQ;, t~.--":.:h ca.'pecLc!cations as the" gofn-">,,',lf;.dpjjg operht)gir." thj;.gptoajatiq;;, c,': c.:..>>-..-'.cn.'L".~

appropriace.

"'.".'afety)pmtqm do jf 1)jest'66jrlon;as.rq.-...-~.-..-..c specLcicat,ons.will~

$-'uj~~hq: Ucensep'4haL,~er apjjgp wl.--:eac:crs s=U='m upo"!mpqitant!ncludipg~the cause',.of the condition be.".ecessary to reasonably prote t.;.he, taken ta, preclude reoccurrence.

a:es'.:: Of CenaLn of the ph)%eh!.,-(B)Limiting cpntrol settings for fuel.h'ch gu-.d against the~:.reprocssiag plants are s:c=:;L'ed re!ease of radloac:!city.'L".

automaticia!arm or piotectivp deyices.ety Umit ls exceeded,'the reac.related to.those,ygziables having, sig-";c.-sh~be shut down.The Ucensee,-nif!Cant:safety" functfops.

-.Where a 5e." notLy the Conunissior rOlew,,.Umlt!ng control'Set'ting is spepified for c":ter and record the r suits of, a;variable'ron whjcP.j:safety,~t)gas,~~".."-"-'-

he review, including the cau'se oT tge~+~" p!aced.'he.

qefUjg slip: t}e.-.sa~~'roc cond'.io.ard the basis for&rect!'Ie.ppqsenvthat, prot'ectly'e,.pctQpr:either",.',r

"-c:~r"-">'~..aCUOn alen tO preClude rea'CCurrenCe.

putf)matic'.Or maii'tial jrfH.aOrreet th'e'!"t'.='"'b 0-erat!on shaH not be resumed,.untg....abnarmaLctsltuatfpn 7ipforg.;cgI

~end',~a'-.harmed by the Commission...,',~-;I!mit 1" exceeded.tU."gjir!ng~eratian.."."r rt"-'r Safecy M~for fuel je jioc@s;~the automatic a!arm'jr,<protjptiva.de-

..'=.;plants are those 5ouRdt,@itin,e<vicealde:ntrt'fun'cti9n~

reqit~d,:Me<<,~

=;;!ch the process variables'st;bq,-licensee BhaH takeccapproprjgct~action

'-'"-'">'-'"+-

.~<<g-s'".taL1ed for adequate.'Copujf,,ofq,uz ttrsr!ntain the%a'ifaSles..prtthin the'." c;-.5 operatio" and which must,'Sat bq dimLMg"control'spy'fpj;.

values and tor exceeded LD G.d r to protect che integs~zepair>promptly,thy,'automat!@;,devices,.;::: of the physical syst'em~atJjg:Q

~.,to'zMt~rdown,the~Qfected:part.of-., c-'-."--:<<gned to x-rd agaLai'he,uncap.-,theyrocessc,ancL' tf required,go

'shut:.'.:i:ed relea~e o'adioactirity'.'"U'a'ny'" doctor,.t;je entire jin)cesr-fog'rppair;ofv t for a fuel repro'cessing,'dfIp&atic devices."Th'g'1(cet)Sce shaH;o~u exceeded, correcth'e'cijoy,,noUfj

.<he,Comlnission,'eview the.';.a" be taken as srated in the t'echni;mater)>and'record tpe.reyulg~f that-.q-.<<." ca!specL!ca:ion or the affected part review, including"'gj~jse of t4e.;con~c."r.proces-, or the entire,process'tion" ahd" the.'%abls'pr*,corrective"rr-,,*rE-""ed.snail'oe shut do~, urJess.>aetign,.tpken to preclude reaccurrence.

-"".;action-ould fur.her reduce.the,., (2), Qicniffnp Condiffons for':oier'-=sr>'a of safety.The!'.cerisee shall'cffon.,Limiting conditions.

ft)r.oper-the Co.~ission, re:1yoCtpe,ation, age the lowest functional capa-=atte.and record the restarts"of the bility or performance levels of equip.333

~<>>J e j<<e v<-LR<CkÃ<4 ti%~)MI<<~55eho4'449 44Am<<it4L,WCSekve

~~<<eenA.~",'$50~~~Title 1~nezffy ment required forsafe operation of January M, 1969,.may submit technf.:4i the facfHty.When a Hmiting condition ca1 specfff Rooks'n accordance with for oPeration of a nuclear reactor fs this section, or in accordance with the!4"-"."'""." not met, the Hcensee shaH hffut.down requirements of tf)fs'art fn effect the reactor or follow any re)neeffal prfoitef-January'16<1969.

""*", action pezmftted by the technical spec-,ŽM3)'Af,"'thb'nftfatfve.of the Coxmnfs.'lQcatlon untQ the.conditfan can be sfan'or'-the licensee, any)fcense xnay met.When a HmfUjg conefftfon'for'op-."'.be a3 o2jitfeff-to fncfueje'technical speci.+w'~U,eratfan Of any-'prOCeSS Ste'p""fn<the'foatMAS-Of'he SCOPe and Cantent system of a fuel reprocessfng pfs'n6'is~which: would be'reef@ed ff a new ff.not met, the Hcensee shaH shfxt down" dexisel!0'er'eked'efng'~e'ef.

Chat Part of the oPeration or follow'-'33 Pfz fssls2 z)gg I$968 any remedial action, pezxzfftted f)y,]he.,gS.pR

@4638, Jul 5, ls'v4)technical specfficatfoh untQ'the'condi-tion can be met.Xn the.cise of'either a*'5'036K Teebnfcaf.spfclficstfons on sf.nuclear reactor or a fuel're)iro6ssfng

"'Tfaents frotn nai.'lsd jower reactozs.,-'*;Plant, the Hcensee'hall'zxotffypthe

"'jaj5ibrd(!g to peels releases of radio.commission, review'th'e matte'x', Md" ictfItj pat'efffafs taunryssrfcted areas record the results of the'review,'"m'-'fur~g tI~z~+peratfons cludlng the eaux'of the'~ondftfon and cfudfxfI(;"exp'cote'ef'.

operational occur.the basis for corrective"action taken to rencei+i jhow as fs reasonably achfev...;...~I'<>>Žpreclude reoccurrence.

"'"'"able,"hsIch."license'fu@orfsfng oper.(3)SuneQLcnce reesfrexnenta Sur."'atfonxof'a nuclear power reactor wQl ,.-.-~~veQfance requfzemepts" are, require.--, include:technical specfffcatfons that.ments relatfng to test caHbzatfon, or'.ln addition.to requiring compHance inspection to assure that, the necessary>>'ith ap'pHcable provisions, of)20.106~"~~'qualfty of systems and components fs of this chapter.require: ",.'",", maintained, that.faciHty operation wQl<(1)Zhat operating procedures devel-~be within the safety Hmits, and Chat: oped pursuant to..'5 50.34a<c)for the the 1}miting conditions of operation control of efQuentsbemtabHshed and wfH be met.""" followed'>>nd that.equipment fnstaHed 4~'4","~.'~'" (4)Des<On feat~Design features fn the radioactive waste system.Pursu-',.to be included are thase features."of ant to 55024(a)be maintained and'he faciHty such as matezials of con-v used.;, structlon and geometric arrangements,~'2)The submfssfah of a report to the which, ff altered'ormodified, would apPropriate NRC.Regional Office have a signfficant effectuxx safety and<.shown fn"AppendfX,D.of Part 20 of"-.-are not covered fn categories described this chapter wfthIn sixty'60)days., in pazagzaphs (c)(1);"<2);"and

<3)"'of 4 after,-January 1'".Iuxd July 1 of each'""":~~.;-'~this section.'ear specifying the quantity of each of (5)Aefnxinisfrezffpe coxetrofL Admln-the Principal radlonffcHdes released Co"+:;"e fStratiVe CantralS are the praVfSfa'nS'M unreStrfCted areas fn llqflfd and in gaS-...'!;--.: latfng to organfsatftm azid mana(ze-.eous efQuents during'the

'previous sfx.".'".;" ment.procedures, recordkeeping, (6)months of'peration, and such'eview and audit.and reporting neces-'ther fnformatfon as may be required"',,'sary to assure operation of the facfHty"by the<ommfssfon to:estimate maxi-',,":;;<<,.-;:," in a safe manner.'-""*mum potential annual zaeffatfon doses (d)(1)This section'shaH.'ot be to the pubHc zesultfng-"fram<

efQuent"",'deemed to modffy'the'echnfcal'-speci-3"relekies Copies of such report shall be",""'""-;-."~~

Qcations included in ILny Hcense'issued

'sent Co'the'Director of<~ection and...>>~.""=.'prior to January 16, 1969: A Hcense'fn'Enfoichnexit.

UN.nuclear Regulatory

'"(<which technical=-specfffcxftfoxfs shave*CoaMLssfbn, Washington, D.C.20555..~".,"'"",""""not been designated shall'e'deemed

'f-'quantities of':radfoslctfve'materials

,<"',,,to include the'ezltfzef safety analysis'" released"-diIZfng-the'rego~

perfod..report as technical specfffcatfons;

">>=ire sfffnfffeantfy'aboVe.besfgn obJec-~+".~~~."'" (2)An appHcant for-a.Hcense autho--'tfves,'he report shall cover this spe-""',;,'".,:

rising operatfon Of 4L graduation" or utf--'ff fcaDy.<On the bash'of'such reports ,"."-y'>>

";~'4mtfan facQlty to whom a construe-and any additional""fnfozmatfon the'~,I..-Con permit has been issued-prfor'to=

commission may'obtain from the H-Ie i~r~~~i~<~~~V 4l<<'W 0 w>>Nacfeat ftS"lc nsee or others, th f m time to time require t~e such action as the poems appropriate.

<b)1~t bH hLCmdf the operatfng procedures smgzaph (a)of this sec>>..nsee shaD be gufded by'-,g considerations:

Expe;.".e design.construction ax o.'uclear power reacto<hat compliance with tk x~"ecffications described in keep average annual wdfoactfve mate~in:mall percentages of the!!ed in (20.106 of this ch-.he operating Hcense.A:~e, the licensee fs pe..exfbfifty of operation,"-.ith considerations of suety, to assure that the;;!ded a dependable sour'.."en under unusual oper:!ons v:hich may-tempora.

elesses higher.',than svc.er<tages, but stiD wfthf: specified fn)20.106 of and the operating license.ed that fn using P~~er bflity under un<,~~e:fons, the Hcens e: efforts to keep e~.~fs o;materfal in efQuents as 1 cable.The guides set out 1 provide numerical guide fng conditions Cor opezat water~cled nuclear pow meet the zequfZement, th;materials in efQuents re restricted areas be kept reasonably achievable.

(35 FR 18388, Dec.3.1SVO.sx FR 8<89, Mar.3, ISVS'0 FF IS'XS: 40 PR 5884<, Dsc.If I6446.APr.I9.l996)$50.33 hgreexnent flmftins sericteef Data.As part of hfs applicati e"er, pdo to the receipt Data or the issuance oi cons:ructfon permit t shaD a~e fn Wt<ag th permit any individual co Restricted Data untQ thi Commission shaD hav.n tigation and report to th on the characte., associa 4>>~t V*<<.<J~0 4 I~iv,l r e i Jftergy echni.with'-h the effect tmmfso e lnay specfa antent lew lf.eded*e o n efa tots radfo-areas a"a, in-occul'chiev-oper-'r will delht..4r the ad and tailed pursu d and to the Offfce~20 of days.'ach.ach of+ed to in gas.luS sfX i such quired maxi-l doses fluent tlaff be on and liatory 20555.lterials'eriod obiec-'fs spe:e ports>n ehe the ll-%,+if rp"T ATTACHMENT 7"'for l No~loot Roffufofog Comnlfssfhna.ws cz~;1',J".s"c'*a i-~""a gey Of Su+'fndfvfduafe and the t Dm>:<at:"i>>e~n'"-<<~.r-censee or others, the Co~o.,-....,+---~M hav'e deteradnedr

'that from tilne to tilne require the ic..;Q"j~juch p'erson to have.access-,-:,.qs tol'a to tahe ntoh action at.the Cemmtta!On

.: n+Q ta<tt m"j'vttt not'e'nttanaer," ie,,'eems appropriate d RÃe e't~f"-'9~",,]he-cpmmon defense,and se@ty.The-.~.In es ehe operating procedures d'escrfb~.

-..;gr"~Qb (cerned p,~',iofjl'leaf

..censee shall be guided by the q..w.z.cease~Qr g-~paragrap" o'f ff'-."-~'rue'tfon"permit;vthether,'-";

1..<<ln':it consfdemtfons:

~erience" with so stated therein or noh,'..tc,ar the deSign.COnSeruCtiOn and Operaefpnr

".:;-'-'<>e:

>'gelt'bffft'y'Of Certal'lf"aft'91f'CigtS

':;'1"'" l eaotprS fndfbateS' gl g3".t, g, ei'hat colnp lance 1th the teqhnfcaf.,n-Any POrsqn vho 9',a cigheg: symfffcatfons described fn this)ecto%" glqr~ent of a-fpe4p c.ouv o.':>'"-'-&" 4h~~@@w o~~any qoZp)mete~~ave~material In etttuenti'-'ttt

'-.tt'tij.Ctimnt'totten"kneert Or hm<<eterne smfl percentages of the limits'speal-:" to gi.*lieve...'fs owners}cont+lie,'-:;.'":~~@~~fi d l$20.106 of this chapter a'nd fri"yqntfnatpet.bw an,alien,,a fqrefgp cor.;,:;,'.;,;the operating license.Ae the'-<am'+"jggtfo't'f, ot'Aorefgn..govern-ep t".:-OI t>o eh e.the licensee fs permitted'ehe-'haIff.ge'+eligible" to apply for~d.ix..et eo J fl xfbfffty of operation, compatf5le

',,obtaItfp pcense..p,t;.

wfth consfderations of health'an'"'ts t 161;laS~amended"Pifb.<'-63='t53PW~"-.',"';;".safety.to~ure that the public 8 pro-.'eat i,9<<,(<<.

U.S~..: 301gdeec'."PU aY""'"'i':."'eleaSeS higher than SuCh.Small pel"" pR,693e.abel"..19'78).-a.: a.S':<': '..m>~j centages, but stiff w ithin'the ffmfts: '.,'"a',."'.=-",.e...."'.".i<<-'=0.106 of this'chapter$50.39ublfc inspection of appfie'ations.

sp~fed in J-0"-'~f~'.-"'d that in using tMs OPeraeional fi'e-i'.'tptf)o tqe, qommfssfon.

in connection

..:.~bilfty under unuSual Operating COndf-With appffoatfpnS maylbermade;ZVaffa-.,-':.."",".'~..=eions, the licensee>iH exert hfs)estd"bfelfpe;public inspection;fn accordance

'fforts to keep levels of radfoactfye,-,"wit'i.t.",e.pzpvfsfons.of ehe:regulations."r.

qcollbafned fll:Par t2 of ehfs'.chapter:

cable.The guides set out fn'hppenlffx.'".,, I provide numerica gufdanctf.oh I+ti" t1, QTA?tDAJtDS Pga$dcptsxs AND;v~ing condftions for operation'Ibr lfItfff-z~.t.".~cfiisTRacnott Patsurs';c,.'.meet the requirement that racuo~qvh.

~~.la~.,;.<.materialS in effluentS released';eO",.iVf-',;;In,de~ermftlfng.eclat g)fCCflSe.mg,f19.

e t-.i restricted areas be pep,.,~<<';',4'"',-'D reasonably achievable.

'.",."o>sf~p;be.gu],, y>/he.processes to be performed."rasr, laa":...gr,atoeraitnn nroeeuureeghe meUttr r.'i'e 16446.Aor.19.19961$56.3T Agreement limiting ac'cess'to'.~>g~~proppsafs fn,tregaedlttp, any Qf ghe:,.As are of hfs aPPffcatiozi,jng~y,o affine.assurance that;,the.aPPlfcantbwifl..;

.;: event prior to the recefpt of, estric e~,~co p y,pa 0 t d.corn f wit~the.regulatfons, in ehfs;t t l.*.e.f'.jg;" Data or the issuance of ta.'entre;or....gLjpiey; fjiglu ing tile..recllaf4ws:

construction permit,.'th'.;, applicant-,Bart,-20-.

and thai.s.Wg..>

e shall agree!n writ fng thaf he.wfL,not.~

safety p f the public mffl pptbe edda>;...;:.ermft any individual to have ace@to"jqfed.,'.-, n~.:.~~-'si permft any Civil iServfce-,-.th),The applfcantrfsutechtlfcaffy,and

",, ualified to engage in the Commfssion shall have made an!nves-financi y qua e tigation and report to the Commission proposed actjvitfes in accordance w t on the character, associatfons, and loy-the regulations fn this chapter.t,'35 I C~'<."~Fig~~

tt+Mp"qg'l5%.%;

liVt>>j.g g4 vq",","c;~..'~f','rt~'-','1 fits~~~~~.t>~jP+th ef~gP.t,r g g,~~S-rf~,~,p~.~+~'ae,~av g(]ev

~, 0 y'l.I CO