IR 05000424/1981012
| ML20040E746 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/16/1981 |
| From: | Debbage A, Merriweather N, Upright C, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20040E730 | List: |
| References | |
| 50-424-81-12, 50-425-81-12, NUDOCS 8202050306 | |
| Download: ML20040E746 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
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E REGION 11 101 MARIETTA ST., N.W., SUITE 3100 o,
s ATLANTA, GEORGIA 30303 s
Report Nos. 50-424/81-12, 50-425/81-12 Licensee: Georgia Power Company 270 Peachtree Street Atlanta, Georgia 30303 Facility Name:
Vogtle Docket Nos. 50-424, 50-425 License Nos. CPPR-108, CPPR-109 Inspection at licensee corporate offices in Atlanta, Georgia Inspectors:
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R. W. Wrighp ->
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A. G. Debbage
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Date' Sidned Yr
/2 //c./7i N. Merriweather
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Date Signed Approved by: I /[// [!
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C'. M. ~ Upright /Shcti ~ Chief
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Engineering (p( ar 'on Branch t
Engineering and.echnical Inspection Division SUMMARY Inspection on November 17-19, 1981 Areas Inspected This routine, announced inspection involved 60 inspector-hours at licensee headquarters in the areas of the licensee's quality assurance program, design control, procurement activities, and audits.
Results Of the four areas inspected, no violations or deviations were identified in three areas; one violation was found in distribution of QA department manual procedures
- paragraph Sa.
8202050306 820201 PDR ADOCK 05000424 G
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REPORT DETAILS l
l 1.
Persons Contacted Licensee Employees
- R. W. Staffa, Manager Quality Assurance
- C. W. Hayes, Vogtle Project QA Manager R. C. Walker, Senior Engineering Assistant D. Foster, Project General Manager
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on November 19, 1981:with i-those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items
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f.
Unresolved items were not identified during this inspection.
5.
Quality Assurance Program (35060B)
.a.
QA Program Changes i
The VNP PSAR Chapter 17 52 (Post-Constructicn Permit. Supplementary
Information - March 2, 1977) Specifies the licensee's commitments for plant Vogtle's quality assurance program. Georgia Power Company (GPC)
i has incorporated certain changes to the program which have been j
documented internally. These recommended changes are being accrued for input to the licensee's next revision to the PSAR which will be sent to
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NRR for their review. The subject changes will also be incorporated in the licensee's FSAR when published.
The GPC manager of quality assurance (MQA) has a present general office j
staff of three technical personnel participating in the administration i
of the QA programs for the Vogtle Electric Generating Plant (VEGP).
(GPC is in the transition of changing the name of the Alvin W. Vogtle Nuclear Plant to VEGP).
The MQA staff has-been reduced from six members to three (reference PSAR, Chapter 17 S2 & VNP QAM, Section 1,
Fig. 1-4).
The operations QA function has been assigned to C. B.
Boatwright and two former QA staff technical personnel along with their
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job functions (supplier surveys, qualification of suppliers, codes and standards work) have been transferret to Nuclear Procurement within the Engineering Department.
VNP QAM, Figure 1-1, Project Organization Chart for Quality Assurance is to be revised to portray the current implementing organization. One of the most significant organization changes to this chart has been the creation of two new managerial positions; the Manager of Project Engineering and Licensing and the Senf or VP Engineering Construction Project Management.
These additional positions are viewed as beneft-cial to the program in that they have alleviated somewhat the work load placed upon the project general.ianager and the project executive and result in all priorities advancing in the same direction.
Various GPC QA Department Manual procedures govern the activi'_ies of the QA Department in the implementation and management of the GPC QA prog ram. These procedures apply to the QA General Office staff and to the QA Field representative's office on each plant site.
The below listed QA Department procedures were examined for changes (revisions)
implemented to verify that these changes were approved at appropriate management levels to assure that procedures are reviewed in accordance with ANSI N 18.7 - 1976 to determine if changes are necessary or desirable and to ensure document control (distribution) requirements had been effectively complied with:
QA-05-01 R4 Corporate Staff Audits QA-05-03 R3 Supplier Audit / Inspection QA-01-05 R5 Job Functions & Responsibilities QA Site Supervisor QA-04-03 R3 Inquiry / Specification Review and Approval The changes made to the above identified procedures were examined to verify that these revisions were made in accordance with the following applicable approved GPC procedures:
QA-02-03 R0 Procedure / Document Review QA-04-12 R4 QA Department Procedure Manual Control
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l QA-04-13 R2 Procedure Preparation and Control
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All revisions executed were found to be accomplished by approved appropriate management and procedures were being reviewed per ANSI N18.7; however, the controls for distribution of QA Department procedure revisions were found inadequate. Procedure QA-04-l? applies to the QA Department Manual which encompasses activities oc the QA staff in the General Office, the QA Field staff at construction sites i
and operating nuclear plants.
Paragraph C of the subject procedure states that control of the manual is accomplished through use of the Statement of Receipt (Exhibit II) and assigned manual numbers. The
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enclosed Statement of Receipt which accompanies every revision change is to be returned promptly to the sender so that GPC may be assured
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that the manual holders have received the latest information. The inspector _ examined the Statement ' Receipts for.the last three amend--
ments 19, 20 and 21 (issued 1/13/81, 5/13/81, 7/1/81 respectively) that were' returned by controlled manual holders. Receipts from controlled copies No. 5, 6, and 7 for amendment 20 could not be accounted for.
Procedure manual No. 5 (PM) which was issued to Dr. Savage of the General Office staff was examined by the inspector and found remiss 'in that the latest filed amendment of procedural changes in this manual was amendment 15. A telephone call placed to plant Hatch verified that PM No. 6 assigned to G.E. Spell Jr. was missing the amendment 20
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procedural. revisions.
At the same time, PM No. 7 assigned to C. E.
Belflower at plant Hatch had been updated with the latest revised procedures; however, either the manual holder did not follow instruc-tions and return a Statement of Receipt for Amendment 20 or the subject receipt was lost in the mailing system.
The above item of noncompliance was identified as violation 424-425/81-12, Failure to Control QA Department _ Manual procedure revision distribution.
b.
Licensee Reviews of QA Program Effectiveness A quality assurance committee (QAC) has been organized utilizing management of GPC and Southern Company Services, and acts as ' the advi sory group to the GPC Executive Vice President.
The primary purpose of this committee is to evaluate the effectiveness of the VNP quality assurance program and to recommend corrective measures to the
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GPC Executive VP where necessary.
The inspector examined the pro-ceedings of the following QAC meetings which are scheduled four times per year or on call by any member of the QAC.
MEETING NO.
DATE
02/08/80
05/27/80
09/03/80
12/04/80
04/16/81 c.
Corporate QA - Site QA Interface The QA site supervisor transmits to the PQAM copies of site audit reports, monthly copies of Vogtle's nonconformance report listing and status.
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The Senior Vice President Project Management makes periodic visits to the Vogtle site appruximately every six weeks to review the "Construc-tion Review and Status Meetings." Reports of these meetings are made available to management on a regular basis in order that they may be made aware and kept abreast of inspection and audit activities in the field. Trend analyses concerning NRC and GPC QA audit findings are presented during these meetings. The inspector was informed that such a meeting was taking place at the time of this inspection. The inspec-tor examined the minutes and records presented at the September 10, 1981 meeting.
Within this area, no deviations were identified. One violation for failure to control QA Department Manual procedure revision a M ribution was identi-fied (Paragraph Sa).
6.
Design Review - External A/E (350608)
a.
Documents Examined (1) Vogtle Electric Generating Plant PSAR, Chapter 17 (2) Southern Company Services Quality Assurance Department Policy and Procedures (3) Georgia Power Company Quality Assurance Manual, R4 (4) QA Department Procedures Manual b.
QA Program Requirements The licensee's QA Program as described in Chapter 17 of the Vogtle PSAR states that the requirements of the ANSI Draft Standard N45.2.12-1973 will be applicable to the QA program for design activities.
The procedures identified in paragraph 6.a were reviewed for compliance with this draft ANSI standard.
Within the areas examined, no violations or deviations were identified.
c.
Design Assurance Audits The objective of this inspection was to review the licensee /AE contracted mechanism and determine the licensee ~ organizational responsibilities for design assurance.
The - inspector reviewed the Georgia Power Company (GPC) Vogtle Project Organization to understand the internal and external interfaces for design.
The inspector reviewed the contract between Southern Company Services and Bechtel Power Corporation (BPC) - Los Angeles for Architectural and Engineering l
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(A/E) Services dated December 12, 1971 and as amended by letter on
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July 8, 1981. The licensee has designated Southern ' Company Services-(SCS) as the lead organization to perform audits of design quality
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assurance activities.
These audits are used to evaluate and comply with the approved QA program. The audits are performed twice a year t
usually every six months.
The Project Quality Assurance Engineer-(PQAE), Southern Company Services (SCS) is responsible for auditing BPC,_and these audits may be observed by the Project Quality Assurance
Manager (PQAM), Georgia Power Company. The audit plan is coordinated with and approved by the PQAM.
The audit reports are approved and
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i distributed by the PQAM.
The SCS/GPC audits of Bechtel for the period 1979 thru _1981 were reviewed to determine if the objective and scope established in the audit plan was accomplished, the followup on audit findings was timely and corrective action was adequate.
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Within the areas examined, no violation or deviations were identified.
d.
Design Inputs The inspector looked at the interfaces between GPC, SCS and BPC for handling NRC Bulletins, Circulars and Information Notices to assure
that the NRC requirements and positions that are transmitted to the
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i licensee are reviewed by the A/E for design input. The Project Quality Assurance Manager (PQAM) receives the bulletins, circulars and informa-tion notices from the Manager Quality Assurance (MQA), Georgia Power
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Company and transmitts a copy to BPC.
BPC will review bulletins,
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circulars and information notices for applicability to balance of. plant systems and will transmit a copy to Westinghouse and assign an action i
item for tracking. Westinghouse will review for applicability to the
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nuclear supply systems and will send their response to BPC and BPC will transmit their response to GPC.
l The inspector selected NRC bulletins 81-01, 81-02 and 81-02 Supple-
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ment 1, Information Notices 81-29, 81-25 and 81-01, and circular 81-12 for examination. The applicable correspondence between GPC and BPC was l
reviewed to ensure that the interface procedures QA-04-09, R4 and QA-05-13, R6 were being implemented.
Within this area, no violations or deviations were identified.
7.
Procurement (350608)
l a.
Procurement Organization Controls l
l Bechtel Power Corporation, Los Angeles (Bechtel) is the architect-l engineer for Ger rgia Power Company Vogtle Electric Generating Plant I
with Westinghouse being the NSSS supplier. Bechtel performs vendor i
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audits, maintains a Bechtel evaluated supplier list, prepared proposed supplier evaluation lists and procurement bidder list for Georgia Powcr Company, and provides engineering and quality assurance controls in procurement of safety related items and services.
Southern Company Services, Inc. is the lead organization for procure-ment and expediting of items and services for Vogtle Electric Generating Plant.
Southern Company Services is a member of CASE and administers supplier surveillance and conducts audits of the Bechtel procurement supplier quality department; these audits may be observed by the project quality assurance manager, Georgia Power Company.
Southern Company Services is also responsible for performing evalua-tions of items falling under the scope of 10 CFR 50.55e.
Georgia Power Company and Alabama Power Company conduct joint audits of the Southern Company Services quality assurance department.
Procedures controlling the above activities were examined to ensure that they had been prepared by the designated authority, approved by management and reviewed by the quality assurance manager. The proce-dures were reviewed to determine consistency with the commitments of Georgia Power Company PSAR. The procedures included the following:
QA-01-02,R4 Job Functions and Responsibilitiet/ Manager of Quality Assurance QA-04-04,R3 Proposal-Requisition Review / Approval QA-05-03, R3 Supplier Audit / Inspection QA-04-06, R4 QA Manual Review / Approval EPP4-20, R2 Design Contractor Controls EPP6-7, R12 Preparation of Engineering Requisitions EPP6-2, R4 Supplier Evaluation and Reevaluation for the SCS Evaluated Suppliers List b.
Procurement Document Control Several procurement documents were reviewed to ensure that:
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Applicable regulatory requiru ents, design basis, and other requirements were included or rt 'erenced
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Procurement document changes were subjected to the same level of control as used in the original preparation
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- Scope of work to be performed by the vendor identified
. Technical. requirements referenced appropriate documents
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Test, inspection and acceptance criteria identified Vendors had a documented QA program and required to incorporate QA
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requirements in subcontract documents
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Special instructions / requirements were included for activities such as designing, identification, fabrication, cleaning, erecting, packaging, handling, shipping and extended storage
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Documents identified which were.to be sent to Georgia Power Company for review and approval
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Nonconformance reporting and control specified
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Access to the vendor's facilities and records for inspection or audit incorporated.
The procurement documents reviewed included the following:
Requisition Number 1X4AR17 Main Steam Isolation Valves Requisition Number 1X4AR19 Gate Valve with Anchor / Darling Selfcon-tained Hydraulic Activator Requisition Number 1X3AJ04 Instrument and Speciality Cable Requisition number IX4AR17 was written by Bechtel and prepared on MAG cards to Georgia Power Company purchase order format.
The MAG card accompanied the purchase requisition on submission to Georgia Power Company.
The requisition was for main steam isolation valves, Rockwell equiwedge ASME class 2 gate valves with Green stored energy activators. The first page of the requisition identified that the order contained Q items. The specifica-tion identified tests to be performed such as pneumatic leak test and seismic qualification and operability test. Technical deviations to the specifications were given e.g. ANS.A5.13 Stellite 21 for hard facing seats, disks and gate. Weld repair documentation was required; QA program to be supplied; inspection hold points listed for review of radiographic film, witnessing hydrostatic test and final inspection; and free access to the work by inspection and expediting personnel specified.
Revisions to this purchase order were examined. Revision I replaced the Green' actuator with a Rockwell actuator; revision 5 implemented the requirements of 10 CFR Part 21; revision 7 deleted the seismic qualification and operability test; revision 9 required actuator qualification test data, and revision 12 dated August 24, 1981 was for a price revisio *
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Requisition number 1X4AR19 was for Anchor / Darling carbon steel gate valves with self contained hydraulic actuators. Technical deviations were that the valves should be designed, manufactured and tested in accordance with ASME Section III 1977 edition and with code cases 1567, 1677, 1773 and 1774.
Stellite 156 was to be used for hard surfacing seats and discs.
The provisions of 10 CFR Part 21 were required and seismic qualification test and seismic calculations were to be performed.
The revisions to this purchase order were examined. Revision 2 was for the addition of accumula-tors and control instruments to provide fully redundant actuators; revi-sion 8 cancelled the seismic qualification tests but added seismic analysis of valve assembly and resonant frequency search.
Requisition 1X3AJ04 was for instrument and specialty cable. Qualification tests to IEEE 323-1974 and IEEE 383-1974 were specified; LOCA qualification test and accelerated aging test to demonstrate a 40 year life at 90 C was required.
The test data was to be approved by the purchaser and require-ments of 10 CFR Part 21 were included in the requisition. Revision to this requisition were principally concerned with cable code, quantity and price changes.
The requisitions reviewed were replaced by purchase orders PA-1334, PAV-1765 and P0-5772c The MAG cards ensured that all the technical specifications and QA requirements in the requisition were all incorporated into the purchase orders and subsequent revisions to the purchase order. During this inspection it could not be verified that procurement document changes were subjected to the same level of control as used in the original preparation since this is an activity under the control of Bechtel Power Corporation, Los Angeles.
c.
Vendor Evaluation Bechtel Power Corporation maintains an Evaluated Supplier List which is updated monthly; printouts of this list are distributed to locations that do not have access to a system terminal. The list dated November 6, 1981 was reviewed; approximately 750 suppliers were listed.
It lists all Bechtel suppliers of Q-list safety related engineering equipment or ASME section III materials.
The date, results and type of most recent survey of the suppliers is given, ASME certification stamps and date of expiration are shown and other information detailed to indicate the status of supplier r
quality.
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Audit schedules of suppliers for Vcgtle Electrical Generating Plant are prepared by Bechtel two months in advance of the date due, and cover a three month audit plan.
Southern Company Services approves the audit list and l
Bechtel conducts the audits.
Monthly schedules from June 1981 through
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October 1981 were examined. Approximately 25 vendors were proposed for each j
month, indicating an audit rate of 300 suppliers annually.
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d.
Audits of Southern Company Services, Inc.
Audits conducted by Alabama Power Company and Georgia Power Company quality assurance personnel were reviewed; those reviewed were dated March 15, 1978, December 19, 1978, August 7, 1979 and September 9, 1981.
The audit conducted during March 1978 was an in-depth reaudit to verify implementation of the corrective action taken following the September 1977 audit; the corrective action taken was satisfactory to the audit team. One new audit finding concerning criteria for the maintenance of auditor qualifications was opened during this audit.
The December audit was aimed at verifying compliance t_o ANSI-N45.2.11 and N45.2.13, in addition to the review of previous findings.
Five new noncompliances were identified during the audit; these five were closed during the next audit conducted in August 1979. The audit in August 1980 identified one noncompliance and the report stated that three items remained open.
The response October 1,1980 and supplemental response November 4, 1980 from Southern Company Services satisfactorily addressed concerns identified in the August audit report. No items of noncompliance were found during the recent audit on September 9, 1981.
e.
Audits by Southern Company Services, Inc.
Audits conducted by Southern Company Services on Bcchtel Power Corporation Power Division, LA were reviewed. The audit conducted October 9, 1980 was to evaluate the adequacy and implementation of Bechtel's procurement supplier quality department surveillance program. No findings were identi-fled.
The audit April 13-16, 1981 was to verify implementation of Bechtel's Vogtle Nuclear Project Quality Assurance Program as represented in the Project Reference Manual and Bechtel QA Manual - ASME III Division 1, REV 0 with Amendment 1.
The audit team also audited the system for the review and approval of supplier quality assurance manuals.
They reported that the Project Reference Manual was in compliance with the project's licensing commitments with exceptions which were documented in four audit finding reports.
Within this area, no violations or deviations were identified.
8.
Audits (35060B)
a.
Audit Program The inspector examined the following controlling QA Department audit procedures, Regulatory Guide and American National Standards:
QA-05-01, R4 Corporate Staff Audits QA-05-02, R5 Site Audits (PQAM)
QA-05-03, R3 Supplier Audit / Inspection
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QA-05-04,R2 Audit /10 CFR 50 Appendix B Verification QA-05-07,R5 Audit Report Writing QA-03-05, RO Qualification of Auditors ANSI N45.2.12 Requirements for Auditing of QA Programs for Nuclear Power Plant ANSI N45.2.23 Qualification of QA Program Audit Personnel for Nuclear Facilities RG 1.144 Auditing of QA Programs for Nuclear Power Plants VNP PSAR (Supplementary Information - March 2, 1977), Section 17.1.18 as amended by recommended changes discussed in GPC's attachment to-internal memorandum dated February 27, 1979 details the Vogtle QA ~ audit program.-
Design audits are conducted to evaluate Bechtel and Westinghouse on the effectiveness with which they implement and comply with their respective QA programs. These design audits are conducted annually at a rainimum.
The project quality assurance engineer from Southern Company Services, Inc. (PQAE.- SCS) is responsible for auditing Bechtel whereas the Bechtel PQAE is responsible for auditing Westinghouse. The QA site supervisor's (QASS) personnel audit safety-related construction and preoperational testing activities based on a preplanned schedule which is approved by the project QA manager (PQAM).
Random, unscheduled audits are also conducted to provide a well-rounded program. The PQAM conducts an annual audit of the QA site supervisor's activities and continually monitors these activities through frequent site visits, review of QASS audit reports, daily logs and open item summaries. In conjunction with their surveillance inspections, Bechtel Procurement Supplier Department and the SCS QA Department conduct planned audits of suppliers.
The General Office 1981 QA activities schedule and the tenative Vogtle site construction audit schedules for years 1981 and 1982 were examined and discussed with the PQAM to ascertain that the QA audit program c
encompasses all internal and external organizations and extends to all
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elements of the program within a reasonable time frame. The audit team
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j size, composition and use of specialists routinely assigned from other
' organizations to the teams was discussed with QA management.
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inspector examined auditor training, experience and certifications of i
corporate level QA department personnel and found the auditors all qualified to the requirements of ANSI N45.2.23.
b.
Audit Reviews The following audits and respective audit plans were examined to j
determine applicability to the QA element audited, qualification of audit team members, that audit findings were reported to upper
management and the organization audited, corrective actions as required
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are being initiated and that there is followup and re-audit by QA as necessary:
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AUDIT DATE/0R NO.
SUBJECT (CONDUCTED BY)
04/16-17/80 Audit of QA Site Activities (Corporate QA)
11/05/80 10 CFR 50.55(e) & 10 CFR 21 (Corporate QA)
10/19-21/81 Audit of QA Site Activities (Corporate QA)
05/20-22/80 Westinghouse WRD, Monroeville Pa (Bechtel PQAE)
Implementation & Effectiveness of QA Plan 06/2-4/80 Westinghouse WRD, Monroeville Pa (Bechtel PQAE)
Implementation & Effectiveness of QA Plan GD10-81/24 Procurement (Site QA)
GD07-81/28 Drawings & Document Control (Site QA)
Within this area, no violations or deviations were identified.
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