IR 05000424/1985027
| ML20198A707 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, 05000000 |
| Issue date: | 06/30/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198A692 | List: |
| References | |
| 50-424-85-27, 50-425-85-26, NUDOCS 8511060140 | |
| Download: ML20198A707 (26) | |
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P ENCLOSURE 2 SALP BOARD REPORT
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U. 5. NUCLEAR REGULATORY i.0MMISSION
REGION II
SYSTEMATIC ASSESSvENT OF LICENSEE PERF0T+MANCE INSPECT:0N REPCRT NUMBERS 50-424/S5-27 AN 5'J-425 /S S-26 GECRG:A P0 DER CCV;ANY ALVIN W. V0GTLE bNITS 1 AND 2
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NOVEMBER 1, 1983 THROUG4 JUNE 30, 1985
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B511060140 051023 DR ADOCK O y1
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I.
INTRDDUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available cbservations and data on a periodic basis and to evaluate licensee performance based upon this infor-mation.
SALP is supplemental to normal regulatory crocesses used to ensure compliance witn NRC rules and regulations.
SALP is intence: to be suffi-ciently diagnestic tc r-ovice a rational basis for allocatinc NRC resources and to provide meaningful guidance to the licensee's manageTent to promote quality and safety of plant construction and operation.
An NRC SALO Ecard, co.cosed of the staff members listed belew, met on September 17, 1985, to review the collection of performance observations and data to assess the licensee performance in accordance with tne guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety perfor-mance at Vcgtle for the period of November 1,1983, through J;ne 30, 1985.
SALP Board for Vogtle:
R. D. Walke, Director. Division of Reactor Projects (DRP), :.egion II (RII) (C airnan)
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII A. F. Gibson, Director, Division of Reactor Safety'(DRS)~, RII
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D. B. Vassallo, Chief, Cperating Reactors Branch 2, Division of Licensing (DL), Office of Nuclear Reactor Regulation (NRR)
V. L. Browriee, Chief, Projects Branch 2, DRP, RII Attendees at SALP Bearc Meeting:
M. V. Sink.'e, Cnief.
cjects Se:: ion 2D, DRP, RI:
M. A. Mille,
0- je:: *'a na ge r, L' censing Branch 4. :_, NRR
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J. F. ;og;e. Se-icr ;+;' cent Inspe: tor, Ve; tie, CR:
RII R. J. Scre:+ns. Res':e : Inscector, Vogtle,
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W. H. Rant',
- je:: E gineer, Projects Se :icn 2E. DRP, R::
M. W. Bran:, A::inc C 'ef, Tecnnical Supp:-t Staf' (TSS), C;, RII T. C. MacA-hur, R;d'a ion Specialist, TSS DRP, R::
G. A. Belisle, Acting Cnief, Quality Assurance Frog am Secti:- (CAPS), DRS, RII J. J. Blake, Chief, Materials and Processes Sectier (MPS), DRS, RII J. J. Lena an, Reacter Inspector. Test Program Section, DRS, RII S. J. Vias. Reactor Inspector, MPS. DRS, RII W. H. Miller, Reactor Inspector, Plant Systems Section, DRS, RII R. W. Wright, Reactor Inspector, QAPS, DRS, RII
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II. CRITERIA Licensee performance is assessed in selectec functional areas, depending upon whether the facility is in a construction, preoperational, or operating
phase. Each functional area normally represents areas which are significant to nu: lear safety and the environment, and which are normal programmatic areas.
Some fun:tional areas may not be assessed because of little or no licersee activities or la:L of meaningful ecsersations.
Special areas may be added to highlight significant observations.
One er more of tne following evaluation criteria were used to assess eacn functienal area.
A.
Management involvement and control in assuring quality B.
A;oroach to resolution of technical issues from a safety standpoint C.
Responsiveness to NRC initiatives D.
Enforcement history E.
Reporting and analysis of reportable events
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Staffing (including management)
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Training effectiveness and qualification l
However, the SALO Board is not limited to these criteria and others may have
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been used where appropriate.
Based cron the SALP Board assessment, each functional area evaluated is
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classified into one of three perfor.rance categories.
The definitions of these' performance' categories are:
Cataccry 1:
Recuted NRC attention may be apercpriate. Licensee management attentien and involvenent are aggressive ard oriented toward nuclear safety; licensee resources are ample and effectively used so that a bigh level of perfc-rance with respect to operational safety or construction is being achie sc.
Cate:: ;. 2:
NR: attertien snculd be mair:a' e: at n:rral level s.
Licensee nana;e e-t atte :'en and involve ent a re e,'
ent ard are cr:erned w th
nuclear safety; 'icensee resources are ace:. ate and are reascrably effective so : at satisfa:tery performance with resre:: to cperational safety or const :t'on is :eing achieved.
Cate:: y 3: Bot. NRC and licensee attenti:
should be increased. Licensee managerent attention or involvement is at:ectable anc considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or cct effectively used so that minimally satisfactory performance with respect to operational safety or constructior is being achieved.
The SALP Board has also categorized the perfermance trend over the course of the SALP assessment period. The trend is teant to describe the general or prevailing tendency (the performance gradient) during the SALP period. This cate:orization is not a corparison betweer tne current and previous SALP ratings: rather the categori:ation process involves a review of performance
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during the current SALP period and categorization of the trend of cerfor-mance during that period only.
The performance trends are defined as follows:
Improving:
Licensee performance has generally improved over the course of the SALP assessment period.
Constant:
Licensee cerfcrmance has remained essentialjy censtant over the course of the SALP assessment period.
Declinin;:
Licensee performance has generally declined over the cou se of the SALP assessment period.
III. SUMMARY OF RESULTS Overall Facility Evaluation The licensee continues to implement a vigorous construction project management effort with well cualified and experienced personnel.
Licensee programs have been effective in the identification and resolution of problems.
Major strengths have been identified in the areas of Soils and Foundations, Safety Related Components - Mechanical, and Quality Programs and Administrative Controls Affecting Quality.
No major weaknesses were identified.
The licensee has taken the initiative and implemented two programs which appear to be ef fective: "the Quality Concerns Program; and, the Readiness Review Program.
The Quality Concerns Prograc was initiated by Georgia Power Company in December 19S3 to enhance the ability to assure a quality power plant and to af forc encloyees an acd'ti:na'. avenue to pursue their concerns anon >rously or in cen'icence.
Georgia cwer Ceepary (G;:)
as imple ented a Readiness Review Prc;-am for Vogtie 1.
This pro;-a cc 3 3:s of a review of the design, corst.ction, anc :ne c-soaraticr for c;e-2:fon tc cetermine tne a;plicant's p-eoa-ecness
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to receive an opera:'ng licerse. GPC ranagement has cemonstratec irftiative ir under:a.ing the Reaciness Review Prcgram.
It indicates a keen ma-agement interest ard participation in :ne construction of the plant and represents a significant increase in mara;ement involvement in tne quality of the plant.
While implementing the program, GPC has been responsive to NRC questions and concerns expressed as part of the NRC program review.
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Nov. 1, 1982-Nov. 1. 1983 Oct. 31, 1983 June 30. 1985 Trenc During Category Category Latest SALP Functional Area Rating Rating Period Units 1 and 2 A.
Soils and Feundation
Constant
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B.
Containment. Safety Related Structures anc Major Steel Supec s
Imorovic; C.
Piping Systems and Supports
2 Not Determined D.
Safety Related Components -
Mechanical
1 Constant E.
Auxiliary Systems Not Rated
Constant
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F.
Electrical Equipment and
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Cables
2 Improving G.
Instrumentation Not Rated NO: Rated Not Rated H.
Quality Programs and Administrative Controls Affectic; Quality
Constant I.
Licensing A :ivities
2 Constant
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IV.
PERFORMANCE ANALYSIS A.
Soils and Foundations 1.
Analysis During this assessment period six inspections were performed Oy regional inspectors in this area. Additional inspections in inis area were also performed by the resident inspectors.
The inspectors reviewed quality assurance implementing procedures and specifications, o0 served backfill operations, examinec calibration controls on soil testing equipment, examined quality records cocumenting inspection and testing activities, and discussed backfill operations with QC inspectors to verify that they under-stood specification and procedure requirements.
The inspectors also examined the settlement sursey program utilized by the licensee to monitor settlement of Category I and other major structures.
Specifications and procedures being used to control the backfill met FSAR commitments and industry standards. Work activities were cerformed in accordance with procedure and specification requirements, and testing was done with equipment having current calibration data. Discussions with QC inspectors indicated that the inspectors were knowledgeable in specification and procedure requirements and that they were documenting their inspections on applicable documents.
The ongoing settlement monitoring program is being done with precision instrumentation and First Order, Class 2 survey rethods, a technique which exceeds ncrmal industry practices.
In addition to the routine backfill inspection and testing program, Georgia Power has done additional sampling and testing of the backfill and, also at the request of NRC, engaged an independent testing lacoratory to provide additional assuran:e tnat the backfill program complies with design requirements.
- nspections related to foundstion work were limited to Unit :
- iesel Generator Eaiidin; base slab. Proper placement activit'es eere noted.
Vanagement involvement. resolution of technical issues ac staffing were acecuate for tne level of activity involved.
No violations or ceviations were identified.
2.
Conclusion Category:
Trend: Constant
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3.
Board Recommendations i
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j The Board notes the licensee's effort in the area of settlement j
monitoring as a strength. Appropriate management attention was
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applied to this area.
No change in the level of NRC staff resources
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applied to the routine inspection program is recommended.
B.
Cor.tainment, Safety Related Structures, anc Major Steel Supports 1.
Analysis - Concrete Structures Structural Steel and Containment Post Tensioning During this assessment period routine and special team inspections were performed by regional and resident inspectors.
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j inspections by Region II inspectors involved review of QA imple-menting procedures, observation of work actisities and review of records for reinforced concrete structures, structural steel
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and post tensioning operations.
Special team inspections by Region II inspectors and reviews by NRR and Office of Inspection and Enforcement (IE) were performed i
to evaluate the Readiness Review Procram (RRP) being conducted by
Georgia Power as an additional initiative te provide assurance j
that the program for reinforced concrete strc:t'_res complies with
FSAR commitments.
These inspections of RRP included an in-depth review of licensing commitments, verification that construction and design commitments were being implemented in project documents,
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i and verification that records were representative evidence of i
quality controls.
These inspections also showed that FSAR commitments were being implemented in the project specifications
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and pro:edures and that work was performed in a:ccrdance with the specifications and crocedures.
Evaluation of :ne RRP for rein-
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'orcir.g cencrete snewed that 'the review perfer ed by the Georgia ower Readiness Review staff was comprehensive i. scope and depth j
and tnat the OA/CC cecgram for reinforced c: c ete complies with i
- SAR cc--itments.
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l Reviews of trainir; snowed that a comprehenshs training program nad bee-provided 'or the craf tsmen in the a ea of concrete clacements.
Oase vation also showed that "piedglas" forms were
ceing usec in areas of difficult piacements s: :nat the consolida-
-ion of the concrete could readily be observed.
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Post tensioning activities, consisting of prog-am review, tendon j
sulling, tenoon stressing, and greasing of tne vertical tendons
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installed were observed.
It was noted that ne licensee had
provided program overview of the contractor in the form of GPC QC
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coverage in addition to the contractor's QC, and by obtaining a knowledgeable consultant to enhance post tensioning experience of
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tne contractor.
Ir. addition the GPC OA organication had performed i
an audit of tendon activities and recommended irarovements to the program.
These recommendations are currently being implemented.
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Management involvement in resolution of technical issues, staffing and training were adequate for the level of activity involved.
The inspections noted tne presence of acequate QA/QC coverage during the work process.
One strong point in the licensee's program was the use of Area Coordinators to control the many simultaneous work activities.
No violations or deviations we-e icentified.
2.
Analysis - Welding and Nondestructive Activities One special and several routine inspections were performed by regional and resident inspectors during the evaluation period.
The inspections involved observation of welding and nondestructive activities including repair welding on containment pipe support racks; and review of QA implementing procedures, design drawing revisions, fabrication procedures, and quality records.
Five violations were identifiec in this area during the inspection period; two involving the control of special processes (welding)
and one in each of the following areas; corrective action, revision of design drawings, and failure to follow nonconformance procedure. The violations were not indicative of a programmatic breakdown.
The three administrative-related violations were primarily the result of unusual complexity of design drawinos for the containment pipe support racks in relation to other ongoing work.
The two welding violations were the result of failure to follow procedures which are adequate to implement the licensee commitments. With exception of the identified violations, work activities were found to have been performed in accordance with QA and QC procedure requirements: OA and QC procedures were found to meet NRC requirements; and CA records were generally complete, well maintained and retrievable.
Management involvement, resoluticn of tet"nical issues, staffing, anc training were adeauste fc : e level c' activity 'nvolved and tne licensee was resconsive in correcting the violations icentifiec.
The following five viciations were identified:
Severity Level IV violation for failure to control welding a.
(improper identification of a welder and electrodes during pipe rack structural welcing).
b.
Severity Level IV violation for failure to incorporate corrections in revisions of design drawings resulting in undersize fillet welds being specified for pipe rack struc-tural connections.
c.
Severity Level IV violation for f ailure to follow noncon-formance procedure in that repair work was initiated on a cracked weld while it was in QC hold status.
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d.
Severity Level IV violation for failure te adecuately accomplish corrective action resulting in uncersi:e fillet welds on structural steel pipe rack connections.
e.
Severity Level V violation for failure to address all essen-tial variables in a welding procedure.
The following ceviation was also identified:
Deviation for visual weld inspection criteria not in conformance with applicable code.
The licensee response to this deviation is curre-tly being evaluated.
3.
Conclusion Category:
Trend:
Improving 4.
Board Co=ents Licensee resc eces in this area were appropriate.
The Board recom, ends tna. NRC staff resources applied to e routine
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. inspection program be maintained.
C.
Piping Systems and Supports 1.
Analysis Inspections were cerformed by the resident and reg': ai inspection staffs.
Adait'
ally, a special inspection was ::-: acted to folicw;p an irve stigation which was perforned by t a '.:.C Of fice of Invest'caticrs. and a tea ~ insection was ccnducts: :: fcliewap conce~s whi:n aere expressed by piping and welci ; " s;ectors.
The irspections incluced the review of programs a*: :-ocedures, interv'ews wit-site personnel, observaticn of w: - activities, and a review of cecords.
Work activities inspected included:
the control c#
aterials by GPC and by the piping contractors, design activit'es of the licensee's Architectural Engineering firm and the '. : lear Steam System Supplier; installation and inspection activ' ties; preser-vice inspection activities of Southern Company Se vices; and the control and coordination activities of GPC.
Record reviews included:
final design documents (crawings and calculations); and, the final weiding and hanger inspection records.
Visual inspections were performed of tne installed materials for conformance to design and inspection criteria. The
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visual inspection activities included as-built verification walkdowns of a number of piping systems by the resident inspectors and visual inspection of a number of piping welds and pipe supports by regional based inspectors.
Management involvement in assuring the cuality in the area was
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There was esicence of prior plannir; and assignment of priorities.
Records were generally complete, well raintained, and available.
Knile there were fif teen violations icentified curing this rating reriod they appear to be spreac out over the various disciplines and do not indicate a programmatic breakdown in any one area.
Violations (a), (c) and (e) identified some minor design issues.
Violations (b), (c), (f), (h), (i) and (j) identified problems in anchor bolt, pipe support, and hanger installation and inspection.
Violations (g), (m), (n) and (c) identified minor problems in the area of welding and violations (k) and (1) involved nondestructive examinations.
This number of individual problems in the implementation of c ograms and procedures is fairly typical for the level of work activity by the licensee and inspection activity by NRC.
ifteen viciations were identified as follows:
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(a) Severity Level IV violation for inadequate design control for support design.
(D) Severity Level IV violation for inadequate procedures for installation and inspection of pipe supports.
'c)
Severity Level IV viclation 'or inadecuate control and installation of rock bolts.
c) Seve-i:3 Level IV violatien #c
'-acequate cesign co :-ol of cite succort design calculatio 5.
(e) Severity Level IV violaticn fc-inadequate design certrol of fil'er plates with pipe straps used in support installations.
(f) Severity Level IV violation for failure of pipe support field installation and fabrication procedure to provide for control of welding quality.
(g) Severity Level IV violation for visual inspection of weld joint configuration on safety-related piping.
(h) Severity Level IV violation for failure to follow procedures for nanger installation and inspection.
(i) Severity Level V violation for failure to follow procedures for hanger inspection.
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(j) Severity Level V violation for failure to follow pre:edures for hanger and structural steel inspections.
( k) Severity Level V violation for failure to follow a precedure for ultrasonic thickness measurements.
(1) Severity Level V violatie-for failing to have a prc:ecure to ensure that u!:rasonic examination blocks are prc:erly identified and controllec.
(m) Severity Level V violation for failing to follcw pre:edural reouirements for marking wire brushes and grinding wneels used on reactor coolant system piping.
(n) Severity Level V violation for failing to follow fit-up inspection procedure for reactor ccolant pressure boundary piping.
(o) Severity Level V violation for failing to follow precedure for control of welding cc samables.
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Conclusion Category:
Trend: Not Determined 3.
Board Comments:
Licensee rescu-ces in this area was appr:priate.
The Board recommencs that NRC staf f resources applied to the reutine inspection pregram be raintained.
D.
Safety Related Ccmponents - Mechar':al 1.
Analysis
- nspections were :: :.::ed r+;a-cing st:-age of safety-e ated
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ecuipment, 'it.p cf e Ur.i:. <eactor vessel ir:ernals. c esel
- e ne ra tor urgrace
- :; ram, a: installaticn of reactor :::iant pumps.
The proce u es and : rtrols u:"lized to perform tne fitu :# the reactor vessel internals demonstrated that the licensee was well prepared.
Proper management i volvement was apparent at :ne time of the fitup. During a secor: #itup operation one violatien was icentified where twc dissimila metals were allowed to c:ntact es.c h other.
Tne licensee was very responsive in immediately correcting the problem. Overall, the actual fitups conducted were judged to have been performed with extreme care and deliberateness as this task mandates.
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The placement of the four Unit I reactor coolant pumps and motors also demonstrated the licensee's ability to handle complex tasks.
Tne licensee was prepared and staffed to properly execute the required procedures.
The above two examples collectively demonstrate the licensee acility to plan and execute major events ir a timely fasnion.
The storage of safety related equipment was found in most instances to be adeauate.
On occasion, it was noted, craft personnel had not fully restored protection coverines following work. The licensee's program ensures that e::uipment is inspected periodically for storage and preventive maintenance to improve protection of safety related equipment.
The licensee has cor.tinued to demonstrate a technically sound and thorough approach to resolving the trechanical problems with the diesel generators.
The licensee completed direct inspection activities on the diesel generators based on the interim TDI Owners Group recommendations and performed evaluations of defi-ciencies in a timely manner. Near the end of the appraisal period the diesels were undergoing a similar program to incorporate final recommendations.
Licensee management's direct involvement with tne TDI Owners Group has been extensive in resolving the relia-bility issues.
This characteristic is indicative of a proper safety outlook.
One violation was identified:
Severity Level V violation involving failure to prevent contact of dissimilar metals.
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Conclusion
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Trerc:
Constar.
3.
Ecarc Recommencations Licersee resources in this area were ao opriate.
Licensee management should increase the awareness by area cecrdinators and craf t foreman to improve the protection of safety related
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equiement in storage.
The Board -ecommenos that NRC staff resources applied to the routine inspection program be maintained.
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E.
Auxiliary Systems 1.
Analysis - Fire Protection / Prevention Systems During this assessment period inspections of the construction site fire protection program and the permanent fire protection features were conducted by Regional based inspectors.
Additicnal inspection in this area was also performed by the resident inspectors.
Fire prevention crocedures and the surveillance inspections anc tests of the corstruction site fire protection systems and equipment were satisfactory.
A well trained construction site fire brigade composed of volunteers from the construction and security groups was provided for all shifts.
The permanent plant fire protection features reviewed during this assessment period included the fire pumps, fire protection piping system, automatic sprinkler system, and fire dampers. Two of the three fire pumps have been turned over to operations. A number of fire pump installation discrepancies have been identified by the
operations group which are to be corrected prior to fuel load.
The fire protection systems were being installed during this assessment period.
A corteactor's QC program was in e#fect te verify that these systems were being installed in accorda ce witr the construction crawings.
However, a procedural violation was identified in which the licensee's -'QC-' organization was not documenting the Q: surveillance inspections of work activities ir.
this area as stipulated by cne of the QC procedures.
Subsequently, the licensee revised the procedure to clearly defire the surveillance 0: progra-as a suoplemental activity to the normal or basic ccrstruct'on QA/C: progran perforred ny the contractor which 's the ;r:; ram to verify that the corst uctic-activities neet t*e acplicacle const action documents.
- nstallation of : e auto a 'c scririier systems was in : e ear',
stages of constra::':n An assesorent of the contrac:cr's cesi;-
'nstallation and testing ce: gram was not made. However, seri#ica-tion was made t-at trese systems are to be cesigned and cor.structed under a contractor's CA QC program that hac been reviewed and accepted by the licensee.
An insoection of fire darrer installations indicated that ir general the dampe s were nc being irstalled in accorcance witr the manufacturer's instaliation instructions. The licensee state that the installed dampers met the construction design documents and approved tested damper configuration.
However, records were not available to substantiate this position. A review of the fire camper 0A/QC prograr appeared to indicate that all of the requirec QC inspections and tests were not being performed. QC data was reviewed for 10 dampers.
No data was available on four dampers and the data on the remaining six was inadequate or incomplete.
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Since the plant was not licensed, this issue was identified as an unresolvec item.
The fire protection features at Vogtle are in the early stages of construction and installation, except for installation of the exterior fire protection water system which is practically ccmolete.
No major discrepancies were icentified curing this assessment period in ne water piping system installation.
The practice of perforning surveillance inspections on the fire water protection system was noted as geoc practice.
However, performance of these surveillances was not properly docurented.
The technical resolution by the licensee was considered not to be conservative when the licensee determined that this item was not part of the QA/QC program and the requirements to formally document the activity were deleted. Upon further discussions with NRC, the licensee upgraded its position to provide for written documentation.
One violaticn was identified in this area.
Severity Level V violation involving the failure to document the licensee's QC surveillance of work being performed by the fire protection water system contractor.
i 2.
Analysis - heating, Ventilating, Air Conditioning Systems
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During this assessment period inspections of the installation of safety-related HVAC supports and equipment were conducted by regional-based inspectors.
The insoect'cns included the review of programs arc procedures for installati
. welding, and inspection; coservation of work activities: 'nterviews with site personnel, and review of records.
Yarage er;
'-volvere-t.
resolution of techrica'
issues and
- -airing a:: eared te ce adequate for the level :f safety related activity :cie ved.
Cne viciatice involv' g welding containec twc examples 'where
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informatier supplied to welcers was not censistent with the welding va-iables specified in the applicable welcing procedures.
(Variables involved were shielding gas flow and allowable arperage.) This was an indication that the cortractor needed to cay more attention to ne details of the requirerents that make up a quality program.
(See Section B.2.a)
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Conclusion:
Category:
Trend: Constant
Board Ccmments The Board noted a weakness in the area of fire pump and fire damper installations.
It apoears that additional management attention should be given towarcs the irstaliation of all of the fire protection features to assure that tnese systems will be properly installed and tested.
The Board recommends that NRC staf f resources applied to the rcutine inspection program be maintained.
F.
Electrical Equipment and Cables 1.
Analysis During this evaluation period inspections were performed by resicent and regional inspecto-s.
The areas examined were electrical cable installations a-d terminations, electrical components and systems installat'or and storage, protective relay settings, storage of electrical cable caring installation, employee training and licensee control of contractor activities.
Additional special inspections were conducted in response to empicyee concerns regarding Qi 'CC activities relating to electrical construction.
The installation of safety relatec cables was one of the major activities curing this evaluatice perict.
The licensee had identified a weakness in peccecres c: t-alling activities cerforred by tne electr' al cc t-a: tor arc centract pe-sonnel.
The corrective action to correct :-is wes. ess, however, aas not
- f suf'icient cepth to ::-rect : e :-:ble-
,is resulte: in two
.iciations (g and h bel:v.) teir: ':e :is: bj the N;C re'ating to
.he f ailure to use prc:er metness #:r pr::er re revisions and the f ailure to provide ade:aate tra' ' g fc-c tract QC electrical inspectors. During follev up irs:s:tions these areas, a noted
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cifference in nanagement's iraci,e er.
relating to safety related QC inspection activities was idertifiec witn the start of a reorganization of the CC cepartmer.: wnich nas continued dJring the latter months of this evaluation re-icd.
During inspection of the installation anc calibration of electrical equipment and components, a violation was identified involving management's failure to establish a documented QA program for design activities performed by the System Protection Engineering Section which is res:Onsible for the selection, application and set point deter.Tination of protective relays and other protective devices.
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The licensee has continued to expend adequate protection for inplant equipment storage.
This was an area of weakness noted curing the previous evaluation period and was considered resolved.
However, with the start of electrical termination work the protective covering of cabinets became a problem as identified in a violation for failure to protect electrical equipment. In this time f rame management also committed to improve the storage of cable reels movec into the power bluck for cable installation.
Followup inspections cid not identify furtner problems in this area.
During this esaluation period, seseral employee concerns were examined. The employee concerns were submitted to the NRC staff on several occasiens by different personnel. Many of the concerns were similar in nature of ten addressing the same problems.
The concerns were spread over z broad spect um of both safety and non-safety related activities and in many cases supervisor to employee related.
Several concerns were substantiated but lacked safety significance.
Other concerns were substantiated and resulted in violations in QC records, component installation, and procedure adequacy and co~pliance.
Concurrently with the receipt of the concerns and inspection by NRC, the licensee's quality concerns program had detected the increase of electrical QC related problems and hac formed a task force to review the area. As a result of the task force iecommendations and NRC firdings, the licensee has ree ganized the electrical QC group by reducing the supervisor to em;loyee ratio to improve communication and created a technical support -group reporting -to - the QC manager.
The technical suppert group will develop adequate inspecto" procedures, provice technical expertise to QC inspectors, and act as a technical resolution entity between Engineering anc the QC inspectors.
Overall, the a:ity of the licensee to trend anc cevelop corrective acti:-
as considered a strong point.
H never, the a
initial electrica' prcgram was considerec weak.
As a result of this weal ess,
.:' 'ations were identif'ed for failure t; cefire engineer'rg
- -9 :ation to e:uipre.t.
rovice ace:; ate instruct 0ns i
"0:ecures to dis;0siti On r.c 00nform'*:g "e;Crts,
and imorc;er asse Cly of safety related cattery racks.
The following e'ght violations were ider.tified:
a.
Severity Level IV violation for failure to protect electrical ecuipment cu-ing installation.
b.
Severity Level IV violation for failure to establish a documented QA program for safety related work done by protection engineering.
Severity Level IV violation involving an inadecuate procedure c.
for the installation and inspection of cable supports in electrical penetrations.
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d.
Severity Level IV violation involving instructio s for acceptance / rejection of ceviation reports.
e.
Severity Level IV violation for failure to disposition Deviation Reports in accordance with procedures.
Severity Level IV violat'on for f ailure to assemble battery racks in acccrcance with accrosed irstructions.
g.
Seve-ity Level V
violation involving training and indoctrination of electrical contract QC personnel.
h.
Severity Level V violation involving changing of procedure requirements by memorandu-2.
Ocnclusion Category:
Trend:
Improving 3.
Scard Com ants Licensee resources in this a ea were appropriate.
The Board recommends that NRC staff resources applied to the rcutine
'rspection crogram be maintai-ed.
G.
Ins: urentation 1.
A alysis Ne inspections were performed in this area during this evaluation ce-icd.
2.
- clusion
- :: E.ated
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3.
E: arc Co- + :s
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H.
Qual'c;, Programs and Administrative Controls Affecting Quality 1.
Analysis During this evaluation period, routir.e inspections were performed by the resicent and regional inspection staff.
The licer.see has ceronstrated sound technical cecision taking commensurate with cuality assu-ance concerns.
Tnis was cest exemplified Oy the licensee's response to Quality Concerns raised by several l
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electrical QC inspecte-s.
As a result of these concerns, the licensee proceeded in a diligent fashion to assess the root causes and implement effective corrective action.
The effectiveness of the corrective actions are still under evaluation but appear favorable at this time.
Tne regional QA specialists specifically includec the folle 'rg areas in their inspe::icrs activities:
in-depth inspection Of piping / welding, civil / structural, electrical / instrumentation work performance; onsite design activities; nonconformance controls; procurement, receiving, and storage; conduct of audits, cnarge requests and change netices; 10 CPR Part 21 requirements: litersee actions on enforcement matters; and, licensee actions on presicusly identified inspector followup matters.
Recognizing that a grc ing number of employees at sarious reactor sites around the country are questioning the quality of werk carried out, GPC manacerent decided to establish a highly visicle Quality Concern Prograr at Plant Vogtle.
If an employee cannot receive a satisfactory answer from their supervisor regarding a concern, or from other established methods or is hesitant to use these options the Quality Concern Program has been establishec to resolve the concern. Inis program allows an employee to voice a concern without risk cf reprisal.
The establishment of sucr a program which goes bsjond the licensee's normal accepted Ci program further exempli #ies management's commitment to build i' ant Vogtle in a quality manner which meets.or exceeds all regula cry requirements.
Significant corporate QA organizational changes were impleme :ed during this assessment -oriod.
Tne licensee elevated the position of General Manacer, Q.
ty Assurance and Radiological Health and Safety to Vice Presice : and Quality Assurance General Ma a;e.
Tnis position nange sem es to nighlight the emphases arc -:'e tnat the licensee wa :s Quality Assuran:e to take.
A sec
significant cha.ge was
'n shif ' ; the Plant Vogtle QA Mara;e-(VOAM) and QA staff :: tre site.
Inis r ve has been e+ re + j eeneficial in elimira:' ; communication and travel ceiays
':n coulc hamper QA effe :'.eness. Ci<ectly reporting to the V;iv ae the QA Site Managers #:r Cons:-u: tion (CASMC) and Cperatic 5 (QASMO).
Tne sti rd s';-i f! ant crange irvolved establisnmer: of tne OASM3 posit'on. T ese QA organization changes are incica:'ve of a desire to achieve cirect project invcivement at all levels of the 0A organization.
Cc4ncident with the movement of corporate level QA staff to the ;cbsite was the movement of the Vice President and General Manager (VPGV.) for tne Vogtle Project and staff to the site.
Inis change of the VPGM to the jobsite ras provided additional cc porate control in the prompt resolution of several site problems. The VPGM has been so directly involved and beneficial that the ideensee nas redirected the Senior Vice President (SVP) from V:gtie Froject to the site. Both the SV and VPGM are exercising tneir aut;writies to ensure the project is completed in a quality and timely fashion.
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There has not been any indication of QA programmatic b-eakdowns.
However, as evidenced by the number of NRC violations, employee concerns, and licensee deficiency reports identified in the electrical area (See Section F for violation listing and further discussion) it appears that sufficient management oversight was lacking in this area.
QA has proceeded in a diligent fashion to assess and implement corrective action to resolve roo: causes.
Howeve, the fact that QA audits and sun Eillar.ces Cic not identify weakness in the electrical area indicates tnat possibly cast audits may have been too shallow or not broad enougn in scope to icertify these problems first.
Staf fing of QA positions continues to be adequate for the status of ccnstruction.
The QA positions and respective authorities are well defined and have sufficient organicational indepencerce from cost and scheduling.
These personnel are adequately trained and understand the authority and responsibilities of their pcsitions.
The licensee has been responsive to NRC initiatives. Violations identified in the QA area have been promptly addressed,
"oroughly evaluated to determine the full extent of the deficiency, properly corrected, and acticos have been satisfactorily taken tc preclude recurrence of similar problems.
The methodology arc logic approacn taken to complex violations a and b identifiec below is typical of the scurd technical decision rakirg that as been r
appliec to Vogtle QA findings.
Procurement, receiving, storage, and onsite design activities were revieaed and found generally well controlled, dccumentec troperly, and reeting regulatory requirements.
The pesting of recuirements (Form NRC-3 and 1C CFR Par: 21) were fcunc aceauately cisplayed on the constra:: ice sice c the e
orcje::, but were found lacking in operaticr staff a-eas (See vicla ':- d.).
- ou-J
- 'ations were idertified:
a.
Se,erity Level IV viclation c o r.c e rr i r ; ; ree CA a.:'ts that ae-e not coc. rented, issued, or foilta,: in acccrca ce with A',5 : N45.2.12 requirements.
b.
Severity Level IV violation concerning incomplete cc-rective action for closure of audit findings.
c.
Severity Level IV violation for failure to establisn access control measures for the instrumentation satellite warehouse on top of the control building.
d.
Severity Level V violation for failure te post For t,RC-3 and 10 CFR Part 21 information in three operation staff areas.
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j 2.
Conclusion Catego ry :
Trend:
Constant 3.
Board Comments The Board notes the initiatives and the extra effort the licensee has taken regarding establishment of the Quality Concern Program.
This orogram is not required; however, it has Deen effective in the identificatien of problems in the electrical anc piping areas.
The Board recommends that it would be prudent for the licensee to pursue why the normai Quality Control / Assurance Program had not identified the problems in these areas.
The Board recommends that NRC staff resources a'piied to the routine inspection program be maintained.
I.
Licensing Activities 1.
Analysis Licensee management was aware of the open issues during the review process. Appropriate levels of management were involved to assure timely communications and gene-ally prompt resporses to staff
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cencerns.
Cecisions were usaaily made at a level that ensured adequate management review.
prior planning and assignment of priority was usually demonstrated.
In particular, management involvement was evider.t in preparation for the structural audit and the mechanical engineering review meeting both at the archi-tect/ engineer's offices.
Prior planning for both of these meetings contributed greatly to productive discussions between the appli-cant and staff Management rvclvement was especially evicent in
key review areas on t:gtle sucr as reactor systems, hydrolcgy, and ge: technical engineering.
Accitionally, Cecrgia Power C pany raragement has initiated the V:;tle operational reau; ness review cr: gram to ass;re i tself arc re NRC tFat Vcgtl e L'ni t 1 mill be reacy for caeratior.
Tne applicant's procosed resciutions to open and confirratcry isrues were generally tecnrically sounc and conservative.
The applicant understood staff positions and usually approached resolution of issues based on technical merits and not solely to expedite the licensing precess.
Areas where the apclicant proviced sound acercaches to resolution in a timely ranner incluced instrumentation anc controls, hydrology, reactor systems, and effluent treatrent.
Although the applicant's responses were usually timely, they sometires lacked detail.
The applicant's responses to open items and staff questions have been generally timely and thorough. Sufficient care was not always taken in FSAR amendments because sometimes revisions conflicted with other portions of the FSAR. In the area of licensee qualifications, the
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applicant has not always demonstrated a level of understanding of the issues that the staf f would expect of a utility with an operating plant.
The applicant has expressed a willingness throughout the review period to discuss various issues with the staff to achiese reso-lution.
Tne aopiicant has been especially responsive to tne numerous staff questions in the reactor systems a rea.
At the beginning of the assessment period, the staff was having cifficulty in obtaining resolution of issues in the geotecnnical area.
However, curing the later part of the assessment period the applicant has cisplayed a willingness te r ovide technically sound and thorough solutions acceptable to the staff.
NRC initiatives were also. addressed well in the-areas of mechanical engineering and effluent treatment.
Responsiveness was sometimes lacking in the fire protection area because responses were not always timely.
The applicant is generally responsive te staff concerns in the area of emergency planning but the responses of ten do not contain adequate detail and clarity resulting in cifficulty in resolving issues.
In most instances, the applicant has appropriate staf f available to address and respond to NRC issues and concerns.
In the FSAR, the applicant has defined adequate staf#ing for licensed and nonlicensed personnel.
Additionally, c:erational staffing is fairly well along for this stage of plant completion.
The applicart's training and qualificaticn program is fairly well cefined as cescribed in the FSAR.
The pregram should be able to provide and maintain qualified personnel.
With respect to security procram, there was evicence o# prior planning by 9e applicant. Respcnses rega-ding sa'e;;a-cs matters were genera' b te:hnical'y sound and cons' stent, ce :nstrating the existence o' ::licies a-d pr:cedures fc-centrol Of se:urity rel a tec a:t', ' ti e s.
So'ations to techr':al safe; 2-ds :-cole s aere generaib sound. timely and conse.ative, '*cicat'ng an
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uncerstancir; :# :ne issues. Resolutions.ere sub-ittec ; omptly, and in most cases were acceptable the 'frst ti e.
Se:urity organicatior c sitions and responsibilit'es are identif'ed and defined.
Security staffing level is ade: sate to implement the security prctection program.
2.
Conclusior Category: 2 Trend:
Constant 3.
Ecard Comments The conduct of activities in the area of licensing showed a proper concern for ruclear safet e
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V.
SUPPORTIN3 DATA AND SUMMARIES A.
Licensee Activities Between October 31, 19S3 and June 30, 1985, the construction project progressed from 52% to 67% completion.
Unit 1 and common areas prog essed from 61% to 82%; Unit 2 was 47% comriete. Staffing for the prcject has remained at a high level.
Work on the containment buildings continued to progress.
For Unit 1 the concrete placements were completed and the installation of tendons has commenced. All major piping had beer completed inside containment and milestones of reactor vessel internals and head fitup had been accomplished as well as the installation of the reactor coolant pumps.
The first safety-related flushes have been completed.
For Unit 2, the major activities were the placement of the reactor vessel, steam gene ators and containment dome.
Currently, progress is being made toward completion of the dome concrete work.
Progress in the other power block buildings has continued with the major emphasis on Unit 1 pipe, pipe supports, electrical cable instal-lation and termination work and HVAC installation.
System completion for construction acceptance testing has started. The diesel generator building has been essentially completed and ;;rtions of the diesel support system had been turned over for testing.
Turb4 r.e building work has continued to progress' with major empnasis on the steam supply system for Unit 1.
General Electric Company is working rapidly toward final completion of the turbine installation.
Stea cnetical cleaning of the main cer. denser has begun.
Seve-al support buildings such as the Mai tenance, Service, and Nuclear Ope-stiers Warehouses have been cc pleted anc olaced in operation.
Ccm; etien of the Security Euilding is i n progress.
Nersifety related structu-es su: as : e colir; : eers for both units have oeen essentially completec and a "
tes; :f :ne river intake and cir:.lating water system has beer perf0- ed.
Rece tly a change in the constrc: tion w -i schecoles has been effected.
This change involves going f rom two te nour snif ts, Monday through l
Thursday, and two twelve hour snif ts, Friday tnrough Sunday to two eight hour shifts Monday through Friday.
Onsite corporate management control has been established by locating the Senior Vice President and tne Vice Presioent and General Manager at the jobsite. This change was to focus the corporate effort with more direct project management.
The Quality Concern Program anc Drug crogram have become essential aspects in the licensee's overall program of ensuring quality work is l
performed by capable craftsmen and staf.__
t e
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The licensee was engaged in a nur.ber of activities in an effort to meet operational program needs.
Some of these activities are as follows:
operational staffing levels have been increased; the majority of the preoperational tests, maintenance and operational procedures have been developed; a training program has been established to develop the neces sa ry experience for operational activities; selected personnel have been placed at etner nuclear facilities to obtain SRJ iicenses; the Operations Department has implenented control room manning to control final construction and testing activities; and, in order to cevelop a skilled maintenance staff, the Operations Maintenance Depa-t ent is being utiliced to perfore construction and testing activities.
B.
Inspection Activities Sixty dual unit inspections were conducted during this assessrent with additional inspections ccnducted to support the Vogtle Readiness Review Program.
Two of the sixty inspections were in the form of team inspections to examine performance in the electrical and rechanical
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areas of construction.
Fourteen inspections were conducted cy the
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Resident Inspectors. In addition, one inspection was conductec in the NRC regional office to examine the licensee's ability to cerform ultrasonic examination on centrifugally cast stainless steel.
C.
Licensing Activities A partial exemption to G:: 4 was issued February 5, 1935. Ar a endment was issued to reflect the partial GDC 4 exemption.
NRR/ Licensee Meetines December 15, 1983 Compliance with GDC 51 April 11, 1954 Power systems questions May 14, 1934 Geesciences review May 15, 1984 Eme ;ency Plan June 5, 1934 Arcitrary intermediate oice b-ea. 'ssue June 27, 1954 Quaty assurance questions June 27-25, 1954 Auc't of backfill mater'ai test' ;
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August 14, 195
- eactor systems review August 27-30, 1954 Inst a entation and control s>sta s September 11, 1954 Tecn-fcal Specifications September 18, 1954 Inst umentation for Inadeauate
- : e Cooling (NUREG-0737, Item II.:.2)
September 19, 1934 Component classification
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December 4-6, 1984 Structural ergineering review
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Decemoer 12, 1934 Powe systems review Decemoer 13, 1984 Training program open items December 13, 1984 Open item status December 14, 1984 Fire protection January 8-10, 1985 Mechanical engineering review January 22, 1985 Containment systems review
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a o
e eeca NRR/ Licensee Meetings ( Cor.:i nue c )
January cc,
,9:-a nux1,iary syste s review
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Janua y 23, 1955 Gecte:hn cal rev ew i
i January 30, 1955 Ecuipme-: cual"" :ation Jaruary 31, 1955 Safe an alte-a:s snutaosn Fec uary 7,19S5 Me:har.ical en;: +ering resie-Ferrac y 1:,1955 tirarc' c g i c re s ' +.
February 15,19S5 Project status :-tefing Ma r c r. 11, 1955 Er argen:y Plan Mar:r 20-:^, 1935 Open item status Ap-il 11, 1935 Open item status Apri' 24, 1935 Readir.ess Revie Program May 8, 1955 Retesting of si.lator response NRR Site Visits January
., Ave *
Pnysical securi:3
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le February 7,19S4 Hydrology March 6-9, 1984 Geotechnical a : reactor systems review h,ay cm,,
.-,4 Cerbicu.ia 1:2 Juna 12, 1984 Quality assura :e questions July 24, 1934 Radiological assessment Nove-be-E-9, 19E4 Mechar.i al eng' sering review NoveToer 15-10, 1954 Caselcad Furecas: Panel Apr11 es - May 1,
.,3o.
tmergen 3 rrepa-ecness
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May 2, 1955 '
Metecrelogical -e.ies D.
Investica:;c, and Ailegation Review The #al'ceinc is a summary of allegat'ons wn': were closed cur'nc the e s ~. :: 1-d v.ere d::.merted in i s;e:t";n rer:':s
39.i'21 allEg5:': t
, n ', i ' s i g i". I i ; ~~ Ces'L;iD" i:: 1: an:
t'i'
c$5pS5't 0n were F9,-iewtc -1d swC:
12:sC.
C Ei.:'a.
EIlE;ati:F: Aers re,95nE: o
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". ~,e; i'ita '5
':' cf eli;;' ital e;J': Tert.
Sone Cf : ese a'
-;5:icns here sLb:;6ntia 0d.
[Tt i'lega*i:- in',:Is9d 9 ui:FGn; tarn.:': ceirg tAde n";"?Jt tre
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insta t ;ation ceing ccTpie:e anc :ne apc ::-tate cocure.:2 icn not
,
befr.; cn file.
This allegation resultec '. a siclation.
i l
Ore allegatior involved a conce-n that : 3-e was ne pro ecure tc irsce:: bra Lets holcing armour 10ck to. ' struts.
This carticular item, was identified as an Inspector Fol'exup Item in Inspection Report No. 50-424/85-20 and 50-425/35-20.
Anctter series of allegations involved e'e:trical Quality Control Freg-am ceficiencies.
Tnese allegati: s generally irvolved cccce-ns relative to inspection pro ecu es. Q: docuTentation and l
A
o
,e
-.un training.
Several of these concerns were substantiated and ore was icentified as a violaticn.
One allegation was reportec and involved a concern rela:ive to tne size of welding -od ir a ra-ticular application.
This issue was sucsequently sucstar. iated.
Tnese anc a d di t i e r s '. a'le;atiens are discussed in Rercr Nos.
50-4:4 E5-16 anc 50-425 E5-16. anc 50-424.65-20 and 50-425'55-20.
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c_scalated n orcenent %:: ion.s
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e None F.
Management Conferences Held D; ring the Assessnent Period Decemeer 9, 1953 Management reeting to discuss organizational changes.
Feoruary 9,1954 Management r.eeting to discuss Quality Assu-ance measures to improve sub:cntractor perforrance.
May 18, 1934 Management reeting to discuss Vogtle ciesel generators.
September 5, 19S4 Manage ent reeting to discuss constru::ior progress.
September 6, 1934 Managemer; reeting to discuss tne GPC Readiness Review Fregram.
Septe-ter 14, 1954 Managemer.: reeting to discuss the GPC Readiness Review Program /
Septerber 27, 1954 Management reeting to discuss licensirg cf operators.
Oc:cber 17 1984 Managere.: reeting to discuss the
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a, mei~ "ei: %e\\'EW rr:p'a?
I.'v6 tr 15-f 233$
Manage s*t."{tt rg to C#c _5s :"e
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,au 555 :::
Yare:as
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Ce: ether 12. 1954 Mana;9 er.t * etirg to dis:ess tre
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- e ',, e n rI;;ra" a.
h e i c '. n i :..
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s Mar:n :5,19s5 Manage +r.:
eeting to disc.ss 30:':
submittai of ~eadiness Revie,,-
Mocuie Nr. ;. Reinforcec C:r: rete
.
Structu-e u.ay,,,
,m-a u.a.agerer,t resting to viscoss u-rv-,3 r
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a
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as suomitta; of Readiness Revies Module ho. 3 Initial Test Prograv.
Preoperatioral Testing May 16, 1985 Management meeting at the licensee's request to discuss quality control problems in the electrical area June 25, 1955 Management meeting to discuss GDC's submittal of ;eaciness Review Moaule ho. 4 Mechanical Ecuipmer.t and Fiping
a a
o
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La G.
Confi-mation of A: tion Letters t
None M.
Review of Constructien Deficiency Reports (CDR) and 10 CFR 21 Reports
,
Suomitte: by tre Licensee Durir; this re-icd, twenty-eight CDRs and six 10 C :. 21 reec-ts were submitted.
O'
si> 10 CFR 21 repe-ts were submitte: in conju. : ion with asse:iated CDRs.
Twenty-cne items we-e cause: r3 errors assc:iated witn component cesign-seven items were caused D.s corstruction fac-ication errors.
Ten a::itienal items were censice-ed arc iz er ceter.ir.ed to be not reportsele, while another five are s-ill unce-licensee review.
The reports we-e submitted in a tirely manner.
Initial telephone reports trovice: sufficient information to a'.lew ea ty NRC evaluation.
The licensee's effort to reduce tne timeframe frcr initial notification to final evaluation submittal was noted.
The defic'en:ies were properly icentified, analy ea anc corrective actions appeare: effective taseo on NRC inspection followup.
I.
Inspection Activity and Enforcement Functional No. of No. r# Violations Area Deviations in ea:- Severity Level
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111
.t s
i Units 1 and 2 Ccnstruction Contai-ent a-d Other Safe:s-Relate: Structures, and 'ij:r Stie' fu;;cr
Picir:
- . ste :
--d Sacre :s i
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Safet. Relate: :: ;; nerts-
" :.a-i:al Syst2 s
Electricai Equ ; ent l
and Cable C
i i
!
Quality Progra s and l
A 'nistrat ve Centrols
i
1
0
21
- NRC Esalaatice Review of Licensee Response is in p c; ess
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