IR 05000424/1985031
| ML20205F326 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/23/1985 |
| From: | Belisle G, Jackson L, Sinkule M, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205F316 | List: |
| References | |
| 50-424-85-31, NUDOCS 8511050318 | |
| Download: ML20205F326 (14) | |
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Sa rf4 UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Report No.:
50-424/85-31
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Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No'.:
50-424 License No.:
CPPR-108 Facility Name: Vogtle Unit 1 Inspection Conducted: July 22-26 and August 5-9, 1985'-
Inspectors:
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L. H. Gackson W
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G. A<' Belisle,9dting Section Chief Ddte Signed Division of Re tor Safety J
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TABLE OF CONTENTS Topic Page Summary
Scope of Review
Methodology
Eval ua tion
Findings
Conclusions
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V0GTLE !!LECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM APPENDIX I PROJECT. QUALITY ASSURANCE ORGANIZATION SUMMARY
TI.i s - report is. an evaluation of Appendix I of the Vogtle Readiness Review-Program.
This program is being conducted as an initiative of Georgia Power Company (GPC) management to assure that all design, construction, and operational commitments have been properly implemented at the Vogtle Electric Generation Plant Unit 1.
Appendix I, which is one of an anticipated eleven appendices, presents an assessment of the program implemented by the Project Quality Assurance (QA) Organization for design, construction and operations.
This evaluation was conducted to determine if the results of the program' review on the Project QA Organization presented in this appendix are an effective and accurate assessment of design, construction, and operational yequirements, that these requirements are being properly implemented, and that the resolutions of findings
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.This evaluation was performed by NRC inspectors from Region II. The evaluation
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was. accomplished through a detailed review of all sections of the appendix by:
1) verifying that-the design and constru.tfon commitments, listed in the appendix are correct and comply with Final Safety Analysis Repor,c (FSAR) requirements; 2) reviewing the appendix findings and evaluating the correctness of their
' resolution; 3) reviewing a :.omprehensive and representative sample of the records
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- reviewed by the Readiness Review Staff (RRS);. 4) selecting and reviewing a comprehensive and representative random sample of records concerning QA audits; and 5). review of prior inspection activity in this area.
During the review, it was appa ent to the NRC ' inspectors that GPC management supported the program by active participation in the development and implementa-
' tion of the program. This_ evaluation also indicates that the licensee's program
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-review of the Project QA organizati.n was comprehensive and that the subject program complies with NRC requirements and FSAR commitments. Some programmatic discrepancies were identified by the NRC inspectors. These items are classified as; deficiencies or unresolved items. A deficiency is considered. to be an item having minimal safety significance, but one which should be evaluated by the r,
licensee.to determine what action could be taken to correct the item and thus preclude the. pt ssibility of the ~ development of safety problems. An unresolved item is a matter which - requires further information and investigation to determine if it-is acceptable'or may involve a violation or deviation. A listing-of the deficiencies and one unresolved i>;em identified during this evaluation is
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summarized below:
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Deficiency'
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Update of Final Safety Analysis Report Deficiency
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Unavailable Early Procedure Revisions
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. Unresolved Item
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Retrievability of QA Audit Records
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As stated in Appendix I, Project Quality Assurance Organization, this appendix was developed by five personnel; all having broad backgrounds in quality assurance, quality control, and nuclear power plant activities.
The actual appendix verification was conducted by four of these five personnel on April 11-19, 1985.
An appendix verification checklist was used during this activity.
The verification con si sted of four phases.
Phase I determined consistency between tt.e wording of six selected GPC QA Department procedures and commitment sources. Phase II determined that 37 GPC construction and operational audits and 50 audit finding reports complied with the implementation of Vogtle project commitments and pre-established procedures.
Phase III determined by reviewing 49 audits of contractors with their own QA programs that GPC had audited all appropriate elements of the subcontractor site QA programs.
Phase IV determined by reviewing 33 audits of Southern Company Services and Westinghouse that these QA programs were in compliance with their programs and procedures.
Based on this four phase review, six findings we e identified. Three findings were eventually determined to be non-findings based on additional information provided.
The remaining three findings were cetermined to be two minor deviations from procedural requirements and one case needing enhancements to QA Department procedures.
NRC inspectors reviewed Appendix I on site during July 22-26 and August 5-9, 1985. Approximately 128 inspector hours were used during this review.
Review details are delineated in this report. As previously stated, two deficiencies and
- one unresolved item were identified.
It appears that these deficiencies and one
unresolved item will not represent significant programmatic weaknesses.
Details on these items are discussed in the main body of this report.
1.
Scope of Review
This review, which consisted of an examination of each section of Appendix I was performed by inspectors from Region II. Append.ix I, Sections 1.0, 2.0, 4.0, 6.0 and 8.0 which present data on the appendix scope, responsible
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organization, program description, changes and conclusions regarding the assessment of the appendix, did not require as detailed a review or evalua,
tion as the other sections.
The more significant aspe-ts of the appendix are in Section 3.0, 5.0 and 7.0.
These sections discuss licensee commit-ments and impleme7tation, audits and inspections, and appendix verification.
Review of these sections included a detailed review of content and examina-tion of items identified as findings regardless of their finai level of classification. The inspectors examined a sample of the records reviewed by-the RRS and examined an independently selected sample of records to assess the thoroughness of the overall evaluation.
Methodology used for this review ano an evaluation of each section are presented in. the following paragraphs, t
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2.
Methodology
'The technical review and evaluation of Appendix I were conducted in the Region II office during the week of June 24, 1985, and was supported by onsite inspection activity during the weeks of July 22-27 and August 5-9, 1985.
The office review of Section 3.0 compared the applicant's accepted QA
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program licensing commitments with the (NUREG-0800) Standard Review Plan (SRP) positions, regulatory guides, industrial codes, and Vogtle FSAR documents.
During the onsite inspections, the program description, Section 4.0, was reviewed to verify that essential elements of the program were audited in accordance with accepted QA program criteria and with ANSI N45.2.12 commit-ments.
Project procedures were reviewed to confirm that they contained implementing requirements necessary to evaluate the adequacy of the program.
Audit schedules, planning, preparation, performance, reporting, followup, and records were reviewed to evaluate the adequacy of the auditing process.
Auditor and Lead Auditor qualification records were reviewed to verify that personnel qualifications were in accordance with ANSI N45.2.23-(1978).
Audits covering construction and operations activities performed by GPC, and audit activities performed by Bechtel Power Corporation (BPC) - (the Architect - Engineer (A-E)), Southern Company Services (SCS), and Westing-house (W) - (the Nuclear Safety System Supplier (NSSS)) were reviewed to confirm adequacy and effectiveness of program implementation.
3.
Evaluation The evaluation of each section of Appendix I is provided below.
For each section, a description of each section, what was reviewed, and the basis of acceptance are provided.
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a.
Section II - Scope This section encompassed the quaitty assurance organizations involved and activities carried out by these organizations for the Vogtle project. This section was reviewed for background information only.
No followup or evaluation of this section was required.
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Section I2 - Responsible Organizations This section presents a description of the organization and division of responsibilities of GPC, BPC, SCS, W, and site contractor organi-zations for auditing activities relative to design, procurement, construction, preoperational testing, and operations, conducted on behalf of Vogtle.
This section was reviewed to verify implementation responsibilities for audit functions of essential elements of the QA ' rogram delegated to p
others or retained by GPC. Where audit functions were delegated, GPC E
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retained primary responsibility and selectively provided audit participation when contractors performed implementation.
.The.- period of August 1982 through July 1984 was selected by the inspectors for review of audited activities of W. Three audits were reviewed-to verify that applicable elements of the QA program were audited once in the life of the activity or on a triennial basis.
'ection 13 - Commitments and Implementation S
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'(1) The inspectors reviewed commitments to confirm that they were the same as those committed to in the FSAR and identified by the RRS.
The review also included an examination of QA procedures to verify the FSAR commitments were being correctly transposed into these project documents. The historical file of GPC's implementing QA procedures was reviewed to confirm that Regulatory Guide (RG) and American National Standards Institute (ANSI) standard commitments were updated in these procedures as necessary.
The following revisions to these historical procedural documents were not available for the inspectors review:
QA-01-01, R2, R4
.QA-01-08, RO QA-01-11, RO QA-05-02, R1 QA-05-04, RO QA-05-07, R0 All but one of these missing procedural revisions are initial issues of the procedure or pre-1976 revisions--that were written essentially prior to any safety-related. construction work being accomplished. Revision 4 to GPC procedure QA-01-01 was determined acceptable by confirming that R3 and R5 contained-adequate commit-ments.
The licensee fis conducting further searches for these missing revisions; however, recovery of these documents appears doubtful.
This deficiency for failure to maintain z copy of superceded QA procedural revisions does not appear to constitute a threat to the healtn and safety of the public.
(2) BPC audits of W have been conducted in accordance with WCAP 8370, Revision 10A, since approval of this document by the NRC on August 29, 1984. However, Chapter 17 of GPC's accepted'QA program (Supplement 10) still specifies that WCAP 8370, Revision 9A is the applicable W QA program. This failure to update the QA program appears to be a deficiency to update as required by 10 CFR 50.55f(3) in that this change was not reported to Region II until Amendment 18 of the application dated August 9, 1985.
(3) The NRC Vendor Program Branch (VPB) periodically inspects Bechtel and Westinghouse, as well as the other major AE and NSSS firms, regarding issues identified through licensee construction-c
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deficiency and operating reactor event reports; vendor reports of product deficiencies; allegations received from members of the public; and vendor issues identified by the NRC through its inspection programs. These issues may either pertain to specific reactor plants, or be of a generic nature applicable to seseral plants.
Inspection findings a e issued as inspection reports (published quarterly as NURF 3040) and may be the subject of an IE Information Notice or Bui.. in. Selective audits were reviewed by the inspectors to verify implementation of an adequate audit program.
(4) Chapter 17 of the FSAR states that SCS QA program commits to RG 1.144(1979), which endorses ANSI N45.2.12(1977) for the conduct of audits and the training and qualification of auditors.
SCS implementing procedures (34.2-50 and 34.2-51) also endorse ANSI N45.2.23 requirements for auditor qualification and certification.
(5) The operations' QA audits are conducted in accordance with the commitments contained in RG 1.144 which are implemented by proce-dures QA-05-01 and QA-05-02. The qualification and certification of auditors was confirmed to meet the requirements of RG 1.145-1970 and is implemented by procedure QA-03-05.
Review of this section by the RRS and Region II inspectors identified that Vogtle's licensing commitments and implementing documents comply with the FSAR, SRP, RGs, and industry codes and standards.
d.
Section I4 - Program Description This section of the appendix provides a description of the functions of the Vogtle Project QA organization which includes auditing, surveil-lance programs, quality evaluations and investigations, and QA engineering support activities. A description and purpose are given for the Vogtle Project Quality Concern Program (QCP) which was self-initiated by GPC in December 1983.
This QCP is a licensee enhancement program that is not a commitment in the FSAR. The QCP was reviewed by the NRC during an inspection conducted July 10-11, 1985.
Results of this inspection were documented in Inspection Report Nos.
50-424/85-33 and 50-425/85-28.
Review of the section confirmed that the subject program description is correct and in agreement with the FSAR and project requirements.
e.
Section 15 - Audits and Inspections (1) This section contains a discussion of the audits and inspections and more salient findings identified by the NRC, BPC, and GPC concerning Vogtle QA activities.
Audits by GPC include self-initiated evaluations conducted in accordance with the Institute of Nuciear Power Operations criteria and annual assessments by the GPC QA Department.
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(2) This section also includes the results of four NRC Systematic Assessment of Licensee Performance evaluations of the QA program.
(3) Review of this section indicates that it is an accurate presenta-tion of the deficiencies identified against the audit program.
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Section I6 - Program Changes (1) This section, in conjunction with referenced Section 12.3, describe major events in the evolution of the Vogtle Project QA erganizational structure and two FSAR commitment changes that were reviewed and accepted by the NRC.
The Deputy General Manager -
Quality Assurance position described in Section I2.3 is not mentioned in the licensee's accepted QA program.
Subsequent to this inspection, the licensee notified the NRC by letter dated
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July 30, 1985, of several organizational changes and additions, one of which was the Deputy General Manager - Quality Assurarce position and related responsibilities.
(2) No other findings were identified during the review of this section.
g.
Section 17 - Appendix Verification This section describes 'the project QA organization programs verifica-tion, resulting findings, and corrective actions.
The Vogtle QA organization verification was approached by RRS in four phases.
In Phase I, the commitments which were identified in Section I3 of the appendix were compared to the source document and the implementing procedures. Phase II evaluated GPC field construction and operational field audit activities for compliance to Vogtle Project commitments and implementino procedures. Phase III involved GPC site QA evaluation of site contractors with their own QA programs.
Phase.IV assessed the audits of the QA programs of SCS, BPC, and W to determine if these programs were in compliance with their respective commitments and procedores.
(1) Phase I Phase I of this appendix verification was performed by developing checklists from 10 CFR 50 Appendix B, Criterion I, V, VI and XVIII requirements. The RRS then compared these requirements with thne contained in implementing procedures to verify by objective evidence that commitments were adequate.
Examication of these same documents by tne NRC inspectors confirmed that the work by RRS was ace:ptable.
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(2) Phase II The RRS: examined the GPC annual audit system plans and schedules, 35 field construction audits, 2 field operations. audits, 50 related audit finding - reports, and the certification and qualification of pertinent auditors for compliance with Vogtle Project commitments and implementing QA procedures.
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During a Regional. Office review of Appendix I, Table 17-1, the Region II inspectors 'were unable to conclude if all essential elements (such as training, instrumentation, excavation, and
' backfill) 'of the Project QA Program had been audited at least c.nnually or at least once within the life of the activity (whichever is shorter) as required.
Subsequent discussions with responsible site audit personnel and examinations of a'dditional audits conducted in these areas convinced the inspectors that all essential elements were being audited.
The inspectors reviewed five field construction audits (condu;ted during 1980) and the two field operations audits that were previously selected for review by the RRS for examination. These audits were examined to verify that existing QA audit procedures,
had been properly implemented.
The audit report, audit plan, checklist, written replies, audit finding reports and specific corrective actions taken, and auditor ertification and qualifica-tion records were examined for each ay5 fit. This review identified that two lead auditors utilized in tro above audits did not have their audit;r qualification records maintained and updated
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annually as required by the licensee's commitment to ANSI N45.2.23.
The documentation of these auditor requalifications had, in some instances, exceeded the required 12-month interval by a few months.
However, the subject auditors ' involved were verified to have been. certified and qualified during this interim.
The licensee informed : the NRC inspectors that this identical deficiency had been previously identified by - the NRC and was documented in Inspection Report Nos. 321/82-42 and 366/82-40.
Appropriate record keeping corrective ' action was taken at that -
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time.
Examination of the above audits identified that operations QA-audit TP01-84/01 checklist could not be located.
Based on this finding, the inspector increased the sample size of their audit records review to determine if the retrievability of QA audit records from project document control was 'a more widespread problem. The inspector examined 100 percent of the MD 04 (valve)
and MD 05 (tank) audit records cantained in the vault. Several audit reports and checklists were not immediately retrievable, but were eventually found. They vare either misfiled in the vault or in the _ microfilm files. Although audit checklists were found to exist in the Construction QA Department files for audits MD 04-81/79, 81/47, 80/13 ed MD 05-81/31, these checklists could not be located in the vauh prior to the exit interview,
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(3) Phase III Audits of contractors with their own QA program are performed by GPC QA department personnel, in addition to those performed by the contractors' own QA organization. The RRS reviewed all audits by GPC associated with the Chicago Bridge and Iron onsite fabrication of containment liners and tanks; and the Pullman Power Products'
piping system fabrication and installation for large bore pipe during 1983 and 1984, including valves from 1979 - 1983.
These audits were reviewed by the NRC Region II inspectors to assure that essential elements of the program were covered, industry identified problems were considered, and that GPC had performed audits on a regular basis.
The NRC inspector reviewed all 49 audit reports which were reviewed by the RRS to assure adequate QA coverage onsite. These reviews concentrated.on program coverage applicable to ongoing activities such as; procurement, receiving, storage, material identification and control, welding processes, documentation, nondestructive examination, nonconformance control, records, and audits.
The NRC inspectors evaluated Audit Finding Reports (AFR)
identified by the audit process to confirm adequate corrective action. Objective evidence that GPC had reaudited problem areas and confirmed implementation of corrective actions prior to closure of AFRs were also key elements used to access the GPC QA audit program. Evidence of QA program approval prior to start of t
activities was also verified by the inspectors. Audit MD 01-84/50 was a QA assessment of Pullman Power Products QA Manual, working procedures, documentation review, and personnel interviews. Audit MD 04-82/87 and MD 04-82/70 "eviewed Pullman's program for evalua-tion of NRC Information Noti:e Nos. 82-20 and 83-80, respectively.
Phase III of the review conducted by the RRS for the audit verification program was considered adequate.
(4) Phase IV The inspectors performed a detailed review of Phase IV of Appendix I to assess the effectiveness of the licensees audit program by SCS, BPC, and W.
Audits were selected to cover a triennial ~ period in order to evaluate the total program coverage, of essential elements as required in Regulatory Guide 1.144 (1979)
and ANSI N45.2.12-1977. Chapter 17 of the FSAR was reviewed to ensure that commitments were consistent with those reviewed by the RRS and that the audit procedures reflected these requirements.
Audit findings associated with the 'following were reviewed in detail to verify content, adequacy of review, and to ensure closure of findings. Licensee implementation of corrective action L
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to resolve audit findings was reviewed and found to be acceptable.
The' period of August 1982 through July 1954 was selected by the inspectors for review of BPC, SCS, and GPC audited activities of W.
These three audits confirmed that applicable elements of the QA program were audited once in the life of the activity or on a triennial basis.
One audit of Westinghouse's Tampa, Florida facility, file GN20.1.4, log VQSI-64, and one audit of Westinghouse's Pensacola, Florida facility, file GN20.1.4, log VQS2-26, activities were reviewed to confirm adequate coverage cf essential elements applicable to the manufacturing process.
Essential QA elements covered during the audits were 10 CFR
Appendix B, Criterion III, VI, VII, VIII, IX, X, XII, XIV, XV, XVI, and XVII.
Audits of BPC from July 1982 through December 1983 were selected for review by the inspectors.
These audits were participated in by SCS and two of the audtts were participated in by GPC.
The scope of the audits confirred that essential elements of the design process were adequately covered during these audits.
Licensee implementation of corrective action to resolve audit findings was reviewed by the inspectors and determined to be acceptable.
The above audits confirmed that the audit process is effective in identifying problems. Also, implementation and reaudit. confirma-
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tion of adequate corrective action verified the program to be a management supported objective.
(5) RRS Findings and Corrective Actions The inspector's examination of the six RRS findings determined that they were of minor significance and the resolution of these findings, with the exception of Readiness Review Finding (RRF)-
21-5, was adequate. Three of these findings were determined to be non-findings based on additional information provided.
Of the remaining three, two were determined to be minor deviations from procedural requirements and one involved enhancement to QA Depart-ment procedures.
RRF 21-5 identified and properly resolved the deficiency identified concerning SCS, audit finding report ( AFR) No. 76-1, but failed to identify another deviation from SCS procedural requirements concerning the subject AFR.
SCS Quality Assurance Department Policy and Procedures, Appendix C requires the final acceptable corrective action taken to be described on all AFRs.
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Contrary to this procedural requirement, the corrective action taken was not entered on AFR 76-1.
Review of additional SCS AFRs revealed that this deficiency appeared to be an isolated case and L
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tne licensee had taken corrective action on this AFR prior to our leaving the site.
4.
Findings The following findings, which are identified as either a deficiency or an-unresolved item, were identified by the Region II inspectors. A deficiency is considered as in item having no safety significance but one that should be evaluated further to preclude safety problems. An unresolved item is a matter which requires further information and investigation to cetermine -if it is acceptable or may involve a violation or deviation. Deficiencies will be pursued as an Inspector Followup Item (IFI) in future routine inspections.
Deficiency (IFI 85-31-01)
Update of Final Safety Analysis Report.
BPC audits of W have been conducted in
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accordance with WCAP 8370, Revision 10A, since approval of this document by the NRC on August 29, 1984.
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Chapter 17 of GPC accepted QA program (Supplement 10)' specifies that WCAP 8370, Revision 9A, dated October -31,1979, is the applicable program. This failure to update the QA program appears to be a deficiency in that this change was _not reported to Region II until Amendment 18 of the application for an operating license dated August 9, 1985.
Deficiency (IFI 85-31-02)
Unavailable Early Procedure Revisions.
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Review of the GPC historical QA procedure file identified a few initial.and very early procedural revisions that were not
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available for the inspector's review. It should be noted that six of the seven unavailable procedure revisions were either initial issue (Revision 0) or pre-1976 revisions that were written essentially prior to any safety related construction being done.
Mobilization for construction and some excavation commenced in 1974 but was stopped and.
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resumed again in 1976 at which time these procedures were immediately revised and
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Revision'4 for procedure QA-01-01 was determined acceptable - by confirming that revisions 3 and 5 contained adequate commitaents.
The licensee is conducting furt.her searches ~
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for these missing proceduros.
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- Unresolved Item (UI 85-31-03)
Retrievability of QA Audit Records.
Review of audit records contained in the project document control vault initially identified several audit reports and audit checklists which were not immediately retrievable but were essen-tially found either misfiled in the vault or in the microfilm. files.-
The inspectors discovered this apparent problem near the conclusion of their inspection.
At the conclusion of this inspection, five audit checklists were identified to the licensee as possibly still missing from the vault.
The licensee is conducting a search for thes'e missing audit reports.
Appendix D, Document Control, is under development. A comprehensive review of document control will be conducted during this module inspection.
5.
' Conclusions Based upon the review of this appendix and independent review of documenta-tion on site, the NRC concludes the following:
a.
Licensing commitments and implementing procedures comply with.FSAR, SRP, Regulatory Guides and industry codes and standards.
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The licensee has implemented an effective audit program which covers essential elements of construction activities.
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Audits of essential elements of the design process have been performed in accordance with Regulatory Guides and ANSI standards.
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Audits of the manufacturing process at W facilities
.n Tampa and Pensacola, Florida covered essential elements and were determined to be effective.
Audit reports covering various aspects of onsite activities have been reviewed by Region II inspectors since 1982 and documented in NRC Inspection Report Nos. 50-424/82-02, 82-13, 82-25, 83-05, 83-19, 84-06, l
and 84-14. Audits performed by GPC will continue to be evaluated to assess audit prograrp ef fectiveness.
Review and evaluation of Appendix I by the NRC indicate that the review
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performed by the GPC RRS was sufficiently comprehensive in scope and depth to identify problem areas, and that the dispositions of findings were proper and satisfactory, except as noted in Section 3.g.(5).
The NRC findings t
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identified as deficiencies appear to be minor and do not represent a breakdown in the quality assurance program.
The NRC furthermore believes that Appendix I accurately assesses the status of design, construction, and operational auditing activities.
This conclusion is based on information currently available to the inspectors and reviewers.
Should information subsequently become available which was not considered during this review or previous inspections and which conflicts with earlier information, it will be evaluated to determine what effect it
'may have on the above conclusion.
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