IR 05000424/1985055

Insp Rept 50-424/85-55 on 850819-860214.Major Areas Inspected:Readiness Review Module 5, Operations Organization & Administration

ML20197B763
Person / Time
Site:	Byron, Vogtle
Issue date:	04/28/1986
From:	Belisle G, Debs B, Mccoy F, Novak T, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20197B754	List: IR 05000424/1985055 ML20197B751
References
50-424-85-55, NUDOCS 8605130117
Download: ML20197B763 (27)

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UNITED STATES

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Report No.: 50-424/85-55 Licensee: Georgia Power Company P. O. Box'4545 Atlanta, GA 30302 Docket No.:

50-424 Construction Permit No.: CPPR-108

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Facility Name:

Vogtle Unit 1 Review. Topic: Vogtle Readiness Review Module No. 5,' Operations Organization and Administration

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Review Conducted: August 19, 1985 - February 14, 1986 On-Site Inspections Conducted - September 9-13, 1985, September 30 - October 4, 1985, January 6-10, 1986, February 10-14, 1986 NRC Offices Participating in. Inspections / Reviews:

Office of Inspection and Enforcement, Bethesda, MD Office of Nuclear Reactor Regulation, Bethesda, MD Region II, Atlanta, GA Lead Technical Reviewer:

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F. R. McCoy, R6ac~to spector, RII

'Ddte Signed Review Members:

NRR/IE Reviewers:

W. Belke, IE M. Lamastra, NRR G. McPeek, NRR-B. Liaw, NRR G. Staley, NRR H. Clayton, NRR L. Rubenstein, NRR J. Guttman, NRR

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F. Allenspach, NRR F. Burrows, NRR M. Wohl, NRR K. Kniel, NRR Rv; ion II Inspectors:

R.-Latta K. Poer ner Approved by:

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3//&/M B. Debs, Acting Section Chief Date Signed Operational Programs Section Division of Reactor Safety 860513o117 86043o R

ADOCK 05000454 G

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$7 G. A. Belisle, ActTng Section Chief

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Quality Assurance Programs Section-Division of Reactor Safety Y

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os M. V. Sinkule, Chief Da1(e Signed Projects Section 2D Division o Reactor Projects i

YW T.Novak,DeputyDirectof]

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Division of PWR Licensi@ A Office of Nuclear Reactor Reg"lation

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TABLE OF~ CONTENTS ~

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TOPIC PdGE Summary

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j Background and Scope of Review

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Methodology

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Evaluations-5-

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Findings.

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Conclusions

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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE'S OPERATIONS ORGANIZATION AND ADMINISTRATION SUMMARY The readiness review program is being conducted at the initiative of Georgia Power Company management to assure that all design, construction, and operational commitments have been properly identified and implemented at the Vogtle Electric Generating Plant Unit 1.

Module 5, which was submitted on August 19, 1985, and a revision. to module 5, which was submitted on November 1, 1985, presented an assessment by the applicant, which concluded that operations organization and administration programs as implemented at Vogtle comply with Final Safety Analysis Report (FSAR) commitments and regulatory requirements.

The NRC conducted an evaluation of the applicant's assessment to determine if the program review of the operations organization and administration presented in module 5 was an

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effective and accurate assessment. The NRC evaluation was conducted to determine if requirements are being properly identified and implemented at Vcqtle and to determine if the resolutions of the findings identified in module 5 were appropriate.

This evaluation was performed by NRC reviewers and inspectors from the Office of Inspection and Enforcement (I&E), the Office of Nuclear Reactor Regulation (NRR),

and Region II (henceforth referred to as the staff).

The evaluation was accom-plished through a detailed review of all sections of the module by:

1.

Verifying that commitments identified in the module properly reflected FSAR commitments and regulatory requirements.

2.

Verifying, by review of a comprehensive and representative sample of approved procedures, that commitments are being implemented into procedures.

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Verifying, by review of a sample of programs delineated within the module, that program implementation is in accordance with procedures and commit-ments.

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Reviewing the module findings identified by the applicant and evaluating the

correctness of their resolution.

During this evaluation, it was apparent to the staff that applicant management supported the program by active participation in the. development and implementa-tion of the program. This evaluation also indicates that ' when deficiencies, which indicated potential programmatic problems with the review process itself, were' identified by the NRC, management responsiveness was positive and thorough i

and resolution of concerns was adequate.

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As discussed in NRC Inspection Report 50-424/85-36, the staff considered that the applicant's initial program review for operations organization and administra-tion, which was presented on August 19, 1985, was inadequate in that commitments were not being implemented by designated procedures and yet the applicant's readiness review effort was indicating that they were. This situation was later confirmed by the applicant to be isolated to module 5, the module programs were rereviewed as described in NRC Inspection Report 50-424/85-36, and the module was resubmitted to the NRC on November 1, 1985.

The NRC evaluation of the revised module indicated that, as a result of corrective actions implemented by the applicant, an adequate and comprehensive program review for operations organiza-tion and administration programs has now been conducted by the applicant. The evaluation also indicated that commitments. identified in the module accurately agree with those commitments. in the FSAR and SER and that commitments are being satisfactorily implemented.into procedures. With the exception of some specific deficiencies identified by the staff as findings, the NRC evaluation of the revised module indicated that programs associated with operations organization and administration programs, which were specifically reviewed, are being-implemented in accordance with NRC requirements and FSAR commitments.

Additionally, this evaluation indicated that the applicant currently has controls and processes in place which should assure proper implementation of all programs associated with this module.

The findings identified during this evaluation are discussed. in detail in sections 3 and 4 of this report and are summarized below:

Deficiency - inadequacies in the initial applicant review of module 5 (URI 424/85-36-01)

Deficiency - incomplete identification of implementing documents within the commitment tracking system for one commitment (IFI 424-85-55-01)

Deficiency - a procedure revision is required to more appropriately ensure Plant Review Board review of required changes (IFI 424/85-36-03)

Deficiency - errors in Plant Review Board meeting minutes and Plant Review Board comment resolution (five examples) (IFI 424/85-55-03)

Deficiency - evaluation of one operational event report was not of

sufficient depth to ensure that a similar event is precluded at Vogtle with indication that this concern may be generic (IFI 424/85-36-02)

Deficiency - errors within the readiness review module commitment matrix for two commitments (No Followup Number assigned)-

1.

Background and Scope of Review Module 5 delineates program commitments for operations organization and administration programs which includes implementation of the operations quality assurance program required by 10 CFR 50, Appendix B.

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PriortotheNNCevaluation,theapplicanthadinitia'lly'performedaprogram

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verification to ascertain that an extensive;and representative sample of the -

272' program commitments ' for operations organization and qualification.were

properly implemented. This verification,was accomplished.by nine readiness

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review team members who expended in excess of.1100 personhours to accomplish l

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the. review..The initial NRC evaluation indicated serious deficiencies with

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~the applicant's review process for. module 5 as delineated in.NRC Inspection

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Report.50-424/85-36. This prompted a rereview of module 5-by the applicant-j and a ~ rereview of selected: other modules - which. ascertained that the

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deficiencies were - isolated to _ module 5.

The ' scope of the applicant's i

reverification of ' module 5 consisted of a 100% reverification of. the

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commitment matrix to ascertain if commitments were properly identified, a 100% reverification of.the implementation matrix to ascertain.if commitments-r were being properly implemented in designated documents, and a. SM,

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reverification of - program implementation to c.scertain if procedural

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requirements were being complied with in practice. - The applicant corrected i

deficiencies noted during the initial NRC evaluation and deficiencies

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identified by the' applicant's. reverification.

These' cor'rections: were

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reflected in a revision to module 5 and the -revised module was resubmitted l

to the NRC for reevaluation.

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The' scope 'of the.NRC evaluation of module 5 as reported herein focused on l

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the resubmitted module in order to determine in present time, - that, as

.i revised, commitments are properly identified 'and that. they are being

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The scope of this NRC evaluation included:

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A review by NRR and IE reviewers of all commitments delineated in l

section 3.4 of module 5 in order to-determine if the'specified commit-

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ments agreed with those delineated in the..FSAR and~ Safety Evaluation

Report (SER).

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A review by-Region II inspectors of-the. implementation of 100 commit -

i ments (36%) delineated in section 3.5 of module 5 'in order to ascertain l

l-that the commitments were being implemented into procedures.

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c.

A -review by Region II inspectors of selected programs to verify.

procedural compliance. This was limited to activities.where the work-

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effort was considered significant enough at this' stage of review.to i

render meaningful conclusions.

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d.

A limited' programmatic review by Region II; inspectors of-implementation

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of:10 CFR 50, Appendix B.

This review'was limited due to the_ fact-that

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r the operations quality assurance program is not required to be

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implemented until :90 days. prior to fuel load and,. though partially -

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criteria of.this program are not considered to be extensive enough to i

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A review by Region II inspectors of 15 readiness review verification packages (58%) to determine if module 5 accurately reflected the review findings.

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A review by Region II. inspectors of the applicant's verification process review findings to evaluate resolution.

2.

Methodology-a.

The review by NRR and IE reviewers of commitments within section 3.4 of module 5 was conducted by comparing the description of each commitment specified in the matrix to the corresponding FSAR and SER description in order to verify that the commitment description was accurate.

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The evaluation by Region II inspectors of the implementation of those commitments selected for review was conducted by reviewing documents in section 3.5 of module 5 and verifying that the selected commitments

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were completely implemented within those documents. The review was restricted to only approved documents except for minor isolated cases identified in paragraph 3 of this report.

c.

The review by Region II inspectors of selected programs to verify

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procedural compliance was conducted in the areas of the Plant Review Board activities, the commitment tracking program, and the operations assessment program.

Plant Review Board activities were evaluated by reviewing procedures governing plant review board activities, reviewing a representative sample of past and current Plant Review Board meeting minutes to determine accuracy, reviewing a representative sample of Plant Review Board comments and procedures to determine if comments are being properly resolved, interviewing Plant Review Board personnel to determine how activities are actually implemented, and observing a Plant Review Board meeting.

• The operations assessment program was evaluated by reviewing procedures governing implementation of the operations assessment program, interviewing cognizant regulatory compliance personnel to determine how the program is actually implemented, walking through an operating event to determine how it is processed, tracked, and dispositioned, and evaluating applicant responses

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to selected operating events within the program.

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The commitment tracking program was evaluated by reviewing procedures governing implementation of the commitment tracking program, interviewing cognizant regulatory compliance personnel to determine how the program is actually implemented,- reviewing

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selected source document commitments to' determine if they were..in fact, included in the commitment tracking program, and if the status of commitment implementation.was correct.

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The programmatic review by Region II inspectors of 10 CFR 50, Appendix B implementation was conducted by selecting 33 documents-(42%) identified inef'able 4.1-1 of module 5 as implementing designated criteria of.10 CFR 50, Appendix B and reviewing those documents to determine if the designated criteria were met.

e.

The review by Region II inspectors of readiness review findings was-conducted in two parts:

a review of 15 of the applicant's readiness review team reviewer

checklist packages (58%) to ascertain if there were cases where review team member findings were not properly reflected in the module.

a review of all of the findings delineated in the module in order

to evaluate the applicant's resolution.

3.

Evaluations The evaluation of each section reviewed is provided below.

For each section, a description of the section, a description of the review conducted on that section, and a description of the results of each review is provided, a.

Section 1.0 - Introduction This section discusses the scope of the module and the status and schedule of implementation of programs and organizational activities.

This section of the module was reviewed for content only with no comment by the staff.

b.

Section 2.0 - Organization and Division of Responsibility This section discusses the organization and division of responsibility associated with the operations organization, the initial test organiza-tion for Vogtle, and the interface of these organizations with other corporate organizations. This section of the module was reviewed for content only with no comment by the staff.

c.

Section 3.0 - Commitments This section of -the module defines commitments as project obligations to regulatory guides, industry standards, branch technical positions, and other licensing requirements, to the extent defined in the FSAR.

This section also identifies the source of commitments to be restricted to the FSAR and responses to NRC questions associated with the FSAR.

As defined, commitments which were considered by the applicant to be.

most appropriately categorized in this module were tabulated in a commitment matrix identified -in section 3.4 of the module.

The applicant identified 272 commitments as 'being most -appropriately categorized in this modul.

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This section of the module also defines an implementing document as a working level document, either program control or test procedure, that

fulfills a nuclear operations commitment applicable to a specific activity.

Implementing documents were identified for each of the 272.

commitments and this information was tabulated in an implementation matrix identified in section 3.5 of the module.

The evaluation of this section consisted of reviewing the commitment.

matrix delineated in section 3.4 and reviewing the. implementation

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matrix delineated in section 3.5 as discussed below.

i (1) Evaluation of the Section 3.4 Commitment Matrix:

Fach commitment in section 3.4 of the module was reviewed by either the responsible NRR review branch or the IE Quality Assurance Branch to determine whether. the appropriate licensing commitments were -included.

Six comments were identified which required further clarification by the applicant. The requested clarifications were provided by the applicant in a letter dated December 30, 1985.

The specific comments and the applicant's response to each comment are delineated below:

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(a) Comment

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On page 6 of the commitment matrix, please. clarify if the first FSAR reference should be 13.5.1.1N rather than 13.5.1.2G. The commitment subject is Emergency Core Cooling System (ECCS) outage data procedures.

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Response Amendment 16 to the FSAR moved this commitment from Section 13.5.1.2G to Section 13.5.1.1N.

Module 5 commitments were based on the FSAR through Amendment 14.-

(b) Comment On page 35 of the commitment matrix, the commitment with regard to NRC question 420.5 should state that. the analysis

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will be provided concurrent with the setpoint methodology in lieu of the first quarter of 1985.

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Response

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The project response to NRC question 420.5 was revised in FSAR Amendment 20 to state that the results of the analysis will be provided concurrent with the setpoint methodology report. Module 5 commitments are based on the FSAR through Amendment 14.

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(c) Comment The commitment '! Settlement Monitoring Program,"_ on page 34 does not correctly reflect the agreements reached with' the applicant on this subject. The matrix should be revised to correctly identify the monitoring commitments that cover specific settlement markers to be monitored, frequency of surveying, need for -monitoring following unusual-events (e.g.,

earthquake or large _ fluctuation in groendwater levels), and allowable total and differential settlement limits as described in the applicant's letter of May 21, 1985, and in the June 1985 SER in Sections 2.5.4.4.3 and.

2.5.4.5.

It appears the commitment matrix should also: include a subject for permanent groundwater monitoring The applicant has committed to numerous features of the monitoring program in FSAR Section 2.4.12 and in response to NRC question 241.10. In addition to the FSAR, details of the program are also contained in the Groundwater Supplement 'and the Geotechnical Verification Work Report transmitted by letters, Bailey to Denton, dated May 21, 1985, and August 23,

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1985, respectively.

Response NRC question 241.19 was reviewed and we believe that the commitment was correct as stated on page 34 of the commitment

matrix at the time this matrix was assembled..The commit-ments in this module are based on the FSAR through Amendment 14.

Any subsequent commitments made by Georgia.

Power Company regarding this subject will be factored into the Settlement Monitoring Program through the VEGP plant'

operations commitment tracking program.

Commitment with regard to monitoring. groundwater will -be

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addressed in modufe 9, as appropriate.

(d) -Comment On page 2, section 3.4, table 3.0-1, commitment matrix, ANSI N45.2.9-1972 should be changed to read ANSI N45.2.9-1974.

Response We agree with your comment. This correction was made in the addendum to module 5.

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(e) Comment On pages a and 5 of section 3.5, table 3.0-2, implementation matrix, there is a reference to FSAR commitment _1.9.38 which endorses ANSI N45.2.2-1975.

Page 1.9-37 of the FSAR lists the endorsed ANSI standard.as N45.2.2-1972. Pages 4 and 5 of the table should be changed to reflect the correct date of-1972.

Response We agree with your comment..This. correction was made in the addendum to module 5 which included revised pages 5 and 6:of the implementation matrix.

(f) Comment The commitment in table 3.0-1 by the applicant, to provide a Reactor Vessel Material Surveillance Program for Vogtle - is acceptable as stated on page 34, 241.1. ' In addition, the applicant should commit to operating the reactor. vessel in accordance with pressure temperature limits. The pressure temperature limits must consider the effect that neutron irradiation has on the fracture resistance of the Vogtle reactor vessel belt-line materials and must be calculated in accordance with the requirements of ^ Appendix G,10 CFR 50.

The amount of neutron. irradiation damage should be calculated using the methodology recommended by the staff in Regulatory Guide 1.99. These commitments appear to be related to plant operation and should be identified in section - 3.4 for module 5.

Response Your reference to FSAR 241.1 with regard to the Reactor-Vessel Material Surveillance Program'is in error. The proper reference is FSAR 251.1.

NRC question 251.1 was reviewed and we believe that the commitment matrix is correct. for this. question.

We are committed to comply with the conditions of-the. plant operating license, and the Technical Specifications are - a -

part of that license.

The - reactor vessel pressure temperature limitations are-specified in Technical Specifica-tion 3/4.4.9. Operating within these limits, in conjunction with the reactor vessel belt-line Material Surveillance Program, is a condition that will insure we meet the design requirements for the reactor vessel as described in the bases for the pressure. temperature limit specif.ication.

Our position on Regulatory Guide 1.99 is addressed in FSAR-Section 1.9.99.

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The staff reviewed. the applicants' responses and agrees with those responses and clarifications.

The staff has concluded that commitments delineated in Section 3.4 of the module, as editorially corrected in the November 1985 module resubmitted accurately agree with those commitments in the FSAR and SER.

(2) Evaluation of the.Section 3.5 Implementation Matrix During the initial evaluation of_the implementation of commitments pursuant to the implementation matrix of section 3.4, the staff identified deficiencies with the ' review process associated with module 5.

The staff had reviewed Vogtle procedure 00002-C, Plant Review Board - Duties and Responsibilities, to verify that selected FSAR' and proposed Technical Specifict+. ion commitments associated with the Planc Review Board were in fact. properly implemented into procedure 00002-C -pursuant to the readiness review module 5 implementation matrix.

Six commitments were determined by the staff _to not be implemented in' procedure 00002-C at all. These commitments were:

FSAR section 12.1.1.2: To verify that the overall radiation protection program is functioning properly, the Plant Review

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Board will review the written reports from audits of the ALARA program.

• FSAR section 14.2.2.4: -The members of the Plant Review Board will review the startup test results. Test results that are not satisfactory will be resolved under the direction of the Plant Review Board prior.to test acceptance. Once acceptance criteria have been met to the board's satisfaction, the members will recommend that the Plant Manager or designee approve the test as complete.

Completed tests.will become part of the permanent plant record.

(This is in actuality two commitments in the readiness review module 5 implementa-tion matrix; however, to maintain consistency with Georgia Power readiness review checklists, it is presented as a.

single commitment.)

• FSAR section 14.2.2.4: The Plant Review Board will review startup test results prior to management approval.

• FSAR section 17.2.3: The Plant Review Board shall review all proposed modifications to safety-related systems to determine whether an unreviewed - safety question (10 CFR 50.59) is.

involved.

• Technical Specification 6.7.1:

In the event a safety limit is violated, the NRC operations center shall be notified by telephone as soon --as possible within one hour. -The : Vice President and General Manager, _the Plant Review Board, and the Safety Review Board shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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Technical Specification 6.7.1:

The Safety Limit Violation

Report shall be submitted to the NRC, Safety Review Board, and Vice President and General Manager, Nuclear Operations within 14 days of the violation.

A review of Vogtle readiness ' review -checklists for _ module 5 reflected that one reviewer had verified that five of these six commitments were implemented in procedure 00002-C, and another reviewer had verified that one of the six commitments was implemented in procedure 00002-C. An interview with the reviewer who had verified five of the commitments reflected that an.

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improper and inadequate interpretation was involved in conducting that particular review and verification.

These deficiencies were identified as an unresolved item (424/85-36-01) and necessitated the termination of further NRC

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evaluation of this module until the applicant could properly determine the scope of the problem.and resolve it with appropriate corrective actions.

The staff considers these deficiencies identified in the unresolved item to be a finding.

On October 21, 1985, the applicant presented to Region II manage-ment, the results of their assessment of these deficiencies.

The applicant stated that extensive rereview, subsequent to the NRC inspection, had been performed by Georgia Power in order to define the bounds of the problem and in order to formulate appropriate corrective actions. The applicant stated that a 100% rereview was performed on the commitment matrix and implementation matrix of module 5 and a 50% rereview was performed on the verification process of module 5.

Additionally, 10% of each commitment matrix and at least 10% of each implementation matrix for modules 1, 2, 3A, 4, 7, 8, and appendices D and I were rereviewed.

The applicant stated that the results of their review indicated that:

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Although some commitments may not have been specifically delineated within commitment matrixes, in all cases redundant commitments ensured that the subject matter of the commitment

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was identified and tracked.

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The verification process of module 5 was satisfactory.

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The implementation matrix of module 5 was deficient in that 32 of the.260 commitments (12%) were either. not implemented by procedure at all, or were not implemented by the specific procedure identified by the matrix, but were implemented in other documents. Additionally, in 107 of.the 260 commitments-(41%), the commitments could have been more precisely implemented by the procedure specified, or other documents should also. have been identified within the matrix The

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remaining 121 commitments (47%) were determined to_ be ccmpletely satisfactory within the implementation matrix.

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The implementation matrixes for the.other modules-. reviewed

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had some minor ~ discrepancies which. involved " umbrella" procedure not completely. delineating some particular commit-

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ments.

The. applicant ' indicated that - they. considered ; these -

~ discrepancies to be isolated and concluded that they were not-l

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indicative of the problems noted with module 5.

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. The applicant stated that in the case of-modules 1, 2, 3A,- 4,;7,

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'8, and appendices D and I, different team leaders..with different

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review techniques. from that 'used in the module 5. review; were

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initially employed.

Additionally, in some cases, --even the :

discipline-managers and inspection processes were different'. The-applicant stated that in the case of module-5, the verification

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process was initiated prior to full -development of the implementa-

-- ti on matrix, and commitments for.. module 5 reviewers,were

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previously categorized to " umbrella" procedures prior. to the i

review taking place. Consequently, the applicant considered that

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j seeing the commitments-actually being : implemented may have erroneously led the reviewers to conclude that a given' " umbrella"-

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procedure adequately delineated specific commitments when in fact 4'

-it'did not. For these reasons, and as a result 'of.the rereview, the applicant concluded that'the problem' was isolated to module 5

and, specifically, the implementation matrix of: module 5, and-considered that the root cause-of; the problem with. module 5 was

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insufficient guidance for reviewers _ performing implementation

verification and-ir. sufficient feedbackmto ensure reviews were being properly performed. The applicant. stated that an; addendum

i to module 5 would be submitted which would correct deficiencies within the module. Additionally,. the applicant : stated that the-1.

following corrective actions. were. being-implemented to-prevent.

recurrence of.this type of problem:

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Discipline manager and--team leader overvie'w ' would be

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expanded, team training would be enhanced, readiness review l

administrative procedures would be strengthened, and a policy

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statement for. line organization responsibility - would 1 be-

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issued in order to ensure reviewers fully understood what-was

expected of them during the course of their review.

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.The readiness review teams would review the implementing

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j matrix in detail with the cognizant operational-superinten-

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dent to ensure complete understanding.

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Manageme would more thoroughly review the experience and r

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qualiff_ations of personnel assigned -specific. readiness review functions.

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Quality assurance involvement with readiness review would be

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expanded.

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The NRC. acknowledged the applicant's assessment and stated that'ai

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reevaluation.of ' module! 5 L and an' evaluation of Ethe-process and q

results.of Ethe applicant's ; rereview of < other ? modules would be.

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conducted by the. staff in order to determine if-the< applicant _had j

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i properly bounded this problem,:and'if correctiv'e-actions taken in

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response..to ;this. problem were ; adequate.

These actions.Lwere,

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identified as - inspector followup u item. (424/85-36-04).

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applicant revised module 5 ~and resubmitted it' to the :NRC fori

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evaluation-on-November.1, _ 1985.

On1 January 6-10 : and

February 10-14,.1986, the-staff-conducted the inspection effort

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identified in inspector followup item 424/85-36-04.

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F In assessing the module. 5. implementation. matrix, l100 Jof_ 277.-

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commitments =were selected forEreview.. For each commitment

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selected, the implementation matrix ' indicated that approved r

procedures. were associated with '.the commitment. : Ninety-two of-

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the 100 commitments were found to be satisfactorily implemented

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in the designated documents.

Seven of the 100 commitments were-

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not found to be implemented in any. :of the. approved: procedures-j

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associated with the commitment. However,xthese seven.were either i

E designated within the commitment _ tracking system as an open. item.

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l for implementation in a draft document' associated with.a commitment j

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or a document hr.d not yet been selected in the commitment tracking.

j system for the commitment and the L item was_- reflected as open.

• l These conditions are considered acceptable by the sta.ff. In-the j

i-case of one commitment, the staff considers that'the implementation

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l matrix, as well. as the commitment tracking. system,.provided for.

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l only partial implementation of this commitment; Specifically, FSAR l

j Section 13.5.1.2 contains a commitment that: ' administrative a

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procedures will include measure's - for ' feedback c of1 operating i

experience from within and outside utilities to the operators and -

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other appropriate personnel in accordance with NUREG-0737,.' Item -

1 I.C.5.

The module 5 implementation matrix identifies procedure

i 00414-C, Operations Assessment Program ~, as the Limplementation.

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documentation for that commitment.

Although : procedure 00414-C ~

does provide for programmed evaluation of operating experience and

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for distribution of operating; experience'to affected departments, j

it does not provide for establishment 'of e departmental' required

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reading files or for establishment of; training _ material.

Those

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documents which do provide for. these aspects of-- NUREG-0737, l

I Item I.C.5 should also'be: identified within-the commitment tracking.

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i system in order to-prevent inadvertent deletion of~ commitments from'

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-any procedure in effect for this commitment. This deficiency is

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considered to be a finding - and.is ~ identified as an inspector

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j followup item (424/85-55-01).

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f In assessing the applicant's rereview of other modules,- the staff:

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evaluated' the applicant's reviewer t checklists associated.with -

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modules 1, 2, 3A, 7, 8, and appendices D and I to determine!if

these checklists supported the applicant's conclusions 7that E the

problem was isolated to module ~ 5.

This evaluation-supported the

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applicant's. conclusions.

It _is noted, however,:;that -the

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documentation associat'ed with these reviews' was not'in all cases

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orderly _ and that. additional efforts were required by the : applicant -

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to. demonstrate that commitments were'in fact properly implemented.

j For example, the' module _3A reviewer checklists were incomplete 11n

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that resolution _ of -identified problems was~ not documented in some

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cases, some. checklists were unsigned, and -summary sheets ~ were fnot t provided for" portions of the creview.

At an ~ inspection-exit

interview' on; February:14,- 1986,. the applicant was able t to.

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demonstrate that the procedures-or commitment tracking system J

adequately provided for - commitment. implementation and that; the

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only problem was one of inadequate-. documentation in - the review i

i package.

The ' documentation has since. been -verified-to ( be-

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corremted with -the exception of: signing-~.one-preview. sheet

j associated with..a ' commitment-from: Regulatory. Guide :1.68. A.1.j(9);

i ar.d ensuring. that summary sheets reflect the 1 entire. review.

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Resolution of this concern is' not considered to be a-finding-but j

j is identified as an inspector followup item _ (424/85-55-02).

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The staff considers that, based on this review, the' applicant had f

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properly bounded the commitment. implementation problem and_ had l

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taken appropriate corrective actions with respect to this finding.

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Unresolved item 424/85-36-01 and inspector followup. item i

424/85-36-04 are closed.

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A d.

Section 4 - Program Description

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This section of the module addresses ~ the ' Georgia'~ Power Company-

l organization for plant operation.and how the organization implements ~

the operations quality assurance -program. _ In addition, -it discusses

i the implementation of licensing commitments.and describes'the responsi-ti

bility, authority, and measures for the. control and accomplishment of

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i activities affecting the quality of safety-relatedistructures, systems,

and components-of Vogtle.

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The evaluation of this - section consisted of _ a. program verification of ~-

three major activities where approved procedures - were in place and.

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where the work effort at this stage of operational: preparations was

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considered significant enough : for a review - to render meaningful:

conclusions.

The activities evaluated :were Plant -.. Review Board-

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activities, the - commitment tracking _ program, andjthe: operations

assessment program. Additionally, a programmatic review was conducted

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of 33 of the documents delineated in Table'4.1-1 of-module 5 in order

.i to ascertain the adequacy of implementation of 10 CFR _50, Appendix :B -

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criteria.

This review of 10 CFR -50, Appendix J B Limplementation was

limited since there was -not sufficient data available at this time..to.

a develop meaningful _ conclusions about the implementation of the. operations

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quality assurance program.

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(1) Evaluation of Plant Review Board Activities The staff reviewed the applicant's program for Plant Review Board activities and for performance of safety evaluations as defined'in proposed _ Technical Specifications, paragraph 6.5.1; ' readiness review module 5, paragraph 4.1.1.4; and procedures 00056-C, Safety Evaluations, 00051-C, Review and Approval of Procedures, and 00002-C, Plant Review Board - Duties and Responsibilities. The staff noted that the approach for-utilizing the Plant Review Board at Vogtle is different from that experienced at other utilities and different from that addressed in Westinghouse Standard Technical Specifications. As an example, the Vogtle Plant Review Board is staffed at a lower level of management than that

'

recognized by Westinghouse Standard Technical Speci fi c4 '.i ons.

The staff noted that Vogtle's approach for utilizing ' the Plant Reviaw Board is in compliance with Section 4.4 of ANSI N18.7-1976 and is consistent with proposed Vogtle' Technical Specifications.

Final disposition of Vogtle Plant Review Board activities.will be addressed through closure of the open item on this subject _in the SER and through approval of the Vogtle Technical Specifications. With respect to review of specific material, some procedures delineated in Westinghouse Standard Technical Specifications are not required to be reviewed by the Vogtle Plant Review Board.

For example, maintenance procedures, surveillance procedures, system operating procedures, annunciator response procedures, and changes to these procedures do not require review by the Plant Review Board unless-it has been determined that an unreviewed safety question -or Technical Specification change is involved. This determination is made by an independent safety evaluation reviewer and his supervisor in accordance with procedure 00056-C, Safety Evaluations The applicant, stated that they had -committed to a safety

'

evaluation reviewer qualification program in response to NRC questions associated with the NRR review of_FSAR Chapter 13. The staff reviewed the checklists for regulatory compliance safety evaluation reviewers and confirmed that a qualification program was implemented for reviewers in that department.

Although, the staff has some reservations concerning the fact that surveillance procedures, system operating procedures, and annunci-ator response procedures do not receive Plant Review Board review and approval, the staff does consider that the applicant's method for performing safety evaluations and utilizing the Plant Review Board is in compliance with regulations and can be adequate provid _

ed that Vogtle Technical Specifications are approved as proposed and provided that technical review of documents and safety evalua-tion reviews are properly implemented.

A determination as to whether procedures are technically adequate will be made as part of the routine preoperational and operational preparedness inspec-tion program, and at that time, conclusions concerning the scope ard extent of documents reviewed by the Plant Review Board can be more appropriately formulated.

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During c this evaluation, the. staff z noted' that' neither procedure

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. 00056-C, Safety' Evaluation, nor <00051-C, D Review. and Approval of Procedures, specifically stated that iff theJ safety evaluation A

reflected thatL &n. unreviewed safety.' question'.or Tech;nical-l

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Specification change existed,.' the! safety evaluation and c%nge -

would be' submitted to the Plant; Review Board 1 or. review.

The.

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staff considers that one of these procedures should be revi-ed to r

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speci,'ically delineate this requirement. This will ensure full-l compliance with. procedure 00002-C requirements which establishes:

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l the; Plant Review Board as. responsible for. review.of proposed -

-l procedures and changes to procedures, equipment, or systems which

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involve an unreviewed safety question;as defined by 10.CFR 50.59.

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.This concern -is considered to be a ~ finding and-has been identified -

as-inspector followup item 424/85-36-03.

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l In evaluating Plant Review Board activities, the staff interviewed l

i-the' Plant Review Board recording secretary, reviewed 17 meeting

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minutes. including all minutes'of meetings conducted in 1986, i

' reviewed resolution of Plant Review Board procedure comments for

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selected procedures from 12 meetings, - and ~ attended ' one P.lantJ

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- Review Board meeting.

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The staff considered that the conduct of-the observed Plant. Review

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Board meeting was proper and.- in - accordance. with : procedural ;

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requirements.

Board members ' were considered to - be ' properly -

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prepared and technically cognizant. of-the material' under review.

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In reviewing. the Plant Review Board-minutes, Plant Review Board

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j comments, and -procedures subject _ to those comments, the! staff.

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noted several deficiencies:

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l Plant Review Board minutes 85-28 reflected mandatory comments d

for emergency operating procedures' 19004 and 19010. :The

l letter which - forwarded - these comments E to - the ~ 0perations'

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l Superintendent,. dated June 28,.1985, -did not-iritcates -that

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any of the comments were. mandatory. The majority of_ comments.

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were = not incorporated.into the procedures. 'Since the

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mandatory comments were not identified 1to.the Operations-

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Superintendent and'since many comments were not incorporated,.

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it is not known whether mandatory comment.s were incorporated l

pursuant to procedure 00002-C, Plant Review Board Dutics and.

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-Responsibilities.

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Adequate ~ documentation _ of specific comments forie'nergency i

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operating procedures which :were approved.-with comment in; r

meeting minutes 85-29.was ~ not available. The -letter which

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was to forward the comments toithe-cognizant. departments for.

resolution, merely stated that.the procedures were approved

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i with comment and did -not indicate what the comments :were.

Additionally,.the letter did not : indicate if comments ~ were

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i-mandatory or optional. LConsequently, it is'.not possible to determine if Plant Review Board comments _were properly dispositioned in the affected procedures.

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Plant Review Board minutes 85-30 did Lnot reflect review of

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emergency. operating procedure 19121 which was accomplished" r

during that meeting. This is contrary to proposed Technical

i-Specifications, paragraph'6.5.1.

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Plant Review Board minutes '85-31 did not reflect review of:

administrative procedure 00200-C which.was accomplished

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during that meeting. This.is contrary to proposed Technical

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Specifications, paragraph 6.5.1.

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There were inco'nsistencies ^ in the way in which' procedu'res

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approved with comment were documented -in the minutes.

In some cases, the' mandatory and optional categorizations were

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designated in the minutes; in other cases, they were not'.

In.

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some cases,. a-comment was specified;-in other cases, it would

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not be. Additionally,_where there were two or more comments

i applicable to the documentp orly'one of the~ comments would be documented in the minutes.

i These deficiencies are considered to _ be a finding and ~ are identified as an inspector followup item (424/85-55-03).

The staff noted that coordinatian ~ and -documentation of meeting

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i minutes, Plant Review Board comments, and _ action -items are

dependent on the efforts of a single-individual,1the Plant Review Board secretary.

In the caseL of procedure comments, the' Plant

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Review Board members convey comments orally. to' the secretary who i

then documents them in' a letter to the cognizant. department -

responsible, for the procedure. The comments;are: categorized as i-either mandatory or optional.

The cognizant -- department must.

resolve all comments and must incorporate all mandatory comments.

i Once this is done, the procedure and _ comment letter is_-forwarded l

to the Plant General Manager'with certification'from the cognizant department head that comments have been resolved. Further-Plant

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Review Board review is not required._ Preparationiand issue of the

comment letter, Plant Review poard minutes, and updating _of various logbooks for tracking purposes'is time critical and intensive for

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the individual preparing the, docuentation, particularly when large-

numbers of procedures are being reviewed andJeeetings are -being.

conducted weekly or more frequently. The staff noted that the

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Plant Review Board secretary also ~ fulfills. responsibility:as-the i

Test Review Board secretary which is - currently : implemented 'in l-support of the preoperational test p'rogram. The ' staff considers

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j that the workload of the individual. fulfilling ~ these roles; in t

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conjunction with the allowed time frame for accomplishing this workload and the nrocess by which it is accomplished may be overly._

burdensome for that individual and contributory to these types of deficiencies.

(2) Evaluation of the Commitment Tracking Program A review was conducted of the implementation of-the Vogtle commitment tracking program as defined in procedure 00405-C,

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Commitment Identification, Tracking, and Implementation, and as defined in paragraph 4.9.1 of readiness review module 5.

The commitment tracking program was found to be implemented in accordance with procedures and the programmatic aspects were considered by the staff to be satisfactory. One problem was noted in that a regulatory compliance staff member had verified as complete that a commitment, for the Plant Review Board to review all proposed modifications to ~ safety-related systems _ to determine whether an unreviewed safety question was ' involved, was implemented in procedure 00002-C when in fact it was not. An interview with the individual who performed the verification reflected that his basis -for verification was an improper interpretation of paragraph 2.1.c (the Plant Review Board will review proposed tests and experiments that affect nuclear safety),

and 2.1.d (the Plant Review Board will review changes to Technical Specifications) of procedure 00002-C. The inspector noted that -

the individual was a new employee with Georgia Power and that his prior experiences were with another licensee. This concern was identified as a portion of unresolved item 424/85-36-01.

The applicant reopened the commitment tracking system item for this commitment and revised inputs to the system, as necessary, in conjunction with the rereviews associated with the module 5 commitment implementation problem delineated in paragraph _3.c.(2)

of this report.

Following this resolution, the staff conducted an additional review of 50 randomly selected commitments to determine if they were properly identified and dispositioned within the commitment tracking system.

All ' of the reviewed commitments were determined to be properly identified and dispositioned. As previously noted in paragraph 3.c.(2) of this report, unresolved item 424/85-36-01 has been closed.

(3) Evaluation of the Operations Assessment Program An evaluation was conducted of the implementation of the Vogtle operations assessment program as defined in readiness - review module 5, paragraph 4.9.3, and as defined in procedures 00414-C, Operations Assessment Program, and 80009-C, Operations Assessment Program - Coordination.

This evaluation ' focused on the coordination, ' tracking, and processing of operating experience requiring evaluation and action.

The inspection did not address the processing of operating experience with regard to training and required reading. Within the areas inspected,. the program was

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found to be implemented in accordance with procedure.

The programmatic aspects of the Vogtle operations: assessment program were considered to be' satisfactory and-in compliance with Item I.C.5 of NUREG-0737. Staff and. supervision associated with this.

program appeared to.be committed to proper implementation of this program.

One area of concern war noted in the evaluation of

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operational event reports. An inspection of selected responses to operational event reports indicated a -tendency for the applicant

to address issues programmatically rather than technically.

A. an example, IE Information Notice f 85723 identified inadequate surveillance testing at another facility which failed.to detect

the inoperability of the overpower delta - temperature reactor protection function and also which failed to detect the inoper-ability of a safety system due to improperly conrected-differential pressure instrument's. The applicant's., evaluation of this operational event report addressed only the program controls

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associated with ensuring performance of testing following work on -

i a giver component, utilization of maintenance work orders, and

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review of the work and testing performed.

The technical aspects

associated with defining what is an adequate test for ensuring operability of the overpower delta temperature function and for

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ensuring operability of differential pressure instruments were not

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addressed in the applicant's evaluation.

The staff. :onsidered

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l these particular examples to be significant since another s

Region II facility recently experienced the same overpower delta temperature problem and a' Region III facility recently experienced l

a similar problem with improperly connected differential pressure instruments.

The staff did not consider that the applicant's evaluation and actions with respect to this operati'onal event.

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report would preclude similar occurrences at Vogtle.

The applicant committed to reopen and reevaluate IE Information Notice 85-23 in light of this evaluation and additionally committed to -

evaitute the preoperational testing' associated with differential i

w ease. nnstruments in order to ensure that full operational capability is demonstrated for normal operating conditions during pacf;/cepts of these tests. The staff considers that the concern -

nbt(d LV an is a finding which has been identified as inspector followup item 424/85-36-02.

(4) Evaluation of 10 CFRL50, Appendix B Implementation Table 4.1-1 of module 5. delineates procedures which implement the

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operations quality assurance program and identifies those procedures to the specific criteria of 10 CFR 50, Appendix B.

The

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staff reviewed 33 procedures (42%) delineated in Table 4.1-1 and has concluded that from a programatic standpoint, these documents appear to adecuately implement ' the-applicable criteria of 10 CFR 50, Appendix B.

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Section 5 - Audits

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This section of the module describes the quality assurance -audit program and delineates those audit finding reports considered by the applicant to be pertinent to this module. Additionally, a response for

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each audit report finding as well as a readiness review conclusion is identified.

The staff verified that an audit schedule had been prepared for-1984, 1985, and 1986, that approved audit checklists were being-used during the conduct of audits, that audits were being issued in accordance with procedure, and that corrective actions were being planned or had been completed for audit findings. The staff independently reviewed audit reports and determined that section 5.0 of the module appeared to correctly reflect audit report findings applicable to this module. The staff reviewed the._ responses and readiness review conclusions associated with the audit report findings delineated in this section of the module and considered them to be adequate.

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Subsequent to the initial submission of module 5 and initial NRC review

,

of module 5, the onsite quality assurance group had performed one audit of the operations organization and administration area. This audit, SP01-85/15, QA Audit of Readiness Review Activities, addressed the following modules or appendices:

Module 2 - Operations Training and Qualification Module 3A - Initial Test Program Module 5 - Operations Organization and Administration Appendix D - Document Control The purpose of this audit was to determine the overall effectiveness of the readiness review organization in identifying commitments in the nuclear operations area, and verifying that these commitments were included in implementing procedures.

Relative -to module 5, the following is a summary of problems found:

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Implementing procedures for all commitments were not identified.

• Some commitments were not addressed in implementing procedures.

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Some commitments were only partially implemented by the procedures identified in the readiness review module.

This was due to

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l errors in the commitment matrix and errors in the procedures.

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The staff considers that the problems identified during this audit confirmed the deficiencies noted in unresolved item 424/85-36-01.

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Section 6.0 - Operations Organization and' Administration Verification

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This section of _ the module describes the' verification process and the.

• verification - results obtained -by the applicant's operations organiza-tion ~and administration readiness review-team.

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The initial verification plan was developed and implemented by the

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applicant's readiness review team. The nine members expendedjapproxi--

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mately 1100 personhours examining more than 4600 program ~ elements :to

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ascertain. whether the operations organization Jand administration

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commitments were implemented properly.

Each element was. either. a

' program commitment, program 1 implementing document, or any meaningful

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part thereof which was verifiable.

The 4600_ program. elements made :up the checklists arsociated with. the review program verification-i activities.

The nine team. members had cumulative experience of 76-person years in the construction, startup, and commercial operation of j

nuclear power plants. The initial objective of the. module 5 team was

to ascertain whether commitments applicable'to the_ operations organiza-tion and administration programs were implemented in the organization

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I procedures. To determine implementation, the team prepared a commitment-i matrix. The FSAR, through Amendment 14, was the controlling or baseline l

document for the identification of commitments. The completed commit-q ment matrix contained 272 commitments. The applicant's! readiness review j

team then reviewed plant procedures to determine the implementation or

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capture of these commitments. An implementation. matrix.was prepared

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which identified each of the 272. commitments, along with the procedure which fulfilled that commitment. Where an implementing procedure was

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identified but not issued, it was noted in the. remarks column. -The im91ementation matrix was presented as a product of.the module 5 effort which could _ be used to ensure present and.: continued commitment-fulfillment. The team then developed a plan for verification of these commitments and implementing procedures.

Specific areas chisen for observation included operations quality control,- operations cocument control, regulatory compliance, procedure development and revision,-

administration, Safety Review Board, Plant Review Board cIndependent-

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Safety Engineering Group, contractors quality assurance, corrective-action, and material' control.

Review of_these' items by the applicant-included direct observation of activities and interviews with line supervisors, engineers, quality control specialists, and reviews off completed documents.

During the. review. process,- over 150 of 272 commitments were reviewed.

Items not reviewed - included. some ANSI -

standards, procurement document. requirements, and-design 1 control requirements.

The applicant - concluded that' this review ' process not

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only confirmed and documented the effectiveness of controls within the operations organization, but.also identified certain concerns that were submitted as 16 readiness review findings. Corrective action' responses for ' these findings were prepared by the project, reviewed by the readiness review team,- and found to be acceptable.

One original finding was reduced to a.nonfinding. after the project identified;the-proposed procedures that implemented the commitments in question. This reduced the number of applicant readiness review findings ~to 1 *

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As previously identified, the staff. considered that this initial review process was inadequate.

However, efforts -taken by the applicant, to date, in order to resolve this deficiency are considered adequate.

Additionally, the staff considers that the applicant's subsequent'

reverification process, conducted in order to achieve resolution of this problem, does constitute an adequate review.

In evaluating the verification process and results ~ obtained by the readiness review team, the staff conducted a two phase review, Phase 1-involved a review of 15 of 26 of the applicant's readiness review checklist packages (58%) in order to determine if the methodology and concerns noted by the individual applicant reviewers on their check-lists were properly reflected in section 6 of the module. Phase 1 also included interviews with the readiness review team leader.

Based on this review, the staff considers that the module adequately addresses the methodology and concerns of the individual reviewers.

Phase 2 of this evaluation involved a review of each of the applicant's

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verification process findings and the proposed corrective action for these findings. Based on this review, the staff considers that the proposed corrective actions for those findings appear adequate. The staff was unable to completely verify completion of corrective actions since several actions remained outstanding at the time of this review.

The staff does note, however, that the applicant's quality assurance group has scheduled a specific audit - to verify conpletion of all readiness review action items.

Inspector followup item 424/85-44-01 was previously identified in NRC inspection report 50-424/85-44 to review results of this audit once completed.

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Section 7.0 - Assessment The section contains a summary of open corrective actions associated with the readiness review findings. Additionally, statenents assessing the acceptability of the readiness review from the readiness review quality assurance representative, the nuclear operations organization, and the readiness review board are included. Resumes of the personnel instrumental in the development of module 5 were also included. This section was reviewed for content only with no comment by the staff.

4.

Findings The following findings were identified from the staff's evaluation of this module. With the exception of the deficiency identified as unresolved item 424/85-36-01, the findings identified below are considered to be deficiencies which have minimal safety significance but which should be evaluated further to preclude safety problems.

These findings' have been

~ identified as inspector followup items and resolution of these specific-findings will be addressed during the routine -inspection program unless designated 55 closed in the finding.

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-In the. case of unresolved item 424/85-36-01, the stiaff considers' that the l

applicant responded to the deficiency in :a positive fashion by undertaki_ng'a J

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thorough reverification program,. revising, and resubmitting the module,' and

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. implementing - appropriate long term corrective. : actions.

-The staff's-

reevaluation. of ' module 5. following the applicant's' resolution' of. this -

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deficiency ' indicates that the module 5_ review may -now' be considered _to _ be

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satisfactory.

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The' initial ~ applicanti review "of

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. Deficiency (URI 1424/85-36-01):

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module 5 was considered inadequate due. to six commitments not' being :

' implemented in -designated procedures and yetureadiness reviewers.had '

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verified thatLthey were. implemented _ in those procedures.

The staffi

. considers that -the applicant-has implemented;. appropriate corrective

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actions to res'olve this concern and unresolved ? item.424/85-36-91.is

considered closed.

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Deficiency (IFI 424/85-55-01): Lower tier documents.which provide.for.

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implementing the required' reading and training aspects of FSAR Section

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13.5.1.2 and NUREG-0737, Item I.C.5 commitments are not adequately

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identified within the' commitment tracking system.

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Deficiency (IFI 424/85-36-03):

Neither, procedure 00056-C, Safety.

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Evaluation, nor 00051-C, Review and Approval-of Procedures, contained

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a specific requirement that if a safety evaluation reflected that an

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unreviewed safety question or Technical Specification change existed,-

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the safety evaluation and change would be submitted to the' Plant. Review

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Board'for review.

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,

Deficiency (IFI 424/85-55-03):

Two examples were noted where ' Plant -

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i Review Board meeting minutes did not reflect review of all.. procedures

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reviewed by the Plant-Review Board as required by proposed Technical l

Specifications.

Additionally, _ several examples were.noted where-it t

could not be demonstrated by the applicant that mandatory Plant Review-

Board comments had been satisfactorily dispositioned ?in -- documents as '

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required by procedure 00002-C, Plant Review. Board Duties and

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l Responsibilities. Also, inconsistencies were noted in the way Plant l

Review Board comments were documented in the minutes, j

.

'

Deficiency (IFI 424/85-36-02): An inspection. of: selected responses _to-

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operational event reports indicated, in the majority ~of cases reviewed, i

that there was a tendency. for reviewers to address -issues program '

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matically rather_ than technically resulting 'in _ evaluations and ! actions i

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which may not completely preclude similar occurrences - at'. Vogtle.

Evaluation of IE Information Notice 85-23 was noted as -a particular

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example where the staff considered that the ' applicant's ' evaluation

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would not preclude a similar problem from occurring at Vogtle~.

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Deficiency: Two examples were noted in the commitment matrix where the wrong revision date was delineated for quality assurance ANSI standards. Corrections were made in the resubmitted module and action associated with this finding has been completed.

Consequently, no follow-up item number is assigned.

.

5.

Conclusions The staff has concluded that commitments delineated in section 3.4 of the module, as editorially corrected in the November - 1985 module resubmittal, accurately agree. with those commitments in the FSAR and SER.

The staff notes that the initial verification of commitment implementa-

'

tion by the applicant's readiness review group was inadequate; however, the reverification accomplished by the applicant in response to the NRC's concern with this deficiency is considered to be adequate.

The staff has concluded, based on the sampling evaluation described in this report, that commitments delineated in this module are now.being satisfactorily implemented into precedures.

The staff has concluded that, with the exception of specific deficiencies noted in the report, activities of the Plant Review Board, the operations assessment program, and the commitment tracking program are implemented in accordance with procedure'and are satisfactory. The specific program deficiencies are not considered to be of significant enough scope or magnitude to affect the programs as a whole.

Additionally, the staff considers - that appropriate controls and processes are in place to reasonably conclude that other programs described in the module, which were not-reviewed, should be satisfactorily implemented.

This will be verified as part of the normal inspection program.

• The staff has concluded that portions of the module dealing with implementation of 10 CFR 50, Appendix B may have been prematurely submitted. This is based on the fact that insufficient data exists to develop meaningful conclusions with regard to implementation of this program at this stage of pre-operations.

6.

References 1.

Vogtle Electric Generating Plant, Readiness Review, Module 5,

Operations Organization and Administration.

2.

July 18,1985, letter from D. O. Foster, Vice President ~ and Project General Manager, Vogtle Project, Georgia Power Company forwarding module 5 for NRC evaluation.

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3.

NRC Inspection Report 50-424/85-44 issued September 24, 1985.

4.

October 29, 1985, letter from V. L. Brownlee for Director, Division of Reactor Projects, Region II, forwarding interim review NRC questions

._

_T associated with module 5.

l 5.

NRC Inspection Report 50-424/85-36 issued Nove-ber 25, 1985.

6.

November 1, 1985, letter from D. O. Foster, Vice President and Project General Manager, Vogtle Project, Georgia Power Company, forwarding revised module 5 addendum for NRC evaluation.

7.

December 30, 1985, letter from D. O. Foster, Vice President and Project

'

General Manager, Ve3tle Project, Georgia Power Company, forwarding

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Responses from Georgia Power Company to NRC Questions on module 5.

8.

NRC Inspection Report 50-424/86-02 issued February 10, 1986.

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