IR 05000424/1986024
| ML20211A111 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/25/1986 |
| From: | Belisle G, Moore L, Sinkule M, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211A040 | List: |
| References | |
| 50-424-86-24, NUDOCS 8610100784 | |
| Download: ML20211A111 (16) | |
Text
A C EIog'o UNITED STATES j
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NUCLEAR REGULATORY COMMISSION p[
REGION 11
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101 MARIETTA STREET,N.W.
- e ATLANTA, GEORGI A 30323
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Report No.:
50-424/86-24
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Licensee: Georgia Power Company
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P. 0.' Box 4545
" Atlanta, GA 30302 Docket No.':
50-424 License No.: CPPR-108
' Facility Name:
Vogtle 1
. Inspection Conducted: March 24-28, April 21-25, May 12-16, and June 2-6, 1986
' Inspectors:
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f//0[M L. R. Moore
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'Date/ Signed
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Y/Df/b p-R. W. Wright
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Date' Signed
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9/N[d Approved by:
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G. A LBelisle, Actitig Section Chief Date ' Signed-Quality Assurance Programs Section Division of eagtorSafety i.75 b d
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M. V. Sinkule, Chief, Projects Section 2D Dat'e Signed Division of Reactor Projects 86101o0784 $ h 24
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TABLE OF CONTENTS Topic
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. Sumary
Scope of Review
Methodology
Evaluation
Findings
Conclusions
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P V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM APPENDIX F INSPECTOR QUALIFICATION AND CERTIFICATION SUMMARY Th'is report is an evaluation of Appendix F 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 comitments have been properly implemented at the Vogtle Electric Generation Plant Unit 1.
Appendix F, which is one of an anticipated eight appendices, presents an assessment of the construction inspector qualification and certifi-cation (IQC) program implemented by the licensee and the site contractors. This evaluation was conducted to determine if the results of the program review
- presented in this appendix are an effective and accurate assessment of the project construction IQC requirements, that these requirements are being properly
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implemented, and that the resolution of findings identified in the appendix were correct.
This evaluation was performed by Nuclear Regulatory Comission (NRC) inspectors from Region II. The evaluation was accomplished through a detailed review of all sections of the appendix by:
(1) verifying that the construction IQC comitments
listed in the appendix-are correct and ccmply with Final Safety Analysis Report (FSAR) requirements; (2) reviewing the appendix findings and evaluating the correctness of their resolution; (3) reviewing a comprehensive and representative-sample of the records reviewed by the Readiness Review Staff (RRS); (4) selecting and reviewing a comprehensive and representative random sample of records concerning IQC; and (5) review of prior inspection activity in this area.
During the review, it was apparent 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 review of the construction IQC system was comprehensive and that the subject-program complies with NRC requirements and FSAR comitments.
Some programatic discrepancies were identified by the NRC inspectors. These items are classified as deficiencies.
A deficiency is considered to be an item having minimal safety significance, but one which should be evaluated by the licensee to determine what action could be taken to correct the item and thus preclude the possibility of the development of safety problems.
A listing of the deficiencies identified during this evaluation is sumarized below:
Deficiency - Procedures Not Revised to Meet GPC's Minimal Education
Comitment Deficiency - Specific Examination Given for Level I Liquid Penetrant Inspector Testing Did Not Contain the Required Number of
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As stated in Appendix F, IQC, this appendix was developed by a team comprised of experienced representatives from GPC Quality Control (QC) and the Skills Development Department.
The team's activities were overseen by Readiness Review Board technical consultants from Stone and Webster (S&W) Engineering Company.
The development of this appendix was monitored by the Readiness Review Quality Assurance staff.
The Readiness Review (RR) program consisted of two separate reviews: a governing and historical procedures review and an inspector qualification records review.
The governing procedures of GPC and each of the seven contractors were reviewed with reference to the applicable licensee comitments regarding Regulatory Guide (RG) 1.58, R1-1980 requirements.
The incoector qualification records review was conducted with the aid of a verification checklist which provided consistency during the review.
This verification process began with an initial plan which required reviewing representative samples of 60 contractor and GPC inspector certification folders to ensure compliance with existing approved procedures.
This review was later expanded to 100 percent examination (916 inspectors) of all identifiable past and present QC inspectors by the Project as a means of responding to a need for corrective action identified by RR Finding F-1.
To handle this expansion of work review, teams from GPC and each contractor were formed which consisted of individuals selected by the discipline level III administrators, the corporate nondestructive testing (NDT) administrator for GPC, and by appropriate management for the contractors. This reviewing group grew to 65 members at one point. The GPC QC and Skills Development organization provided overall leadership and coordination.
Additional technical guidance was provided by a technical consultant from S&W.
Once all corrective actions had been implemented by the Project for discrepancies identified from the 100 percent inspector qualification records review, a reverification review was conducted. This reverification review was performed by two individuals highly experienced in QC management but with no previous involvement at Plant Vogtle.
Based on these reviews, three findings were identified which were evaluated by the licensee to be violations with no safety concerns.
The first finding involved missing supporting IQC documentation and other administrative discrepancies concerning the original 60 contractor and GPC inspector certifi-cation folders examined. The second finding identified a discrepancy between the Chicago Bridge and Iron (CBI) IQC program and the requirements of ANSI N45.2.6 for levels of qualification and capability.
The last finding concerned a previous GPC-QA audit finding (TR01-80/28) which was believed to have been prematurely closed based on the preventive action taken to revise a Heating, Ventilating, and Air Conditioning (HVAC) training program without addressing the adequacy of training given to inspectors prior to the program revision.
NRC inspectors reviewed Appendix F on site during March 24-28, April 21-25, May 12-16, and June 2-6, 1986.
Approximately 180 inspector-hours were used during this review. Review details are delineated in this report. As previously stated, two deficiencies were identified.
It appears that these deficiencies do not represent significant programmatic weaknesses.
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Details on these items are discussed in the main body of this report.
1.
Scope of Review This review, consisted of an examination of each section of Appendix F by inspectors from Region II. Appendix F, Sections 1.0, 2.0, 4.0, 6.0, and 8.0 presents data on the appendix scope, responsible organization, program description, changes, and conclusions regar ing the assessment of the d
appendix, did not require as detailed a review or evaluation as the other sections. The more significant aspects of the appendix are in Sections 3.0, 5.0, and 7.0.
These sections discuss licensee commitments and implemen-tation, audits and inspections, and appendix verification. Review of these sections ' included a detailed review of content and examination of items identified as 'indings regardless of their final classification level. The inspectors er.4 mined 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 and an evaluation of each section are presented in the following paragraphs.
2.
Methodology The technical Appendix F review and evaluation was conducted in the Region II office during the week of March 17, 1986, and was supported by onsite inspection activity during the weeks of March 24-28, April 21-25, May 12-16, and June 2-6, 1986.
The office and site review of Section 3.0 compared the applicant's accepted QA program licensing connitments with (NUREG-0800) Standard Review Plan (SRP) positions, regulatory guides, industrial codes, and Vogtle FSAR documents.
During onsite inspections, the program description, Section F.4.0 was reviewed to verify that methods prescribed for qualifying and certifying inspection and NDT examiners was in agreement with current Project procedures and Regulatory Guide (RG) 1.58, R1-1980 requirements.
Audit reports, applicable IQC audit findings and the RRS findings were also reviewed to determine the significance of problem areas identified and the effectiveness of the IQC program implementation.
Project inspector qualification records were reviewed to verify that personnel qualifications were currently complete and met RG 1.58, R1-1980 requirements.
Inspector qualification files were also examined to assure that inspectors held the correct certifications during specific construction inspection activities.
3.
Evaluation The evaluation of each Appendix F section 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 F1 - Scope This section discusses the finite boundaries to which the IQC construction program was evaluated by the RRS.
The IQC program was examined by the RRS to ensure that construction personnel responsible for confirming-quality by inspection and test methods were adequately qualified for the performance of their assigned activities.
This appendix does not assess IQC during the initial test program nor during plant operations which are reportedly described in Modules 2 and 3.
This appendix does not ascertain whether inspectors held the correct certifications during specific construction inspection activities.
Verification of this attribute was performed by the RRS and the NRC during their routine module program reviews.
This section was reviewed for background information only. No followup or evaluation of this section was required, b.
Section F2 - Responsible Organizations Georgia Power Company (GPC) has the overall quality responsibility for all work performed at Plant Vogtle.
GPC provides primary inspection for those site contractors that do not provide a quality program as part of their contractual agreement.
Seven site contractors whose product or service is safety related and having GPC approved quality programs provide their own primary inspection. GPC provides secondary (monitoring) inspection responsibility for these contractors.
This section describes the various site contractor organizations at Plant Vogtle who are responsible for providing and adhering to their own IQC programs.
These site contractor IQC programs are required to be consistent with the GPC QA program and commitments contained in the FSAR.
Since the licensee has also relied on hired contract inspection personnel to fill specific needs in the GPC inspection program from time to time, this section details how these inspection personnel were certified.
This section was reviewed for background information and for general understanding of GPC primary and secondary inspection responsibilities.
c.
Section F3 - Commitments and Implementation (1) The inspectors reviewed the IQC commitments identified by the RRS in this section to confinn that they were the same as those
committed to in the FSAR.
t (2) The historical file of GPC's and pertinent site contractor's procedures governing IQC activities was reviewed to confirm that applicable RG, American National Standards Institute (ANSI), and the American Society for Nondestructive Testing (ASNT) standard commitments were updated in these procedures as necessary.
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(3) The RRS and the inspectors reviewed the' current procedures for GPC's.and the contractor's IQC programs to ensure compliance with licensee commitments and the requirements _of RG 1.58, R1-1980, ANSI N45.2.6-1978, and ASNT-SNT-TC-1A-1975.
One deficiency was identified in this area.
Section F4, Program Uescription, states that certified (ANSI and NDT) inspector personnel are currently required to have as.a minimum, a high school diploma or equivalent General Education Development (GED)
diploma. Affected GPC and contractor IQC procedures were supposed to have been revised by January 1, 1985, to reflect this mandatory minimum education requirement.
However, reviews conducted March 21,1986, of the latest revisions to Chicago Bridge and Iron's (CBIs), Pullman Power Products. (PPPs), and Nuclear Installation Service Company's (NISCOs) NDT certification procedures, and CBIs ANSI certification procedure revealed that this education requirement had not been incorporated into these contractor procedures to date.
Discussions with responsible personnel from the above mentioned contractors tnd related record reviews revealed that although their respective IQC procedures had not been updated, each contractor was well aware of this comit-ment and all active inspector personnel were found to meet this requirement. During the week of April 21-25, 1986, the inspectors reviewed and found acceptable the above mentioned contractor's revised IQC procedures which incorporated the minimum education comitment.
(4) Prior to June 1,1983, Vogtle Electric Generating Plant (VEGP)
was comitted to RG 1.58, R0-1973.
This guide endorsed ANSI N45.2.6-1973, subject to several alternative regulatory positions, and ASNT-SNT-TC-1A for nondestructive examination personnel.
On May 4, 1981, the NRC staff determined that the. intent of RG 1.58, R1-1980 should be implemented by all operating nuclear plants, and those still under construction. Generic Letter 81-01 required all licensees to comit to this revision, and either to provide their planned date for doing so or to provide alternate methods of doing so.
GPC's letter dated November 12, 1982, in response to.the NRC's Generic Letter 81-01 comitted to be in compliance with RG 1.58, R1-1980 with the exception of RG Position C8 for which the licensee proposed a satisfactory alternative described on Page 1.9-50 ' of the FSAR.
The date for project compliance was June 1983.
However, due to the licensee's misinterpretation of the requirement of position C.6. of RG 1.58, R1-1980, GPC has since June 1983, allowed certification of 32 inspection personnel without verification of their high school diploma or GED equivalent.
Licensee followup on this matter revealed that actually only 20 inspectors were proven to lack a high school u
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diploma or GED equivalent,14 of which have since passed the GED examination.
Six inspectors who are no longer employed at VEGP are known not to have obtained this education requirement.
The consequences of this deficiency appears minimal in that all inspectors were observed, trained, had appropriate experience and passed rigorous testing as required by ANSI N45.2.6 prior to certification and assignment.
The licensee kept the Commission informed of this deficiency by correspondence GN-489 and GN-742 which reported the corrective action taken to resolve this matter.
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 F4 - Program Description This section describes methods currently prescribed procedurally that are used for qualifying and certifying technical inspectors and NDT examiners for GPC and the seven QC organizations effecting the construction of VEGP.
In accordance with NRC RG 1.58-1980, technical inspectors are qualified and certified according to requirements established by ANSI Standard N45.2.6-1978; and NDT examiners are qualified and certified according to ASNT's Recommended Practice No.
ASNT-SNT-TC-1A-1975.
The GPC and contractor certification programs are described for ANSI and NDT inspectors in the following order:
Education and experience Physical requirements Training and certification requirements Recertification requirements All of the programs are similar; however, different procedures are used, and variations in certification /recertification processes and document handling exist.
Review of the section confirmed that the subject program description is correct and in agreement with the FSAR and project requirements.
e.
Section F5 - Audits and Inspections This section contains a review of various audits and evaluations performed in the IQC program area by GPC QA personnel, NRC Inspection and Enforcement (I&E) personnel, the Institute of Nuclear Power Operations (INPO) personnel, and for a self-initiated evaluation (SIE)
performed by off-project personnel from GPC, Southern Company Services (SCS), and Bechtel Power Corporation (BPC).
Problem areas identified by the review of audits or evaluations relative to IQC activities are tabulated in an enclosed table in Section F5.
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Those audit findings that were considered more significant in nature in
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that they resulted in corrective action that in some way effected the overall improvement of the IQC program were further identified.
This section also contains a listing of IQC program concerns that were identified in NRC Construction Assessment Team (CAT) inspection reports compiled from nine different nuclear facilities under construction.
These !QC concerns were factored into a checklist which was used to review GPC and contractor programs to determine if similar practices were evident at the Vogtle Project.
Review of this section indicates that it is an accurate presentation of the deficiencies identified against the IQC program.
f.
Section F6 - Program Changes (1) GPC The GPC and site contractor IQC procedures have been subjected to various changes as the Project progressed, as IQC responsibilities and training changed, and as regulations, standards, or commit-ments were updated or added to the Project requirements.
During the early stages of construction, there were not enough experienced nuclear construction inspectors available that met the minimum experience requirements of ANSI N45.2.6.
Plant Vogtle overcame this problem by establishing their own certification program; i.e., training, supervising, observing, and testing their own personnel to assure inspections were performed by qualified inspectors.
As the Project and site training programs progressed and the availability of experienced inspectors became a less significant problem, ANSI certification responsibility was transferred from the Atlanta General Office to the Vogtle jobsite in 1983.
Site-specific procedures were generated to govern all aspects of the IQC program and the position of Level III administrator (for each disciple) was developed to oversee the process.
The Level III administrators have completed training in administering the certification program and are capable of reviewing and establishing certification curricula.
Each has administrative responsibilities and does not work in the capacity of a field Level III inspector as addressed in ANSI N45.2.6-1978, or ASNT-SNT-TC-1A.
The new GPC site specific procedures, which revised certification, qualification, and responsibility, also eventually implemented a program (as of June 1983) designed to fully comply with RG 1.58, Rev.1,1980 and the FSAR alternative to RG Position C8 as required by NRC Generic Letter 81-01.
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(2) Contractors Pullman /Kenith-Fortson (P/K-F) made major changes in their train-ing and IQC procedures, and retrained their inspectors after a GPC audit identified inadequacies in their program.
In this area, GPC and its contractors, through QA audits and other evaluations have revised their programs when necessary, continually strengthening and enhancing their IQC programs.
g.
Section F7 - Verification of Project Quality Control Inspector Qualification and Certification This section describes the Project IQC program verification, resulting findings, and corrective actions taken to these findings.
The Vogtle IQC verification process conducted by the RRS was conducted in two phases.
(1) Phase I - Commitments / Procedures The applicable implementing procedures (described in Table F3-1)
for GPC and the corresponding procedures for each of the seven contractors who were performing inspections within the scope of this appendix were reviewed by the RRS to verify by reviewing objective evidence that commitments identified in Section F3 were contained within these procedures.
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The RRS reviewed and evaluated past audits and their associated audit-findings related to this area and concluded all findings had been adequately addressed by the Project.
Two RRS findings were identified in Phase I which were subsequently determined to be non-findings based on additional review and information.
Examination of these same documents by the NRC inspectors confirmed that the work by the RRS was acceptable except for the deficiency previously identified in paragraph 3.c.(3).
(2) Phase II - Implementation The RRS examined 60 inspector qualification folders (25 GPC,10 Williams Contracting (WC), 25 PPP) for the following attributes:
Procedures used for certification Training requirement completion High School diploma / General Education Development (GED)/
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Eye examination current for period in question
Date qualification / certification forms completed Supervisor's report of continuing satisfactory performance in file
Copy of certification / card in file Resume on file Verification of resume on file Experience waivers in file (if required)
Testsmaintained(ifrequired)
A checklist utilizing the above certification attributes was employed by members of the review team to assure that qualifi-cation folders were evaluated uniformally and systematically.
Phase II resulted in one finding (F-1) concerning incomplete documentation in the inspector certification files.
In response to the finding, the project examined 100% of all identified past and present QC inspector qualification records.
Discrepancies where found were investigated, and missing information, or justification for a lack thereof was collected to provide complete qualification folders which substantiated certifications held by the Project inspectors.
The NRC inspectors reviewed several of the completed checklists and the available supporting backup data prepared by the RRS on inspector qualifications.
The NRC inspectors independently examined 57 GPC and contractor inspector certification records (many inspectors had multiple certifications) out of the total of 916 certified inspectors identified to have worked onsite for conformance to the above applicable checklist attributes and RG 1.58, R1-1980. This random sample of 57 inspector certification records included eight GPC civil, ten GPC electrical, four GPC mechanical, five Soil and Materials Engineers, Inc. (SME), eight PPP, five CBI, four NISCO, three P/K-F, five WC, and five VSL Corporation (VSL) inspectors.
One deficiency and two examples of bad practice were identified during this review. The deficiency concerns a former PPP employee who was administered a NDE Liquid Penetrant (LP) Specific Exam for Level I qualification on September 22, 1981.
The test contained only 15 questions contrary to the contractor's commitment to SNT-TC-1A-1975 which requires 20 questions for Level I specific.
The subject employee failed the examination with a grade of 60%;
however, this employee was administered the same examination again
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on October 22, 1981, and passed with a grade of 100%.
Although SNT-TC-1A-1975 does not address this area, reexamination of inspection personnel using the same examination is a bad practice which needs to be avoided.
The - NRC inspector conducted discussions with responsible PPP representatives and examined their response (dated May 15,1986)
to the above deficiency during this June 2-6, 1986 inspection.
The inspector agrees with the contractor that even though this discrepancy exists, it does not present a problem. The LP Level I inspector involved could not evaluate and sign-off LP reports.
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All work that he performed had to be reviewed and signed-off by a Level II inspector.
The subject inspector terminated his employment with PPP 33 days later on December 3,1981.
PPP examinations now have the correct number of questions and the examiners have at least two examinations for each part of each NDT discipline.
This deficiency for giving a portion of an examination that did not contain the required number of questions was an isolated case and does not appear to constitute a threat to the health and safety of the public.
Another bad practice which was brought to the licensee's attention concerned a few occasions where GPC mechanical NDE personnel seeking certification in two or more disciplines have taken credit for initial work experience that was obtained well in advance of examination-testing and certification. A prime example of this is certification No. K-104 (Employee No. 49886) who was certified a ultrasonic testing (UT) Level I inspector in May 1985, based on visual testing (VT), liquid penetrant testing (PT), and magnetic particle testing (MT) work experience gained in 1984 and 25 percent of his work experience in UT which dated back to September 16, 1980.
Even though it was not the intention of this Appendix (See F1 - Scope) to assess whether or not inspectors held the correct certifications during specific inspection activities (this matter is discussed in the individual modules and appendices) the NRC review examined this area.
Inspection records from the various GPC disciplines and from the seven site contractors with their own QA programs were examined and the following informatian extracted:
Inspector's name and level (if available)
Inspection function performed Date inspection performed The Region II inspector then verified by examining each (approxi-mately 60 inspectors) IQC file that documentary evidence existed to assure that these inspection personnel were qualified to the proper level and discipline to perform the inspection tasks they participated in at that point in time.
No discrepancies were found during this review.
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The NRC inspectors examined the findings pertaining to the RR reverification study, a GPC-QA IQC related audit (CP05-85/84)
i conducted after the development of Appendix F, and the first (dated April 23,1986) Semi-Annual Review of GPC and Contractor Files.
The NRC inspectors concluded from the above audit reviews, discussions with responsible GPC and contractor IQC personnel, examination of the RRS methodology employed, the depth to which this review was performed (100%), the RRS resulting findings and the NRC inspector findings; that although an occasional administrative or procedural discrepancy is still being identified, the project's IQC program is effective and the personnel performing inspections at VEGP have been and are adequately trained and qualified in their specific area and level of certification.
(3) RRS Findings and Corrective Actions The NRC inspectors examination of the three RRS findings determined that they appeared to be properly categorized and the corrective actions taken to these findings was satisfactory.
Finding F-1, was written because the RRS found 568 instances of missing supporting documentation or other administrative discrepancies while checking approximately 3610 qualification attributes from a random sample of 60 inspector (many inspectors had multiple certifications) qualification folders.
In response to this finding, the project examined the above identified discrepancies and then conducted extensive reviews and corrective action that included the following:
Performance of a comprehensive review of all identifiable
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past and present QC inspector qualification records Identification of certification related documentation not in qualification folders but required by procedure. Most of the documents were located, reviewed, and, if found satisfactory, filed in appropriate folders.
When the required documents were not found, a review was performed to determine whether sufficient evidence existed to warrant generating a waiver or whether the certification was in jeopardy Identify other inconsistencies and take corrective action to
reconcile certifications for the time periods when certifi-cations were in force Achievement of consistent and complete certification folders for GPC and contractor QC inspectors
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The remedial actions taken to clear the inspector qualification folders of observed discrepancies resulted in reverification of inspector qualifications.
In some instances, additional examination of the inspector's work or work capabilities was necessary to validate past work and to assure that there was no hardware impact.
The project QC management analyzed the discrepancies found to determine what additional controls were needed to maintain a more satisfactory level of record keeping.
Program improvement recommendations were consolidation of files on the job site, establishing a uniform systematic format for all GPC and contractor certification files, establishing responsibility for accountability and maintenance of qualification folders, and the performance of semi-annual project IQC audits by GPC-QC to evaluate and assess the status of the IQC program.
All of the above improvements were found to have been already effectively implemented prior to the NRC inspector's review. These immediate actions taken by GPC management have greatly strengthened the IQC program.
Readiness Review finding F-2 identified what was perceived to be a discrepancy between CBIs ANSI IQC program (specifically procedure TIP-1 with appropriate supplements), and the requirements of ANSI N45.2.6 for levels of qualification and capability. A subsequent management review of CBIs qualification procedures and require-ments reaffirmed that the CBI experience and training given was equivalent to ANSI Level II requirements, consequently, no problem really existed.
Finding F-3 concerned a previous GPC-QA audit finding (audit-IR01-80/28) which was believed to have been prematurely closed based on preventive action taken to revise a HVAC training program without addressing the adequacy of the training given the inspectors prior to the revision.
Examination revealed that the course material being taught prior to the training being revised was adequate for the limited HVAC inspection activities being performed at that point in time.
4.
Findings During the course of this review, two deficiencies were identified by the NRC inspectors.
A deficiency is an item having no safety significance but one that should be evaluated further to preclude safety problems.
For documentation tracking purposes only, the below listed deficiencies are identified as Inspector Followup Items (IFIs) that have been opened and closed during this Appendix review.
As stated previously in this report, the NRC inspector examined the licensee's evaluation and corrective actions taken to resolve and mitigate recurrence of the subject deficiencies and concluded that these actions were satisfactory.
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Deficienc (IFI 86-24-01) Procedures Not Revised to Meet GPC's Minimal
(Closed Education Comitment Deficiency (IFI 86-24-02) Specific Examination Given for Level I (Closed)
Liquid Penetrant Inspector Testing Did Not Contain the Required Number of Questions 5.
Conclusions Based upon the review within the scope of Appendix C, Inspector Qualification and Certification, the NRC has reached the following conclusions for Vogtle Unit 1.
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Summary of Specific Conclusions (1)l Comitments - The inspectors have reviewed Section F3 and conclude that. Vogtle's licensing comitments and implementing documents comply with the FSAR, SRP, RGs, and industry. codes and standards.
(2) Program - The inspectors reviewed the program description in Section F4 and conclude that it is correct and in agreement with the FSAR and project comitments.
The Vogtle Project has upgraded its construction IQC program as required by the NRC's Generic Letter 81-01 and currently is in full compliance with RG 1.58, R1-1980, except for Position C8 for which the licensee has provided a satisfactory alternative position in the FSAR.
(3) Audits and Inspections - The inspectors reviewed Section F5 and concluded that it is an accurate presentation of the deficiencies identified against the IQC program.
(4) Program Verification - The inspectors concluded that although an occasional administrative or procedural deficiency is still being identified, the projects IQC Program is effective and -the personnel performing inspections at VEGP have been and are
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adequately trained and qualified in their specific area and level
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of certification. This specific conclusion can also be supported by performance of the Construction Inspection Program (Manual I
j Chapter 2512) by Region II Inspectors.
This program required
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observation and evaluation of the certification and qualification of the applicants' inspection personnel during the performance of their duties during construction of the facility.
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General Conclusions:
l Although discrepancies have been found with the construction IQC program since its inception, the licensee and applicable site contractors have promptly addressed, evaluated, and corrected the
deficiencies as necessary, and continually upgraded and enhanced this l
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Review and evaluation of Appendix F by the NRC indicate that the review 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..
The NRC findings identified as deficiencies appear to be minor and do not represent a breakdown in the quality assurance program.
The NRC furthermore believes that Appendix F accurately assesses the status of construction inspector qualification and certification 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 conclusions.
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