IR 05000424/1986037
| ML20212R520 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/16/1987 |
| From: | Dan Collins, Novak T, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20212R516 | List: |
| References | |
| 50-424-86-37, NUDOCS 8702020693 | |
| Download: ML20212R520 (45) | |
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Report No.:
50-424/86-37
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Licensee: Georgia Power' Company
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P. O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424 Construction Permiti ho.:
CPPR-108 Facility Name: Vogtle Unit -1 Review Topic:
Vogtle Readiness Review Module No. 7, Plant Operations and Support Review Conducted: April 1, 1986 - August 11, 1986 On-Site Inspections Conducted - April 1 - May 13, 1986, May 14 - June 30, 1986 July 1 - August 11, 1986, May 5-9, 1986 May 13-15, 1986, May 19-23, 1986, and June 2-6,1986, June 17-18,1986 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: J. F. Rogge, Senior Resident Review Members:
NRR/IE Reviewers:
W. Belke, IE F. Orr, NRR A. Masciantc.nio, NRR S. Chan, NRR S. Lee, NRR N. Fields, NRR S. West, NRR W. LeFave, NRR K. Dempsey, NRR 8702020693 870120 PDR ADOCK 05000424 G
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Region II Inspectors:
R. Schepens L. Nicholson
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P. Burnett J. Moorman A. Cunningham J. Macdonald W. Gloersen G. Troup G. Kuzo Approved by:
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M. V. Sinkule, Chief Date Signed /
Projects Section 2C Division of Reactor Projects
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($r14-l~ /(s 97 D. M. Collins, Chief Date Signed Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards l /h 8l f=
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T. Novak, Deputy 61 rector J
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Division of PWR Licensing A y
Office of Nuclear Reactor Regulation (NRR)
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TABLE OF CONTENTS TOPIC PAGE Summary iv Background and Scope of Review
Methodology
Evaluations
Findings
Conclusions
References
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE 7 PLANT OPERATIONS AND SUPPORT 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 7, which was submitted on February 6, 1986, presented an assessment by the applicant, which concluded that plant operations and support programs-at Vogtle are of sound quality and principally 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 plant operations and support presented in Module 7 was an effective and accurate assessment. The NRC evaluation was conducted to determine if requirements were being properly identified and implemented at Vogtle and to determine if the resolutions of the findings identified in Module 7 were appropriate.
This evaluation was performed by NRC reviewers and inspectors from the Office of Inspection and Enforcement (IE), the Office of Nuclear Reactor Regulation (NRR),
and Region II (henceforth referred to as the staff).
The evaluation was accomplished 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.
Veri fying, by review of a comprehensive and representative sample of approved procedures, that commitments are being implemented into procedures.
3.
Verifying, by review of a sample of programs delineated within the module, that program implementation is in accordance with procedures and commit-ments.
4.
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. The evaluation also indicated that commitments identified in the module accurately agree with those commitments in the FSAR and SER and that commitments were being satisfactorily implemented into procedures. With the exception of some specific deficiencies identified by the staff as findings, the tv
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NRC evaluation of the module indicated that programs associated with plant operations and support programs, which were specifically reviewed, are being implemented in accordance with NRC requirements and FSAR commitments. Addition-ally, 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
" Review Licensee Plan for Separation of Facilities and Systems Between Unit 1 Operation and Unit 2 Construction".
(IFI 50-424/86-31-03) (Closed)
Deficiency
" Review Minimum Shif t Crew Requirements as Implemented in
Procedure 10003-C for a Defueled Status". (IFI 50-424/86-31-04)
(Closed)
" Review Implementation of Technical Specification Overtime
Deficiency
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Conflicts with Procedure 00005-C". (IFI 50-424/86-31-05) (Closed)
Deficiency
" Review Licensee Changes to Procedure 00402-C prior to license issuance". (IFI 50-424/86-31-06) (Closed)
Deficiency
" Review Maintenance Procedure 20427-C for Incorporation of the ANSI Requirement to Document Closecut Inspection Results". (IFI 50-424/86-31-07) (Closed)
" Review Technical Specification Surveillance 4.8.1.1.1 Deficiency
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Implementation Procedure for Proper Verification of independent AC Power Sources". (IFI 50-424/86-60-03) (Closed)
Deficiency
" Review Licensee Response to the Locking of Four RHR Valves Pursuant to FSAR Section 7.6.2.2.0". (IFI 50-424/86-60-11) (Closed)
Deficiency
" Review Licensee FSAR Update to Reflect ASTM D3803 Criteria for Carbon Testing". (IFI 50-424/86-37-01)
Deficiency
" Review Licensee FSAR Update and Plant Procedures to Delete
Reference to In-place Efficiency Testing of HEPA Filter or Equipment".
l (IFI 50-424/86-37-02)
Deficiency
" Review Revised Implementing Procedures to Specify Correct
i Leakage Values for HEPA filter banks". (IFI 50-424/86-37-03)
I Deficiency
" Review Final Resolution Between NRR and Applicant Regarding
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Filter System Classifications for the Four ESF Systems". (IFI 50-424/
86-37-04)
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" Review Results of Baselining the Regulatory Compliance
Deficiency
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Computer database with the Readiness Review Module 7 Database". (IFI 50-424/86-60-04) (Closed)
Deficiency - " Review Compliance with TMI Item I.C.2, Shift Relief and
Turnover Procedures". (IFI 50-424/86-60-10) (Closed)
Deficiency - " Review Licensee Procedure Changes to 10000-C and 10006-C
Regarding Reactor Shutdown and Trip Review". (IFI 50-424/86-51-04)
(Closed)
Deficiency
" Review the Inspection Status Regarding Plant Housekeeping and
Cleanliness Control". (IFI 50-424/86-60-05) (Closed)
Deficiency
" Review the Establishment of a Plan to Collect and Evaluate
Transient or Operational Cycles for Adequacy". (IFI 50-424/86-60-06)
Deficiency - " Review Corrective Action Regarding Item #7-5 and #7-9 of Readiness Review Module 7". (IFI 50-424/86-60-07)
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1.
Background and Scope of Review Module 7 delineates program commitments for plant operations and support programs which includes initial plant startup and routine testing, plant operation, plant maintenance, plant engineering programs, and implementation of the operations quality assurance program required by 10 CFR 50, Appendix B.
The scope of the NRC evaluation of Module 7 as reported herein focused on commitments being properly identified and, as verifiable, satisfactorily implemented.
The scope of this NRC evaluation included:
a.
A review by NRR and IE reviewers of all commitments delineated in Section 3.2 of Module 7 in order to determine if the specified commitments agreed with those delineated in the FSAR and Safety Evaluation Report (SER).
Technical Specification commitments were not reviewed.
b.
A review by Region II inspectors of the implementation of the commitments delineated in Section 3.3 of Module 7 in order to ascertain that the commitments were being implemented into procedures.
c.
A review by Region II inspectors of selected programs to verify procedural compliance.
This was limited to activities where the work effort was considered in progress at this stage of review to render meaningful conclusions.
d.
A review by Region II inspectors of the readiness review verification packages to determine if Module 7 accurately reflected the review findings, e.
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 3.2 of Module 7 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.
b.
The evaluation by Region II inspectors of the implementation of those commitments selected for review was conducted by reviewing documents in Section 3.3 of Module 7 and verifying that the selected commitments were implemented within those documents. The review was restricted to only approved documents except for minor isolated cases identified in paragraph 3 of this report.
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The review by Region II inspectors of selected programs to verify procedural compliance was conducted in the areas of the operations, maintenance, and quality assurance standards.
d.
The review by Region II inspectors of readiness review findings was conducted in two parts:
a review of the applicant's readiness review team reviewer checklist packages to ascertain if there were cases where review team member findings were not properly reflected in the module.
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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.
Also where applicable reference is made to the specific inspection report which supports the below listed paragraphs.
a.
Section 1.0 - Introduction This section provides the scope of the module and the status and schedule of implementation of the programs that will support plant operation. 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 organizations involved with plant operations and support. 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 and other official documents.
This section also identifies the source of commitments to be from the FSAR (only including chapter 6 to the Technical Specifications); responses to NRC questions associated with the FSAR; Responses to generic letters; responses to IE Bulletins; and self-initiated correspondence.
This module is considered accurate as of October 15, 1985 thru FSAR Amendment 18.
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 3.2 of the module. The applicant identified 1266 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 that fulfills a project commitment applied to a specific activity.
Implementing documents were identified for most of the 1266 commitments and this information was tabulated in an implementation matrix identified in Section 3.3 of the module.
It should be noted that when an implementing document was not approved it was listed as a draft document.
The evaluation of this section consisted of reviewing the commitment matrix delineated in section 3.2 and reviewing the implementation matrix delineated in section 3.3 as discussed below.
(1) Evaluation of the Section 3.2 Commitment Matrix:
Each commitment in section 3.2 of the module was reviewed by either the responsible NRR review branch or the IE Quality Assurance Branch to determine comprehensiveness and consistency with their respective FSAR and Technical Specifications sections.
The Vogtle SER (NUREG-1137) and its Supplement No. I were utilized to determine the acceptability of FSAR information.
The applicant was contacted to assist in the assessment of the significance of identified items by providing clarifications, and to assist in resolution of other items.
The following methods were used to resolve items under consideration:
1.
Finding that the i tem (s) was not significant to licensing commitments, 2.
Referencing the completed review of other modules; e.g.,
Section 14.2 commitments were reviewed in Module 3A, Initial Test Program-Preoperational Test Phase, 3.
Finding that the commitments are beyond the valid scope of this review; e.g., Technical Specifications commitments, 4.
Revision or addition of commitment items; e.g., amendment of Commitment 1731, or 5.
Acceptable revision of the FSAR source statement for clarification; e.g.,
Commitment Number 2256 versus FSAR Section 17.2.14.C.
The following 19 commitments were considered separately and found acceptable.
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i 1706 1707 1708 1709 1710 1711 2621 2747 2748 2749 2750 2751
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2290 2874 2289 2282 2283 2619 2620
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l Forty commitments representing approximately 4 percent of Module 7, were checked for obvious concerns, but were not reviewed in detail.
Based on the relatively small
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number of commitments involved and the small amount of significant corrective action experienced in the resolution of the other commitments (approxi-mately 900 commitments) that were reviewed, this approach was judged to be acceptable.
Sixteen comments were identified which required further clarifica-tion by the applicant.
by the applicant in a letter dated October 3, 1986.The requested c After resolving over 140 commitments by employing options consistent with the above methods the list of controversial commitments was reduced to the following, where the resolutions are discussed below.
1.
Commitment 1731, FSAR Section 13.5.1.1. A the applicant stated that General Manager - Vogtle Nuclear Operations (GMVNO) has
'i the ultimate responsibility for all plant procedures.
GMVN0 is also the approving authority for procedures which The establish plant wide administrative controls, and other listed procedures.
The applicant also stated that nuclear operations department heads are the approving authority for other procedures in their respective areas of authority.
Commitment 1731 as originally stated would give nuclear operation heads approving authority, under direction of GMVNO for all procedures in their respective areas, implicitly including those listed by the FSAR as reserved for the GMVNO.
The commitment this inconsistency.and/or FSAR should be clarified to resolve RESOLUTION:
The applicant has responded by amending Commitment 1731 with an appropriate clarification, as requested.
2.
In FSAR Section 13.5.1.1.C the applicant identified that the superintendent of Regulatory Compliance will have overall responsibility for direction, control, and administration of the operations assessment program.
the Module 7 commitments and should be resolved.This is RESOLUTION:
By letter dated October 3,1986, the applicant stated that this commitment is implemented in Module 5 of the Implementa-tion Matrix, Section 13.5.1.2 (Document 00414-c).
finds this reference acceptable.
The staff
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3.
FSAR.Section 13.5.1.1.C contains a discussion identifying that procedures include steps which ensure records are maintained to reflect the status and disposition of operating experience evaluations and their associated corrective actions.
Completion status and followup verification status of completed action is tracked to ensure implementation.
Additional steps ensure that plant personnel do not routinely receive a large volume of operating esperience that might obscure the lessons to be learned from more significant events.
This is not reflected in Module 7 commitments and should be resolved.
RESOLUTION:
By letter dated October 3,1986, the applicant stated this material is covered in Module 5; and is also covered by Commitments 2342, 9125, and 9126 in the Operations Commitment Tracking Database.
The staff finds these references acceptable.
4.
In Module 7, Commitment Number 1889, the applicant states that gamma and neutron surveys are taken at various power levels.
In the FSAR, Section 14.2.6.4, the applicant also indicated that these surveys are to be taken at " selected" points.
Since the purpose of the surveys is indicated to be the verification of radiation shielding adequacy, the latter specification should not be omitted.
RESOLUTION:
By letter dated October 3, 1986, the applicant indicated that this commitment is addressed in Module 9A. We also note that the material related to FSAR Section 14.2 is also covered in Module 3A.
Because the completed reviews of Modules 9A and 3A do not identify this as an open item, the staff find the reference acceptable.
5.
Module 7, Commitment Number 2256 was not consistent with its source FSAR Section 17.2.14.C.
RESOLUTION:
The applicant has committed to amend FSAR Section 17.2.14.C to clarify its intent, thereby resolving the question.
l 6.
FSAR Section 13.5.2.1 includes a discussion of a general I
format which will normally be used for operating procedures.
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Since the format also implies the content, the format and its
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RESOLUTION:
By letter dated October 3, 1986, the applicant indicated that Commitment 1793 references FSAR Section 1.9.33, which in turn addresses compliance to ANSI Standard N18.7-1976 for enforce-ment of compliance. The staff finds that these references clarify the classification basis and are acceptable.
7.
In FSAR Section 13.5.2.1, the applicant identified seven classifications of operating procedures. This classification system is not identified in the Module 7 commitments.
Since the classification of a procedures could influence its implementation, the seven classes should be identified in the Module 7 commitments.
RESOLUTION:
By letter dated October 3, 1986, the applicant indicated that the seven classifications of operating procedures are implemented through Operations Commitments 8151, 8152, and 6790.
The staff finds these references acceptable.
8.
In FSAR Section 13.5.2.2, the applicant identified four categories of maintenance procedures. Module 7 commitments address only one maintenance procedure category.
The other three categories should also be addressed in Module 7 commitments to give an appropriate perspective for mainte-nance procedure categorization.
RESOLUTION:
By letter dated October 3, 1986, the applicant referenced Procedure 00050-C, " Procedure Development" as implemented through Readiness Review Commitment 1803 and Operations Commitments 8151 and 8152.
The staff finds that with the implementation of these commitments the intent of the concern will be addressed and, therefore, the reference is accept-able.
9.
In FSAR Section 13.5.2.2, the applicant stated that mainte-nance procedures will be completed approximately six months prior to fuel loading and that the maintenance department has responsibility for work performed in accordance with these procedures. Module 7 commitments do not cover these items.
This should be resolved.
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RESOLUTION:
By letter dated October 3, 1986, the applicant indicated that-all the originally identified procedures have already been completed in accordance with FSAR Section 13.5.2.2.
The staff finds the applicant's response addresses the intent of the question and is acceptable.
10.
In FSAR Section 13.5.2.3, the applicant discusses "other procedures" in four areas.
Three of these areas, Health Physics Procedures, Laboratory Procedures, and Emergency Plan Implementation Procedures are not covered in Module 7 commitments.
This should be resolved.
RESOLUTION:
By letter dated October 3, 1986, the applicant indicated that the items in question are covered by Modules 9A, 9B and 15, respectively. Because these commitments were not identified as being of concern in the referenced Modules, the staff finds the references acceptable.
11. With exception of Commitment Number 1889 (discussed above),
FSAR Section 14.2 items were assumed to be covered by the Module 3A review.
12. As discussed above (" Scope"), Technical Specifications commitments were determined to be beyond the scope of this review.
13. On page 3 of the Operations Commitment Matrix in Module 98, ANSI 45.2.9-1972 should be changed to ANSI N45.2.9-1974 in order te reflect the correct date of the ANSI Standard as endorsed by Regulatory Guide 1.88, Rev. 2.
RESOLUTION By letter dated October 3, 1986, the applicant committed to correct Commitment 822 to reflect the correct date as requested.
The staff finds this acceptable.
14.
In Table 3.2-1, Commitment Number 1110, Conduct of Mainte-nance, R.G.1.118, the commitment subsection should be more precisely identified since other Reg. Guides are mentioned in this section.
This section should be 7.5.2.3.1.3.J.
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By letter dated October 3,1986, the applicant has committed i
to make the requested clerical correction. The staff finds this acceptable.
15.
In Table 3.2-1, Commitment Number 1147, Maintenance Procedures and Documentation, the commitment should be more precisely identified as FSAR Section 8.3.2.1.1.1 rather than 8.3.2.1 as shown in the Commitment Matrix.
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i RESOLUTION:
By letter dated October 3,1986, the applicant has committed
te make the requested clerical correction.
The staff finds i
this acceptable.
16.
FSAR Section 5.3.1.6, Surveillance Testing Programs, Commitment No. 1007, and FSAR Section 5.3.1.6, Surveillance Testing Programs, Commitment Number 2713, are not consistent with SER requirements. The Commitment Matrix and the FSAR section show conformance to ASTM E185-1979. However, the SER indicated that conformance to ASTM E185-1982 is required.
j Thus, the commitments and the FSAR should be updated to the
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edition of the standard specified in the SER.
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RESOLUTION:
By letter dated October 3,1986, the applicant clarified the Commitment 1007 was consistent with the FSAR revision current at the time Module 7 was written and indicated that the
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discrepancy will be corrected to be consistent with the Commitment 2713. The staff finds this acceptable.
17.
FSAR Section 6.6.1, Surveillance Testing Programs, Commitment
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Number 1089, is not consistent with the contents of the FSAR
section. Class 1 components are not included in this FSAR l
section and should be deleted from the description of this
commitment in the Commitment Matrix.
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RESOLUTION:
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By letter dated October 3,1986, the applicant committed to
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correct Commitment 1089 to reflect consistency with FSAR l
Section 6.6.1.
The staff finds this acceptable.
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18.
FSAR Section 1.9.34 (Regulatory Guide 1.34), Control of Electroslag Weld Properties, should be included as a commitment.
Regulatory Guide 1.34 is referenced in FSAR Section 5.2.3.4.6.
Because FSAR Section 5.2.3.4.6 is included as a commitment (Commitment Number 1004), the referenced Regulatory Guide should also be included as a commitment.
The applicant stated that fabrication procedures are not within the scope of Module 7.
Regulatory Caide 1.34 is included in an in-house Module 21, Appendix W (Commitment Number 214).
We are of the opinion that fabrication procedures appear to be within the scope of Module 7 because Regulatory Guide 1.31,
" Control of Ferrite Content in Stainless Steel Weld Materials," is included as a commitment (Commitment Number 755). Furthermore, Regulatory Guide 1.34 is not included as a commitment in any of the Modules submitted for review. Thus, Regulatory Guide 1.34 should be included as a commitment.
RESOLUTION:
By letter October 3, 1986, the applicant committed to include FSAR Section 1.9.34 as a commitment if the need to use electroslag welding arises.
The staff finds this acceptable.
19.
FSAR Section 5.2.3.3.2, Control of Welding, should be included as a commitment.
FSAR Section 5.2.3.3.2 describes the control of welding in ferritic materials.
FSAR Section 5.2.3.4.6 describes the control of welding in austenitic stainless steel. Because FSAR Section 5.2.3.4.6 is included as a commitment (Commitment Number 1004), FSAR Section 5.2.3.3.2 should also be included as a commitment for consistency. Furthermore, FSAR Section 5.2.3.3.2 references Regulatory Guide 1.50, " Control of Preheat Temperature for Welding of Low-Alloy Steel;" this Regulatory Guide should also be included as a commitment.
The applicant stated that fabrication procedures are not within the scope of Module 7.
Regulatory Guide 1.50 is included in an in-house Module 21 Appendix W (Commitment Number 216).
We are of the opinion that fabrication procedures appear to be within the scope of Module 7 because the control of ferrite in stainless steel weld metal and methods used, described in FSAR Section 5.2.3.4.6 is included as a commitment (Commitment No. 1004).
Thus, the control of welding is ferritic metals described in FSAR Section 5.2.3.3.2 should be included as a commitment. Similarly, the
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referenced Regulatory Guide 1.50 should be included as a commitment.
Although Regulatory Guide 1.50 is included as a commitment in Module 16 (Commitment Number '1546), this does not preclude its inclusion in Module 7.
For example, Regulatory Guide 1.31 is included as a commitment in Modules 7 and 16.
RESOLUTION:
By letter, dated October 3,1986, the applicant has cTarified that its implementation of FSAR Sections 5.2.3.3.2 and 5.2.3.4.6 will meet the intent of our concern. The staff
, finds this acceptable.
The staff has concluded that the commitments are consistent with the Vogtle licensing commitments and are within the defined scope of Module 7 and are, therefore, acceptable.
(2)
Evaluation of the Section 3.3 Implementation Matrix The section was evaluated in conjunction with the evaluation for section 6.0 verification.
The staff selected various commitments where an approved procedure existed and compared the source document to the listed commitment and verified that tne commitment
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had been incorporated.
Since the readiness review team had performed the development of the matrix beginning in June 1985 until December 1985, numerous differences between the table and what is implemented were noted. In each case the staff reviewed the latest revision of the approved document.
Of the 1266 commitments, 777 were listed as having approved documents which could be reviewed. The staff divided the 1266 commitment into the following functional categories, a.
Operations b.
Maintenance c.
Quality Assurance Standards d.
Test Activities e.
Emergency Planning / Health Physics f.
Fire Protection / Prevention It was then noted from this process that the areas of Test Activities, Emergency Planning and Health Physics, and Fire Protection / Prevention had not been sufficiently developed to warrant onsite staff review beyond the scope that the applicant performed.
A partial review of test activities was conducted.
These areas were determined appropriate for review under the normal inspection program.
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All commitments were reviewed and a smart sample was taken from those commitments that were in a fully implemented status.
A smart sample differs from a random sample in that it ensures that significant commitments are examined.
The results of this selection are as follows:
Functional
% of All
% in
%
%NRC Category Commitments Draft Selectable Examined a. Operations 14.1
79 97.8 b. Maintenance 20.2 57.5 42.5 51.3 c. Quality Assurance 23.0 23.6 76.4 28.7 Standards d. Test Activities 27.4
31 27.5 e. Emergency Planning /
7.6
13
Health Physics f. Fire Prctection/
7.7
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Prevention 100.0 The staff identified the following deficiencies during the examination of individual commitments:
During the review of commitment numbers 2706, 2707 and 728 the staff identified that the implementing documents were not correct to control the separation of Unit 1 and 2 upon licensing of Unit 1.
For commitment 2706, Procedure 1-500-01 " Initial Fuel Load Test Sequence" Step 5,20 does not -satisfy this commitment.
Commitment 728 incorrectly lists the sections of the actual procedures verified and appears to be short on scope in that only two systems out of twenty-three shared systems identified in FSAR Section 1.2.2.2. have been addressed.
From discussions with the licensee the overall program has been established to control the separation of Unit 1 and 2, was developed by Southern Company Services, Inc. and access to the plan will be provided. This item will be tracked as Inspector Followup Item 50-424/86-31-03 " Review Licensee Plan for Separation of Facilities and Systems Between Unit 1 Operation and Unit 2 Construction".
Commitments 765.01 and 765.02 concern the designation of positions requiring R0 and SRO licenses and the establishment of minimum staffing levels. Site Procedure 10003-C " Manning the Shift" and 10010-C " Operator Qualification Program" were reviewed.
In discussions with the Readiness Review Team, the staff was informed that Procedure 10003-C was only verified to ensure minimum crew levels were specified, but no judgment was made as to adequacy of the numbers specified.
The staff reviewed various source documents of minimum requirements such as 10CFR 50.54 (M), NUREG 0737 1. A.1.3, Generic Letter 82.12 and the Standard Review Pla.
.
The staff determined that the procedure does not adequately discuss minimum manning for a defueled state. Final minimum shift crew will be established by Technical Specifications upon license issuance. Inspector Followup Item 50-424/86-31-04 " Review Minimum Shift Crew Requirements as Implemented in Procedure 10003-C for a Defueled Status".
In reviewing Commitment 765.06 it was noted that Procedure 00005-C, Rev 1 " Overtime Authorization" allows approval at the department superintendent level for exceeding the guidelines instead of the General Manager - Vogtle Nuclear Operations. The procedure does not specify the paramount consideration that need be made prior to approval of excess overtime. The procedure does not control regular overtime to monitor the obtainment of a 40-hour week objective.
The procedure references NUREG 0737 I.A.1.3 which has been replaced by Generic Letter 82-12 and 82-16.
In FSAR Change Submittal Number 22 the licensee has revised the level of authorization to coincide with the Site Procedure 00005-C. It was noted that this issue will be resolved when the Technical Specifications are issued.
Inspector Followup Item 50-424/86-31-05 " Review Implementation of Technical Specification Overtime Conflicts with Procedure 00005-C".
In the review of Commitment 764.01 the staff noted that the word
" body" had been deleted from the phrase " independent review body".
The listed implementing _ document, 00402-C " Licensing Document Change Request" was not correctly verified in that other procedure reviews were taking credit for implementing this commitment nstead of the " independent review body", namely the Plant Review bsard. Procedure 00402-C does not discuss the second " independent review body" entitled the " Safety Review Board".
The staff
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determined that this commitment had not Deen properly verified nor implemented. Procedure 00402-C was also noted as weak regarding the following:
a)
Step 4.2.1 limits the PRB review for potential USQ's
" Unresolved Safety Questions" vice the full scope of a PRB review to advise on all matters related to nuclear safety.
b")
The procedure does not coordinate reviews to the SRB.
c)
Section 4.2.9 states in the note "The superintendent of Regulatory Compliance has 60 days from the date the NRC approved the change to ensure the change is fully implemented in the plant activities".
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The -staff informed the licensee that license changes are usually effective upon issuance.
Failure to comply with a requirement
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would warrant on NRC citation.
The Readiness Review Team identified Procedure 00001-C " Plant Review Board Duties and Responsibilities" as the appropriate document for commitment 764.01.
This item will be tracked as Inspector Followup Item 50-424/86-31-06 " Review Licensee Changes to Procedure 00402-C prior to license issuance".
During review of the above noted commitments in the maintenance area, the staff noted that commitment No. 765.43 referenced Administrative Procedure No. 00254-C, Rev. 1 " Plant Housekeeping &
Cleanliness Control" is the implementing document for ANSI N18.7-1976 Paragraph 5.2.10.
However, in review of the subject procedure the staff could not find where the procedure implemented the statement "Immediately prior to closure an inspection shall be conducted to assure cleanliness and the result of such inspection shall be documented "Per Paragraph 5.12.10 of ANSI N18.7-1976."
During the revitw of Maintenance Procedure N. 20427-C, Rev. 0
" Maintenance Cleanliness and Housekeeping Control" the staff noted that Paragraph 4.3.5.b.6 addressed that an inspection be conducted prior to closure.
However, there was no requirement that the inspection results be documented. This matter will be identified as Inspector Followup Item No. 50-424/86-31-07 " Review Maintenance Procedure 20427-C for Incorporation of the ANSI Requirement to Document Closeout Inspection Results".
Commitment 827 pertains to proper implementation of a Technical Specification (TS)
for electrical systems per Regulatory Guide 1.93.
T.S. Surveillance Item 4.8.1.1.1.a will require that each independent circuit between the offsite transmission network and the Onsite Class IE Distribution System be determined OPERABLE at least once per 7 days by verifying correct breaker alignment and indicated power availability.
Procedure 14230-1, "AC Source Verification", was established to implement this requirement, however, only verifies independent systems up to the Reserve Auxiliary Transformers. This procedure needs to include verifica-tion to the IE Class power to ensure that two independent AC power sources exist.
The staff determined that this would have constituted an NRC violation. A second issue was noted to the licensee regarding TS surveillance 4.8.1.1.1.b.
This item has been proposed for deletion by the licensee based on the plant design not having a typical PWR transfer setup on the class 1E bus between normal and alternate power supplies.
The staff informed the licensee that this surveillance pertains to all transfer devices that interface with the " independent circuits between the offsite transmission network and the onsite Class IE Distribution
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System." A review of FSAR Fig. 8.3.1-1 indicates the following busses would be included in this surveillance: INAA, INAB, INA01, INA04, INA03, 1AA02 and IBA03. Both items will be reviewed closer to licensing and tracked as Inspector Followup Item 50-424/
86-60-03 " Review Technical Specification Surveillance 4.8.1.1.1
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Implementation Procedure for Proper Verification of independent AC
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Power Sources".
Commitment 1120 concerns the implementation of FSAR Section 7.6.2.2.0 which states that the bypass of RHRS interlocks at the local station is under strict administrative control with the valves locked closed to prevent unauthorized opening of the valves.
The valves in question are 1-HV-8701A, 1-HV-8701B, 1-HV-8702A and 1-HV-8702B are the RHR isolation valves utilized during cooldown and must be maintained shut during Modes 1, 2 and 3.
The implementing document 13011-1, " Residual Heat Removal System" controls the opening and locking of the power supplies to prevent operation from the control room as part of placing RHR in standby.
The staff questioned the licensee why the manual handwheels were not locked and what procedure controls this evolution.
The staff noted that P&ID 1X4D122 does not denote these valves as being locked closed. In order to track this item the following is identified Inspector Followup Item 50-424/
86-60-11 " Review Licensee Response to the Locking of Four RHR Valves Pursuant to FSAR Section 7.6.2.2.0" In commitment 1253, acceptance criteria for batch testing of activated carbon were referenced to Regulatory Guide 1.52, Revision 2 (March 1978), ANSI /ASME N510-1975 and to RDT-M-16-1T (a standard promulgated by the Department of Energy, Division of Reactor Development and Technology).
Both RG 1.52, Rev. 2, and
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RDT-M-16-1T specified carbon testing at a temperature and humidity
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which was subsequently determined to produce invalid results.
This test, recognized by the industry as being invalid, is the
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test currently specified in the applicant's FSAR and implementing procedures.
In 1980, ANSI /ASME N510-1980 was published refer-encing ASTM D3803 criteria for carbon testing.
While NRC has not revised either RG 1.52, Rev. 2, or RG 1.140, Rev. 1, NRC acknowledges that ASTM D3803 is the preferred method for carbon testing. In October 1981, RDT-M-16-1T was revised to reference ASTM D3803. All certified carbon testing laboratories now use ASTM D3803 and no longer perform the old RDT test.
In the interests of consistency, the applicant should reference the 1981 version of RDT-M-16-1T, ANSI /ASME N510-1990, or ASTM D3803 for activated carbon testing.
This item is identified as Inspector i
Followup Item 50-424/86-37-01 " Review Licensee FSAR Update to Reflect ASTM D3803 Criteria for Carbon Testing".
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In commitment 1255, FSAR Section 9.4.3.2.4 states that HEPA filters will be tested in place prior to operation to verify efficiency of at least 99.97 percent using the guidance of RG 1.52, Rev. 2.
The applicant has incorrectly assumed that the leak test specified in RG 1.52 is an efficiency test; the RG 1.52 test is a specific test for bypass leakage only and should not be construed as an efficiency test.
There is no recognized or acceptable test of HEPA filter efficiency other than the factory test method. All references to in place efficiency testing of HEPA filters or HEPA filter banks in the FSAR, Technical Specifi-cations, and procedures should be corrected to specify leakage or bypass testing.
This item is identified as Inspector Followup Item 50-424/86-37-02 " Review Licensee FSAR Update and Plant Procedures to Delete Reference to In place Efficiency Testing of HEPA Filter or Equipment".
Under commitment 1245, in place leak testing of charcoal absorbers is stated to be accomplished using " freon." Applicant should be aware that " freon" is a registered trade name for a fluorinated (or halogenated) hydrocarbon refrigerant supplied by a specific manufacturer such as R-11 should be specified.
In a number of instances, as in commitment 1243 through 1249, the implementing procedures specify a DOP smoke test efficiency of 99.5% for HEPA filters and a " freon" leak test criterion of 99.5%
halide removal for carbon absorbers.
The FSAR commitments reference RG 1.52 and 1.140 for these tests but do not specify numerical values for the tests.
The Regulatory Guides recommend
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that both the 00P and halogenated hydrocarbon leak tests show leakage of less than 0.05?s.
Unless the applicant has taken specific exception to the RG 1.52 and RG 1.140 guidelines, the implementing procedures should be revised to specify leakage of less than 0.05?s.
This item is identified as Inspector Followup Item 50-424/86-37-03 " Review Revised Implementing Procedures to Specify Correct Leakage Values for HEPA filter banks".
The inspectors noted that Section 6.5 of the FSAR contained descriptions of four engineered safety feature (ESF) filter systems:
(1) Control Room Emergency Filter System; (2) Fuel
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Handling Building Post-Accident Filter System; (3) Piping Penetra-tion Filter System; and (4) Electrical Penetration Filter System.
After discussions with the applicant and a review of the appropriate filter testing procedures, the inspectors noted that the applicant was only claiming the Control Room Emergency Filter System and the Electrical Penetration Filter System as ESF filter systems.
The staff informed the NRR Vogtle Project Manager of this situation of June 20, 1986, This item is identified as Inspector Followup Item 50-424/86-37-04 " Review Final Resolution Between NRR and Applicant Regarding Filter System Classifications for the Four ESF Systems".
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During the process of locating the above commitments the staff was informed that the Readiness Review data base had not been baselined into the Regulatory Compliance Commitment data base.
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The baseline process would ensure that the Regulatory Compliance data base contains all commitments in order to prevent maintaining two data bases. In order to ensure that the baseline process is completed the following staff follow-up item is identified as Inspector Followup Item 50-424/86-60-04 " Review Results of Baselining the Regulatory Compliance Computer database with the Readiness Review Module 7 Database",
d.
Section 4.0 - Program Description This section of the module addresses the Georgia Power Company
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organization for plant operation and how the organization implements the operations quality assurance program.
In addition, it discusses the implementation of licensing commitments and describes the respon-sibility, authority, and measures for the control and accomplishment of activities affecting the quality of safety-related structures, systems, and components of Vogtle.
The evaluation of this section consisted of a program verification of four major activity areas where approved procedures were in place and where the work effort at this stage of operational preparations was considered significant enough for a review to render meaningful
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conclusions.
The activity areas evaluated were operations, mainte-
nance, quality assurance programs and test activities.
(1) Section 4.1 - Operations Activities (a) Section 4.1.1, Conduct of Operations This section describes the policies and practices regarding
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the conduct of operational activities.
There are ten subparts to this section as listed below.
Each of the eight subparts were reviewed against the applicable plant procedure.
Plant tours were conducted to determine the level of compliance commensurate with the test status and plant conditions where appropriate.
Section Procedure 4.1.1.1 Authorization to Startup and 00300-C Shutdown 4.1.1.2 Shift Relief 00003-C 4.1.1.3 Shift Manning 10003-C 4.1.1.4 Control Room Access 10003-C 4.1.1.5 Logkeeping 10001-C i
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Section Procedure 4.1.1.6 Equipment Return to Service 00350-C 4.1.1.7 Reactor Trip Review 10006-C 4.1.1.8 Notification Requirements Not Reviewed 4.1.1.9 NRC Monthly Operating Reports Not Reviewed 4.1.1.10 Standing Night Orders 10002-C Section 4.1.1.1, Authorization to Startup and Shutdown, lists four conditions by which any licensed operator is authorized to shut down the reactor without prior approval. Procedure l-10000-C, however, omitted one condition for the Reactor
Operator and Balance of Plant Operator.
This item is considered an oversight in Procedure 10000-C.
It was noted that Procedure 00300-C did convey the correct requirements.
Section 4.1.1.2, Shift Relief, was examined against the
requirements of TMI Item I.C.2. " Shift Relief and Turnover i
Procedures" This item involves the establishment of plant procedures for shift relief and turnover which requires
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signed checklists and logs to assure that the operating staff
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possess adequate knowledge of critical plant parameter-
l status, system status, availability, and alignment.. FSAR Section 13.5.1.1.H describes the procedures which will be
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implemented to ensure that a comprehensive exchange of information takes place between the oncoming and offgoing shift personnel.
Administrative procedure 00003-C, Rev. 0
" Shift Relief" is the basic implementing document which establishes general guidance to be further implemented by the Operations Maintenance, Health Physics and Chemistry Departments.
Operations Procedure 10004-C, Rev.1 "Shif t Relief" establishes the general requirements for shift relief
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and directs the use of the following checklists:
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11869-C, " Balance of Plant Operator Relief Checklist"
11870-C, " Operations Supervisor Checklist" 11871-C, " Shift Supervisor Relief Checklist" 11872-C, " Plant Operator Relief Checklist" 11873-C, " Plant Equipment Status Checklist" 11878-C, " Shift Technical Advisor Relief Checklist" The latest revision of the above checklists were reviewed
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.against NRC requirements contained in a November 9, 1979 letter to all licensees. The staff determined that implemen-
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tation of this item by the applicant did not conform to the
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l NRC requirements in that checklists do not include:
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(1) Critical plant parameters and allowable limits.
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(2) What is to be checked and acceptance criteria to assure the availability of all systems essential to prevention and mitigation of operational transients and accidents during a check of the control room panel.
(3) The requirement to make a separate. checklist entry for each system and component that are in a degraded mode of operation permitted by Technical Specification.
In addition, no system had been established to evaluate the effectiveness of the shift and relief turnover procedures.
This item will be further inspected when the licensee has
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implemented corrective action. This item will be tracked as Inspector Followup Item 50-424/86-60-10 " Review Compliance with TMI Item I.C.2, Shift Relief and Turnover Procedures".
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Section 4.1.1.5, Logkeeping, describes the types of logs, who maintains the logs and in general what information is contained within the logs.
Procedure 10001-C, Rev. 2
"Logkeeping" was reviewed.
This procedure contains additional detail on specific activities which would be recorded.
Logkeeping practices in the control room were reviewed on various days to determine compliance with this procedure.
In general, compliance was noted, however, to have a complete understanding of the activities being logged one has to review test logs. An example of this was repeated logging of Reactor Coolant Pump stopping and starting without stating the purpose or test in progress.
Management attention is needed to improve performance in this area.
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Section 4.1.1.7, Reactor Trip Review. This section states that following a safety limit violation, NRC approval for startup is required. The staff questioned why the safety
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limits were not called out specifically in Procedure 10006-C nor was mention made of the NRC approval.
The licensee stated that Procedure 10006-C was the appropriate location and the procedure would be revised.
The above two findings identified for sections 4.1.1.5 and 4.1.1.7 will be tracked as Inspector Followup Item 50-424/
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86-51-04 " Review Licensee Procedure Changes to 10000-C and 10006-C Regarding Reactor Shutdown and Trip Review".
(b) Equipment and Plant Status Centrols This section describes the methods by which operators remain aware of and control equipment and plant status. There are seven subparts to this section.
Each subpart was reviewed against the applicable plant procedure as listed.
Plant tours were conducted to determine the level of compliance commensurate with the test status and plant conditions.
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Section Procedure 4.1.2.1 Operability Status Indication 10005-C 4.1.2.2 Clearance and Tagging 00304-C 4.1.2.3 System Alignments 10000-C 4.1.2.4 Independent Verification 00308-C 4.1.2.5 Key Control 00008-C 4.1.2.6 Rounds Sheets 10001-C 4.1.2.7 Equipment Labeling 10016-C The review of the procedures and practices determined that basic implementation has occurred except for independent verification and that the Readiness Review Module reflects these procedural programs.
(c) Section 4.1.3, Housekeeping and Cleanliness This section describes controls established to ensure plant areas meet established cleanliness.
Procedure 00254-C, Rev. 2
" Plant Housekeeping and Cleanliness Control" establishes a program of monthly inspections to be performed by the superintendents of the various departments.
The staff reviewed the results of the inspections by examining the data forms in Document Control.
The staff noted that only the Warehouse and Warehouse Receiving. Building were being consistently inspected. Areas such as the Maintenance Building and Service Building, and River Intake Structure have been inspected at least once but appear to have not been inspected for at least three months. Other areas such as the Water Treatment Building, Fi re Pumphouses, Administration Building, Nuclear Training Center, and Meteorological Tower should have been inspected but no records exist.
The remaining areas in the procedure are under construction i
control and inspection by operations is not necessary. The licensee was requested to review the item to determine the current status of inspection.
This item will be tracked as Inspector Followup Item 50-424/86-60-05
" Review the
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Inspection Status of Regarding Plant Housekeeping and Cleanliness Control".
(d) Section 4.1.4, Fire Prevention and Firefighting This section describes the measures to be established as part of the fire protection program.
This area will not be evaluated as part of this module but will be inspected during the NRC fire protection team inspection.
This will allow time for construction to be completed and the procedures to be established to support a more meaningful review.
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(e) Section 4.1.5, Control Room Design Review This section describes the basic effort to upgrade the control room, emergency response facilities and procedures.
This area will be evaluated by the Office of Nuclear Reactor Regulation and not as a part of this module.
(2) Section 4.2 - Maintenance and Modification Control (a) Section 4.2.1, Control of Maintenance This section of the module described the process by which maintenance activities were identified, controlled, and documented to ensure proper implementation.
The following procedures were reviewed which implement requirements pertaining to the above areas:
Procedure /Rev Title 00304-C
Equipment Clearance and Tagging 00306-C
Temporary Jumper and Lifted Wire Control 00350-C
Maintenance Program 00420-C
Equipment Qualification Program 00853-C
Material Identification, Control and Issue 85301-C
Work Planning Group and Hold Point Assignment The l i cer.see has implemented a maintenance program in accordance with the startup manual during the preoperational test phase. This program is similar to the programs being established for operations.
The staff has observed the implementation of this program during this readiness review.
To date approximately 558 of 568 maintenance mechanical and electrical procedures have been issued. The licensee intends to work as many of these procedures as possible during the preoperational test program to ensure their workability.
These procedures combined with the additional programatic elements required of a plant in the operational phase should comprise an adequate maintenance program.
Based on this review the staff has determined that commit-ments made in this area appeared to be implemente,
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(b) Section 4.2.2, Control of Modifications
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This section of the module describes the process by which
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planned changes in plant structure, systems, or components are accomplished to ensure that implementation is in accordance with the requirements and limitations of applicable procedures, codes, standards, specifications, licenses, and predetermined safety restrictions.
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The following procedJres were reviewed which implement requirements pertaining to the above areas:
Procedure /Rev Title 00056-C
Safety Evaluations 00400-C
Plant Modifications 00307-C
Temporary Modifications 50005-C
Request for Engineering Assistance The licensee has implemented a modification control program during the preoperational test phase. The staff has observed implementation of this program during the readiness review.
These procedures combined with the additional programatic elements required of a plant in the operational phase should comprise an adequate plant modification control program.
Based on this review the staff has determined that commitments made in this area appeared to be implemented.
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(c) Section 4.2.3, Measuring and Testing Equipment l
This section of the module described calibration, issuance, identification, and tracking of M&TE.
l The following procedures implemented commitments pertaining to the above areas:
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Procedure Rev Title 00208-C
Control of Measuring and Test
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Equipment 20230-C
Control of Instrument Shop Measuring and Test Equipment
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l 20405-C
Control of Maintenance Shop Measuring and Test Equipment
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The staff toured the I&C and Mechanical / Electrical M&TE calibration labs and issue stations to determine if M&TE was being controlled and calibrated in accordance with estab-lished procedures. Each lab retained copies of records that traced their calibration standards back to nationally recogni:ed standards. Original copies of these records were maintained in the document control vault. Offsite calibra-tions were performed by approved vendors from the Qualified Suppliers List.
Sensitive items were packaged individually for shipment to offsite calibration -labs.
Environmental conditions were monitored and were within the required range
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in the I&C calibration lab.
The Mechanical / Electrical calibration lab had provisions to monitor these conditions if required by a calibration procedure.
Each item of M&TE was uniquely identified with a GPC serial number and had either a calibration sticker listing date calibrated and date due or a hold tag to prevent usage.
Those items with hold tags were segregated from calibrated items to prevent inadvertent use.
Calibration status was r
checked for an item at time of issue and this check was documented.
Each lab has a tracking system to insure that if a piece of M&TE was found out of calibration, all work performed using that piece of M&TE could be evaluated to determine whether or not the work was affected by the out of calibration condition.
Calibration intervals could be
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changed based on calibration history if approved by a
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supervisor. Based on this review, the inspector determined that the M&TE program appeared to meet commitments.
(d) Section 4.2.5.1, Procurement Activities t
This section of the module described the initiation, review, and approval of purchase requisitions.
The following procedures implemented requirements pertaining to procurement of goods and services:
Procedure Rev Title 00203-C
Requisition Review for Technical and Quality Requiraments
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Requisition of Materials and Services Nuclear Procurement Policy Manual, Revision 2 Purchase requisitions could be initiated by anyone needing to acquire material or services.
Technical and quality requirements were specified by the initiator and the
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requisition was reviewed by the initiators supervisor. The
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requisition was reviewed for inclusion of technical and quality requirements. by the Procurement Review Section.
Af ter all technical and quality requirements were verified, the requisition was typed onto a purchase order and sent out to an approved vendor.
If competitive bids were solicited, the bids were compared to the original requirements of the purchase requisition to
determine if the supplier had met all applicable require-ments.
Any discrepancies between a bid and the purchase requisition were resolved by the Procurement Review Section.
From this review, the staff determined that commitments in this area appeared to be implemented.
(e) Section 4.2.5.2, Receipt of Material This section of the module described the process by which materials received at the Nuclear Operations Warehouse were processed through Receipt Inspection either to be stored in the warehouse or issued immediately.
It also described the process by which materials were conditionally released.
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The following procedures implement requirements pertaining to the above areas:
Procedure Rev Title 00853-C
Material Identification, Control, and Issue 85307-C
Quality Control Receipt Inspection
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85100-C
Quality Control Inspection Plans, j
Reports, and Documentation The staff reviewed the receipt inspection process to
determine if receipt inspections were being conducted in accordance with project commitments. The staff also reviewed the system for conditional release of material s from the warehouse.
The staff determined that controls for conditional release of items were in place.
These controls involved a review of the conditional release request by the Quality Control Department and the Procurement Review Section. After approval, the conditional release was
documented in a conditional release log and on a discrepancy report which was traceable to the MWO. This assured that the conditional release was cleared up prior to the system being declared operational.
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During this review, the staff determined that personnel conducting receipt inspections were knowledgeable of their duties as well as their interface with other departments.
The staff reviewed training records to determine if receipt staff had been trained and that training had been documented.
From this review, the staff determined that commitments in this area appeared to be implemented.
(f) Section 4.2.5.3, Storage, Handling, and Shipping This section of the Module described levels of storage, maintenance of items storage, warehouse inspections, methods of handling materials, and shipment of items from the plant.
The following procedures implement commitments pertaining to the above areas:
Procedure Rev Title 00850-C
Materials, Receiving, and Inspection 00851-C
Storage, Handling, and Shipping Requirements 00853-C
Material Identification, Control and Issue The staff toured the operations warehouse facility to determine if storage levels were being maintained in accordance with approved procedures and items were being stored properly.
The warehouse facility consisted of a Level A and a Level B storage area.
It also contained a separate Level B storage area for chemicals and oils, a j
separate Level B area for receipt inspections, and provisions for outside storage (Level D).
Sprinkler systems for fire suppression and provisions for rodent control were in all of the facilities.
A calibrated temperature and humidity monitor with a chart recorder was monitoring environmental conditions in the level A storage area. Limits for tempera-ture and humidity were conspicuously posted near the monitor.
At the time of the inspection, the humidity in the storage area was barely within the allowable limits.
A GPC representative stated that they were aware of this and that arrangements had been made to install dehumidifiers.
Provisions had been made for maintenance of items in storage.
Reviews of procurement documents identified items requiring maintenance while in storage. This information was entered into a computer data base and a MWO was generated when the
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maintenance was due.
Shelf Life items were tracked on a computer data base capable of providing a report on those items whose shelf life expiration dates were approaching.
Although GPC currently does not have any items in storage requiring the use of desiccants, a program was in place for control of desiccants.
GPC conducted periodic inspections of the warehouse facility to determine if items were being stored properly and were in good condition.
A monthly inspection was documented in accordance with GPC procedures, however, additional inspections were performed. The licensee also had one person assigned to conduct a continuous inventory of stored items.
Most items in the warehouse were of a nature such that they could be handled using standard material handling practices.
However, if an item was determined to need special handling due to size or sensitivity, written instructions were provided.
From this inspection, the staff determined that commitments made in this area appeared to be implemented.
(g) Section 4.2.6.1, Preventive Maintenance This section of the module describes the program by which equipment maintenance is to be conducted to minimize unplanned outages due to breakdown, to maintain equipment in a satisfactory condition for safe operation, and to assure equipment operates at its maximum efficiency. Preventive maintenance includes, but is not limited to, tasks such as inspection, lubrication, megger testing, calibration, and verification of operability.
Preventive maintenance also incorporates scheduling equipment qualification requirements for plant equipment and components.
The following procedures were reviewed which inplement requirements pertaining to the above areas:
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Procedure /Rev Title 00350-C
Maintenance Prcgram 20015-C
Planned Maintenance Based on this review the staff has determined that commit-ments made in this a~rea appea,ed to be implemented.
The license has implemented a preventive maintenance program in accordance with the startup manual procedure no. SUM-25 during the preoperational test phase.
This program is consistent with preventive and storage maintenance identified
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and performed by construction personnel. The staff observed implementation of this program during the readiness review.
Preventive maintenance checklist are presently being generated for the operations phase.
These will be implemented-upon system release to operations.
(h) Section 4.2.6.2, Predictive Maintenance
' This section of the module describes a program which is an extension of the preventive maintenance program.
This program consists of monitoring key parameters such as vibration analysis, fluid analysis, infrared surveillance, and failure analysis as appropriate to diagnose impending equipment failure and to schedule maintenance at the most appropriate time.
The following procedures were reviewed which implement requirements pertaining to the above areas:
Procedure /Rev Title 00350-C
Maintenance Program 20016-C
Predictive Maintenance Program The licensee is presently developing the predictive mainte-nance data base.
Implementation of the program to obtain base line data is scheduled to begin once equipment is up and running for an extended period of time.
(3) Section 4.3 - Testing Activities Equipment and Plant Status Controls This section describes the methods by which testing activities are conducted and controlled.
There are four subparts to this
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section.
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I Section
4.3.1 Surveillance Tests 4.3.2 Inspections
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l 4.3.3 Initial Test Program, Startup Test Phase
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Of the above sections, only 4.3.2 and 4.3.3 were reviewed. These reviews were limited due to the lack of physical work available to examine procedure implementation against.
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The staff reviewed the 10 CFR 50, Appendix J commitments identified in the module.
The objective of this review was to verify that the licensee had performed an appropriate assessment of the Appendix J program, and to independently determine its adequacy.
Based on the present program completion level, the staff had no findings in the Appendix J program. The staff determined that the licensee had identified the appropriate implementation documents for each commitment and had also adequately verified the commitments in the implementation documents.
The staff reviewed the fuel movement commitments that are included in - the module.
Selected commitments were compared with the appropriate source documents to determine if the commitment had been adequately captured.
These commitments were then verified to be incorporated into the correctly specified implementation document. Although this effort was hindered by the large number of fuel movement documents listed as "in draf t,"
the inspectors did determine that the applicant had at minimum demonstrated an awareness of the commitments and implementation regarding fuel movement.
Section 4.3.3 describes the administrative details of the startup test phase of the initial test program.
This section was evaluated by review the administrative program contained within the following procedures:
(1) SUA-01 (Revision 0), Startup Test Procedure Preparation, Review, Approval, and Revision, (2) SUA-02 (Revision 0), Startup Test Program Implementation, (3) SUA-03 (Revision 0), Startup Shift Test Director and Test Supervisor Qualification Checklist.
The three (SUAs) reference the FSAR Chapter 14 startup test descriptions and acceptance criteria; and Regulatory Guide 1.68, but do not reference the readiness review program or the regulatory compliance commitment list. (The latter was described by applicant personnel as continuing the commitment tracking program from the point at which the readiness review program ended.)
However, the Startup Procedure Review Checklist, a two page, desktop procedure, clearly addresses a requirement to incorporate commitments, and references the commitment book and computer tracking as the sources.
The commitment book is organized by startup test procedure with a page describing each applicable commitment.
The pages originate from either the readiness review program or the regulatory compliance commitment list.
The reference to computer tracking is to the updated commitment list maintained by regulatory compliance.
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Based upon these reviews and discussions with persons responsible for writing the startup test procedures, it was concluded that the readiness review program had made a significant contribution to establishing a commitment data base and to sensitizing procedure writers to incorporate commitments in the startup test procedures.
The readiness review program also included a review of procedures, some of which were in draft, to confirm that each commitment had been addressed.
However, the review was limited to confirming that each ccmmitment had been addressed in at least one place without confirming that each commitment had been addressed everyplace it was required.
Moreover, that review did not evaluate the technical adequacy with which a commitment was implemented.
For these reasons, the effort involved in the inspection of the startup test procedures will continue as these procedures are prepared and issued for use.
(4) Section 4.4 - Coordination Activities This section describes the activities which coordinate plant operations and support.
There are four subparts as follows:
Section
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4.4.1 Procedures 4.4.2 Manuals and Drawings 4.4.3 Data Processing 4.4.4 Planning and Scheduling (a) Section 4.4.1 was evaluated by reviewing the plant procedures which establish the format, terminology, component identifi-cation, and writing styles for the various type procedures.
Procedures reviewed in conjunction with the evaluation of commitments were noted as being in conformance with the guidelines.
One problem was noted between the body of procedures and data forms where the required signatures for each completed step were not consistent. This item had been identified by the licensee as part of this readiness review area and corrective action is in progress.
The following plant procedures were reviewed which govern the writing, and control the use of procedures.
Procedure /Rev Title 00050-C
Procedure Development 00051-C
Procedure Review and Approval 00052-C
Temporary Changes to Procedures
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00053-C
Temporary Procedures 00054-C
Rules for Performing Procedures 10011-C
Operations Procedure Preparation and Review Guidelines 10012-C
E0P and A0P Writers Guide 10013-C
Writing E0P from the Westinghouse ERG 10014-C
Verification of E0P 20409-C
Maintenance Procedure Review and Qualification Checklist A random sample of department procedures were reviewed for compliance with Plant Administrative Guidelines, Regulatory Guides, and applicable codes and standards listed below:
Regulatory Guide 1.33, Rev. 2
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00050-C, Rev. 5, Procedure Development 00051-C, Rev. 3, Procedures Review and Approval
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00053-C, Rev. O, Temporary Procedures
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00054-C, Rev. O, Rules for Performing Procedures
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00056-C, Rev. O, Safety Evaluation Procedures were selected for review on a random basis. This review selected five System Operating Procedures, eight Operations Surveillance Procedures, and eight Instrumentation and Control Surveillance Procedures.
The staff concluded that an adequate program has been established to develop procedures and procedures are being developed to the program.
The staff noted that due to the status of construction and testing the majority of procedures have not been in actual use.
The plant test program does utilize plant procedures to the maximum extent practicable for operating and maintenance procedures.
It is expected that operations surveillance and maintenance surveillance procedures will be utilized as much as possible prior to fuel load.
The staff also note > that the inadequacy of procedure 00051-C need to be resolved as addressed in paragraph 3.(f)(2).
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(b) Section 4.4.2 references Readiness Review Module 5 and Appendix D and this was not reviewed.
(c) Section 4.4.3 pertains to the following Data Processing systems:
Nuclear Plant Management Information System Nuclear Plant Reliability Data System Nuclear Network Nuclear Operations Records Management System The evaluation of this section was performed by having the licensee discuss the input / output features and through discussions with plant staff.
In addition to the above computer systems the Technical Specifications Surveillance Tracking System was also reviewed.
The Nuclear Plant Management Information System provides computer control for maintenance work orders, plant equip-ment, preventative maintenance and inventory control.
Each display format and data base structure was reviewed with the licensee.
Maintenance work order (MWO) processing flow was discussed in detail. As an MWO is reviewed by the various disciplines various support data files can be accessed, such as, a three year history, applicable procedures, technical specification, vendor and equipment data.
These files provide for a more in-depth review capability. The MWO are each statused as they are processed to completion.
This system also provides the necessary failure data to the Nuclear Plant Reliability Data System. Inventory control is also a major portion of this system, however was not reviewed in detail.
Future improvements to the system will include a clearance tagging and control system.
The staff concluded that this computer system is a major benefit for the licensee, greatly enhances the level of research and review which can be conducted by the plant staff and should provide the necessary level of support to meet the needs of the plant in the future.
It was noted, however, that data is still being loaded to the support files. One area of particular note is the technical specification (TS) surveillance file.
This file is waiting finalization of the TS.
While the impact at this point is minimal, the lack of data hinders the overall system capabilities.
The Nuclear Plant Reliability Data System was found to not be in actual use.
Procedures are being developed to control the use of the system at the Plant level.
Engineering is currently making entries to baseline the data base with
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Component failure data should start at the time the plant reaches commercial operation.
The Nuclear Network was found to be in use at the Plant.
Information is being distributed to various department coordinators for use.
Important information such as INPO significant event reports are incorporated into the Operational Assessment Program in order to achieve trace-ability and resolution of each item.
The Nuclear Operations Records Management System was found to l
be implemented at the Plant. This system is a state-of-the-art type system to maintain and enhance the retrieval of
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documents.
This system utilizes multiple cross-referencing schemes to allow for rapid location of documents. The data entry process appears to capture sufficient data to support this function.
The staff reviewed the various computer display formats that are utilized by the end user and determined that the system will be an exceptional tool.
i Currently a backlog of maintenance work orders, construction and operations records need to be entered in order to have full use of the systems capabilities.
The Technical Specification Surveillance Tracking Program was also demonstrated to the staff.
The data bases and programming parameters were discussed.
This system will track the completion status for all surveillance with one month or longer periodicity.
Department coordinators are established and are providing the necessary data to support the system.
This system, when fully functional, should support the plant's needs to ensure that technical specifica-tion surveillances are completed at the required perio-dicities.
The overall conclusion was that the plant has or will have computer systems which should greatly improve plant i
performance if fully utilized by the plant staff, however, data loading time delays degrade the capabilities.
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e.
Section 5.0 - Audits (1) Section 5.1, Audit Summaries This section summarizes the various audit activities of the following groups:
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GPC Quality Assurance Audits
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NRC Audits
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INP0 Evaluation Visit
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Southern Company Services Audit
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Plant E.I. Hatch Management Assistance Visit
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These audit activities were considered by the applicant to be pertinent to this module.
Table 5.1-1 lists each finding, response and status. The staff selected three GPC audit findings and verified the corrective action implemented agreed with the response. The NRC findings were reviewed against the complete NRC list of findings.
This review indicated that the applicant had identified all items pertinent to this module.
It was noted that Unresolved Item 50-424/85-07-02 as described in the module is open vice closed as listed. The GPC project listing was verified to have this item in an open status.
In order to
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evaluate the effectiveness of the GPC QA organization since the readiness review effort was completed the staff reviewed QA audit findings regarding this area.
The following audits were reviewed:
Audit Title
i OP15-85/12 Maintenance Program OP09-85/13 Surveillance Program SP01-85/14 Readiness Review Module 7 OP21-86/02 Corrective Action Program OP07-86/06 Material Control 0P09-86/08 Records Management & Document Control OP13-86/09 Design Control & Plant Modification Control 0P10-86/13 Test Equipment Calibration & Control OP01-86/14 Administrative Controls & Reporting
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Requirements OP15/19-86/15 Procedure Control & Review / Records Management and Document Control a
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Of particular note was audit report OP15/19-86/15 where the QA auditor reviewed the corrective action of regarding readiness review findings #7-5, #7-9, #7-12, #7-15 and #7-16 which pertain to this module. In this review the auditor determined that items
- 7-5 and #7-9 were not fully implemented. The stafff considered this determination to be indicative of an objective QA audit. The results of the audit for items #7-5 and #7-9 are discussed in paragraph 3.f.(2) Section 6.2 - Findings and Responses of this report.
Overall the review concluded that this section of the module does reflect the audits that pertain to this area and that the QA program is aggressively pursuing an effective audit program.
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Section 6.0 - Program Verification (1) Section 6.1 - Verification Plan This section of the module describes the verification process and the verification results obtained by the applicant's plant operations and support readiness review team.
The initial verification plan was developed and implemented by the applicant's readiness review team.
The sixteen members examined more than 3346 program elements to ascertain whether the plant operations and support commitments were implemented properly.
Each element was either a program commitment, program implementing document, or any meaningful part thereof which was verifiable.
The 3346 program elements made up the checklists associated with the review program verification activities.
The sixteen team members had cumulative experience of 241 years of nuclear experience.
The initial objective of the Module 7 team was to ascertain whether commitments applicable to the plant operations and support programs were implemented in the organization procedures.
To determine implementation, the team prepared a commitment matrix.
The FSAR, through Amendment 18, was the controlling or baseline document for the identification of commitments.
The completed commitment matrix contained 1266 commitments.
The applicant's readiness review team then reviewed plant procedures to determine the implementation or capture of these commitments.
An implementation matrix was prepared which identified each of the 1266 commitments, along with the procedure which fulfilled that commitment. Where an implementing procedure was identified but not issued, it was noted in the remarks column.
The implementation matrix was presented as a product of the Module 7 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 chosen for observation included work process controls, requisition of materials and services, material receipt and inspection, storage, handling, and shipping, procedure development controls, conduct of operations, conduct of mainte-nance, plant status controls including temporary modifications, fire protection programs, preservice and inservice inspection
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program.
Review of these areas included observation of activities in progress; interviews with maintenance personnel, operators, stores personnel, engineers, and supervisors; and review of completed documents. The reviews confirmed and documented the effectiveness of the operations and support programs and also idehtified 57
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program elements which were not in compliance with licensing commitments.
These 57 program elements were grouped by subject, resulting in findings which were issued to the Project.
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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 the applicant's readiness review checklist packages in order to determine if the methodology.and concerns noted by the individual applicant reviewers on their checklists were properly reflected in section 6.2 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.
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Phase 2 of this evaluation involved a review of each of the applicant's 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 i
findings appear adequate.
The staff was unable to completely verify completion of corrective actions since several actions remai. led outstanding at the time of this review. The staff does note, however, that the applicant's quality assurance group has scheduled specific audits to verify completion of all readiness review action items.
The staff review and evaluation of the findings are presented in Section 6.2 - Findings and Responses below.
(2) Section 6.2 - Findings and Responses This section of the module contains the conclusions of the Readiness Review Team as a result of the team's findings. The overall evaluation of the findings determined that four categories exist which characterize the results as follows:
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Inadequate administrative controls
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Inadequate procedures
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Inadequate procedure review
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Procedure noncompliance
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The review of this section consisted of reading the finding as presented in the module; reviewing the actual documentation which documents the finding and project response; verifying selected commitments are now implemented; and discussions with knowledge-able project personnel.
The following findings were reviewed:
- 7-1 Inservice Ir pection
- 7-3 Startup Procedures
- 7-4 Data Collection
- 7-5 Procedure Qualifications
- 7-6 Procedure Revisions
- 7-9 Temporary Procedure Revisions
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- 7-10 Standing Orders
- 7-11 Surveillance Procedure Writing
- 7-12 Maintenance Procedures
- 7-14 Surveillance Procedure Electrical
- 7-15 Housekeeping Requirements
- 7-16 Overtime
- 7-17 Fire Brigade Leader
- 7-18 Fire Hazards
- 7-20 Storage, Handling and Shipping
- 7-21 Startup Test The following findings of the Readiness Review Team, classified by the project as nonfinding, were also examined to determine the validity and appropriateness of the response:
- 7-7 Procedure Approval Authority
- 7-8 Annunciator Resr;onse Procedures
- 7-13 Control of Measuring and Test Equipment
- 7-19 Source Rarge Count Rate Finding #7-4 concerns a finding that no plan or program could be found in Operations, Maintenance, or Engineering departments to collect data related to transient or operational cycles for components in Table 5.7-1 of Technical Specification. The project response determined the root cause to be related to the commitment assignment process and conducted a program to have commitments evaluated for correct cepartment assignment. The staff's review of this item determined that the project did not address the subject of establishing a plan or program to collect the data. In order to ensure that an adequate program or plan is established the following is identified as Inspector Followup Item 50-424/
86-60-06 " Review the Establishment of a Plan to Collect and Evaluate Transient or Operational Cycles for Adequacy".
Finding #7-5 concerns a finding that objective evidence that maintenance procedures had been reviewed by appropriately qualified personnel was not available.
The GPC QA audit OP18/
19-86/15 did an indepth review of the area of reviewer qualifica-tion. Programmatic concerns of the original concern were extended in the audit to other departments. A sample of reviewer qualifi-cations resulted in a determination that problems still exist in providing objective evidence and a final overall conclusion that the readiness review finding has not been fully corrected.
The staff agrees with the reselts of this audi ^
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Finding #7-9 concerns a finding that two of four temporary changes (TCP) to procedures issued were processed improperly.
GPC QA audit OP18/19-86/15 attempted to verify that the routing and issuance of TCP's by selecting seventeen TCP's and reviewing their status. This verification instead disclosed numerous discrepan-cies and overall process problems. This resulted in an overall conclusion that procedure 00051-C, Rev. 2 " Temporary Changes to Procedures" was inadequate. The staff agrees with the results of this audit.
Findings #7-5 and #7-9 both represent a lack of achieving in-depth corrective action beyond the original finding.
The staff determined that the GPC QA group has done a more extensive job at determining the root cause.
In order to further evaluate the final corrective action this is identified as Inspector Followup Item 50-424/86-60-07
" Review Corrective Action Regarding Item #7-5 and #7-9 of Readiness Review Module 7".
The staff concluded, except for the following above listed items, that project responses to the findings were appropriate and implemented per commitments contained in the responses.
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Section 7.0 - Assessment j
This section contains a summary of open corrective actions associated
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with the readiness review findings. Additionally, statements assessing the acceptability of the readiness review from the readiness review
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quality assurance representative, the nuclear operations organizations, and the readiness review board are included. Resumes of the personnel instrumental in the development of Module 7 were also included. This section was reviewed for content only.
4.
Findings The following findings were identified from the staff's evaluation of this module.
The findings identified below are considered to be deficiencies l
which have minimal safety significance but which should be evaluated further to preclude safety problems.
These findings have been identified as staff
followup items and resolution of these specific findings will be addressed during the routine inspection program.
I Inspector Followup Item 50-424/86-31-03 " Review Licensee Plan for Separation of Facilities and Systems Between Unit 1 Operation and Unit 2 Construction".
Inspector Followup Item 50-424/86-31-04 " Review Minimum Shift Crew Require-ments as Implemented in Procedure 10003-C for a Defueled Status". (Closed)
Inspector Followup Item 50-424/86-31-05 " Review Implementation of Technical Specification Overtime Conflicts with Procedure 00005-C". (Closed)
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Inspector Followup Item 50-424/86-31-06 " Review Licensee Changes to
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Procedure 00402-C prior to license issuance". (Closed)
t Inspector Followup Item 50-424/86-31-07 " Review Maintenance Procedure 20427-C for Incorporation of the ANSI Requirement to Document Closecut
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Inspection Results". (Closed)
Inspector Followup Item 50-424/86-60-03 " Review Technical Specification Surveillance 4.8.1..1 Implementation Procedure for Proper Verification of independent AC Power Sources". (Closed)
Inspector Followup Item 50-424/86-60-11 " Review Licensee Response to the Locking of Four RHR Valves Pursuant to FSAR Section 7.6.2.2.0".
Inspector Followup Item 50-424/86-37-01 " Review Licensee FSAR Update to Reflect ASTM 03803 Criteria for Carbon Testing".
Inspector Followup Item 50-424/86-37-02 " Review Licensee FSAR Update and Plant Procedures to Delete Reference to In place Efficiency Testing of HEPA Filter or Equipment".
Inspector Followup Item 50-424/86-37-03 " Review Revised Implementing Procedures to Specify Correct Leakage Values for HEPA filter banks".
- Inspector Followup Item 50-424/86-37-04 " Review Final Resolution Between NRR and Applicant Regarding Filter System Classifications for the Four ESF Systems".
Inspector Followup Item 50-424/86-60-04 " Review Results of Baselining the Regulatory Compliance Computer database with the Readiness Review Module 7 Database". (Closed)
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Inspector Followup Item 50-424/86-60-10 " Review Compliance with TMI Item I.C.2, Shift Relief and Turnover Procedures" d
Inspector Followup Item 50-424/86-51-04 " Review Licensee Procedure Changes to 10000-C and 10006-C Regarding Reactor Shutdown and Trip Review".
Inspector Followup Item 50-424/86-60-05
" Review the Inspection Status Regarding Plant Housekeeping and Cleanliness Control".
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Inspector Followup Item 50-424/86-60-06 " Review the Establishment of a Plan
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to Collect and Evaluate Transient or Operational Cycles for Adequacy".
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Inspector Followup Item 50-424/86-60-07 " Review Corrective Action Regarding
Item #7-5 and #7-9 of Readiness Review Module 7".
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5.
Conclusions
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Within the scope of Module 7:
The staff has concluded that commitments delineated in Section 3.2 of the module, accurately agree with those commitments in the FSAR and SER.
- The staff has concluded, based on the sampling evaluation described in this report, that commitments delineated in this module are now being
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satisfactorily implemented into procedures.
The staff has concluded that, with the exception of specific de#icien-cies noted in the report, activities of operations, maintenance, quality assurance programs, and test activities are being implemented in accordance with procedures and are currently 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 satisfac-torily implemented.
This will be verified as part -of the normal inspection program.
6.
References 1.
Vogtle Electric Generating Plant, Readiness Review, Module 7, Plant Operations and Support.
2.
January 10, 1986, letter from D. O. Foster, Vice President and Project General Manager, Vogtle Project, Georgia Power Company forwarding Module 7 for NRC evaluation.
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l 3.
NRC Inspection Report 50-424/86-31 issued June 2, 1986.
4.
NRC Inspection Report 50-424/86-41 issued June 12, 1986.
5.
NRC Inspection Report 50-424/86-43 issued June 17, 1986.
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6.
NRC Inspection Report 50-424/86-51 issued June 23, 1986.
7.
NRC Inspection Report 50-424/86-52 issued July 7,1986.
8.
NRC Inspection Report 50-424/86-60 issued September 4, 1986.
9.
September 8, 1986, letter from R. D. Walker, Director, Division of Reactor Projects, Region II, forwarding interim review NRC questions associated with module 7.
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10. October 6,1986, letter from D. O. Foster, Vice President and Project General Manager, Vogtle Project, Georgia Power Company, forwarding Responses from Georgia Power Company to NRC Questions on Module 7.