IR 05000424/1986085
| ML20215F378 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/12/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215F366 | List: |
| References | |
| 50-424-86-85, 50-425-86-42, NUDOCS 8612230373 | |
| Download: ML20215F378 (52) | |
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ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBERS
50-424/86-85 j
50-425/86-42 l
GEORGIA POWER COMPANY
V0GTLE UNIT 1 AND UNIT 2
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JULY 1, 1985 THROUGH SEPTEMBER 30, 1986
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B612230373 861212 PDR ADOCK 05000424 O
PDR i
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INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this informa-tion. SALP is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulations. SALP is intended to be suffici-ently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee's management to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed belew, met on November 13, 1986, to review the collection of performance observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Vogtle for the period July 1,1985, through September 30, 1986.
SALP Board for Vogtle:
L. A. Reyes, Deputy Director, Division of Reactor Projects (DRP),
RII (Chairman)
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII D. M. Collins, Chief, Emergency Preparedness and Radiological Protection Branch, Division of Radiation Safety and Safeguards (DRSS), RII V. L. Brownlee, Chief, Reactor Projects Branch 3, DRP, RII H. H. Livermore, Senior Resident Inspector (Construction), Vogtle, DRP, RII J. F. Rogge, Senior Resident Inspector (Operations), Vogtle, DRP, RII P. W. O'Connor, Senior Project Manager, PWR Licensing Division-A, NRR M. A. Miller, Project Manager, PWR Licensing Division-A, NRR Attendees at SALP Board Meeting:
M. V. Sinkule, Chief, Reactor Projects Section 3C, DRP, RII E. F. Christnot, Project Engineer, Reactor Projects Section 3C, DRP, RII K. D. Landis, Chief, Technical Support Staff (TSS), DRP, RII C. J. Paulk, Reactor Engineer, TSS, DRP, RII T. C. MacArthur, Radiation Specialist, TSS, DRP, RII R. J. Schepens, Resident Inspector (Operations), Vogtle, DRP, RII P. G. Stoddart, Chief, Radiological Effluents and Chemistry Section, DRSS, RII T. E. Conlon, Chief, Plant Systems Section (PSS), DRS, RII J. D. Harris, Reactor Inspector, PSS, DRS, RII J. J. Blake, Chief, Materials and Processes Section (MPS), DRS, RII W. H. Miller, Reactor Inspector, PSS, DRS, RII T. D. Gibbons, Reactor Inspector, PSS, DRS, RII
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'G. A. Belisle, Chief, Quality Assurance Programs Section (QAPS), DRS, RII W. J. Tobin,~Phy'sical Security Specialist, Physical Security Section (PSEC),DRSS,RII G. F. Gibson, Physical Security Specialist, PSEC, DRSS, RII D. Thompson, Physical Security Specialist, PSEC, DRSS, RII G. R. Wiseman, Reactor Inspector, PSS, DRS, RII P. M. Madden, Reactor Inspector, PSS, DRS, RII T. Decker, Chief, Emergency Preparedness Section, DRSS, RII II.
CRITERIA Licensee performance is assessed in selected functional areas depending upon whether the facility was in a construction,.preoperational, or operating phase. Each functional area normally represents areas which are significant.
to nuclear safety and the environment, and which are normal programmatic area. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful NRC observations. Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria was used to assess each.
functional area.
J A.
Management involvement and control in assuring quality B.
Approach to resolution of technical issues from a safety standpoint
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C.
Responsiveness to NRC initiatives
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Enforcement history E.
Reporting and analysis of reportable events F.
Staffing (including management)
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Training effectiveness and qualification l
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of
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these performance categories are:
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Category 1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and
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oriented toward nuclear safety; licensee resources are l
ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to opera-tional safety or construction quality is being achieved.
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Cateqory 3:
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction quality is being achieved.
The functional area being evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or 3.
The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of,ndividual items.
The SALP Board may also include an appraisal of the performance trend of a functional area.
This performance trend will' only be used when both a definite trend of performance within the evaluation period is discernible and the Board believes that continuation of the trend may result in a change of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment period.
Declining:
Licensee performance was determined to be declining near the close of the assessment period.
The SALP Board concluded a performance trend in one area - Training.
III. SUMMARY OF RESULTS 1.
Overall Facility Evaluation Management attention and involvement in both construction and operating activities were evident as reflected by satisfactory performance during this review period. Major strengths were identified in the areas of:
soils and foundations; containment, safety related structures, and major supports; instrumentation; quality programs and administrative controls affecting quality; independent design review; other licensee initiatives; preoperational testing and, emergency preparedness.
A major initiative undertaken by Georgia Power Company (GPC) was to perform a Readiness Review on Vogtle Unit 1 to verify that regulatory commitments have been accurately identified and the facility was designed, constructed, and ready to operate in accordance with the applicable regulatory requirements.
This program lead to early identification and correction of problems.
The Readiness Review Program involved a major effort by the applicant and resulted in additional assurance that the plant was designed and constructed in a quality manner. Another major initiative was the implementation of the Employee Concerns Program. This program involved a major effort by GPC
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and led to the identification and resolution of a number of quality concerns. 'Neither of these programs were specifically required; however, they are considered an aggressive effort related to quality.
The licensee usually exhibited technical competence in understanding complex issues and developing sound and thorough resolutions.
The licensee's approach to the resolution of technical issues was conserva-tive and the applicant was typically responsive to NRC initiatives. A major weakness was identified in the area of physical security. This weakness was primarily promulgated by the late date of construction and testing completion and was not indicative of the performance exhibited during the period.
Continued management attention to this area is recommended. The results of the initial operator examinations indi-cated that increased management attention should be placed in this area to ensure that a further decrease in the effectiveness of training not be experienced in the future.
No major deficiencies affecting licensing activities became apparent during the evaluation period.
Several examples were identified where the licensee's submittals did not provide sufficient information or showed a lack of understanding of certain staff policies and positions; however, these shortcomings were not indicative of the licensee's performance for the majority of licensing activities.
Trend 11/1/83 7/1/85 During 6/30/85 9/30/86 Latest Category Category SALP Rating Rating Period Functional Areas Unit 1 and Unit 2 Construction A.
Soils and Foundations I
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B.
Containment, Safety Related
1 Structures and Major Supports C.
Piping Systems and Supports
2 D.
Safety Related Components -
2 Mechanical E.
Auxiliary Systems
2 F.
Electrical Equipment and Cables
2 G.
Instrumentation Not Rated
H.
Quality Programs and
1 Administrative Controls Affecting Quality I.
Licensing
2 J.
Independent Design Review Not Rated
K.
Other Licensee Initiatives Not Rated
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Unit 1 Preoperational Testing
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A.
Preoperational Testing Not Rated
Unit 1 Operations B.
Operational Readiness Not Rated
1.
Plant Operations 2.
Startup Testing 3.
Surveillance C.
Radiological Controls /
Not Rated
Chemistry 1.
Radiological Controls 2.
Chemistry 3.
Nuclear Air Cleaning Systems D.
Maintenance Not Rated
E.
Fire Protection Not Rated
F.
Emergency Preparedness Not Rated
G.
Physical Security / Material Not Rated
Control and Accouata-i bility
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H.
Quality Programs and Not Rated
Administrative Controls
Affecting Quality Operations i
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Training and Qualification Not Rated
Declining Effectiveness IV.
CONSTRUCTION A.
Soils and Foundations
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1.
Analysis During this assessment period one routine and two special j
inspections were perfor.aed by Region II NRC inspectors.
The routine inspection dealt with investigation of employee concerns regarding improper backfilling against the control building and falsification of soil density test. The special inspections were performed to evaluate module 13A, Foundation Materials and Backfill, of the Readiness Review Program which was conducted by Georgia Power Company as an additional initiative to provide i
assurance that plant Vogtle complies with FSAR commitments.
Review of this module was conducted from January 6 through March 28, 1986.
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The inspections of concerns regarding improper backfilling and falsification of records involved review of drawings, specifica-tions, procedures, records, interviews with QC inspectors, and observation of work activities. Results of this inspection showed that there had been some problems with backfill placement, but that these problems had been identified by the licensee and were corrected prior to this assessment period.
No evidence of falsification of records was identified.
Review of module 13A, Foundation Materials and Backfill involved in office review of the module and two on site inspections. The evaluation was accomplished through a detailed review of all sections of the module and by:
Verifying that the design and construction commitments listed
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in the module were correct and complied with FSAR commit-ments.
Reviewing the module findings and evaluating the correctness
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of their resolution.
Reviewing a comprehensive and representative sample of
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documents selected by the Readiness Review Staff and an independent sample of documents selected by the NRC inspec-tors.
Walkdown observation of construction activities.
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This evaluation resulted in a conclusion that the licensee's foundations have been designed and constructed in accordance with FSAR commitments and applicable Regulatory Requirements.
The evaluation also resulted in a conclusion that the Readiness Review program for Foundations conducted by the Georgia Power Readiness Review Staff was comprehensive in scope and depth and that the QA/QC program for foundations complied with FSAR Commitments.
The inspections and review of module 13A indicated that management involvement, resolution of technical issues and staffing were adequate for the level of activity involved.
No violations or deviations were identified.
2.
Conclusion Category:
3.
Board Comments:
None
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8.
Containment, Saraty Related Structures and Major Steel Support 1.
Analysis-Containment Structures and Containment Post Tensioning During this assessment period inspections were performed by resident and regional inspectors.
The routine inspections by Region II inspectors involved review of QA implementing procedures observation of work activities for reinforced concrete structures and post tensioning operations. Three special inspections were performed to evaluate module 13C, Post-Tensioned Containment, of the Readiness Review Program being conducted by Georgia Power Company.
Review and evaluation of Module 13C Post-Tensioned Containment involved an in-office review by Region inspectors and l
reviewers from the Office Nuclear Reactor Regulation (NRR) and the Office of Inspection and Enforcement (IE), and three on-site inspections.
The evaluation of this module was accomplished through a detailed review of all sections of the module and by:
Verifying that design and construction commitments listed in
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the module were correct and compiled with FSAR commitments and regulatory requirements.
Review of a comprehensive and representative sample of
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records reviewed by the Readiness Review Staff and an independent sample of documents selected by inspectors.
Observation of construction activities.
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This evaluation resulted in a conclusion that the licensee's program review for the Post-Tensioned Containment was ccmprehen-sive and provided adequate assurance that the post-tensior@g system was designed and constructed in accordance with NY requirements and FSAR commitments.
The inspections of controls for reinforced concrete structures and post-tensioning operations and review of module 13C concluded that management involvement, resolution of technical issues and staffing were adequate for the level of activity involved.
No violations or deviations were identified.
2.
Analysis - Structural Steel and Steel Support During this evaluation period inspections were performed by the resident and region inspectors.
These inspections were princip-ally directed toward assessing the adequacy of the Readiness Review Program of structural steel conducted for Vogtle Unit 1.
The Readiness Review Program was performed to provide additional assurance that the structural steel complied with licensing
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commitments and that there were no serious undetected deficiencies that ' affect the quality of structures and delay the licensing process. The NRC inspections of the Readiness Review included a review of licensing commitments, verification that construction and design commitments were implemented in project documents and verification that records were representative evidence of quality controls.
These inspections showed that commitments were being implemented in the project specifications and procedures and that work was performed in accordance with the specifications and procedures.
Evaluation of the Readiness Review showed that the review performed by the Georgia Power Readiness Review staff was comprehensive in scope and depth and that the program for struc-tural steel complied with FSAR Commitments.
The inspectors found that management involvement, resolution of technical issues, staffing and training were adequate for the activities being under taken.
No violations or deviations were identified.
3.
Conclusion Category:
4.
Board Comments:
None C.
Piping Systems and Supports 1.
Analysis During this evaluation period, inspections were performed by the resident and regional inspectors. Most of the regional inspection effort was directed to assessing Georgia Power Readiness Reviews covering Vogtle Unit 1 piping and supports. The Readiness Reviews were intended to provide additional assurance that the piping and supports complied with licensing commitments. The NRC inspections assessed the Readiness Reviews in a manner similar to that des-cribed in B.1 and B.2. above.
The NRC assessment found that the Readiness Review of supports was satisfactorily performed and concluded that the design and construction program for supports was adequate with the exception of certain identified deficien-cies.
The NRC assessment of the piping Readiness Review found that the Review performance was not fully satisfactory in that the review procedures were not in place.
However, the review concluded that the design and construction program for the Vogtle piping was adequate except for certain violations which were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
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In addition to conducting inspections assessing the Readiness
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Review, the NRC also performed routine inspections in the areas of piping and supports in which the procedures, work activities and records for design, construction and preservice inspections were examined and were found satisfactory.
A weakness was noted in the licensee's treatment of written communications with the NRC regarding some safety issues.
In several instances written information provided to the NRC regarding design and inspection work was inaccurate, implying acceptable conditions, whereas the conditions were either unacceptable or required additional evaluation.
A deviation listed below cited examples of inaccurate information provided to the NRC.
These instances were isolated instances and were the exception to the rule.
Management involvement in assuring the quality in the area was generally satisfactory.
There was evidence of prior planning and assignment of priorities.
Records were generally complete, well maintained, and available.
The licensee's approach to resolving technical issues was normally sound and characterized by viable and thought out approaches.
Their staffing and training and their responsiveness to NRC initiatives were generally satisfactory.
The licensee's enforcement history indicates one particularly significant violation, involving intimidation of QC inspectors by a contractor's construction manager.
Although the situation involving the violation was considered potentially very serious, the manager involved was removed shortly after the licensee became aware of his actions, and no evidence has been found that the manager's actions resulted in acceptance of inferior or unsafe work. This occurred prior to this assessment period; however, the enforcement action was completed during this period.
One additional item was considered for escalated enforcement, involving the submittal of inaccurate information to the NRC in April 1984 concerning criteria for the elimination of intermediate pipe breaks and associated whip restraints on high energy piping.
Subsequent to the assessment period this issue was resolved and based on the results of the inspection and statements made during the Enforcement Conference, the inaccurate statement did not involve willfullness.
Therefore, no formal enforcement action is being taken against the licensee in this instance.
However, the inaccuracies in the April 26, 1984 submittal are inconsistent with the necessary careful attention to detail and technical competence expected of a licensee and generally exhibited by GPC in the design and construction of the Vogtle facility.
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Ten violations and one deviation were identified during the evaluation period. A very large inspection effort was devoted to
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this area during the evaluation period and in view of this, the number of violations and deviations was not considered large. One r
instance of a repeat violation was identified in thht violation b.,
is considered a repeat of a violation identified in the
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previous evaluation period. This was not considered to represent i
i a significant programmatic weakness.
The violations identified were:
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a.
Severity level III violation for insufficient organizational freedom / control of services through effective audits.
(50-424/85-49-01; 50-425/85-36-01)
b.
Severity Level IV violation for failure to comply with requirements regarding controls of welding material storage and welding.
(50-424/85-40-03;50-425/85-31-03)
Note:
This violation was similar to violation 424,
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425785-14-02 dated May 7, 1985.
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Severity Level IV violation for failing to assure prompt
correction of deficiencies in design basis documents.
(50-424/86-11-01; 50-425/86-06-01)
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Severity Level IV violation for failing to provide require-ments to assure required removal of temporary pipe supports in encapsulation vessel.
(50-424/86-11-03)
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Severity Level IV violation for falling to comply with
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j requirements for identification and marking of support items.
(50-424/86-20-01; 50-425/86-11-01)
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Severity Level IV violation for failing to properly record i
all required information on welding material requisition l
documents.
(50-424/86-39-03;50-425/86-19-03)
g.
Severity Level IV violation for deficiencies in procedures for installation and inspection of spring hangers and clamps.
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h.
Severity Level IV violation for discrepancies in design i
documentation,(50-424/86-62-04)
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Severity Level IV violation for discrepancies installed support conditions and design and QC documentation.
(50-424/86-62-06)
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Severity Level V violation for failure to fabricate a weldment in accordance with the fabrication drawing and I
welding specification.
(50-424/85-60-01; 50-425/85-40-01)
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One deviation was identified:
Deviation for failure to inspect supports as stated in a July 11, 1983 letter.
(50-424/86-11-04; 50-424/S6-06-04)
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Conclusion Category:
3.
Board Comments:
None D.
Safety-Related Components - Mechanical 1.
Analysis During this evaluation period inspections were performed by resident and regional inspectors.
The inspections were directed both to the routine NRC inspection program and to assess the adequacy of the Readiness Review modules that partly addressed this area.
The modules reviewed were Module 4, Mechanical Equipment, Piping and Components and Module 16, Nuclear Steam Supply System (NSSS). The Readiness Review and NRC inspections assessing the review were conducted similarly to those described paragraphs B.1 and B.2 of this assessment.
The scope of the review involved several key areas such as reactor coolant loop equipment supports, NSSS equipment qualification and nozzle loads, and equipment installation requirements.
Deficiencies were identified involvir.g an incorrect reference and the use of an incorrect allowance in a main steam nozzle loading calculation.
Another deficiency was noted involving instrumentation guide tube installation not being identified as deviations when required by procedure. The inspectors also noted one minor area which did not appear to be covered in the Readiness Review involving the development of equipment maintenance requirements.
(Note:
Equipment maintenance as addressed here is not maintenance for
plant operation, but maintenance prior to operation.)
The NRC assessment of the Readiness Review found that the review perfor-mance was satisfactory.
The licensee's design and construction
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activities for safety-related components appeared satisfactory, with the exception of certain matters identified as violations.
The NRC routine inspections of this area examined the licensee's procedures, work activities and records for design, construction and preservice inspection of the safety-related components.
A weakness as noted in assuring that responsibilities for mainten-ance of equipment were understood and adequate maintenance was accomplished.
The inspector found that management involvement, resolution of technical issues, staffing and training were adequate for the activities being undertake.
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Eight violations were identified during the evaluation period.
Violations a.
through e.,
are considered indicative of the confusion regarding maintenance responsibilities.
The violations identified were:
a.
Severity Level IV violation for failure to comply with cleanliness requirements in disassembling a safety injection pump.
(50-424/85-37-01)
b.
Severity Level IV violation for failure to establish acceptance requirements for verification of pump internal cleanliness. (50-424/85-37-02)
c.
Severity Level IV violation for failure to keep pump motor heaters energized.
(50-424/85-40-04)
d.
Severity Level IV violation for failure to protect certain valves and the shutdown panel during storage.
(50-424/
85-43-01; 50-425/85-32-01)
e.
Severity level IV violation for failure to a keep a motor heater energized.
(50-424/86-07-02)
f.
Severity Level IV violation for failing to comply with drawing requirements weld size and for failing to promptly document and correct the condition af ter it was reported.
(50-424/86-11-02; 50-425/86-06-02)
g.
Severity Level IV violation for failure to perform adequate reviews of calculations for main steam nozzle.
(50-424/
86-76-01)
h.
Severity Level V violation for failure to follow procedure for documenting deviations.
(50-424/86-76-02)
2.
Conclusion Category:
3.
Board Comments:
The Board noted the change from a Category 1 to a Category 2 in
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this area. The Board recommends that the normal inspection level be maintained.
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E.
Auxiliary Systems 1.
Analysis - Fire Protection / Prevention Systems
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During this evaluation period, inspections of the construction site fire protection program were conducted by resident and
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regional inspectors.
These inspections included observations of fire prevention /
protection measures throughout the SALP inspection period.
These included details such as the use of welding permits with fire
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watches and extinguishers, post indicator valves being maintained
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in the open position, and fire fighting equipment stored in its designated locations throughout the plant.
The inspectors reviewed and examined porticns of procedures pertaining to the fire prevention / protection measures and housekeeping measures to assure they complied with applicable codes, standards, NRC
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Regulatory Guides and licensee commitments.
Inspections also included observations of fire prevention /
protection measures in work areas containing safety related l
equipment that verified the following:
Combustible waste material and rubbish was removed from the
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work areas as rapidly as practicable to avoid unnecessary a
I accumulation of combustibles.
Fla,nmable liquids were stored in appropriate containers and
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in designated areas throughout the plant.
Cutting and welding operations in progress were authorized by
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an appropriate permit; combustibles were moved away or safely
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covered; and, fire watches and extinguishers were posted as
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required.
Fire protection / suppression equipment was provided and
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Management of the Construction Fire Protection Program was i
responsive to NRC concerns and initiatives, and appears to be
adequately involved in the construction and installation of a j
quality system.
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There were no violations or deviations in this area, i
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2.
Analysis - Heating, Ventilation, and Air Conditioning Systems (HVAC)
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Ouring this evaluation period, resident and regional inspections I
were performed throughout dif ferent areas of both Unit I and 2 I
facilities.
The areas were selected on the basis of the scheduled
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activities and were varied to provide wide coverage. Observations were 'made of activities in progress to determine noncompliance with the required codes and regulatory requirements.
On these inspections, particular note was made of the presence of quality control inspectors, supervisors, and quality control evidence in i
the form of available process sheets, drawings, material identi-ficatian, material protection, performance of tests, and house-f keeping.
Interviews were conducted with craft personnel,
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supervisors, coordinators, quality control inspectors, and others l
as they were available in the work areas. The inspectors reviewed numerous construction deviation reports to determine if require-ments were met in the areas of documentation, action to resolve, justification, and approval signatures.
Periodic inspections by the resident inspectors during this SALP i
period were conducted during daily plant surveillances of safety
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l related HVAC steel welding at various stages of completion.
l Inspections determined that the requirements of applicable specification, codes, standards, craf t and QC procedures were being satisfactorily met.
Routine inspections and an evaluation of the Lice'isee's Readiness Review Module 18A were conducted by the regional inspection staff in the area of HVAC. These inspections involved observation of work, walkdown of completed hardware and review of quality i
records. The review of quality records indicated that the records were well maintained and readily retrievable.
Quality personnel involved in this area were qualified for their job functions and were knowledgeable in procedural requirements. A number of minor (approximately nine) discrepancies were noted during the hardware
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walkdown of completed work as discussed in Inspection Report 50-424/86-59. It appeared that these items were not identified by l
the licensee's, the contractor's QA/QC program, or licensee's l
Readiness Review Team. The unidentified discrepancies were of an isolated nature and appear to be the result of inattention to
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detail.
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The HVAC construction program was implemented by Pullman-Kenith-Fortson (pKF) with a surveillance and management overview by GPC,
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Management by both parties appears to be adequately involved in quality issues.
Staff and management were responsive to NRC concerns and initiatives.
Corrective action was usually timely and effective in correcting root causes.
Two violations and three deviations were identified:
a.
Severity Level IV violation.
HVAC Systems were not fabri-cated, installed and inspected in accordance with applicable procedures and drawings.
(50-424/86-59-01)
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b.
Severity Level IV violation for failure to establish adequate measures to protect installed materials and equipment from temporary construction loads.
(50-424/86-72-01; 50-425/
86-34-01)
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c.
Deviation from a commitment to the Commission to amend the FSAR. (50-424/86-56-01; 50-425/86-25-01)
d.
Deviation for failure to procure explosion proof motors.
(50-424/86-59-02; 50-425/86-26-02)
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e.
Deviation for failure to install electrically interlocked Control Room doors.
(50-424/86-59-03; 50-425/86-26-03)
3.
Conclusion Category:
4.
Board Comments: None F.
Electrical Equipment and Cables 1.
Analysis During this evaluation period inspections were performed by resident and regional inspectors. These inspections included the assistance of consultants during the review and inspection of the licensee's Vogtle Readiness Review Program (VRRP).
The VRRP consisted of modules which covered various phases of construction and installation of electrical equipment and cables. Each module evaluated the design and construction activities associated with the following categories:
Raceways, electrical equipment, electrical cables and terminations, electrical supports, and equipment qualification.
The review of each module consisted of the examination of records for design, on-site receipt and storage, and QA/QC documentation related to installation activities.
Examination of engineering and construction procedures, drawing and documentation were included in the module review. The licensee had selected various items in each module for examination, and had listed any deficien-cies identified as part of the module report. The NRC inspectors reviewed samples of the licensee inspected items but also selected an independent number of items in each module for evaluation. The licensee findings, and corrective actions, and the NRC findings for each of the modules did not identify any violations or deviations.
During the independent inspection activities for these modules two violations were identified. One violation was similar to a violation noted during the last SALP period relating
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to the protection of electrical equipment during construction activities which resulted in damaged cable tray.
The other violation appeared to be the failure to identify the division of responsibility between the construction activities and operational maintenance which resulted in a conduit support being disassembled without any record of work authorization.
During the evaluation period, several employee concerns were investigated by NRC inspectors. A concern was addressed involving the control of design, inspection, and installation of electrical splices. The licensee is aware of the concerns and was in the process of correcting the apparent problems.
During the previous SALP period, the licensee had taken corrective action to strengthen the effectiveness of quality control (QC)
efforts in the electrical area. This action was the result of a number of employee concerns in this area. Inspections during this period indicate that the licensee's actions in this area have been offective.
In addition, the number of employee concerns received by the NRC in this area has decreased during this period.
Licensee management initiated and fully supported the Readiness Review Program as evidenced by the time and manpower allotted for the program. Management continued to address electrical problems.
Their response to NRC concerns have resulted in a reduction of the number of violations for this period.
The following violations were identified:
a.
Severity Level IV Violation for failure to follow procedures for protecting installed equipment / components.
(50-424/
86-31-08)
b.
Severity Level IV Violation for failure to maintain control of a QC accepted Conduit Support.
(50-424/86-61-13)
2.
Conclusion Category:
3.
Board Comments:
None G.
Instrumentation 1.
Analysis During this evaluation period inspections were performed by the resident and regional inspectors.
The inspections were directed both to the routine NRC inspection program and to assessment of a Georgia Power Readiness Review Program that partially addressed this area.
The if censee's Readiness Review Program contained a
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module which addressed instrumentation and controls (I&C).
The moduld examined the I&C on a component basis rather than an overall system concept and was conducted by the licensee and inspected by the NRC in the same manner described in paragraph 'F'
of this assessment. The licensee's findings and the NRC findings for the module did not identify any violations or deviations for the items inspected.
A regional inspection of components and systems identified a violation of minor safety significance which related more to the QA/QC program than instrumentation by itself.
The violation was identified in the area of sensing line valve misidentification. A Licensee Deviation Report had identified the condition but was signed off (closed) without the work being completed.
A resident inspection identified a violation in the area of design control.
The violation was for inadequate implementation of design control in that the function to display pressurizer primary safety valve position indication status was not available on PLASMA display as required and Unit 1 field change requests were marked as not applicable to Unit 2 when, in fact, they were appitcable to Unit 2.
The following violations were identified:
a.
Severity I.evel IV Violation for failure to implement adequate design control.
(50-424/86-60-01; 50-425/86-27-01)
b.
Severity Level V Violation for failure to accomplish the corrective actions prescribed in Deviation Report PP-12074.
(50-424/86-45-01)
2.
Conclusion Category:
3.
Board Comments: None H.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis During this evaluation period, resident and regional special and routine inspections were performed.
Special inspections were performed involving reviews and evaluations of the Readiness Review appendices for procurement, materials control, inspector qualification and certification, project quality assurance organization, and document control.
Routine inspections were
performed in the following areas: materials control; preventive
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maintenance; procurement, receiving, and storage; document control; inspector qualification and certification; conduct of audits; onsite design activities; licensee actions on enforcement matters; and previously identified inspector followup matters.
Based on samples reviewed in each of these areas, there was no indication of any QA programmatic breakdowns.
However, one violation concerning storage of piping subassemblies was repeti-tive and indicates the need for added management attention in this area.
For the purpose of clarification, the Quality Programs area is defined as the ability of the licensee to identify and correct their own problems.
As such, it encompasses the entire plant activities, all plant personnel, and all those corporate functions and personnel that provide resources to the plant. The plant and corporate QA staff is a part of the entity, and as such, is mainly responsible for verifying quality.
The rating in this area specifically denotes the results for various groups in achieving quality as well as the QA staff in verifying that quality is achieved.
A review was performed on all sections of this SALP report in an attempt to capture apparent strengths and weaknesses related to management controls affecting quality.
The following are some strengths in management controls affecting quality:
The licensee's extensive and concentrated participation in licensing activities as shown by the Readiness Review Program. Although problems were identified in some modules, the overall effort was commendable.
GPC senior management involvement and support of the Fitness for Outy Program.
Prior planning was a major contributor to the satisfactory completion of important preoperational testing milestone.
The following are some perceived weaknesses in management controls affecting quality:
Repeat violations in the areas of controls for welding material storage and welding, storage of pipe subassemblies, and protection of electrical equipment.
Assuring that responsibilities for equipment maintenance were understood and accomplished.
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Inattention to detail relative to HVAC hardware identified during walkdowns. These minor problems were not identified by licensee and contractor QA/QC organizations and the Readiness Review Team review.
Written communications with the NRC regarding some safety issues involving design and inspection work were sometimes inaccurate.
QA positions and authorities were defined and have organizational independence to implement an effective program.
These personnel are adequately trained and understand the authority and responsi-bilities for their positions.
Staffing of QA positions declined to minimal for construction of Unit 2.
Experienced personnel have been transferred from Construction to the Operations D9partment and have been replaced with contractor personnel.
Increased emphasis and planning should have been focused on in-line surveillance of construction and engineering real-time functions in order to prevent problems before they happen or at least detect them immediately in a real-time environment.
The licensee has been responsive to NRC initiatives. Violations identified in the QA area were adequately addressed, evaluated to determine root cause, properly corrected, and actions were taken to preclude recurrence of similar problems.
The following Violations were identified:
a.
Severity Level IV for failure to evaluate or incorporate manufacturers recommendations into the equipment, mainten-ance, and storage list (EMSL) program.
(50-424/85-42-01)
b.
Severity level IV for failure to verify that purchased materials conform to procurement documents.
(50-424/
86-58-01)
c.
Severity Level IV for failure to accomplish adequate corrective actions to ensure material control from instru-mentation satellite warehouse.
(50-424/86-76-01; 50-425/
86-37-01)
d.
Severity Level V for failure to provide end caps to protect weld end preparations for valves, fittings, pipes, and tubing, and failure to store piping subassemblies in accordance with procedures.
(50-424/85-62-01)
e.
Severity Level V for failure to document usage and control of Measuring and Test Equipment.
(50-424/86-77-01)
f.
Severity level V for inadequate Pullman Power Products drawing control corrective action.
(50-424/86-15-01)
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Severity Level V for failure to assure applicable require-l ments are included in procurement documents. (50-424/
86-72-02; 50-425/86-34-02)
2.
Conclusion Category:
3.
Board Comments:
l The Board is concerned that the staffing level of the QA Construc-l tion Group, i..cluding contractor personnel, may become inadequate j
to support the ongoing construction activities in Unit 2.
l Management should guard against the dilution of the experience level of the QA Construction organization. The transferring of QA
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personnel to the Operations Department and replacing them with
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I contractor personnel invariably results in a loss of plant-specific QA expertise.
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Licensing 1.
Analysis l
During the present rating period, the licensee's management i
demonstrated extensive and concentrated participation in Vogtle Unit l's readiness for licensing as shown by involvement in both
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the Readiness Review Program and the licensing process.
It was apparent that the licensee's management strongly supported the Readiness Review effort as evidenced by the resources committed to the program. In the licensing process, management involvement was particularly helpful in focusing adequate attention to significant emergency planning issues and contributing to quicker issues resolution during this evaluation period.
Prior planning by the licensee for NRC staff audits and meetings was evident. In particular, management involvement was evident in preparation for the Seismic /Punp and Valve equipment qualification audit, the series of discussions related to the tcxic gas issue, and the design live load meeting.
Prior planning contributed to productive discussions and final resolution between the licensee and the staff of key licensing issues.
The licensee's routine decisions related to licensing issues have exhibited conservatism in relation to significant safety matters.
GPC's understanding of the staff's concerns assured sound technical discussions regarding resolution of safety issues.
These attributes were particularly apparent in relation to fire protection and Regulatory Guide 1.97 issues.
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The 1,1censee's management and its staff have shown a lack of understanding cf certain staff policies and positions.
For instance, the licensee failed to recognize the significance of the spent fuel rack design change and provided insufficient informa-tion in support of the change. Because of this, the staff needed to request additional information and identify this issue as an open item in Supplemental Safety Evaluation Report (SSER) 2.
The licensee's emergency planning submittals reflected management involvement, but sometimes lacked completeness of information, as evidenced by the staff's need to request additional information.
There also appeared to be a reluctance to make definitive commitments to resolve issues in this area. However, in these and other issues, once key areas were identified to licensee manage-ment, prompt technical discussions to further resolution usually followed.
The licensee has been generally responsive to NRC initiatives. In response to requests related to the staff's review of SSER open items, additional information was usually provided in a timely manner. During the rating period, the licensee has made efforts to meet commitments as illustrated by responses to TMI action items such as II.F.1 and 11.D.1 and compliance with the regula-tions related to fire protection.- In response to the many items of Generic Letter 83-28, the licensee responded in a timely and thorough manner. Additionally, the licensee has been responsive to the need for telecons and additional information during the staff's review of the Vogtle preservice inspection program.
A significant licensing area where licensee improvement is needed is plant personnel training. The licensee's continuing changes to the FSAR led to the creation of new open items in SSER 2.
In attempting to resolve these issues, the licensee's emphasis appeared to be on justifying deviations from original FSAR commitments rather than on providing a sound technical basis for personnel training. As a result, these issues remained unresolved for six months.
Other FSAR and comnitment changes during this rating period led to a substantial number of new open issues during this evaluation period as discussed in SSERs 2 and 3.
This trend is contrary to what the staff would expect immediately prior to licensing.
In most instances, the licensee has appropriate staff available to address and respond to NRC issues and concerns as evidenced through telecons, meetings, and formal submittals.
In the FSAR, the licensee has defined adequate staffing for licensing and non-licensed personnel.
There appears to be adequate engineering and technical expertise within the organization to perform the necessary emergency operations and procedures. The security staff
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appears to be adequate to carry out the facility physical protec-tion program; however, deficiencies exist in the actual installa-tion, acceptance testing, and utilization of security alarm equipment and hardware.
During site visits, the staff found that the plant was in relatively good order with respect to cleanliness and house-keeping.
Activities in the control room were observed to be conducted in a professional manner with assigned personnel appearing to be alert ar.d attentive to duty.
2.
Conclusion Category:
3.
Board Comment:
None J.
Independent Design Review 1.
Analysis GPC's Readiness Review Program consisted of a review by Georgia Power Company (GPC) of the design, construction and preparation for operation, to determine the licensee's preparedness to receive an operating license. The Office of Inspection and Enforcement was responsible for assessing the design review portion of the Readiness Review Program.
Of the approximate 22 modules that comprised the Readiness Review Program, only modules 1, 8,13 and 22 address design.
Modules 1, 8, and 13 were associated with design review of the civil / structural discipline and module 22 was a multi-discipline system Independent Design Review (IDR).
For the civil / structural design review, two inspections were performed to ensure that the Independent Design Review contractor had performed a thorough review of the subject Readiness Review module 22, as well as to ensure that the appropriate corrective action had been implemented by GPC where necessary (Refer to Inspection Reports 50-424/86-42 and 50-424/85-64 for documentation of staf f's comments). An inspection conducted by the staff the week of August 11, 1985, verified that all previous staff comments had been adequately resolved.
For the IDR, the staff conducted inspection activities in three phases: (1) inspection of program preparations, (2) inspection of program implementation, and (3) inspection of IDR results and corrective actions.
The first two phases were conducted in July and August 1985 and the results were documented in Inspection Report 50-424/85-34.
Review of GPC's resolution of this inspec-tion report's comments as well as an inspection of phase 3 was
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conducted at the Vogtle site during the week of August 11, 1986.
Subsequent to this assessment period and inspection was conducted at the architect / engineering offices in Log Angleles, the week of October 6, 1986, to assess Bechtell's implementation of the corrective actions in response to the IDR findings, and an inspection report documenting that previous staff comments with regard to the IDR have been closed was signed and issued on November 20, 1986. One open item was identified, Readiness Review 22.F.11, involving support of electrical cables in vertical trays.
This item is under review by the staff.
GPC voluntarily agreed to participate in the Readiness Review pilot program.
In the design area, GPC made a major in progress change in the program to accommodate an NRC suo. :stion regarding the organization of the design reviews.
The c.llity has been responsive to the NRC in both accepting recommendations for programmatic changes and in performing additional technical reviews in areas where NRC found weaknesses in their evaluations.
No violations or deviations were identified.
2.
Conclusions Category:
3.
Board Comments:
None K.
Other Licensee Initiatives 1.
Drug and Alcohol Abuse Prevention Program The licensee's Fitness for Duty Program was reviewed during the week of September 15-19, 1986 at the Vogtle site and at the licensee's corporate offices. GPC has developed and implemented a program which addresses the key elements of the Edison Electric Institute Guide; however, certain areas were identified where the program did not fully meet the EEI guidelines adopted by the nuclear power industry. Of the ten elements in the EEI guide-lines, two elements, Supervisor Training and Chemical Testing, were not totally implemented.
GPC senior management involvement and support was evidenced by a clear policy that was well communicated to the employees.
The disciplinary provisions of the written policy and their communica-tion to the employees were particularly strong, as was the support for the program from site management. The unions and contractors were involved in the development of the program, and supported it, and the licensee has an effective working arrangement with the
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local law enforcement authorities.
The Employee Assistance progra'm lacked certain procedures, and policies had not been established for an individual's return to duty following rehabili-tation.
Training of supervisors in behavioral observation and program implementation was adequate, but a number of supervisors had not yet been trained.
The licensee was making satisfactory progress toward develupment and implementation of the Fitness for Duty Program, although added attention is needed in the areas noted above and in application of the chemical drug testing program.
2.
Quality Concerns Program The licensee has maintained a quality concern program.
The program was implemented the week of December 15, 1983.
This program provides a system for Georgia Power Company (GPC),
Bechtel, Southern Company Services, and contractor personnel associated with the Vogtle project, either at the site or at any other location, to express their concerns about quality and/or safety problems and have them resolved.
The GPC Quality Concerns Program (QCP) is procedurally formalized in the project policy and procedures manual. The QCP scope is not limited to safety related and/or important to safety aspects of the plant, but encompasses all aspects of the project activities where individuals have concerns relative to the quality of the plant.
The program at Vogtle is managed by a staff on site, specifically assigned and full time.
The program is supported by management as reflected in a letter to all employees from the President of the company which encourages reporting of concerns direct to immediate supervision or other management levels first and to the concerns office if not satisfied or if confidentiality is desired.
Employees may register a concern by placing the item in a drop box, verbally describing it on the telephone (toll free number), through the U.S. mail and company mail, showing up in person at the quality concerns office, or through an exit interview at termination.
When a concern is received, an investigation into the matter is promptly started.
Upon completion of the investigation the licensee makes a concerted effort to contact the submitter either in person, by mail, or through the plant Vogtle news publication
" Blazer" (if the, individual is an anonymous submitter) inorder to inform the individual of their findings and corrective actions taken if required as a result of the investigation.
The awareness of the program to the employees is evidenced by large signs posted at key locations, flyers passed out to all personnel arriving or departing the site, wallet calendars, various types of logos for wearing on hats and clothing, and
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vehicle bumper stickers.
The general message conveyed by the print 6d materials is that GPC intends to build the plant in a high quality manner and which also meets or exceeds all regulatory requirements.
The posted and other printed materials are supplemented by orientation sessions for new personnel and exit interviews for the majority of terminated personnel.
During this evaluation period, inspections of the QCP were performed by the resident inspection staff.
These inspections consist of, but were not limited to, verifying employee awareness by observing posted quality concern program signs in appropriate places and interviewing site personnel for their awareness of the program; verifying that a proper staffing level was maintained in the quality concern program organization to support the workload, thereby maintaining an acceptable backlog of concerns; and reviewing key concerns to verify that a comprehensive and thorough investigations were conducted.
Inspectors found that the quality concern files were complete, well maintained, and available.
Management involvement was evidenced by a steering review committee reviewing for accept-ability where required. The program is an effective mechanism for getting concerns reported to licensee canagement.
3.
Conclusion Category:
4.
Board Comments: None V.
PRE 0PERATIONAL TESTING (UNIT 1)
A.
Preoperational Testing 1.
Analysis During this evaluation period, numerous inspections were conducted in the area of preoperational testing by regional based and resident inspectors.
The inspections in this area included
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procedure review, observation of testing in progress, and evaluation of completed test results. Daily status meetings were conducted by site management throughout the test program.
Management awareness of problems as they developed and close involvement with the test program ensured that decision making received adequate management attention.
Detailed test schedules showed consistent evidence of prior planning and a definite assignment of priorities.
Prior planning was considered to be a major contributor to the successful preparation for initial fuel receipt and the satisfactory completion of important testing
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milestones such as secondary and primary hydrostatic testing, hot functional testing, and containment structural and integrated leak rate testing. The Startup Manual, which controls the conduct of the program, contained well stated and understandabie policies.
Observation of testing in progress indicated that procedures were strictly adhered to and rarely violated.
The documentation associated with testing was ccmplete, well maintained, and readily available when requested.
The licensee's approach to the resolution of technical issues from a safety standpoint were normally conservative, thorough, and technically sound.
One example of where this approach to technical issues was best demonstrated was during containment integrated leak rate testing, in which the procedure and test-practices reflected a good understanding of leak rate testing.
Due to management involvement, through the daily meetings previously mentioned, all personnel concerned had a clear understanding of the issues at hand and therefore, the resolutions were timely in most cases. The licensee was responsive to most NRC initiatives in the preoperational area and the resolutions were generally technically sound and acceptable.
Corrective action programs were adequate in that problems identified through the course of testing were promptly documented, repaired, and retested.
In addition, the initial test program was conducted with extensive involvement of permanent plant personnel during testing activi-ties.
Component testing was performed by licensee maintenance personnel to the maximum extent possible.
The majority of positions, such as management test supervisor, lead test super-visor and integrated test supervisor, were filled with licensee employees, so as to retain the experience gained during the test program and to carry this experience into plant operations.
Peak manpower periods were supplemented by centractor startup per-sonnel.
Equipment, systems, and major test evolutions requiring extensive experience (such as the diesel generators, nuclear steam supply systems, and hot functional testing) were supplemented with qualified contractor startup personnel.
Three weaknesses were noted during the preparation for initial fuel receipt. The licensee's plans did not include completion of appropriate preoperational tests prior to use of the spent fuel cask bridge crane.
In addition, the completed preoperational tests did not include the new fuel assembly handling tool. Once these issues were brought to the licensee's attention, ccrrective action was taken prior to ir.itial fuel reciept. A third weakness was noted in the area of security regarding the identification of the areas requiring security surveillanc.-
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Three violations were identified during the evaluation period.
Violation "a." was attributed to discrepancies between Engineering Drawings and Isometric Drawings due to turnover walkdowns not being ~ thoroughly conducted.
Violation "b."
was attributed to ineffective communications at the working level; not requiring the use of approved procedures; and. not establishing appropriate policies to control the use of verbal instructions.
Violation
"c." was attributed to a lack of specifying the technical testing attributes for air operated valves being tested.
The violations do not represent any significant programn tic breakdown with the preoperational test program but represented separate isolated areas in the program where, if more definitive policies had been established, then implementation could have avoided the violation.
The violations identified were:
a.
Severity Level IV violation for failure to perform an adequate system walkdown during the turnover of safety-related systems.
(50-424/86-09-01)
b.
Severity Level IV violation -for failure to establish appropriate procedures to properly control the filling and venting of safety-related systems.
(50-424/86-31-01)
c.
Severi ty Level IV violation for inadequate procedure for testing air operated valves with Bailey controllers.
(50-424/86-74-02)
2.
Conclusion Category:
3.
Board Comments:
None VI. OPERATIONS (UNIT 1)
A.
Operational Readiness 1.
Analysis - Plant Operations During this evaluation period, regional and resident inspections were performed to verify proper implementation of operation activities in accordance with applicable procedures during the initial test program. Also, a special inspection was performed to evaluate Module No. 7, Plant Operations and Support, of the Readiness Review Program being conducted by the Licensee as an additional initiative to provide assurance that plant Vogtle complies with FSAR commitments.
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The routine inspections conducted consisted of a review of the plant ' administrative,and operations procedures manual.
Key functional areas reviewed under plant administration were:
the organization and responsibilities; plant procedures; operations; maintenance; and materials procurement.
Key functional areas reviewed under operations were:
normal system aligr.ments; unit operating procedures; system operating procedures; surveillance procedures; abnormal operating procedures; and emergency operating procedures.
In addition, periodic inspections were conducted of control room operations to assess plant condition and conduct of shift personnel.
Control room operations were conducted in an orderly and professional manner. Shift personnel were knowledge-able of plant conditions, i.e., ongoing testing, systems / equipment _
in or out of service, and alarm annunciator status.
Shift turnovers were observed on various occasions to veri fy the continuity of plant testing, operational problems, and other pertinent plant information during the turnovers.
Control room logs were reviewed for detail of events and were found to be adequate for the present phase of plant operations.
During the evaluation period, the licensee has staffed a full complement of on shift operations shift personnel to support the initial test program as well as to give personnel on shift job training.
Operations personnel exhibited a satisfactory level of performance during the following major test evolutions: secondary hydrostatic test, primary hyrdrostatic test, hot functional testing, containment structural integrity test, and containment integrated leak rate test. The following operational events which occurred during testing were reviewed: pressurizer power operated relief valve lifting; steam generator safety valve lifting; and inadvertent closure of turbine driven auxiliary feedwater pump suction valve during operation.
No equipment was damaged as a result of these events; however, they did indicate some error on the part of the operator. This was considered to be normal for a utility starting up their first unit at a new facility.
Management appeared to be adequately involved in issues affecting quality and to address technical issues in a timely manner. Staff and management were responsive to NRC concerns, requests, and initiatives.
2.
Analysis - Startup Testing During this evaluation period an inspection of the startup test program was conducted as part of the Readiness Review Module No. 7 and the regular inspection program.
Six administrative and twelve test procedures to be used in the startup test program were reviewed.
Four areas in which proce-dural improvement was necessary were identified.
This was
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considered average for a utility starting up their first Westing-house' unit. The basic program for startup testing appeared to be sound, and the personnel assigned to the task of procedure preparation appeared sufficient and adequate for the task.
3.
Analysis - Surveillance During this evaluation period, a special inspection was performed to evaluate the surveillance test section contained in Module No. 7, Plant Operations and Support, of the Readiness Review Program being conducted by the Licensee as an additional initia-tive to provide assurance that Plant Vogtle complies with FSAR commitments.
The licensee had assigned responsibility of surveillance test development and implementation to the applicable departments, i.e., Maintenance, Instrument and Control (I&C), or Operations.
The status of the Maintenance (Mechanical and Electrical) and I&C Departmental surveillance procedures was discussed in the Maintenance Section.
The Operations Department had identified numerous procedures as being required, of which virtually all had been approved and issued. Operations also had performed several surveillance tests.
In addition, Operations had also performed procedure trial use, either by a walkthrough of the procedure or by the preoperational test method, on a majority of the surveill-ance test procedures to verify their workability.
Random inspections were conducted to review Maintenance, I&C, and Operations surveillance procedures.
The basic program for implementing surveillance testing appeared to be adequate in that there was evidence of prior planning, assignment of priorities and defined procedures for controlling activities.
4.
Conclusion Category: 2 5.
Board Comments: None B.
Radiological Controls / Chemistry 1.
Analysis - Radiological Controls During the assessment period, regional inspections were performed in the area of radiological controls and were directed to the review of Module 9A, Radiological Protection, of the Vogtle Readiness Review Program. Additional review of this module was conducted by the Offices of Nuclear Reactor Regulation (NRR) and Inspection and Enforcement (IE).
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- The. Readiness _ Review determined.'that the radiological controls program was defined in accordance with commitments and regulatcry
. requirements and that the commitments were being implement (d in the applicable procedures.
- Pre-startup activities of the radiation protection program were generally well managed and ready to support fuel load and startup testing.
The licensee appeared to have a sufficient number of.
trained radiation protection staff members (supervisory and-technicians) for plant operation.
The licensee was maintaining adequate development -and training programs for the health physics staff.
The facility had sufficient equipment and instrumentation to support in plant radiological controls.
Much of the instru-mentation was current, state-of-the-art technology.
The licensee decided not to complete construction of the waste solidification. and processing facility in conjunction with the completion of Unit 1.
Alternate methods, e.g.,
contracted solidification and disposal services, will be used in the interim.
An amendment to the FSAR was submitted to reflect the change in proposed operations. Although many of the procedures had not been finalized, the applicant had developed an acceptable framework for the radiation protection program.
2.
Analysis - Chemistry During the assessment period, regional inspections were performed in the area of chemistry and consisted of an NRC staff review of Readiness Review Module 9B, Chemistry. This review found that the
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licensee had identified all requirements for establishing an
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effective chemistry program. However, this module did not contain i
detailed implementation information. Also, based on early review l
of the chemistry program development, it appeared that insuffi-I cient lead time had been allowed for full implementation of a water chemistry and radiochemistry program to support the licensing schedule.
This concern was partially alleviated after the first preoperational inspection in that significant progress
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was made in such areas as staffing, procedure writing, training, and construction of physical facilities.
The design of the secondary water system was also found to be conducive to chemistry and corrosive control.
The major deficiencies were noted in the areas of staff training and qualification and the incomplete
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construction of the primary chemistry laboratory. Also, many of the procedures relating to radioactive effluents management were
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During the conduct of hot functional testing, the staff was able to obs'erve both management and the chemistry department perform-ance regarding the establishment of the primary passivation layer and the maintenance of secondary chemistry.
Maintaining an adequate supply of quality water to support plant water usage became the major problem during the testing.
Appropriate management attention was focused to ensure that maximum secondary system cleanup activities were maintained.
Following hot functional testing a corrective maintenance program was estab-lished to ensure that plant water storage systems will maintain water within specification.
These management activities were considered to be indicative of a facility which will place appropriate attention to the area of chemistry.
3.
Analysis - Nuclear Air Cleaning Systems Regional personnel reviewed sections of Vogtle Readiness Review Module 7.
Special attention was paid to sections addressing nuclear air cleaning sys*. ems. The licensee has the basis for an
.idequate filter testing and maintenance program, but during the review NRC staff noted that several procedures were inconsistent with draft Technical Specification requirements, FSAR commitments, or referenced documents.
These deficieraies were not identified during the licensee's readiness review process, but the licensee agreed to make appropriate changes.
4.
Conclusion Category:
5.
Board Comments:
None C.
Maintenance 1.
Analysis During this evaluation period, inspections were performed by the l
resident inspector to verify proper implementation of maintenance activities in accordance with applicable procedures under the jurisdictional control of the startup manual.
Also, a special inspection was performed to evaluate Module No. 7, Plant Opera-tions and Support, of the Readiness Review program being conducted by the Licensee as an additional initiative to provide assurance that Plant Vogtle complies with FSAR commitments.
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The routine inspections conducted of the maintenance program encompassed: maintenance work order (MWO) initiation; review and processing MW0s by the Work Planning Group (WPG); review and releasing MW0s by the Test Supervisor; review and packaging MW0s t
a by the WFG; MW0s performed by the Nuclear Construction Department;
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MW0s performed by the Nuclear Operations Department; functional tests ~and review; and review and closecut of MW0s by the WPG.
Review of Readiness Review Module No. 7, Plant Operations and
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Support, entailed a review of plant procedures as well as observation of work activities which related to the following programs:
control of maintenance's control of modifications; measuring and test equipment; special processes; materials management; preventive and predictive maintenance; and diesel generator program. This review was accomplished by an evaluation of applicable maintenance (i.e.,
electrical, mechanical, and instrumentation and control) sections of the module and by:
Verifying that the maintenance commitments listed in the module were correct and comply with FSAR commitments.
- Reviewing the Readiness Review findings in the maintenance area and evaluating the correctness of their resolution.
- Reviewing a comprehensive and representative sample of the documents reviewed by the Readiness Review staff and an independent sample of documents selected by the inspector.
- Field observation of implementation of maintenance activities during the preoperational test phase.
The licensee has implemented a maintenance program under the jurisdictional control of the startup manual during the initial test program. This program was similar to the program established for plant operations. To date, 462 of 543 mechanical / electrical maintenance and 845 of 897 instrumentation and control (I&C)
procedures were issued.
These numbers include applicable surveillance procedures which have been assigned to maintenance and I&C for responsibility.
The Maintenance Department were actively involved in performing as many as possible of these procedures and continued to update the procedures to reflect changes noted during their use. The licensee intented to perform as many of these procedures as possible during the initial test program to verify their workability.
The licensee was also implementing / performing maintenance activities to the greatest extent possible utilizing their own permanent plant staff personnel.
Peak manpower periods were supplemented as required by contractor maintenance personnel.
Also, the licensee had taken advantage of utilizing vendor representatives almost exclusively when performing major mainten-ance activities on safety-related equipment (such as pumps, motors, valves,etc.).
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This. readiness review evaluation indicated that the licensee's
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maintenance procedures have been written in accordance with NRC requirements and FSAR commitments. These procedures combined with the additional programmatic elements required of a plant in the operational phase, should comprise an adequate maintenance program. The evaluation also indicated that the readiness review program for maintenance conducted by the Licensee's readiness review staff was comprehensive in scope and depth.
The licensee's approach to the resolution of technical issues generally exhibits conservatism from a safety standpoint.
Maintenance staffing and staff training appeared adequate. Staff and management are responsive to NRC concerns, requests, and initiatives. An observed weakness in the maintenance area related to a failure to fully implement procedures governing the mainten-ance work order process which resulted in the violation as discussed below.
During these inspections, a violation was identified when the Nuclear Operations Maintenance Department was implementing a field equipment change order on the centrifugal charging pumps.
The MW0s associated with this job did not contain sufficient detail to allow for proper department reviews, proper establishment of Quality Control hold points, nor performance of work in a quality manner as required by the startup-maintenance program.
This violation was a result of a failure to fully implement procedures governing the maintenance work order process.
One violation was idantified:
Severity Level IV violation for failure to provide adequate maintenance procedures for work on safety-related equipment appropriate to the circumstances. (50-424/85-52-01)
2.
Conclusion Category:
3.
Board Comments:
None D.
Fire Protection 1.
Analysis During this assessment period, regional and resident inspections were conducted of the licensee's permanent plant fire protection and fire prevention program.
Inspections of the plant safe shutdown features available in the event of fire were conducted subsequent to this SALP period and the results are under review.
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The licensee :had prepared procedures-for the administrative contr61 of fire hazards in the plant and the training and organization of the plant fire brigade.
These procedures were
reviewed and found to meet the NRC guidelines except for several minor discrepancies. The -licensee promptly. initiated action to
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resolve these items. The regional staff has not yet reviewed the procedures covering the fire protection systems and features.
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The operational fire brigade's organization and training was weak, apparently due to inadequate training and drills.
The licensee was relying on the construction fire brigade for protection of the permanent plant structures, equipment, materials and supplies.
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i However, upon receipt of nuclear fuel on site, the. licensee was
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required by the NRC license to implement. the permanent plant operational fire brigade: program for fuel receipt areas.
Extensive training was initiated to assure that the Operations
staff was provided with sufficient qualified personnel to maintain a minimum of five man fire brigade for'each shift. A fire brigade
drill was witnessed during the end of this assessment period and
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demonstrated compliance with NRC guidelines. Also, continuation of - the extensive training program should _ assure that the entire fire brigade organization will be well trained prior to fuel load.
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The permanent plant fire protection systems and features were inspected during this assessment period. In the previous period, the NRC inspectors and the licensee's operations group identified i
a number of design, installation, and construction discrepancies
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involving the fire pumps. These items were corrected during this i
assessment period. The automatic sprinkler systems were reviewed and found to contain several minor code and FSAR deficiencies.
The licensee was reviewing these items to determine the appro-priate corrective action.
The interior fire hose system was inspected and found to be satisfactory, except for interior fire hose stations which were not provided in a few plant areas as
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stipulated by the FSAR.
This item was being reviewed by the licensee. The deluge systems for the charcoal filter units were
inspected and found to be modified such that the systems were no
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longer manually operated as stated by 'the FSAR. A blank flange l
had been installed in the piping supply to the filter unit, or a
section of the supply piping had been removed. The licensee was reviewing this item to determine the appropriate corrective action.
The fire detection systems were reviewed and found to be
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properly installed; however, at the time of inspection, the systems had not been functionally tested.
The licensee's corrective action will be reviewed.
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I The fire barrier walls, floors and ceilings separating safe shutdown areas and redundant shutdown trains and the penetration through these barriers were inspected.
The seismic gap between various fire areas were being sealed with a silicone foam
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material; however, this installation was not being performed under a QA/QC program as committed by the FSAR. This was identified as a deviation listed below.
A number of large cable penetrations were identified which exceeded the maximum size permitted by the penetration seal manufacturer's design.
This departure from NRC guidelines is under review by the NRC. Appropriate corrective action was being reviewed by the licensee.
The structural steel fire proofing was reviewed, and although the steel appeared to be properly coated, it wa, not being installed under a QA/QC program as stated by the FSAR.
This was also identified as a deviation. Each of the reactor coolant pumps have an oil collection system arranged to collect oil leaks from the pumps and drain the oil into a collection tank. This system was inspected and found to meet the FSAR commitments and NRC guide-lines.
The licensee's management has developed a program to review and verify that the installed fire protection systems and features at the facility were adequate and meet the NRC guidelines.
This program exceeds NRC requirements and was in addition to the normal plant construction inspection and QA/QC programs provided.
The licensee's approach to the resolution of technical fire protection issues indicates an understanding of the issues and was generally sound and timely, however, the design and installation of some of the fire protection systems and features contained discrepancies.
These problems are to be resolved by the licensee. Also, portions of the fire protection features were not installed under a QA/QC program as committed by the FSAR.
The responsiveness to NRC initiatives was enerally timely and thorough.
Fire protection related violations have been rare, since the plant is not licensed.
However, when discrepancies were found, corrective action was promptly taken.
The licensee's identified fi re protection related events or discrepancies were not normally reported to the NRC, but appear to be properly analyzed and effective corrective action taken.
P Staffing for the permanent plant fire protection program appears adequate to accomplish the goals of the position during the preoperational phase.
Personnel appear qualified for their assigned duties, however, consultants and contractors were used extensively in the preoperational testing and implementation of the permanent plant fire protection program.
The licensee has only one permanent fire protection Georgia Power Company employee.
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One deviation was identified:
Deviation involving the failure to provide a QA program for all fire protection system installations as described by the FSAR.
(50-424/86-64-05; 50-425/86-30-01)
2.
Conclusion Category:
3.
Board Comments:
The Board is concerned that licensee resources were not effec-tively utilized in this area. The licensee has only one engineer assigned in this area and is depending on contractors for the majority of engineering work.
This may result in a low level of plant specific expertise remaining on site.
E.
Analysis During this evaluation period, the following inspections and related activities were performed by the regional and resident inspection staffs: two emergency preparedness (EP) pre-appraisal inspections to confirm the licensee's readiness for an emergency preparedness implementation appraisal; an emergency preparedness appraisal; an evaluation of Near Term Operating License (NT0L)
full scale emergency preparedness exercise; and an initial EP appraisal followup inspection to verify adequacy and completion of licensee's corrective actions in response to improvement and incomplete items identified during the appraisals.
The appraisals, inspections, and exercise evaluation disclosed no
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significant problems regarding the plant site emergency response organizations and staffing.
The corporate Emergency Response Organization was adequately staffed and provided required support to the plant consistent with plant and corporate emergency plans.
Key positions, with assigned alternates, in the corporate and plant response organizations were filled.
Corporate management demonstrated a strong and effective commitment to the emergency response program.
Senior corporate officials were directly involved in the pre licensing emergency preparedness exercise, related drills, and followup critiques.
The NRC appraisal conducted disclosed items which required further j
evaluation and improvement as well as items which vere incomplete and could not be fully evaluated.
During the initial appraisal followup inspection, many items directly addressing the EP program were closed.
The licensee was involved in a concerted effort to resolve the remaining open items.
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The full scale emergency preparedness exercise demonstrated the licensee's capability to promptly activate its emergency response organization to successfully asses and mitigate emergencies.
During the exercise, the applicant - correctly identified the emergency, prope*1y classified the stages of the emergency as it -
developed, made appropriate protective action recommendations, made all appropriate notifications to offsite autherities, and aggressively worked to deal with the simulated plant casualty.
During the current licensing stage, the licensee appears to be developing an effective amergency response capability consistent with the proposed emergency plan and respective procedures.
Based upon the appraisal, exercise, and inspections, the following essential elements were determined to be acceptable:
emergency detection and classification; protective action decision making; notification and communications; shift staffing and augmentation; training; dose calculation and assessment; public information; coordination with offsite agencies; planned emergency respense program audits and quality assurance commitments; identification of weaknesses during drills and the exercise; and resolution of identified weaknesses.
No violations, deficiencies, or weaknesses were identified.
The licensee has developed an effective emergency response training program, and demonstrated a strong commitment to continued training (including period followup and remedial training consistent with the proposed Emergency Preparedness Plan).
Corporate management similarly demonstrated strong commitment to continued development and maintenance of an effective emergency response training program involving offsite support agencies.
The licensee was developing an effective emergency response capability, and has demonstrated a strong commitment to maintain same.
2.
Conclusion Category:
3.
Board Comments:
None F.
Physical Security / Material Control and Accountability 1.
Analysis - Physical Security During this assessment period, three region based inspections of the installation of security facility and equipment, and imple-mentation of the physical security program were conducted.
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Review and observation of licensee efforts and progress in the installation of programmed security facilities and equipment identified several areas of concern relative to functional adequacy of facilities, operational effectiveness of equipment, and compliance with regulatory requirements as committed to in the licensee's proposed Physical Security Plan. Of particular concern was the rate of progress toward completing installation and operational testing of security systems and equipment to ensure availability by the scheduled date for security program imple-mentation. Other concerns identified related to the positioning and application of intrusion detection -equipment, closed circuit television cameras, access control facilities, interim barriers, and penetrations in designated vital area barriers.
Security systems and equipment procured by the licensee for use in establishing a viable security program are of high quality and adequate for the intended use.
However, the installation has proven ineffective due to the positioning of intrusion detection
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equipment to be utilized for assessment. The licensee's enginee-l ring staff responsible for the installation and operational l
testing of security systems and equipment was knowledgeable and highly capable.
However, there was a lack of involvement by security management with the engineering staff, site management, and other licensee functions sharing responsibility for the installation and implementation of the security program. The lack of communication was demonstrated by instances of unawareness of barrier locations, barrier penetrations, access control capabili-ties at access portals, and intrusion detection equipment.
Because of these deficiencies, neither the licensee nor Region II has been able to functionally test the system to determine compliance with commitments.
Not until the NRC inspectors expressed concern was there a noted increase in emphasis by the licensee to improve several of the areas identified. However, recent changes in scheduled completion dates have resulted in a delay in full implementation of the security program until two weeks prior to scheduled fuel load.
The licensee's security training program has been implemented and a computer system simulator has been established for use in training security alarm station operators.
Hands-on proficiency training was pending the availability of operational security systems and equipment.
Security procedures for implementation of the security program have been prepared; however, new security management indicated they needed refinement to be adequate for an operational security function. To date, the licensee's proposed Physical Security Plan I
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has not been approved.
Revisions to update and effect necessary change's to the Security Plan have been submitted to the Office of Nuclear Materials Safety and Safeguards (NMSS).
2.
Analysis - Material Control and Accountability During this assessment period, one region based inspection of Material Control and Accountability (MC&A) was performed.
The licensee had established and was maintaining written proce-dures for controlling and accounting of receipts, storages,.
internal transfers, inventory, burnup calculations, shipments, records and reports. Although the licensee's program to account for and control special nuclear material was not completely implemented the program had been adequately developed. The MC&A personnel were trained and demonstrated adequate knowledge and understanding of their assigned functions.
The MC&A procedures were well written and approved by appropriate management.
3.
Conclusion Category:
4.
Board Comments:
Weaknesses in performance in the physical security area were evident. The licensee did not utilize resources effectively or in a timely manner.
This is identified as needing increased management attention due to problems in understanding security requirements, personnel training, equipment installation, and overall plant activities.
Increased licensee resources and management attention will be required in order to implement an effective security program once the construction and preopera-tional testing are completed. The Board recommends that NRC staff resources applied to the routine inspection program be increased.
G.
Quality Programs and Administrative Controls Affecting Quality (Operations)
1.
Analysis During this evaluation period, resident and region based inspec-tions were performed to verify proper implementation of quality assurance (QA) activities in accordance with applicable procedures during the initial test prcgram.
For the purpose of clarifica-tion, the Quality Programs area includes the ability of the licensee to identify and correct their own problems. As such, it encompasses the entire plant activities, all plant personnel, and all those corporate functions and personnel that provide resources
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to the plant. The plant and a corporate QA staff is a part of the entity', and as such, is mainly responsible for verifying quality.
The rating in this area specifically denotes the results for various groups in achieving quality as well as the QA staff in verifying that quality is achieved.
The operations Quality Assurance Department consisted of a site tranager, two supervisors, four auditors, and six surveillance engineers.
This department has been functionally organized to perform audits of organizations and activities and to perform surveillances of the initial test program. The Surveillance Group was supplemented by four contract personnel.
Additionally, the Audit Group was supplemented by personnel as required to aid in the performance of large audits.
The staffing level appeared to be adequate; however, vacancies are not being filled as they occur.
The licensee's approach to the resolution of technical issues was normally sound and characterized by viable and thorough appro-aches.
The QA staff and management are responsive to NRC concerns, requests and initiatives.
One deficiency was the failure to followup on an issue identified during a site QA audit in a timely manner.
As identified, the violation involved corrective action not being achieved in the time frame stated in the audit report.
As part of the NRC review of Readiness Review Module 7, Plant Operations and Support, certain portions of the Operational Quality Assurance (QA) program were inspected.
These areas were: Measuring and Testing Equipment;- Receipt of Material; Storage, Handling, and Shipping; and Procurement. A review of the Regulatory Compliance Departments commitment identification, tracking, and implementation process was also conducted.
Test and Operations Management involvement in assuring quality was evident at all levels inspected.
Lower level managers supported day-to-day activities in a quality conscious manner while upper level managers appeared to be quality conscious with respect to programmatic goals and functions. Upper level managers were aware of QA commitments in upper and lower tier documents and were working with the Regulatory Compliance Department to insure that all commitments were contained in the appropriate documents.
Personnel requiring training (such as Quality Control Receipt Inspectors) were knowledgeable in their areas, giving the
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impression that their training and experience had adequately prepared them to handle their assigned task.
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During the review of commitment implementation, for the sample selected, commitments were adequately addressed in upper tier documents.
However, some of the lower tier documents could be enhanced by providing a greater commitment detail.
The Regulatory Compliance Department was in the process of reidentifying commitments that they had processed just after the department was created. This reidentification was being performed because commitments identified in the early stages of the program were identified by one person and this led to some variance in interpretation as to what was or was not an actual commitment.
Commitments were subsequently identified by two independent reviewers and then discussed if necessary to insure that the commitments were properly identified.
Once identified, commit-ments were sent to the responsible department for implementation.
The responsible department would review their procedures to insure implementation.
The Regulatory Compliance Department would then verify (on a sample basis) the inclusion of commitments in the appropriate procedures.
Since this review was conducted on a sampling basis, due to the large number involved, all commitments were not individually verified. One potential weakness existed with this effort in that personnel responsible for determining the department responsible for implementing certain commitments did not appear to have an in-depth knowledge of the vast number of functional areas where the commitments should be implemented.
Thus, some commitments would be sent to the wrong department for implementation and a slow feedback process involved would caused delay in commitment implementation and verification.
Programs for Measuring and Test Equipment; Receipt of Material; and Storage, Handling, and Shipping were in place and appeared to require only a few minor changes as new methods of improving operations were discovered. The procurement program was in place but not performing as efficiently as management desired. Work was ongoing to solidify their working procedures.
Operations QA staffing and inspection emphasis during this assessment period was placed on scheduled audits and test surveillance.
Increased emphasis and planning should have been placed on in-line surveillance of maintenance, engineering, and test real-time functions in order to prevent problems before they occur.
Examples of problems that may have been prevented were:
numerous overfills of the reactor vessel during testing; and numerous valves improperly positioned or not correctly restored.
Audit reports appear to be aggressively written and identify numerous specific pogrammatic weaknesses.
However, the audits still declare that the programs are adequate when the findings indicate them to be inadequate. One example of this is a recent
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audit of the maintenance program in which ten specific and serious
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findin'gs could have. resulted in ten separate NRC violations. had 4-they not been identified by the licensee.
Audit actions should exhibit and require more. positive immediate corrective action responses when. serious problems are uncovered.
The violation identified was:
Severity Level IV violation for failure to achieve appropriate corrective _ action on the implementation of a formalized / controlled training / qualification crane operator program for Operations personnel per QA Audit Report No. OP11/16-86/17, dated July 9, l
1986.
(50-424/86-74-03)
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Conclusion Category:
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3.
Board Comments:
The Board is. concerned that _the staffing of the QA operations
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group may become_ inadequate to support the startup and initial I
operation of Unit-1. Management should guard against diluting the
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experience level of the QA Operations Group by transferring QA
personnel to other plant organizations.
H.
Training and Qualification Effectiveness 1.
Analysis
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During the SALP reporting period, four region based inspections were conducted and three site visits for operator license
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examinations were performed.
The inspections were conducted as
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part of the Vogtle Readiness Review Module No. 2, " Operations Training and Qualification."
As a result of the review of the Readiness Review Module No. 2 the staff concluded that training content, quality, and effectiveness
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appeared to be satisfactory with the exception of walkthrough
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training, Technical Specification training, emergency planning
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training, and training for mitigation of core damage.
Also,
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Since Vogtle is an Near Term Operational License (NT0L) plant, none of the training programs were INP0 accredited; however, the i
licensee is scheduled to submit the Accreditation Self-Evaluation Reports for all ten programs over a one year period beginning in
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January 1987.
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Tne licensee currently has an approximately 40,000 square foot traini'ng facility that houses a plant-reference simulator, classrooms, laboratories, and library.
The simulator has been functional since mid-1982 and has undergone numerous hardware changes to keep up with plant design modifications.
The licensee's simulator staff has constructed a remote shutdown panel simulator and is awaiting receipt of a computer system to_make it operational. The NRC has examined and certified approximately 35 Georgia Power instructors (including contractors) on the Vogtle simulator.
The Readiness Review Module No. 2 made the following positive conclusions with respect to the Vogtle training program:
The company's commitment to training was noteworthy and all
employees interviewed were complimentary of the quality of training that they had received.
- With the exception of those specific training areas noted previously, all other areas of training content, quality, and effectiveness appeared satisfactory.
- Efforts toward INP0 accreditation appeared to be progressing satisfactorily.
- Resource allocation for training space, materials, and staffing was considered satisfactory.
The review found several areas to be inadequate but were being corrected by the licensee.
These included:
Some regulatory requirements for operations training and
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qualification were not adequately addressed in the FSAR and module 2.
- Administrative deficiencies existed with training program implementation.
- Training in Technical Specifications and emergency planning appeared to be less than adequate.
The staff also concluded the following training areas to be inadequate and required further resolution:
Walkthrough training and preoperational and hot functional testing participation
Instructor qualifications and requalifications
Training for mitigation of core damage m
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Cold license examinations were administered to operator and senior operator candidates in June, July, and August 1986.
The results of these examinations were as follows:
11 of 20 (55'.') of SR0s passed, and 2 of 11 (18*;) of R0s passed. The overall pass rate of 421; was significantly below the industry average of approximately 75%. The majority of the failures were on the written phase of the examination and a particular weakness was noted in the knowledge and use of Technical Specifications.
The Licensee is ta';i ng action to correct weaknesses.
As a result of these examinations, a management meeting was held with Licensee's representatives in the Region II office in September 1986.
2.
Conclusion Category:
Trend:
Declining 3.
Board Comments:
Licensee resources were not effectively utilized in this area.
This was indicated by the fact that the operator licensing failure rate was higher than the national average. Management's attention to the effectiveness of the training program is highly recom-mended.
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VII. SUPPORTING DATA AND SUMMARIES A.
Licensee Activities Between July 1, 1985 and September 30, 1986 the Unit 1 and common areas construction progressed from 82% to 97%.
Unit 2 construction progressed from 47% to 66%.
Unit 1 is currently scheduled for fuel load on or about the week of December 28, 1986, according to Georgia Power Company's schedule.
Progress in the area turnovers (construction complete) and system turnovers was at a very high rate. The unit construction was essenti-ally completed during this assessment period with an extensive effort to complete the construction testing and preoperational testing programs.
The Unit 2 concrete placements were completed as were the installations of tendons. All major piping has been completed inside of the contain-ment including installation of reactor coolant pumps.
The following major activities were completed:
reactor vessel bottom mounted instrumentation tubing installation; the containment shell pours; reactor vessel integrated head package assembly; reactor cavity liner welding; polar crane load test; partial containment post tensioning; reactor coolant system primary loop pipe welding; containment pipe rack installation; reactor vessel internals initial fit-up; diesel generator building, auxiliary feedwater pumphouse, condensate storage tank pours, condensate storage tank and refueling water storage tank liner plate welding; and safety related piping systems installation and radiographic examinations.
During the SALP period a reorganization occurred which resulted in additional management emphasis being placed on design, construction, preoperational testing and operational readiness.
Specifically, a Senior Vice President was relocated on site as Vogtle Project Manager.
Vice Presidents were also relocated on site in the areas of Engineering and Construction and the former Vogtle Project Vice President and General manager was reassigned as Vice President of Vogtle Project Support.
In addition, a Senior Westinghouse manager was assigned to the site and completion managers for Units 1 and 2 were added to the engineering staff.
GPC has taken a number of initiatives to improve the design program.
Specific examples include modification of certain design organization reporting relationships and reporting procedures to enhance the visibility of engineering items needed to support completion of Unit 1.
- These initiatives include the development and execution of finalization or verification programs such as a hazards walkdown program, a struc-tural load tracking program, a fire protection walkdown program, electrical separation walkdown programs and a seismic separation walkdown progra.
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GPC has developed and executed a major utility readiness review program (VRRP).
Significant resources have been applied to increase the
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assurance that the Vogtle design and construction processes have been
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carried out in a high quality manner and that the plant is ready to operate.in accordance with the requirements.
Senior management attention and participation in project activities was demonstrated, with Vice President level direct participation in such activities as. the daily work status meetings, finalization program execution, critical problem resolutions and the day-to-day oversight of test program restraints.
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In preparation for operation of Unit 1 the following good practices were observed during this assessment period.
Senior Management Involvement, Management Board for Quality Assurance Control, Senior Vice President and three Vice Presidents onsite;. Readiness Review, Quality Concerns, and Fitness for Duty Programs; early staffing.of Operations and Operations QA with their and the involvement in Program Development; QA Initial Test Surveillance Program, QA Operations Audit Matrices, and use of QA to Verify Implementation of Readiness Review, INPO, and NRC Commitments; Licensee's approach in responding to and resolving the intervenors' contentions; establishing the Project Open Item Tracking Systems (PMATS); use of simulator to teach control room discipline and plant operations; operations new organization to plan and support outages; and successful emergency preparedness drill.
In completing Unit I construction and continuing with Unit 2 the licensee implemented the Inspection Attribute Trending Program to identify and recorize individuals or groups excelling in the areas of quality, safety aa#or productivity; prepackaged conduit installation kits to provide be:ter instructions to the craft; implemented consolid-ated computerized Qata base that incorporates all system and area completion items down to the room detail; established a Construction Maintenance Orgnaization (CMO) with responsibility for storage and maintenance of permanent Plant equipment from the time of Site receipt to turnover to Nuclear Operations; and Georgia Power Company also received certificates from ASME for authorization to perform ASME NA, NPT construction activities.
B.
Inspection Activities Sixty-six dual unit regional inspections were conducted during this assessment period.
An additional forty-eight inspections were conducted to support the Vogtle Unit 1 Readiness Review Program and eighteen additional inspections were conducted as part of the regular
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inspection program for Unit 1.
Daily inspections were conducted by the Resident Inspectors, and are documented in ten inspection reports.
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Investigations and Allegation Review There were forty-six allegations cases opened during this SALP period of which eighteen were closed.
The closed cases involved drug abuse, harassment administrative and construction related concerns.
No investigations were conducted during this SALP period.
D.
Escalated Enforcement Actions One item was proposed for escalated enforcement, involving the submittal of accurate information relating to the elimination of pipe whip restraints by use of an alternate pipe break criteria.
The Commission has voted not to issue a violation regarding this issue because the item was not intentional.
E.
Management Conferences Held During Assessment Period August 19, 1985 Present Vogtle Readiness Review Program (VRRP),
Module 2 " Operations Training a id Qualifications" and Module 5 " Operations, Organization and Admini-stration."
August 20, 1985 Brief NRC on QC initiatives with emphasis on electrical construction.
August 27, 1985 Corporate meeting based on Inspection Program Module 30301 B
" Search Corporate Management Meeting".
September 18, 1985 Scheduling and Review of Readiness Review sub-mittals to the NRC.
September 25, 1985 Present additional verification data on VRRP Module 5 " Operations, Organization and Administra-tion."
November 20, 1985 Meeting with local officials of Waynesboro, Georgia and Burke County in Waynesboro, Georgia.
November 25, 1985 Present VRRP Module 8
" Structural Steel,"
Appendix 0
" Document Control" and Appendix
" Material Control".
January 9, 1986 Present VRRP Module 13A "Fourdation Material and Backfill" and Module 16 " Nuclear Steam Supply System."
January 17, 1986 Brief the NRC on VRRP Appendix D " Document Control" and Appendix E " Material Control".
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February 6,1986 Present VRRP Module 7
" Plant Operations and Support."
February 13, 1986 Brief NRC on plant construction status and present inspection program interfaces relative to preopera-tional and operational programs.
February 26, 1986 NRC/GPC assessment of the conduct of the VRRP and discuss activities necessary for timely closure of the program.
March 4, 1986 Present VRRP Module 13B " Coatings", Module 17
" Raceways",
Appendix C,
" Procurement" and Appendix F " Inspector Qualification / Certification."'
March 25, 1986 Present VRRP Module 9A " Radiological Protection",
Module 9B " Chemistry", Module 11 " Pipe Supports",
Module 13C " Post Tensioning," and Appendix G" Measuring and Test Equipment".
April 14, 1986 Present VRRP Module 6 " Electrical Equipment,"
Module 12 " Electrical Cables and Separations",, and Module 19 " Electrical Supports".
May 5, 1986 Present VRRP Modole 18A " Heating, Ventilation and Air Conditioning" and Module 20 " Instrumentation and Controls".
June 23, 1986 Possible Enforcement Action Involving Accuracy of Information Supplied to the NRC.
July 22, 1986 Present VRRP Module 22 " Independent Design Review".
August 12, 1986 Raychem Electrical Splices Briefing.
September 16, 1986 Safe Shutdown and Fire Protection Inspection Methodology and Safe Shutdown Analysis.
F.
Confirmation of Action Letters None.
G.
Review of Construction Deficiency Reports (CDR) and 10 CFR 21 Reports Submitted by the Licensee During this period, 45 potential CORs and no 10 CFR 21 reports were submitted. Six items were in the materials area, 18 items were in the mechanical area,15 items were in the electrical area and 6 items involved design issue,..,
,e
The reports were submitted in a timely manner.
Initial telephone reports provided sufficient information to allow early NRC evaluation.
The licensee's effort to reduce the timeframe from initial notification to final evaluation submittal was noted.
The deficiencies were properly identified, analyzed and corrective actions appeared effective based on NRC inspection followup.
H.
Licensing Activities NRR/ Licensee Meetings Topic July 10-11, 1985 Meeting and site visit with applicant to discuss geothechnical issues.
July 31, 1985 Meeting with applicant to discuss SER Open Item 4, " Toxic Gas evaluation of chemicals."
July 31, 1985 Meeting with applicant to discuss SER Open Item 3, " Containment Sump."
September 11, 1985 Meeting with applicant to discuss SER Open Item 1, " Equipment Qualification" (seismic and pump and valve).
October 16-17, 1985 Meeting with applicant to discuss staff comments on the Emergency Plan (SER Open Item 13).
October 21, 1985 Meeting with applicant to provide guidance regarding the Technical Speci-fications.
December 11, 1985 Meeting with applicant to discuss emergency action levels (SER open item 13).
January 29-30, 1986 Electrical, Instrumentation, and Control Systems Branch site visit.
February 26, 1986 Meeting with applicant to discuss safety parameter display system and detailed control room design review (SER open item 14.)
April 8, 1986 Meeting with applicant to discuss fire damper deviations.
May 27-30, 1986 Meeting with applicant to discuss deviations from the Westinghouse Standard Technical Specification e
..,.,
e -
,
June 4, 1966 Meeting with applicant to discuss
~
arbitrary intermediate pipe breaks (SER open item 15).
June 5, 1986 Meeting with applicant to discuss the instrumentation areas of the Technical Specifications.
June 24-27, 1986 Meeting with applicant to perform a seismic equipment audit and a pump and valve operability audit.
July 23, 1986 Meeting with applicant to discuss design live load criteria.
July 29, 1986 Meeting with applicant to discuss 5ER Open Item 8, " Safe and alternate shutdown capability."
August 27-28, 1986 Meeting with applicant to discuss main steamline break outside of containment.
September 9-11, 1986 Meeting of applicant at site to review proposed organization of Vogtle.
September 9-11, 1986 Meeting of applicant at site to audit documentation & installation of selected piece of equipment.
September 17-18, 1986 Meeting of applicant at site for pre-implementation audit of DCRDR.
September 23, 1986 Meeting of applicant to discuss fire protection.
I.
Enforcement Activity Functional No. of No. of Violations Area Deviations in each Severity Level I
II III IV V
Units 1 and 2 Construction Soils and Foundations None Containment and Other None Safety-Related Structures, and Major Steel Support Piping Systems and Supports
1
1
,
. s..
w.*'
Safety Related Components-
1 Mechanica'l Systems Auxiliary Systems
2 Electrical Equipment
and Cable Instrumentation
1 Quality Programs and
4 Administrative Controls Independent Design Review None Unit 1 Preoperational Testing
Unit 1 Operations Operational Readiness None Radiological Controls /
None Chemistry Maintenance
Fire Protection
Emergency Preparedness None Physical Security / Material None Control and Accountability Quality Programs anc
Administrative Controls
[0perations]
Training and Qualification None Effectiveness
0
1
8