IR 05000424/1986089
| ML20213G809 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/29/1986 |
| From: | Belisle G, Moore L, Shannon M, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20213G794 | List: |
| References | |
| 50-424-86-89, NUDOCS 8611180350 | |
| Download: ML20213G809 (18) | |
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p2 raig UNITED STATES
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'o NUCLEAR REGULATORY COMMISSION
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REGION 11 p
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101 MARIETTA STREET, N.W.
ATLANTA. GEORGI A 30323
'+9 *.. +,o Report No.:
50-424/86-89 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424 License No.:
CPPR-108
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Facility Name: Vogtle 1 Inspection Conducted:
September 22-26, 1986 Inspectors:
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. Smith V Date Si@rfed
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M. C. Shannon Date Si'gned Approved by:
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G. A. Belisle, S& tion Chief Da'te igned Quality Assurance Programs Section Division of Reactor Safety SUMMARY Scope:
This routine, unannounced -inspection was conducted in the areas of measuring and test equipment (M&TE), records, document control, design control, tests and experiments, pre-operational testing quality assurance (QA), and pre-operational test records.
Results:
No violations or deviations were identified.
8611180350 861105 PDR ADOCK 05000424 PDR G
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REPORT DETAILS
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Persons Contacted
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Licensee Employees
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J. Ballehtina,, Consultant
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- R. Bellamy;~M;qager, Test and Outage
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- C. Bellflower, QA Site Manager (Operations)
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- P. Bemis, Manager, Engine 6 ring
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- J. Blocker, PSS
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- G. Bockhold, Jr., General Manager Vogtle Nuclear Operations G. Burke, Senior QA Field Representative
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- R. Conway, Senior Vice President, Vogtle Electrid Generating Plant (VEGP)
C. Corsey, superintendent, Maintenance (Much/ Elect.)
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- C. Cross,< Senior Regulatory Specialist
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J. Curtis, United Energy Services Corp / Georgia Power Corporation Engineering J. D' Amic6, Regulatory Compliance Superintendent
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C. Davis, Senior QA Field Represeitative
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- M. Durban, Quality Control Supervisor
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D. Fiquett,, Unit #II, Field Construction Manager
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- S. Haltoni Quality Assurance Engineering Support Supervisor
- C. Hayes, Vogtle QA Manager (VQAM)
M. Hobbs, Measuring and Test Equipment Supervisor:(Maint/ Elect.)
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S. Kitchens', Manager, Operations
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R. Lide, Nuclear Operations Engineering
- F. Marsh, Pro.iect Engineering Manage ~r - B6chtel
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- G. McCarley, Project Compliance CoordinaCLr '
- R. McManus, Assistant Project Construction Manager II, (APCM II)
- A. Mosbaugh, Superintendent, Engineering Services-
- R. Pinson, Vice President, Const'chction
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B. Qufck, Decument Contiol Supervisor
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P. Ricd, Vice President, Project;Enginee ing L. Rutsel, Operations Procedure supervisor
- J. Sanders, Assistant Project Cons'ruction Manager (APCM II)
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G. Spell, QA Engineering Support Supervis'ar
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- R. Spinnato,dndependent Safety Evaluation Group Supervisor
- H. Swain, Mechanical Quality Control Section Supervisor Constructio6.
W. Wagner, Quality Controb Superintendent - Georgia Power Corporation'
Nuclear Operations
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L. Zechner, Senior Regulatory Specialist-'
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NRC'P3sident Inspectors
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J. Rogge, Senner Resident Inspector H., Live 6nore
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Exit Interview
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The - inspection scope and findings were summarized on September 26, 1986,
with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the _ licensee.
The
licensee did not identify as proprietary any of the materials provided to or j
' reviewed by the inspectors during this inspection.
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Inspector Followup Item, Revise' Lower-Tier M&TE Procedures to Require
National Bureau of Standards (NBS) Documentation, paragraph 5 Inspector Followup Item, Assignment of Administrative Responsibility For Temporary Change Procedure, paragraph 7.
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Inspector Followup Item, Corporate Design Change Manual, paragraph 8.
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Inspector Followup Item, Design Change Implementing Procedures, paragraph 8.
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Inspector Followup Item, Changes to Temporary Design Change Packages, paragraph 8.
Inspector Followup Item, Revise upper-tier and lower-tier QA program
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documents, paragraph 10.
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Licensee Action on Previous Enforcement Matters N
This subject was not addressed in the inspection.
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Unresolved Items s
.o Unresolved items were not identified during the inspection.
5.
Measuring and Test Equipment (M&TE) Program (35750)
References a.
10 CFR 50.54(a)(1), Conditions of Licenses b.
10 CFR 50, Appendix 8, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants c.
Vogtle Electric Generating Plant (VEGP) Final Safety Analysis Report, Amendment 19 d.
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
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ANSI 18.7-1976, Administrative Controls and Quality Assurance for the Operations Phase of Nuclear Power Plants s
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Regulatory Guide 1.30, Quality Assurance Requirements
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for the Installation, Inspection, and Testing of
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Instrumentation and Electrical Equipment
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ANSI N45.2.4-1972, IEEE Standard, Installation, Inspection and Testing Requirements for Instrumentation
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and Electrical Equipment During the Construction of Nuclear Power Generating Stations The inspector reviewed the M&TE program required by references (a) through
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(g) to determine if the ' program had been established in accordance with regulatory, requirements and industry guides and standards.
The following criteria were used during this review to determine the overall acceptability of the program being established:
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l Responsibility was ' delegated and criteria established to assign and
,g adjust calibration frequency for each type of M&TE.
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An equipment inventory list identified the reference standard and
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i location of each item of M&TE.
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Formal requirements exisbd for marking the latest calibration data on in Y
each piece of equipment.
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,The program required that each piece of equipment was calibrated on or before the date specified or stored in a location separate from inservice M&TE.
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Written requirements prohibited the use of MT&E which had not been
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calibrated within the prescribed frequency.
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When M&TE was,found out of calibration, tile program required documented evaluations to determine the cause of the out-of-calibration condition and the acceptability of items previously tested.
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The program assured that new M&TE was added to the inventory lists and calibrated prior to use.
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The documents listed below were reviewed to determine if these criteria had been incorporated into the'M&TE program:
00208-C Control of Measuring and Test Equip.nent, Revision 2
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20230-C Control of Instrument Shop Measuring and Test Equipment
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Revision 4
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20405-C Control of Maintenance Shop Measuring and Test Equipment, Revision 5 31025-C-Control of Chemistry Measuring and Test Equipment, Revision 0 43500-C Health Physics Instrument Calibration and Control Program, Revision 2 The inspector noted that installed process instrumentation used to verify Technical Specification (TS) requirements were not controlled by the M&TE calibration program. Discussion with the licensee indicated that controls for this equipment were provided within the surveillance program. Purchase of calibration services by approved vendors was provided by controls in the site Procurement Manual.
Chapter 5 of this manual designated calibration services of M&TE as level PL-3 and PL-4.
Chapter 8 of this manual required level PL 1-4 items or services be selected from the Georgia Power Company Qualified Suppliers List (QSL). The inspector reviewed a sample of M&TE calibration procedures to verify the adequacy of these instructions to provide guidance for calibration. The procedures provided sufficient detail to perform the calibration and listed applicable reference standards and data sheets to document the calibration performance.
Within this area, one inspector followup item was identified.
i ANSI N45.2.4-1972 requires documentation of traceability of calibrating equipment to the NBS or the basis for calibration. The licensee upper-tier documents, FSAR and QA manual reflected this requirement.
However, the lower-tier implementing procedures express this provision as a recommen-dation -(should instead of shall).
Until these lower-tier documents are revised to state this traceability item as a requirement, this item will be identified as Inspector Followup Item 424/86-89-01, Revise lower-tier M&TE Procedures, to require documentation of National Bureau of Standards (NBS)
traceability.
6.
Records (35748)
References a.
10 CFR 50.54(a)(1), Conditions of Licenses b.
FSAR Section 17, Quality Assurance Program, Amendment 8 c.
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants d.
Regulatory Guide 1.33, Quality Assurance Program Requirements e.
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operations Phase of Nuclear Power Plants-
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Regulatory Guide 1.88, Collection, Storage -and Maintenance of QA Records for Nuclear Power Plants g.
ANSI N45.2.9-1974, Requirements for Collection, Storage and Maintenance of QA Records for Nuclear Power Plants h.
VEGP Quality Assurance Manual, Section 17, Revision 9 The inspector reviewed the licensee's administrative program for the collection, storage, and maintenance of records required by references (a)
through (h) to determine if the administrative controls were in accordance with regulatory requirements and industry guides and standards.
The following criteria were used during the review to determine the overall acceptability of the established program:
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Responsibilities had been assigned to assure that records will be maintained and that the retention periods for records had been specified.
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Records storage controls had been established which accomplish the following:
Define the record storage locations.
Designate a custodian (s) in charge of records storage.
Describe a filing system (s) to be used to allow for records retrieval.
Establish a method for verifying that records received for storage are in agreement with any attendant transmittal document.
Make provisions for governing access to files and for maintaining an accountability of records removed from.the storage facility.
Establish methods for filing supplemental information and establishing required review and approval prior to disposing of superseded records.
The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedure for records control.
00100-C Quality Assurance Records, Administration, Revision 4 70402-C Nuclear Operating Records Management System, Revision 1 The records program and associated hardware were in place and appeared to meet regulatory requirements. The inspector toured the records vault to verify compliance with ANSI N45.2.9-1974, Section 5.6.
The vault appeared to ivieet all requirements. The Nuclear Operations Records Mariageirierit System
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was demonstrated for the inspector. This computer data base system met ANSI requirements for identifying record location and retention' periods.
Record retrievability with the system appeared simple and reliable, provided initial data input was accurate.
Within this area, no violations or deviations were identified.
7.
Document Control (35742)
References a.
10 CFR 50.54(a)(1), Conditions of Licenses b.
Vogtle Electric Generating Plant (VEGP) FSAR Chapter 17, Quality Assurance Program, Amendment 8 c.
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants d.
Regulatory Guide 1.33, Quality Assurance Program Requirements e.
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants f.
Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records g.
ANSI N45.2.9-1974, Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants h.
VEGP Quality Assurance Manual, Section 6, Revision 9 The inspector reviewed the licensee's document control program required by references (a) through (h) to determine if the program had been established in accordance with regulatory requirements and industry guides and standards.
The following criteria were used during this review to determine the overall acceptability of the established program:
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Administrative controls had been established for drawing issuance, drawing change review, obsolete drawing control, and as-constructed and as-built drawing updating.
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Administrative controls had been established for maintenance of indices for drawings, manuals, FSARs, and procedures.
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Administrative controls had been established which assign specific responsibilities for drawing and document control programs.
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Administrative controls had been established which designate responsibilities, specific time periods for use, and adequate evaluation and review of temporary procedures.
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Administrative controls had been established for temporary changes to procedures.
The following documents were reviewed to determine if these criteria had
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been incorporate into the licensee's QA program for document controls:
00050-C Procedure Development, Revision 5 Approval, Revision 4 00051-C Procedures Review and Approval, Revision 4 00052-C Temporary Changes to Procedures, Revision 2 00053-C Temporary Procedures, Revision 0 00101-C Drawing Control, Revision 2 00103-C Document Distribution and Control, Revision 0 00108-C Control, Review, Approval and Use of Vendor Manuals and Revisions, Revision 3 The inspector reviewed data provided by the Nuclear Operation Record Management System (NORMS) to verify the listing of procedures, drawings and vendor manuals which included current revision status.
Controlled drawing locations were indicated on a master distribution list. A weekly update verification of drawings was required for work in progress.
Within this area, one inspector followup item was identified.
Procedure No. 00052-C was identified by the licensee as inadequate for controlling temporary changes to procedures.
Audit Finding Report (AFR)
No. OP18/19-86/15 #38-II documented this finding by the licensee QA group.
Due to the lack of a central responsibility for administration of temporary changes, numerous administrative errors were identified in this program.
Until corrective action for this audit finding is complete such that proceudre no. 00052-C is revised to establish a central administrative control for temporary changes to procedures, this item will be identified as Inspector Followup Item 424/66-89-02.
8.
Design Control (35744)
References a.
10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, Criterion III b.
10 CFR 50.59, Changes, Tests and Experiments
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ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants.
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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
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Regulatory Guide 1.33, Quality Assurance Requirements (Operations)
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Technical Specifications, Section 6.5 g.
Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants.
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FSAR, Section 17, Quality Assurance Program, Amendment 8 i.
VEGP Quality Assurance Manual, Section 3, Revision 9 The inspector reviewed the licensee's design change program required by references (a) through (i) to determine if these activities were conducted in accordance with regulatory requirements, industry guides and standards and Technical Specifications.
The following criteria were used during the review to determine the overall acceptability of the established program:
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Procedures have been established to control design changes which include assurance that a proposed change does not involve an unreviewed safety question or cFange in Technical Specifications as required by 10 CFR 50.59.
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Procedures and responsibilities for design control have been established including responsibilities and methods for conducting safety evaluations.
Administrative controls for design document control have been
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established for the following:
Controlling changes to approved design change documents Release distribution of approved design change documents
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Administrative controls and responsibilities have been established commensurate with the time frame for implementation to assure that design changes will be incorporated into:
Plant procedures Operator training programs Plant drawings to reflect implemented design changes and modifications
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Design controls require that implementation will be in accordance with approved procedures.
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Design controls require assigning responsibility for identifying post-modification testing requirements and acceptance criteria in approved test procedures and for evaluation of test results.
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Procedures assign responsibility to delineate the method for reporting design changes to the NRC in accordance with 10 CFR 50.59.
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Controls require review and approval of temporary modifications in accordance with Section 6 of the Technical Specifications and 10 CFR 50.59.
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Controls require that a formal record be maintained of the status of temporary modi fication s, lifted leads and jumpers, temporary trip points of control equip., etc.
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Controls require evaluation of tha need for independent verification.
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Controls required periodic reviews of lifted lead and jumper records.
The documents listed below were reviewed to verify that these criteria had been incorporated into the licensee design program:
Vogtle Electric Generating Plant, Quality Assurance Manual, Section 3, Revision 9.
00400-C Plant Modifications, Revision 0 00001-C Plant Organization and Managerial Staff Responsibilities and Authority Revision 0 00002-C Plant Review Board - Duties and Responsibilities, Revision 4 50005-C Requests for Engineering Assistance, Revision 0 50002-C Processing Requests for Engineering Reviews, Revision 2 00051-C Procedures Review and Approval Revision 4 00402-C Licensing Document Change Request, Revision 1 00101-C Drawing Control, Revision 2 00100-C Quality Assurance Records Administration, Revision 4 00350-C Maintenance Program, Revision 2 00307-C Temporary Modifications, Revision 0
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00052-C Temporary Changes to Procedures, Revision 2 00306-C Temporary Jumper and Lifted Wire Control, Revision 2 00056-C Safety Evaluation, Revision 0 The inspector requested and reviewed documents related to the design change process.
The responsibilities of organizations and individuals directly related to design changes are detailed in Procedure 00400-C.
This procedure also referenses those other procedures that are required to implement a plant design change.
At the time of the inspection, the inspector found that the Corporate Design Change Manual was being revised.
The revision has a major impact on the site design change program in that the individual implementing procedures must now be revised in order to incorporate the changes in the Corporate Design Change Manual. The revised Corporate Design Change Manual should be released on or about the week of October 20, 1986.
Plant personnel are planning for the design change program to be in place shortly af ter the corporate manual is released. The plant staff has agreed to supply, NRC, Region II, with a schedule for program completion.
The inspector conducted interviews with member of the licensee engineering staff. The members were very knowledgeable of the design change program and its requirements.
Within this area, three inspector followup items were identified and are discussed in the following paragraphs:
a.
The Corporate Design Change Manual Was Not Available for Review.
The Corporate Design Change Manual was being revised and not available for review. The manual will need to be reviewed for responsibilities, approval, interfaces, control of design input, channels of communi-cation, making changes to previously approved packages, controls for implementing design packages per approved procedures, controls for post modification acceptance testing, evaluation test results, restoration of system on a cancelled DCR, and for documentation of verbal approval for changes in a design package during off normal hours.
Until the corporated manual can be reviewed to assure these items are fully delineated, this item is identified as Inspector Follow Item 424/86-89-03.
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Design Change Implementing Procedures Were Not Available or Approved Due to the revision of the Corporate Design Change Manual, the plant design change procedures were also being revised.
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(1) Procedure 50006-C, for a method of initiating a design change request and responsibilities and methods for performing reviews,
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evaluations and approvals.
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(2) Procedure 50007-C, for a documented safety review and the responsibilities and methods for performing an independent design verification.
(3) Procedure 50008-C, for distribution of approved ' design change documents, responsibilities, documentation and approvals, and a process to control field changes to approved DCR packages.
(4) Procedure 50009-C, for controls and responsibilities for updating plant drawings for as-built conditions and a process for cancelling an as-built notice.
(5) Procedure 50010-C, for the same items as listed in "A" for
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corporate design changes manual.
The review items listed above 'are a minimum.
Further review may be necessary depending upon procedure content. Until these procedures can be reviewed, this item is identified as Inspector Followup Item
424/86-89-04.
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Changes to Approved Design Change Packages Procedure 00307-C, step 4.3.3 stated that if the temporary modification
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malfunctions, correct the malfunction.
The procedure needs to be
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revised because tt does not show the requirement for documenting changes to approved packages and it does not show the requirements for
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i reviews and approvals at the same level as the original temporary
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modification package.
Until this procedure is revised, this item is identified as Inspector Followup Item 424/86-89-05.
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9.
Tests and Experiments (35749 B)
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References a.
10 CFR 50 Appendix B, Quality Assurance Criteria for
Nucelar Power Plants and Fuel Reprocessing Plants b.
10 CFR 50.59 Changes, Tests and Experiments I
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Regulatory Guide 1.33, Quality Assurance Requirements
(Operations)
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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power
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Plants
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ANSI N45.2.8-1975, Supplementary Quality Assurance Requirements i
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FSAR, Section 17, Quality Assurance Program, Amendment 8 g.
FSAR, SEction 14, Startup Test Procedures, Amendment 15 h.
VEGP Quality Assurance Manual Section 2, Revision 9 The inspector reviewed the licensee's tests and experiments program required by references (a) through (h) to determine if the program was in conformance with regulatory requirements and industry guides and standards.
The following criteria were used during this review to assess the overall acceptability of the established program.
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A formal method has been established to handle all requests or proposals for conducting plant tests involving safety-related components.
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Provisions have been made to assure that all tests will be performed in accordance with approved written procedures.
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Responsibilities have been assigned for reviewing and approving test procedures.
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A formal system, including assignment of responsibility, has been established to assure that all proposed tests will be reviewed to determine whetiier they are as described in the FSAR.
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Responsibilities have been assigned to assure that a written safety evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specifications.
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Responsibilities have been assigned to assure that all test and experiments are reported as required by applicable guidelines and instructions.
The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's tests and experiments program.
Vogtle Electric Generating Plant, Quality Assurance Manual,Section II, Revision 9.
FSAR Chapter 14.2, Initial Test Program 50014-C Test or Experiment Request, Revision 0, 00053-C Temporary Procedures, Revision 0 50005-C Requests for Engineering Assistance, Revision 0.
50002-C Processing Requests for Engineering Reviews, Revision.
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0002-C Plant Review Board-Duties and Responsibilities, Revision 4.
00056-C Safety Evaluations, Revision 0.
00100-C Quality Assurance Records Administration, Revision 4.
00157-C Routine Annual Reports, Revision 0.
SUA-1 Startup Test Procedure Preparation Review, Approval and Revision, Revision 1.
The inspector reviewed documents related to the tests and experiments program. The program was in place and approved. The program appeared to be acceptable as it was established and documented.
Startup test procedures are channeled through the tests and experiments program for review and approval after they go through the startup review and approval program.
The inspector conducted interviews with members of the licensee engineering staff and operations management. These personnel were knowledgeable of the test and experiments program and its requirements.
They were also knowledgeable of the difference between the startup test program, as listed in the FSAR section 14, and the test and experiments program.
Within this area, no violations or deviations were identified.
10.
Peroperational Testing Quality Assurance (35301)
References a.
10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants b.
Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction)
c.
ANSI N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants d.
FSAR, Section 17.1, Quality Assurance during Design and Construction, Amendment 8 e.
Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants f.
ANSI N45.2.12-1977, Auditing of Quality Assurance Program g.
Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel h.
ANSI /ASME N45.2.23-1978, Qualification of Quality Assurance Audit Personnel for Nuclear Power Plants
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Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination and testing Personnel.
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ANSI N45.2.6-1978, Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants.
The inspector reviewed the licensee's QA program required by reference (a)
through (j) to determine if the program had been developed in accordance with regulatory requirements, industry guides and standards, and proposed Technical Specifications.
The following criteria were used during this review to assess the overall acceptability of the program.
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Procedures have been developed to conduct audits and surveillanca of licensed activities.
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Responsible management personnel have been assigned authorities and responsibilities to implement the QA program.
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Management has knowledge of the QA program and understand their responsibilities.
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Minimum qualifications and training requirements have been developed for QA personnel.
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Systems for handling deficiencies have been established and are functioning.
The following documents were reviewed to determine if the above criteria had been incorporated into the licensee's QA program.
SUM-1 Start-up Manual Introduction and Control, Revision 5 SUM-3 Preoperational Test Program Organization, Responsibilities and Interfaces, Revision 3 SUM-9 System Turnover, Revision 11 SUM-12C Preoperational Test Implementation, Revision 3 SUM-13 Preoperational and Acceptance Test Procedure, Preparation, Review and Approval, Revision 9 SUM-14 Release to Operations, Revision 1 SUM-24 Initial Test Program Personnel Certification, Revision 6 QA-01-01 Organization and Responsibilities of the QA Department, Revision 11
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QA-04-02 Significant Deficiency / Defect Reporting - (10 CFR 50.55(e)/
10 CFR 21), Revision 9 QA-03-05 Qualification of Auditors, Revision 5 QA-03-02 Training and Personnel Qualification, Revision 13 QA-05-01 Field Audits, Revision 15 QA-05-17, QA Surveillance, Revision 2 85000-C Quality Control Organizations, Responsibility, and Conduct of Operations, Revision 2.
00201-C Quality Control Inspection Program, Revision 3.
FSAR Section 17.1 describes the Quality Assurance program during design and construction and establishs licensee commitments for conduct of the preoperational test phase of the initial test program (ITP).
The organizations and administrative controls under which the ITP was accomplished is further described in the start-up manual (SUM).
This document identifies the major activities within the bounds of '.he ITP and assigns responsibilities for the conduct of these activities to specific management organization.
The initial test program consists of the following sub programs which have different administrative controls:
Preoperational test Phase consisting of:
Construction Acceptance Tests System Flushing (including chemical cleaning)
HVAC Balancing Preoperational Testing Start-Up Test Phase cor.3. sting of:
Initial Fuel Loading Precritical Tests Initial Criticality Low Power Testing l
Power Ascension
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The preoperational test phase begins with the turnover of a system, subsystem, or component from construction to nuclear operations.
Administrative control of activities during this phase is delineated in the SUM and plant administrative procedures when referenced in the SUM.
QA program management during preoperational testirg is assigned to the nuclear operations QA department.
The inspector conducted interviews with personnel from the site QA organization to ascertain the degree of their
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involvement in preoperational test activities. The following documents were reviewed in connection with this effort.
Audit No.:
TP05-86/03 Audit Date:
February 20 through March 17, 1986 Activity:
QA Audit of Primary Hydrostatic Test Activities Audit No.:
TP01/02/03/05-85/02 Audit Date:
February 11 through 22, 1985 Activity:
QA Audit of Initial Test Program Activities Audit No.:
TP05-85/07 Audit Date:
November 11, 1985 through January 23, 1986 Activity:
QA Audit of the Preoperational Test Program Audit No.:
TP01/02-85/05 Audit Date:
June 4, through 27, 1985 Activity:
Audit of System / Component Turnover and Nuclear Operations Maintenance Practices Audit No.:
TP01-85/01 Audit Date:
January 15-28, 1985 Activity:
QA Compliance Audit of Training Activities in Support of the Initial Test Program Audit Schedule, Calender year 1935 plus six months.
Audit Schedule, Calender year 1986 plus six months.
QA Surveillance Log.
The inspector determined that planned and scheduled audits of preoperational tests activities have been conducted by the nuclear operations QA site group.
Surveillances of ongoing test activities were also conducted to assure compliance with the QA program requirements. Deficiencies identified during the conduct of audits or surveillances were dispositioned by appropriate corrective action implementation.
The organization structure, functional responsibilities, level of authority, and lines of internal and external interfaces were clearly delineated in writing for the nuclear operation QA site group. A review of the training folders of five operations QA personnel revealed that all five were certified lead auditors (qualified to ANSI N45.2.23-1978). Based on reviews of QA program documents and interviews with QA staf f members, the licensee preoperational Quality Assurance program appears to be adequate.
Quality verification activities have been assigned to the QC Superintendent who is responsible for developing and implementing a quality control inspection and monitoring program. This organization was previously part of Regulatory Compliance, but has most recently been a>>tyned to the Engineering Support organization. Pursuant to the reorganization of Nuclear
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Additional changes to program implementing procedures are anticipated as enhancement to the QC inspection program occurs.
The inspector determined that licensee management is committed to ensure that all QC personnel have completed initial training by fuel load date.
Discussions concerning the status of the QC inspector's training were conducted with Licensee Management. Objective evidence of the progress made to date for training QC inspectors was presented by licensee management in the form of computer printout sheets and graphs.
Licensee management further stated that QC inspectors are qualified to ANSI N45.2.6-1978, at
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levels 2 and 3.
Active participation of operations QC in the preoperational test activities is required by the SUM. The inspection program provides for the development of inspection plans, inspection procedures, and implementation of a QC inspection program during preoperational test activities. The inspector determined that the nuclear operations QC scope of activities for preoperational tests entailed inspections of all nuclear safety related systems.
The organizational change in'volving nuclear operations QC is but a small part of a major reorganization of Nuclear Operations that became effective September 29, 1986.
Dursuant to this reorganization, licensee upper-tier operations QA program documents (FSAR Chapter 17.2 and FSAR Chapter 13.1)
need to be revised. Additionally, FSAR Chapters 13.2, 14.0 and 17.1 need to be reviewed to ensure consistency with changes to the other documents. The plant administrative procedures need to be revised, and similarly Department level procedures need to be reviewed to assess the scope of the changes required by these documents.
The SUM, which is the quality implementing program document for FSAR 17.1, construction QA, must also be revised to ensure adequate implementation of the construction QA program requirements for toe Construction Permit (CP) phase of Unit 2.
The major and significant changes to the accepted QA programs caused by the reorganization of Nuclear Operations was discussed with licensee management.
At the time of the inspection (9/22-26/86), firm plans had not been developed to ensure a smooth transition and continuation of the QA program requirements during this reorganizational change. At the exit interview, the inspector requested and licensee management verbally committed to provide
the NRC a schedule with established milestone dates for accomplishing
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changes to all upper-tier and lower-tier program documents.
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Within this area one Inspector Followup Item was identified.
On September 29, 1986, a reorganization of Nuclear Operations resulted in changes to Chapter 17.2, and 13.1 of the FSAR. Other sections of the FSAR, the SUM, plant administrative procedures, and departmental level procedures need to be reviewed and revised to incorporate the above organizational changes. Until all upper-tier and lower-tier QA program documents have been revised to reflect these changes, this is identified as Inspector Followup Item 424/86-89-06.
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11.
Preoperational Test Records (39301)
References a.
10 CFR 50.54(a)(a) Conditions of License b.
FSAR, Section 17.1.17, Quality Assurance Records, Amendment 8 c.
10 CFR 50, Appendix B, Quality Assurance Criteria for l
Nuclear Power Plant and Fuel Reprocessing Plants.
d.
Regulatory Guide 1.33, Quality Assurance Program Requirements.
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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operation Phase of Nuclear Power Plants.
f.
Regulatory Guide 1.88, Collection Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records, g.
ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants.
The inspector reviewed the licensee's administrative controls for records generated during the preoperational test program as well as other records required by references (a) through (g) to determine if administrative controls were in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during the review:
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Administrative controls have been established for maintaining records
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for the following types of activities during the preoperational testing period:
Preoperational test procedures and results Corrective and preventive maintenance QA/QC audit and surveillance personnel training Personnel qualification Design changes and modifications Component, systems, and structure turnover Responsibilities have been assigned to assure that the records
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identified above will be maintained and the retention periods have been specified.
Record storage controls have been established which accomplish the following:
Def1ne the record storage locations for the types of records identified above.
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Designate a custodian (s) in charge of storage of each class of records.
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Describe the filing system (s) to be used to allow for the retrieval of records.
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Establish a method for verifying that records received for storage are in agreement with any attendant transmittal documents.
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Make provisions for governing access to files and for maintaining an accountability of records removed from the storage facility.
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Establish methods for filing supplemental information and disposing of superseded records.
The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedures for records control:
VEGP Quality Assurance Manual, Section 17, Revision 9 SUM-9 System Turnover, Revision 11 SUM-12C Preoperational Test Implementation, Revision 3 SUM-13 Preoperational and Acceptance Test Procedure Preparation, Review and Approval, Revision 9 SUM-14 Release to Operations, Revision 1 00100-C Quality Assurance Records Administration, Revision 4 00103-C Document Distribution and Control, Revision 0 00101-C Drawing Control, Revision 2 Licensee commitmen+ s regarding the generation, storage and protection of pre-operation test racords are delineated in FSAR Chapter 17.1.17.
Responsibility for r ' operational test records administration has been assigned to Nuclear Operations Document Control, and is performed in accordance with the requirements of VEGP plant procedures.
Based on a review of the listed program documents it appears that adequate administrative controls have been established for ITP QA records.
Within this area no violations or deviations were identified.
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