IR 05000424/1986096

Insp Rept 50-424/86-96 on 861006-10.No Violation or Deviation Noted.Major Areas Inspected:Qa Program Audits, Surveillance Testing & Calibr Control,Procurement Control, Receipt,Storage & Handling of Equipment & Matls

ML20214K697
Person / Time
Site:	Vogtle
Issue date:	11/13/1986
From:	Belisle G, Moore L, Shannon M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214K684	List: IR 05000424/1986096 ML20214K682
References
50-424-86-96, NUDOCS 8612020417
Download: ML20214K697 (13)

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UNITED STATES .

._ [A MI o NUCLEAR REGULATORY COMMISSION j" , REG!ON11 3 j 101 MARIETTA STREET. * 2 ATL ANTA, GEORGI A 30323

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Report No.: 50-424/86-96

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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 .

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Inspect 1on Conducted: October 6-10, 1986 Inspectorsi / OEC / // &b L. R. Moo're Da'te Signed

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M. C. Shannon Date Signed Approved by: b Fk 65 G. A. Belisle, Sdttion Chief

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[h Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of quality assurance (QA) program audits; surveillance testing and calibration control; procurement control; and receipt, storage and handling of equipment and material >

Results: No violations or deviations were identified.

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• REPORT DETAILS Persons Contacted Licensee Employees J. Agold, Supervisor, Southern Company Service (SCS)

E. Barns, Contract Engineer

• C. Belflower, Manager, QA Site Operations

• A. Boatwell, Instrumentation and Control (I&C) Supervisor

• G. Bockhold, General Manager Vogtle Nuclear Operations J. Bowden, Surveillance Tracking Coordinator

• A. Caudill, Senior Plant Engineer

• W. Copeland, Plant Engineering Supervisor, Procurement

• J. D' Amico, Nuclear Safety and Compliance (NSAC), Manager P. Farrow, Procedure Coordinator

• W. Gabbard, Senior Regulatory Specialist G. Gray, Material Superintendent

• J. Hartka, Senior Nuclear Engineer J. Hurdi, Deputy Manager H. James, Engineering Supervisor, Maintenance

• H Jaynes, Plant Engineering Supervisor R. Kuester, Manager, Project Field Engineering Operations (PFEO)

G. Lee, Operations Supervisor S. Lee, Senior Plant Engineer

• C. Miller, Superintendent, Outage Planning

• A. Mosbaugh, Assistant Support Manager

• Mundy, GA Audit Supervisor J. Petro, Sanior QA Field Representative K. Pointer, NSAC Specialist M. Sheibani, NSAC Specialist

• J. Satphin, I&C Supervisor

• H. Varnadoe, Plant Engineering Supervisor R. Walker, QA Engineer W. Wayner, Quality Control (QC) Superintendent

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Other licensee cmployees contacted included construction craftsmen,

engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspector J. Rogge, SRI

• Attended exit interview i

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2 Exit Interview The inspection scope and findings were summarized on October 10, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio Inspector Followup Item, Master Surveillance Schedule Incomplete, paragraph Inspector Followup Item, Scheduling and Tracking Procedure Incomplete .

paragraph 5 Inspector Followup Item, Surveillance Internal Monitoring Inadequate, paragraph Inspector Followup Item, Surveillance Data Trending and Evaluation Procedure Incomplete, paragraph Inspector Followup Item, Surveillance Procedures Incomplete, para-graph . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during the inspectio . Surveillance Testing And Calibration Control (35745B)

References (a) 10 CFR 50.55a, Codes and Standards (b) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (c) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(d) VEGP-FSAR-Section 17.2.14, Inspection, Testing, and Operating Status, Amendment 8 (e) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

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The inspector reviewed the licensee's surveillance testing and calibration control program required by references (a) through (e) to determine if the program had been established in accordance with regulatory requirements, industry guides and standards, and technical specifications. The following criteria were used during this review to determine the overall acceptability of the established program:

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The master schedule for surveillance testing and calibration control delineated test frequency, current status, and responsibilities for performanc The master schedule reflected the latest revisions of the Technical Specifications (TS) and operating licens Responsibilities were assigned to maintain the master schedule up-to-date and to ensure that required tests are performe Detailed procedures with appropriate acceptance criteria were approved for all surveillance testing requirement The program defined responsibilities for the evaluation of surveillance test data as well as the method of reporting deficiencies and malfunc-tion Requirements were established for calibration of safety-related component Responsib111 ties were assigned to maintain, approve, perform and review the calibration program for safety related component he documents listed below were reviewed to determine if these criteria were t

incorporated into surveillance testing and calibration control program activities:

00404-C Surveillance Test Program, Rev. 1 00411-C Preservice and Inservice Inspection Program, Rev. 1 L 00412-C Preservice and Inservice Testing Program, Rev. 1

00405-C Commitment Identification, Tracking and Implementation,

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14000-1 Operations Shift and Daily Surveillance Logs, Rev. 0 20015-C Planned Maintenance, Rev. 4 20100-C ASME Section XI Repair / Replacement Program, Rev. 1 00150-C Deficiency Reports, Rev. O i

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24563-1 Reactor Cavity Sump level IL-7778 Channel Calibration, Rev. 1 24716-1 Steam Generator Blowdown Pipe Break Room Protection... Test and Channel Calibration, Rev. 1 14806-1 Containment Spray Pump and Check Valves Inservice Test, Rev. 0 14803-1 CCW Pumps and Discharge Check Valves Inservice Test, Rev. 0 QA Audit of Surveillance and Technical Specification Compliance OP09-86-27, August 29, 1986 The inspector requested and reviewed documents of the various programs related to surveillance testing and calibration control. The inspector also interviewed various members of plant staff about specific surveillance and calibration program The regulatory compliance group has responsibility for surveillance tracking for items with frequencies greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. They are also responsible for maintaining a surveillance matrix schedule computer program and two hard copy matrices. They are also responsible for distribution and retrieval of surveillance task sheets on a daily basi The surveillance tracking program has minor problems in that not all of the identified technical specifications surveillances have been incorporated into the surveillance matrix. Additionally, Procedure 80012-C, Surveillance Test Scheduling and Tracking System, which is the implementing procedure for the program, has not yet been approve The surveillance tracking program does not appear to have adequate controls in place that would prevent exceeding the 3.25 surveillance interval and the program does not have adequate controls for shorter surveillance intervals because it does not account for actual time in hours and minute Procedure 14000-1, Operations Shift and Daily Surveillance Logs, insures that TS surveillances, less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, are completed. The procedure is approved and appears to be adequat Various departments were interviewed to find out what percentage of surveillance procedures were written and approved and what percentage of those had been walked down or actually used. The inspector estimates that approximately 75% of the TS surveillance procedures have been written and less than 50% of those have been walked dow Engineering Services Department personnel were interviewed by the inspector about the evaluation and trending of pump and valve data and the inservice inspection program. Procedure 50029-C, Trending and Evaluation of Pump and Valve Test Data, was in the initial draft stage. Much of the insarvice

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inspection will be performed by SCS and they had generic procedures in place for various inspection Engineering Services Department personnel were modifying these procedures to be site specific, for those. inspections completed by the Engineering Services Departmen Procedure 20015-C, Planned Maintenance, lists requirements and responsi-bilities for calibration of safety related items not covered under the TS surveillance program. The tracking program was developed on computer and responsible personnel stated that all identified calibration procedures are in plac Within this area, five inspector followup items were identified and are discussed in the following paragraph Master Surveillance Schedule Incomplete During an interview with the surveillance tracking coordinator, the inspector identified that some surveillances were not included on the master tracking schedule. Until all surveillances required by TS are included on the master tracking schedule, this is identified as Inspector Followup Item 424/86-96-0 Scheduling and Tracking Procedure Incomplete Procedure 80012-C, Surveillance Test Scheduling and Tracking System, which lists surveillance responsibilities and requirements has not yet been approved. Until this procedure is approved, this is identified as Inspector Followup Item 424/86-96-0 Surveillance Internal Monitoring Inadequate (1) The surveillance tracking program does not appear to have adequate controls in place that would identify and prevent exceeding the'

3.25 surveillance time interval required by T (2) The surveillance tracking program does not account for actual time in hours and minutes, therefore it does not provide adequate control for the shorter surveillance intervals. Until these two problems are procedurally controlled, this is identified as Inspector Followup Item 424/86-96-03, Surveillance Data Trending and Evaluation Procedure Incomplete Procedure 50029-C, Trending and Evaluation of Pump and Valve Test Data, was not approved and was in the initial draf t stag Until this procedere is approved and issued, this is identified as Inspector Followup Item 424/86-96-0 F l

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i Surveillance Procedures Incomplete Some surveillance procedures that were identified by the surveillance tracking program have not been approved. The inspector estimates that about 75 percent of the surveillance procedures have reached the approval stage. Operations has all but one procedure approved. I&C has 239 out of 309 procedures approved. Until all procedures that are required to meet TS surveillances have been written and approved, this is identified as Inspector Followup Item 424/86-96-0 . Audits (35741)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (c) ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants (d) Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants (e) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(f) ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Pcwer Plants (g) Technical Specifications, Section 6 (h) FSAR, Section 13.1 and 1 The inspector reviewed the licensee's audit program required by references '

(a) through (h) to determine if the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specification The following criteria were used during this review to determine the overall acceptability of the established program:

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The audit program scope was defined consistent with Technical Specifi-cations and FSAR commitment Responsibilities were assigned in writing for management of the various audit program requirement Methods were defined for taking corrective action on deficiencies identified during audit The audited organization was required to respond in writing to audit finding '

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Distribution requirements were defined for audit reports and corrective action response _ . - .

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Checklists were required to be used in performing audit Procedures and responsibilities were detailed _ to ensure qualification of quality assurance program audit personne ,

The documents listed below were reviewed to determine if these criteria had been incorporated into the audit program:

e i Vogtle Electric Generating Plant, Quality Assurance Manual, Sections 1 and 18, Rev. 9 QA-05-01 Organization and Responsibilities of the QA Department, Rev. 11 f

QA-05-01 Field Audits, Rev. 15

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QA-05-18 Annual QA Department Assessment, Rev. 4 QA-03-02 Training and Personnel Qualification, Rev. 13 QA-03-05 Qualification of Auditors, Rev. 5 00409-C Response to NRC, QA, and INP0 Audit Findings, Rev. 1 QA-05-19 Training Annually for Malpractice, Rev. 2 QA-05-17 QA Surveillance, Rev. 3 QA-05-20 QA Trend Program, Rev. 2 QA-04-02 Significant Deficiency / Defect Reporting, Rev. 9 QA-04-17 Procedures Review, Rev. 3 QA Audit, Readiness Review Module: 5, Finding: 5-13

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QA Audit Finding Report, No. OP21-86/28 Corrective Actions Program, August 8, 1986 QA Department Assessment Plant Vogtle, Operations and Construction, 10/85 QA Audit, Surveillance and Technical Specification Compliance, OP09-86/27, August 29, 1986 l Tentative Audit Schedule for 1986 t

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The inspector reviewed documents related to the QA Audit Program. The

! inspector also interviewed the audit supervisor and a lead auditor regarding program documentation, responsibilities, and implementation. The staff

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members were knowledgeable of the audit program and its requirements. The program appears to be acceptable as it is now documente '

Within this area, no violations or deviations were identifie . Procurement (35746)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses

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(b) 10 CFR 50, Appendix B, Quality Assurance Criteria -for Nuclear Power Plants and Fuel Reprocessing Plants (e) Vogtle Electric Generating . Plant (VEGP) Final Safety Analysis Report (FSAR), Section 17.2, Quality Assurance Program (Operational)

(d) 10 CFR 21, Reporting of Defects and Noncompliance (e) Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (f) ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants The inspector reviewed the licensce's procurement program required by references (a) through (f) to determine if the program had been established in accordance with regulatory requirements and industry guides and stan-dards. The following criteria were used during the review to determine the overall acceptability of the established program:

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Administrative controls were established to assign departmental responsibilities for procurement activitie Administrative controls were established to identify safety related equipment, supplies, consumables and services to be procured under the QA progra Administrative controls were established to provide measures and assign responsibilities for the preparation, review, approval and changes to procurement document Procedures were established to assure that vendors, contractors and suppliers conform to procurement and quality assurance document requirements, industry standards and codes and that nonconformances are properly reported and correcte Controls were provided to provide for audits and surveillance of procurement activitie l

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Administrative controls have been established for qualifying and maintaining a current list of approved vendors, suppliers, and contractor The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's QA program to control procurement of safety-related items and services:

VEGP Project Reference Manual, Section 6, Supplier Annual Performance Evaluation, Rev. 3 Georgia Power Nuclear Procurement Policy Manual, Chapter 17, Supplier Qualification, Rev. 3 Plant Vogtle Project Procurement Policy and Procedures Manual (PPP&PM),

Rev. 3 QA-04-06 Corporate QA Department Procedure, Supplier / Bidder QA Manual Review and Approval, Rev. 8 QA-05-21 Corporate QA Procedure, Supplier Qualification and Surveill-ance, Rev. 1 00203-C Requisition Review for Technical and Quality Requirements, Rev. 3 00800-C Requisition of Materials and Services, Rev. 5 00852-C New or Obsolete Parts, Rev. 0 50021-C Replacement Parts and Materials Documentation Review, Rev. 2 ,

Procurement of safety related items and services for Vogtle Electric Generating Plant (VEGP) can be from either a qualified supplier list

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maintained by the Georgia Power Corporate QA Department or an Evaluated Supplier list maintained by Bechtel Power Corporation (BPC) and Southern l Company Services (SCS). Annual and triennial evaluations and audits are required of companies on both supplier lists.

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! The Q-List was maintained by the Project Field Engineering (PFE) group,

! operations. The manager and deputy manager of this group are SCS and BPC l personnel. Procedural guidance was provided from the VEGP Project Reference

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Manual, Section 14, Project Classification List Control, Revision Alterations to the Q-List were made via the design change program and the i Project Reference Manual.

l Procurement levels are designated as one through seve Safety-related items were levels one through five. All requisitions with the exception of nonplant materials (i.e., office material) were reviewed by the Procurement

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Review Group. This group reviews requisitions for technical and administra-tive accuracy in accordance with Procedure 00203-C, Requisition Review for Technical and Quality Requirements. The licensee program for procurement control of- safety-related materials and equipment appeared to meet commit-ments, industry guides and standard Within this area no violations or deviations were identifie . Receipt, Storage and Handling of Equipment and Materials (35747)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) VEGP FSAR, Section 17.2, 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 (0perations)

(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance Requirements for the Operational Phase of Nuclear Power Plants lf) Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water Cooled Nuclear Power Plant (g) ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and Handling or Items for Nuclear Power Plants (h) ANSI N45.2.6-1978, Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants The inspector reviewed the licensee program and procedures required by references (a) through (h) to determine if controls had been established for receipt inspections, initiation of nonconformance reports, disposition of nonconformances, handling, storage and issue of safety-related equipmen The following criteria were used during this review to determine the overall acceptability of the established program:

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Administrative controls were established for conducting and documenting receipt inspections and reporting nonconformance Administrative controls were established for disposition of items, marking, storing and protection of items during storag Administrative controls were established for limited shelf-life items and for performing audits and surveys of storeroom activities.

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Administrative controls were established for qualification of inspec-tion personne The following licensee documents were examined to determine if these criteria had been incorporated into the licensee's QA program to control receipt inspections, handling, storage, maintenance and protection of reactor plant items:

00850-C Materials Receiving and Inspection, Rev. 4 00851-C Storage, Handling, and Shipping Requirements, Rev. 3 00853-C Material Identification, Control and Issue, Rev. 5 85001-C Training and Qualification of Quality Control Personnel, Rev. 3 85307-C Quality Control Receipt Inspection, Rev. 5 50021-C Replacement Parts and Materials Documentation Review, Rev. 2 The inspector's review of the above documents indicated that an adequate program existed for the receipt, storage and handling of material and equipment. Regulatory requirements addressed in the upper-tier documents were reflected in lower-tier working level document Responsibilities fcr receipt of safety related material and equipment were clearly designated in procedures. Specific guidance for receipt inspection of safety-related equipment was provided by QA/QC procedure Receipt inspection nonconformances were trended via the Deficiency Report (DR) program by the Nuclear Safety and Compliance (NSAC) group. Monthly trend reports issued by the Compliance group indicated the volume of DRs attributed to vendor These monthly reports were distributed to the QA Manager, General Manager, and the NSAC Manager; and a quarterly trend report was provided to the Vice President of Nuclear Operation The DR trending process provides a method by which adverse trends can be identified and reported to management for evaluation and corrective action. An additional method of monitoring vendor performance was provided by a replacement parts and materials documentation review procedure. This required a vendor /

supplier feedback form to be completed when a problem attributed to the supplier was n wed. The form described the problem and was forwarded to the General Office Procurement Review Group for inclusion in supplier file The inspector toured the warehouse storage areas for Levels A and B storag The areas were reasonably clean and appeared to meet the requirements of the ANSI Standards and licensee commitments. The inspector verified the implementation of rodent control measures both physically and contractuall This requirement was met by a vendor contract with Borden Pest Control Company of North Augusta, Purchase Order PAV-1938. A general review of

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items on open shelves in Level B storage did not identify any problems. A good practice of providing a clear plastic barrier wrap on stored items was note A small random sample of stored items to verify traceability to purchase orders and requisition documents indicated adequate traceabilit An audit finding by onsite QA, which identified the lack of limits on level A storage and actions to take if limits were exceeded, was adequately corrected by a revision to the appropriate procedur Periodic warehouse evaluations included a shelf-life check on the inspection evaluation for Expired shelf-life items were placed on hold in accordance with materials receiving and inspection procedures. Disposition of these items either by disposal, extended shelf-life, or conditional release, was evaluated by Engineerin *

Within this area, no violations or deviations were identified.

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