IR 05000424/1986098
| ML20215E632 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/08/1986 |
| From: | Belisle G, Jackson L, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215E607 | List: |
| References | |
| 50-424-86-98, 50-425-86-54, NUDOCS 8612230038 | |
| Download: ML20215E632 (16) | |
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l NUCLEAR REGULATORY COMMISSION o
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REGION il
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101 MARIETTA STREET,N.W.
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ATLANTA. GEORGI A 30323
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a Report Nos.: 50-424/86-98 and 50-425/86-54 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA '30302
' Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name: Vogtle 1 and 2 Inspection Conduc
- Oc ober 20-31, 1986
Inspectors:
L.- H. Jac Dite Signed
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Approved.by:
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G. Ar Belisle, W ief Date Signed Quality Assurance Programs Section Division of Reactor Safety
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SUMMARY
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Scope:
This routine unannounced inspection was conducted in the areas of licensee management of quality assurance (QA) activities, licensee action on previous enforcement matters, licensee action on previously identified inspection findings, and an employee concern involving traceability of materials.
Results: One violation was identified - Failure to mark materials with purchase
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order number and item number.
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86122'JOO38 861215 PDR ADOCK 05000424 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. Ballamy, Plant Support Manager R. Beaver, Section Supervisor, Materials Engineering and Planning
- C. Belflower, QA Site Manager, Operations
- P. Bemis, Manager, Engineering, Radiation Safety, Maintenance and Operations J. Boddie, Site Document Supervisor.
C. Burke, QA Field Representative, Operations
- J. D'Amico, Nuclear Safety and Compliance Manager
- J. Edwards, Senior Nuclear Specialist
- G. Frederick, QA Engineering Support Supervisor
- W. Gabbard, Senior Regulatory Specialist
- L. Glenn, Manager, Vogtle Quality Concern Program
- E._ Groover, QA Site Manager, Construction
- D. Hallman, Chemistry Superintendent
- B. Harbin, Manager, Quality Control
- A. Harrison, Electrical Manager
- C. Hayes, Vogtle QA Manager
- G. McCarley, Project Compliance Coordinator
- R. McManus, Assistant Project Construction Manager II
- W. Mundy, Audit Group Supervisor
- W. Nickerson, General Manager, Project Procurement and Materials
- F. Page, Equipment Qualification Section Supervisor
- P. Rice, Vice President, Project Engineering
- K. Whitt, Generation Engineer Other licensee employees contacted included construction craftsmen, engineers, technicians, and office personnel, Other Organizations Bechtel
- S. Hayter, Project Field Engineet ing Supervisor
- F. Marsh, Project Engineering Manager
- S.
Pietrzyk, Assistant Project Engineer, Field
- D. Strohman, Project QA Engineer Pullman-Power Products (PPP)
D. Duhannon, Shop Superintendent
- B.
Edwards, RCM
- J. Miller, QA Manager W. Peninge, Quality Control Inspector / Quality Assurance Engineer R. Wheeler, QA Engineer, Records l
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NRC Resident Inspector
- J. Rogge, Senior Resident Inspector, Operations
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 31, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee.
Violation, Failure to mark materials with purchase order number and item number, paragraph 10.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92702)
a.
(Closed) Severity Level V Violation 424/86-15-01:
Inadequate Pullman Power Products (PPP) Drawing Control Corrective Action.
Georgia Power Company's (GPC) response dated May 9, 1986, was considered acceptable by Region II.
The inspector examined the discrepancies cited and the corrective actions taken for the seven PPP drawing control audits conducted since January 1986.
Review of these audits indicates that PPP has developed an acceptable drawing control program. The inspector also examined the GPC document control histor-ical charts that are being maintained for each audited organization.
These charts show document error rates for each audited organization over an extended period and are useful to management for detecting adverse trends and to evaluate the effectiveness of previous corrective actions.
The inspector concluded that GPC had determined the full extent of the violation, performed the necessary survey and followup
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actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the response have been implemented.
b.
(Closed) Unresolved Item (URI) 424/85-31-03:
Retrievability of QA Audit Records Three of the five identified missing audit checklists were found by the licensee and copies of the subject audit checklists have been placed in the vault. The remaining two missing checklists for audits TP01-84/01 and MD05-81/31 are not available, but could be reconstructed through review of the appropriate audit reports if it were deemed necessary.
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This item is closed on the basis that the subject missing checklists-
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appear to have been an. isolated. incident for which no corrective action-is needed and the fact that there is no safety significance associated
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-with this item.
c.
.(Closed)- URI-424/85-61-01:
Verification of Corrective Actions
' Specified for Readiness Review Findings (RRFs) D-5, D-6, D-7, and D-8
~ Corrective. actions for RRF D-5 were verified by GPC operations QA during audits 0F18/0P19-86/15.
The inspector examined the' subject
. audits and the following pertinent documentation-that supports the closure of'this item:
Vogtle Project Policies and Procedure Manual (PP & PM), R3,
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Part C, Section 2 Nuclear Operations Department Procedure No. 70406-C, R0, Records
Transfer Field Procedure QC-A-06, R0, Transfer of QA Documentation From
Nuclear Construction to Nuclear Operations Supplemental plans to the PP & PM records transfer plan
Bechtel Project Reference Manual (PRM), R3, Part B, Section 4 Southern Company Services supplement to Bechtel's PRM, R1, Part B, Section 4 GPC QA vault records transfer plan L
Pertinent Correspondence
File No. X78H01, Log NOA-00401, April 15,1986
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i File No. X78H01, Log G-9591, June 28, 1986 File No. X7BD21, MQC-862, December 26, 1985 File No. X7BG17, MQC-782, July 15, 1985
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i File No. X7BD21, DR-223, December 12, 1985 l
l The inspector has observed various members of the QC Task Force reviewing quality records, the vaults filing system, and the
l performance retrofit of quality records as necessary during previous site inspections.
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Corrective actions for RRF 0-6 were verified by GPC QA Surveillance
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CP02-86/29. The inspector examined the subject surveillance report and L
the following pertinent documentation to close this finding:
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PP & PM, R3, Part C, Section 2
Plant Administrative Procedure 001000, R4, QA Records
Administration, Section 4.1.5 l
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- Nuclear Operations Department Procedure No. 70406-C, R0, Section 5.3 Correspondence File No. X7BD66, X7BD102, Log G-9571, June 14, 1985
Correspondence File Na. X7BD66, Log NQA-00580, August 22, 1986
Corrective actions for RRF D-7 were verified by a Bechtel QA surveillance.
The inspector examined Bechtel's corrective action request CAR-RR-85-01 which dispositioned this item and the corrections made to Bechtel's PRM, R3, Part B, Section 4, Attachment "A" which was revised to require that document review notices (DRNs) be retained for the lifetime of plant operation.
These actions are satisfactory.
Corrective actions for RRF D-8 were verified by a Bechtel Home Office Engineering QA followup.
Microfilming time has been reduced to one week or less turn around time and all calculations listed on Attachment "A" of the RRF that were issued have been verified to have been microfilmed. The microfilming per PRM, Part B, Section 4 is being complied with.
4.
Unresolved Items Unresolved items were not identified during the inspection.
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5.
Quality Assurance Program (35060)
a.
QA Program Changes Various personnel changes have been initiated in the QA organizational structure since the last inspection of this area. The Vice President and General Manager (VPGM) of QA has been reassigned to VP of Engineering and is located on site. The Assistant to the VPGM of QA was promoted to General Manager (GM) QA. He was recently reassigned (effective 10/20/86) to plant Hatch as Project Plant Support Manager.
GPC has currently assigned their Engineering Support Manager as Acting - General Manager of QA. The position of GMQA will be filled in the near future.
The Corporate QA Engineering Support Manager has been reassigned as Assistant to the VP of Engineering at Plant Vogtle.
These assignments of personnel were reported to the NRC by GPC's Amendment 25 to the FSAR. The inspectors reviewed the resumes of these individuals who have held or are now holding the above discussed positions and concluded they were qualified by education and work experience to fill the positions.
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These assignments do not appear to have had an adverse effect on the independence of the QA organization. The inspectors reviewed the QA Committee meeting. notes of December 20, 1985, and confirmed that
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appropriate agenda items were brought to the attention of corporate management.
Some decrease in onsite construction QA staff has occurred since the last inspection in this area. Construction QA staff have been assigned to the QA Nuclear operations section. These actions were precipitated because of systems being completed and turned over to operations.
Adequate personnel have been retained to perform construction QA activities.
QA organizational policies have remained essentially static in that major changes have not been required.
Program refinements have been implemented when problem areas are identified.
Various GPC QA Department Manual procedures govern the activities of the QA Department in the implementation and management of the GPC QA program. These procedures apply to the QA General Office staff and to the QA Field staff at each plant site.
The following listed QA Department procedures (for controlled manual holders numbers 7, 9,14 and 16) were examined for changes (revisions) to verify that these changes were approved at appropriate management levels, to assure the procedures are reviewed at the required frequency and in accordance with procedure QA-04-01, to determine if changes made were necessary or desirable, and to ensure that document control (distribution)
requirements had been effectively complied with:
QA-04-01, R5 QA Department Procedures and QA Manuals QA-04-06, R8 Supplier / Bidder QA Manual Review and Approval QA-04-17, R3 Procedure Review QA-05-01, R15 Field Audits QA-05-02, R14 Corporate / Supplier Audits QA-05-18, R4 Annual QA Department Assessment QA-05-21, R1 Supplier Qualification and Surveillance In addition to the above QA Department Manual procedure reviews, controlle manual holders of the Vogtle Quality Assurance Manual (copy numbers 4, 8 and 15) were contacted and the inspector verified that the subject manual holders had received and filed the latest revision (Revision 9) to their QA manual.
Revision 9 was issued as a complete manual replacement.
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b.
Licensee Reviews of QA Program Effectiveness The inspectors held discussions with the VP of Engineering to obtain his understanding of program effectiveness. The VP of Engineering was responsible for the evaluation of QA effectiveness during 1984. The GMQA was responsible for the evaluation of program effectiveness in 1985.
The VPGM QA and GMQA selected personnel independent of QA to perform audits at Plant Hatch and Vogtle to assist them in their evaluations.
These audits furnished data en training, procedures, audit program, surveillance program, corrective action, and the QA Department Improvement Program. The VPGM QA and GMQA then conducted individual interviews with.all QA personnel to obtain information as to their perception of the QA program. Suggestions for improvement were solicited from each individual. The following two standard questions were ask of each individual:
(1) Are you free of harassment or intimidation?
(2) Do you have freedom to report and resolve problems?
The VPGM QA and GMQA then presented their findings to the Corporate QA Committee and established goals for the coming year to strengthen the program.
Their conclusion was that the program was effective. The inspectors agree that the QA program for Plant Vogtle is an effective program which identifies deficiencies and implements corrective action.
c.
Corporate QA - Site QA Interface The Vogtle Quality Assurance Manager (VQAM) transmits audits, synopsis of NRC inspections, readiness review findings, Institute of Nuclear Power Operations (INPO) reports, and items of significance to the GMQA to assist in trending items and to provide information for QA Committee discussions and/or resolutions. Site QA personnel present data to the QA Committee when items are identified that warrant upper management attention.
A detailed inspection of the QA organization was performed during the inspection of Readiness Review, Appendix I, Project Quality Assurance Organization.
The results of this inspection are documented in NRC Inspection Report No. 50-424/85-31.
The Manager, Quality Control, issues a monthly Deviation Report Trending Program (DRTP) report and a bi-monthly Inspection Attribute Trending Program (IATP) report which keeps upper management informed of problem areas. The DRTP and IATP reports are intended for use as a management tool and are not considered to be QA records. The DRTP monitors, deviation reports (DRs) and their disposition in an effort to identify programmatic weaknesses or trends adverse to quality so that corrective actions can be initiated in these areas as required.
The IATP is a trending program that utilizes current results from day-to-day inspection activities which identify adverse trends that need correction.
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The inspector examined the following DRTP and IATP Trend Reports for significant trends identified, observations and recommendations, and corrective actions when specified:
,DRTP Trend Report Nos. 86-6, 86-7, 86-8, 86-9 IATP-Trend Report'Nos. 86-1, 86-2, 86-3, 86-4, 86-5 These trend reports were found to be informative and distributed to an adequate number and level of management personnel for review.
Within this area, no violations or deviations were identified.
6.
Design Review - External Architect / Engineer (A/E) (35060)
a.
References:
(1) Vogtle Electric Generating Plant FSAR, Chapter 17, Section 17.1.1
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through 17.1.3.
(2) Southern Company Services (SCS) Quality Assurance (QA) Department Policy and Procedures (3) Georgia Power Company (GPC) QA Manual (4) QA Department Procedures Manual QA-01-01 Organization and Responsibilities of the QA Department, R11 QA-03-02 Training and Personnel Qualification, R13 (5) Bechtel Power Corporation (BPC) Project Reference Manual, Part C, Engineering b.
QA Program Requirements The licensee's QA program as described in Chapter 17 of the Vogtle FSAR states that the Bechtel design control program is based upon the requirements of ANSI N45.2-1971, Section 4, and is responsive to the intent of the proposed standard ANSI N45.2.11, Draft 2, Revision 2.
The GPC QA program is designed to conform with Regulatory Guide 1.28.
The procedures identified in paragraph a.
above were reviewed for compliance with these standards.
c.
Design Assurance - Responsibility GPC has delegated SCS the responsibility for ensuring, through quality assurance audits, the proper implementation and compliance of the quality assurance program by the A/E. GPC participates in audits of BPC and the VQAM approves the SCS audit reports prior to issue. The
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inspectors reviewed the last two audit reports of BPC design.
These audits have improved significantly in that engineers with technical expertise in the area being audited are involved in the evaluation of effective design assurance.
The inspectors reviewed audit GN20.1.2 Log VQ84-15 which was performed from February 20-24, 1984. This audit was-conducted using a 64-page detailed checklist which addressed both the technical adequacy of Bechtel design activities as well as their compliance with QA program requirements.
Portions of three systems i
(1202 Nuclear Service Cooling Water,1205 Residual Heat Removal, and 1206 Containment Spray) were evaluated for (1) circuit design, (2) cable and raceway design, and (3) raceway support design.
One audit finding identified during this audit was later upgraded to
. level I because of a potential for work to have been performed without adequate interface control.
Responses to finding from Bechtel were accepted and closed by GPC in a timely manner.
Audit GN 20.1.2 Log VQ84-125 dated December 14, 1984, was reviewed by the inspectors.
This audit identified 13 findings; seven were categorized as failure to fully implement procedures and six were recommended improvements.
This audit was conducted by two groups from SCS:
(1) Environmental and (2) Seismic.
A 62-page checklist was used to ensure coverage of technical and QA program requirements.
Environ-mental adequacy of the following specifications were evaluated:
SKV & 15KV power cables - Specification X3AJ01(A)
5KV & 15KV power cables - Specification X3AJ01(B)
Cable and wire connectors - Specification X3AJ06 The following material or equipment specifications were evaluated for adequacy of seismic data:
480V Motor Control Centers - Specification X3AC04 Junction Boxes - Specification X3AH05 HVAC Ductwork - Specification X4AJ01 Audit GN20.1.2 Log VQ85-21, performed during February 27-28, 1985, was reviewed to confirm that the licensee was implementing a program to verify by objective evidence that the A/E was implementing timely corrective action to close audit findings.
d.
Design Inputs The inspector examined the interfaces between GPC, SCS, and BPC for handling I&E Bulletins (IEBs) and Information Notices (ins) to assure that NRC requirements and positions that are transmitted to the licensee are reviewed by the A/E for design input.
The NRC transmits copies of IEBs 'directly to the Vogtle QA Manager (VQAM).
The VQAM reviews the IEBs for general applicability to the Vogtle project and to
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determine if a response is required. Copies of Bulletins are forwarded by the VQAM to affected project managers requesting them to respond to.the issue in writing when required. Written draft responses are forwarded to the Project Licensing Manager (PLM) for review, comment, and to ensure that licensing requirements / commitments have been properly observed. The VQAM prepares the final response for the Vice President - Vogtle Project Support's signature and transmittal to the NRC.
Bulletins which cite evidence of design deficiencies are eventually forwarded to the appropriate BPC engineering group supervisor (EGS) for evaluation.
If any design deficiency affects Plant Vogtle, the EGS is responsible for the following actions:
Contacting affected suppliers and obtaining confirmation that the design or unacceptable item will not be furnished under current or future production; and getting the supplier's planned action to remedy any problems with questionable products already received by GPC.
- Assuring that any resulting design change is reviewed against the design and licensing commitments described in the Final Safety Analysis Report.
- Ensuring that the needed design change is implemented, including the revising of design criteria, drawings and specifications, as applicable.
Preparation of the draft response describing applicability to the Vogtle Plant and the corrective action taken for the VQAM.
If during the review process, it is determined that a Bulletin is not applicable to the Vogtle Project, the responsible project manager is required to document this in writing, outlining why the Vogtle Project is not affected by the concerns of the Bulletin.
The inspector examined the VQAM IEB disposition log and reviewed the current status of IEB Nos. 82-01, -02, -03, -04; 83-01, -02, -03, -04,
-05, -06, -07, -08; 84-01, -02, -03; 85-01, -02, -03; and 86-01 and-02.
The inspector concluded the licensee has been responsive, provides accurate reports and maintains excellent control over this area.
Information notices are handled in accordance with Nuclear Operation Procedure Nos. 004140-C and 80009-C. The Operations Assessment Program (OAP) coordinator is the central point for receiving ins.
Upon receipt, the OAP coordinator enters the IN in an OAP log, and performs a preliminary review of each IN for impact to the Vogtle plant. Those ins which do not impact the site are classified "Information Only" and may be distributed to appropriate departments. After review, if the OAP coordinator determines the IN may have significant impact on plant
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safety or reliability the IN is formally transmitted-to the responsible department head for further review and impact verification. A written response is required to discuss the results of the findings and any action taken or ' planned to prevent the problem. Design deficiencies are handled similar to IEBs. The OAP coordinator performs a quality review of completed responses to determine their acceptability and disposition. The OAP coordinator performs periodic checks of the OAP log to ensure that due dates are met and that the item status is accurate.
Within this area, no violations or deviations were identified.
7.
Procurement (35060)
a.
References:
(1) QA-01-01 Organization and Responsibilities of the Quality Assurance Department, R11 (2) QA-04-06 Supplier / Bidder Quality Assurance Review and Anproval, R8 (3) QA-05-02 Corporate / Supplier Audits, R14 (4) QA-05-21 Supplier Qualification and Surveillance, R1 (5) QA-05-16 Stop Work Orders, R4 b.
Procurement Organizational Controls BPC of Los Angeles is the A/E for GPC Vogtle Electric Generating Plant (VEGP) with Westinghouse Electric Corporation being the Nuclear Steam System Supplier (NSSS),
BPC performs vendor audits, maintains a BPC evaluated supplier list, prepares proposed supplier evaluation lists, prepares procurement bidder lists, and provides engineering and quality assurance controls in procurement of safety-related items and services.
SCS is the lead organization for expediting items and services for VEGP.
SCS administers supplier surveillance and conducts audits of BPC design and procurement activities.
These audits are almost always observed by the project quality assurance manager. The more recent audits have had technical personnel participation by GPC which strengthen the audit process. SCS is also responsible for coordinating evaluations of items under the scope of 10 CFR 50.55(e).
The inspectors reviewed a GPC audit of the SCS QA department which was performed from May 5-9, 1985. A total of nine findings were identified during this audit.
The SCS response dated June 23, 1985, appears satisfactory to resolve the identified findings.
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GPC has established a procurement organization onsite and accepted responsibility for almost all procurement activities from BPC.
GPC audit CP03/0P07-86-40, Audit of Procurement, performed from July 21 -
August 1, 1986, was reviewed by the inspectors to confirm that essential elements of an adequate procurement program were included in the audit. A detailed checklist was used to evaluate the adequacy of procurement activities.
Lack of a formal training program for buyers was documented as an audit finding. A formal training program has been established. The resolution of this finding is being evaluated by GPC auditors at this time.
c.
Procurement Document Control Two procurement documents were reviewed to ensure:
Applicable regulatory requirements and other requirements were
included or referenced
Documents were identified which would be sent to GPC for review and approval 10 CFR Part 21 requirements were specified Applicable specifications were incorporated
Code of records were included Special instructions / requirements were included for activities such as identification, cleaning, packaging, handling, and shipping
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Access to vendor's facilities for auditing was indicated
The-procurement documents reviewed were PAV 7296 including C/N 1, 2, 3, and 4 which incorporated BPC specification X4AQ32, R4 and PAV 4741 which incorporated BPC specification X4AQ32, R2. These two procurement activities were selected by the inspectors to assist in the evaluation of an employee concern as discussed in paragraph 10.
The procurement of plate material under PAV 7296 was confirmed to have been purchased I
through O'Neal Steel, Inc., manufactured by Bethlehem Steel, and the material was " drop shipped" from Sparrow Point, Maryland. The contract specified that the material must meet American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME B&PV),1977 Edition through Winter 1977 Addendum, Section NF, Class 2.
The inspector reviewed the Certified Material Test Reports (CMTR) for the five different heats of material to confirm that the material met ASME Section NF requirements. PAV 4741 was confirmed to have been purchased
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through O'Neal Steel, Inc., manufactured by United States Steel, in their Gary, Indiana works. The same requirements were placed on United i
States Steel as on Bethlehem.
The inspector reviewed the CMTR and
confirmed that the material met the applicable requirements.
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d.
Vendor Evaluation BPC maintains an evaluated supplier list (ESL) which is updated monthly. Printouts of this list are distributed to locations that do not hav'a access to a system terminal. The inspectors reviewed the latest list dated September ~29, 1986.
It lists all Bechtel approved suppliers of Q-list safety-related engineering equipment or ASME B&PV code approved vendors for materials..The date, results, and type of survey of suppliers is given, ASME certification numbers -and date of expiration are shown, problem vendors are noted, and other information is noted to assist in evaluating the status of the vendors' QA program.
Audit schedules of suppliers are prepared by BPC two months in advance of the date due, and cover a three months audit plan. SCS approves the audit list and BPC conducts the audits.
Yearly evaluations of vendors are performed by SCS.
The inspector reviewed the evaluations of U. S. Steel and Bethlehem and -confirmed that required evaluations are being performed by SCS.
An extensive evaluation of procurement activities was performed during the Readiness Review Appendix C evaluation.
The results of this evaluation are documented in NRC Inspection Report No. 50-424/86-22.
8.
Audits (35060)
References:
a.
QA-05-01 Field Audits, R15 b.
QA-05-02 Corporate / Supplier Audits, R14 c.
QA-05-18 Annual QA Department Assessment, R4 d.
QA-03-05 Qualification of Auditors, R5 The inspectors reviewed references a.
through d.
to confirm that the licensee is implementing an effective internal and external QA audit program.
Interviews were held with the VQAM and QA Site Manager -
Construction to obtain their understanding of the audit program.
The internal audit schedule was reviewed and confirmed to encompass essential elements of the program. During 1985, 108 scheduled audits and 23 special audits were completed.
Audits of onsite contractors were verified to be included in these scheduled activities.
Internal audits were adjusted to compensate for delays of activities. When activities were rescheduled, special audits were performed to cover these activities.
The licensee delegated SCS the responsibility for design audits as discussed in paragraph 6.c.
The appointment of technical personnel over the past three years has improved the scope and depth of these audits.
The size of audit team has expanded over this period.
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The inspectors selected two technical and one QA implementation audits of design for review.
These audits plus a reaudit are discussed in paragraph 6.c. above. -In addition, the inspectors selected for review BPC reaudit of Bethlehem Steel Corporation, Sparrows Point, Maryland, to assist in the assessment of their implementation of an adequate Materials Control program.
This reaudit of Bethlehem closed an earlier identified problem with calibration of _ micrometers and gauges. The inspectors also reviewed annual evaluations of Bethlehem Steel Ccrporation and U. S. Steel, Gary, Indiana, to assist in the evaluation of materials suppliers.
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Construction audit CP03/0P07-86-40, Audit of Procurement, was selected by the inspectors for review.
The audit was performed using a detailed checklist to assure essential regulatory requirements, ASME B&PV Code requirements, and documents to be submitted to the licensee were included.
This audit was performed from July 21 through August 1, 1986.
GPC obtained the services of a BPC OA Field Representative and assigned a Corporate Field Representative to assist in this audit of procurement. This audit verified that buyers were not receiving training or that training was not being documented. The corrective action for this deficiency was to implement a formal training program. This corrective action will require followup audits to verify by objective evidence that the program is effective.
Lead auditor and auditor qualifications were reviewed and confirmed to meet ANSI N45.2.23 requirements.
An extensive evaluation of the Vogtle Project audit program was performed during the Readiness Review Appendix I evaluation.
The results of this evaluation are documented in NRC Inspection Raport No. 50-424/85-31.
Within this area, no violations or deviations were identified.
9.
Licensee Action on Previously Identified Inspection Findings (92701)
a.
(Closed)
Inspector Followup Item (IFI)
424, 425/84-14-03:
Revisions / Clarifications to Revision 11 of Procedure GD-T-01.
During Region II inspection 424, 425/84-29, revisions that were made to the subject nonconformance control procedure were examined and found satisfactory.
On this inspection, the inspector examined revised QA Department Procedure QA-04-02, R9, entitled Significant Deficiency / Defect Reporting (10 CFR 50.55(e)/10 CFR 21). This examina-tion revealed the licensee has expanded the above mentioned procedure and provided more explicit guidelines for those personnel responsible for evaluating nonconformances for 10 CFR 21/10 CFR 50.55(e) report-ability to the NR. _ _
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b.
(Closed) IFI.424/85-31-01: Update of Final Safety Analysis Report The inspector reviewed GPC's Final Safety Analysis Report (FSAR),
Amendment.18 dated August 9,1985.
This amendment incorporated WCAP 8370, R10A as the accepted Westinghouse Quality Assurance program.
Discussions were held with the GPC Site QA Manager - Construction who verified that the delay in updating the FSAR was because of contractural acceptance of WCAP 8370 with the contractor. This delay in updating the FSAR to incorporate WCAP 8370 does not adversely affect the equipment at Vogtle and has no safety significance.
c.
(Closed) IFI 424/85-31-02: Unavailable Early Procedure Revisions After further searching, the licensee concluded that the subject earlier revisions were not retained following revisions made to these procedures. As notec in NRC Inspection Report No. 50-424/85-31, the inspectors determined that although these procedure revisions were missing, there was cvidence that the requirements as set forth in the licensee's program have been met. This fact was established by considering Vogtle's limited work activities that were underway at that point in time and by a thorough review of the available documents, noting that all requirements were included in those documents. This item was determined to have no safety significance.
10. Employee Concern The NRC was contacted by an employee who expressed a concern relating to the construction quality control program at Plant Vogtle. As a result of this concern, the NRC inspectors interviewed various personnel and examined; QC records, the American Institute of Steel Construction Code (AISC), the ASME B&PV Code, engineering specifications, procurement documents, receiving inspection reports, and certified material test reports.
Seismic supports related to the expressed concern were also examined during this inspection.
Meetings were held with various management employees in an effort to determine if the concern expressed to the NRC was part of the ongoing Quality Concern Committee investigation.
Discussion of the method of evaluation and the findings resulting from the examination of QA records, procedures, specifications, codes and interviews with personnel are as follows:
a.
Concern:
An employee alleged that materials for various components used in the plant are not marked in accordance with applicable procedures.
b.
Discussion:
The inspectors interviewed shop fabrication personnel, QC inspectors, and QA personnel to determine their knowledge of material marking requirements within the timeframe of the expressed concern.
These personnel were knowledgeable of requirements and explained present s
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practices for material marking. The inspectors selected record data packages for the material in question to evaluate the concern. Review of these packages confirmed that some material had been originally cut but not marked as alleged; however, some of the material had been recut at a much later date.
Due to a large number of rejections of material upon receipt in the field by QC, in early 1983, the licensee performed an evaluation of the marking requirements for this material.
The A/E had defined the boundaries of these hangers to be non-ASME B&PV code class NF.
The material in question is classified as building structure; therefore, the AISC code is to be used in erection of these supports.
Subsequently, Pullman Power Products procedure VIII-1, Paragraph 15.2, was revised on December 28, 1983, to require that "no transfer of markings is required.
Structural members shall be coated green prior to placing in stock."
c.
Finding:
From the interviews conducted, review of the record data packages, and inspections of a sample of the materials involved the inspectors concluded that:
(1) Some record data packages contained only cut sheets in the timeframe of the concern; (2) one record data package contained cut sheets dated in early 1983 and later cut sheets in 1985; (3) inspection of the hangers in (1) above indicated that the material was not marked as required bj the applicable procedure. Therefore, the employees concern has been substantiated.
This is a violation 50-425/86-54-01, Failure to mark materials with the purchase order number and item number.
The requirement to mark material with the purchase order number and item number was a site imposed requirement prior to the procedural change.
Upon further review by the licensee, this requirement was deleted, consequently, this violation does not represent a significant safety deficiency.
A licensee response to this violation is not required.
An extensive evaluation of material control was performed during the Readiness Review Appendix E evaluation.
The results of these evaluations are documented in NRC Inspection Report Nos. 50-424/85-62, 50-424/86-58, and 50-424/86-04.
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