IR 05000424/1986102
| ML20214Q233 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/14/1986 |
| From: | Belisle G, Runyan M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214Q221 | List: |
| References | |
| 50-424-86-102, NUDOCS 8612050049 | |
| Download: ML20214Q233 (8) | |
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UNITED STATES
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323 b
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Report No.: 50-424/86-102'
Licensee: Georgia Power Company
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-Atlanta, GA 30302
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Docket No.: ' 50-424-License No.: CPPR-108 Facility Name: Vogtle 1 Inspection Conducted: October 20-23, 1986 Inspector:
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M. F. Ru'nyhn
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Date Signed Approved by:
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h G. AY BelidTe( Section Chief Date (Signed
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Division of Reactor Safety
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SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of quality assurance / quality control (QA/QC) administration, QA for startup testing, design control, and licensee action on previously identified inspection findings.
Results: No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. Belflower, QA Site Manager (0perations)
- R. Bellamy, Plant Support Manager
- G. Bockhold, General Manager, Vogtle Nuclear Operations
- J. D' Amico, Regulatory Compliance Superintendent
- G. Frederick, Engineering Support Group Supervisor
- W. Gabbard, Senior Regulatory Specialist R. Heitz, QC Supervisor R. Lide, Engineering Support Supervisor
- A. Mosbaugh, Assistant Plant Manager W. Mundy, Audit Group Supervisor
- W. Wagner. QC Superintendent
- K. Whitt, Engineer Other licensee employees contacted included office personnel.
Other Organizations J. Arbaiza, Quality Engineering, Bechtel J. Curtis, United Energy Services Corporation /GPC Engineering J. Hurd, Deputy Manager, Bechtel R. Kuester, Manager, Project Field Engineering, Operations (PFE0),
Southern Company Services (SCS)
NRC Resident Inspectors
"H. Livermore, Senior Resident, Construction
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 23, 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.
Inspector Followup Item:
QA Inspection Plans for Startup Testing, paragraph 6.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio *
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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
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Unresolved Items Unresolved items were not identified during the inspection.
5.
QA/QC Administration (35740)
Reference:
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The inspector reviewed the licensee's QA/QC administration program required by the reference to determine if activities were conducted in accordance with regulatory requirements, and industry guides and standards.
The following criteria were used during this review:
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Licensee QA program documents identify those structures, systems, components, documents, and activities to which the QA program applies.
Procedures and responsibilities have been established for making
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changes to these documents.
Administrative controls have been established for QA/QC department
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procedure review, inspection, and auditing.
These controls assure review and approval prior to implementation, provide methods to make changes and revisions, and establish methods for distribution and obsolete procedure recall.
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Responsibilities have been established to assure QA program review for
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overall effectiveness.
Administrative controls have been established to modify the QA program
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based on identified problem areas.
The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's procedures for QA/QC administration activities.
Vogtle Electric Generating Plant (VEGP) Final Safety Analysis Report (FSAR) Section 17.2, Quality Assurance During the Operating Phase VEGP Quality Assurance Manual, Revision 9 Section 1 Organization Section 2 Quality Assurance Program Section 5 Instructions, Procedures, and Drawings i
QA-01-01 Organization and Responsibilities of the QA Department,
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Revision 11
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3 QA-04-01 QA Department Procedures and QA Manuals, Revision 5 1'
QA-04-17 Procedure Review, Revision 3 QA-05-18 Annual QA Department Assessment, Revision 4 QA-05-20 QA Trend Program, Revision 2
00050-C Procedure Development, Revision 5 00051-C Procedures Review and Approval, Revision 4
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00103-C Document Distribution and Control, Revision 0 85000-C Quality Control Organization, Responsibility,
and Conduct of Operation, Revision 2
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85004-C Quality Control Procedure Reviewer Qualification,
Revision 0 The licensee's definition of the systems, structures, and components to which the QA program applies is contained in the VEGP FSAR, Section 17.3 and Table 3.2.2-1.
This highly specific document is also referred to as a Q-list. Items contained in the Q-list belong to the.following three generic l
categories:
Maintain integrity of the reactor coolant pressure boundary
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Shutdown the reactor and maintain it in a safe shutdown condition j
Prevent accidents or mitigate the consequences of accidents which could result in calculated potential exposures to radioactive materials as defined in Regulatory Guide 1.26.
The inspector's review of this material verified that a clear definition exists between Q and non-Q components.
Revision to the Q-list will be controlled by the annual FSAR update process.
The licensee did not have a comparable formal document defining which documents and activities fall under the QA program.
However, within the-scope of the entire QA program, ambiguities in this area should not exist.
Record procedures define which documents are subject to document storage and retention requirements, administrative procedures cover revision and distribution control for all proceduros, and QA audits and surveillances define the licensee's perception of the QA applicability of plant activi-i ties. Contir.uing NRC inspections in these areas could identify documents and activities, if any, which have been inappropriately deleted from the QA
program.
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The control of QA procedures is defined in QA-04-01.
This procedure requires that QA procedures be reviewed and approved prior to implementation and thereafter-reviewed at least once every two years. This procedure also provides controls for procedure revision, distribution, and recall. Quality
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Control (QC) procedures are controlled as VEGP Regulatory Compliance
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procedures. Administrative controls for these procedures are defined in plant administrative procedures referenced earlier in this paragraph.
Requirements and guidance for conducting ~ an annual evaluation of the effectiveness of the QA program are provided in QA-05-18.
The General Manager Quality Assurance (GMQA) is responsible for this assessment, which is designed to determine the performance of the QA Department in meeting its goals, objectives, and regulatory commitments. Elements to be considered in this review are organization, personnel, training, procedures, audit i
program, surveillance program, corrective action program, and improvement
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program.
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The QA program has at least two indepen' dent programmatic mechanisms for providing increased emphasis in problematic areas.
A QA trend analysis
program as described in QA-05-20 identifies. recurring problems from audits, surveillances, and reviews conducted over a period of time. This procedure
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states that when an adverse trend is identified, it shall be documented and reported to the appropriate QA manager and to line management.
Trend analysis results are discussed in quarterly Quality Assurance Committee meetings and are reviewed by the QA Engineering / Support Supervisor for input to the audit schedule and checklists.
In addition to the formal QA trend analysis program, procedure QA-05-17, QA Surveillance, states that surveill-ances and audits will be scheduled when adverse trends are perceived and that the QA Site Manager shall determine necessary additional actions such as scheduling a special audit.
The issue of prompt corrective action on identified deficiencies is crucial and the implementation of the above controls will be closely inspected during the operations phase.
Within this area, no violations or deviations were identified.
6.
QA For Start-up Test Program (35501)
References:
(a)
10 CFR 50 Appendix B, Quality Assurance Criteria for-Nuclear Power Plants and Fuel Reprocessing Plants (b)
10 CFR 50.54(a)(1) Conditions of License (c) Vogtle Electric Generating Plant (VEGP) FSAR Section 17.2, Quality Assurance During the Operating Phase (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
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(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power i
Plants
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(f) Regulatory Guide 1.68, Initial Test Programs for Water Cooled Nuclear Power Plants The inspector reviewed the licensee's quality assurance program for start-up-testing required by references (a) through.(f) to determine if activities are in conformance with regulatory requirements, commitments in the application, and industry guides and standards. 'The following criteria were used during this review:
Requirements have been established and procedures or checklists
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developed for inspection of the following activities on a regular basis by the onsite QA organization:
Conduct of testing Tracking of test deficiencies Test documentation Control of measuring and test equipment i'
The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's QA program for start-up testing.
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VEGP Quality Assurance Manual, Revision 9 Section 1 Organization Section 5 Instructions, Procedures, and Drawings Section 10 Inspection Section 12 Control of Measuring and Test Equipment
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Section 16 Corrective Action Section 18 Audits QA-05-01 Field Audits, Revision 15 QA-05-17 QA Surveillance, Revision 2 QA-05-17-01 (Desktop Supplement) VEGP QA Surveillances, Revision 1 SUM-1 Starcup Manual Introduction and Control, Revision 5 SUM-23 Predispositioned Deficiency Reports, Revision 4 SUM-31 Startup Operating Instructions, Revision 0 Within the VEGP Start-up Procedures Manual, procedure SUM-1 defines the start-up test program as consisting of the following elements:
Initial fuel loading and precritical tests Initial criticality Low power testing Power ascension testing
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The Start-up Test Program is the second phase of the Initial Test Program (ITP) and begins with the start of nuclear fuel load.
Preoperational testing comprises the first phase of the ITP.
QA oversight of start-up test activities will consist of programmatic audits and real-time surveillances. The inspector discussed the projected use of audits to cover the start-up test phase with the Audit Group Supervisor.
The 1986 QA audit schedule lists a total of 25 operational audit areas, each consisting of elements which may involve certain aspects of the start-up test program. With fuel load scheduled for December 15, 1986, most of the start-up test program will be performed in 1987, for which an audit schedule has not yet been devised. This issue is included in an inspector followup item discussed below.
Under the QA surveillance program, on-the-scene observation of start-up test program activities will be accomplished. Procedure QA-05-17-01 (Supplement)
describes the method of developing a surveillance report and the mechanism for initiating, tracking, and closing surveillance findings.
The scheduling and conduct of surveillances is governed by the use of checklists.
Each item on the checklist is keyed to a procedural reference against which the QA inspector performs his review.
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Within this area, one inspector followup item was identified. The inspector was unable to perform a specific detailed review of QA inspection plans for the start-up test program due to the unavailability of a 1987 audit schedule and the lack of QA surveillance checklists for start-up testing. At the time of the inspection, start-up test paocedures had not been completed; therefore, QA surveillance checklists could not be developed.
Until a reinspection 'in this area concludes that 'the 1987 audit schedule and QA surveillance checklists fcr start-up testing are adequate in scope to monitor start-up test activities, this item will be identified as Inspector Followup Item 424/86-102-01, QA Inspection Plans for Start-up Testing.
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Design Control (35744)
The inspector resumed the inspection of the design control program which was partially completed and documented in NRC Inspection Report No. 50-424/
86-89.
The previous inspection in this area could not be completed due to the lack of availability of certain key procedures. The five procedures in question were documented for future review as Inspector Followup Item 424/86-89-04.
The five procedures were approved October 13, 1986, with certain changes in the original concept, and are listed below:
50006-C Preparation of Design Change Requests, Revision 0 50007-C Engineering Review of Design Change Packages, Revision 0 50008-C DCP Implementation and Closure, Revision 0 50009-C As Built Notices, Revision 0 50010-C Field Change Requests, Revision 0
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The inspector reviewed these procedures to determine if they were consistent
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with the references and criteria enumerated in NRC Inspection Report No.
50-424/86-89, Section 8.
A policy decision was made prior to issuance of these procedures that plant staff engineering would not perform design work.
All design change development will be assigned to an onsite consultant group, the Project Field Engineering, Operations (PFEO), or to an offsite consultant. The PFE0 staff will work to its own operations phase engineering procedures, developed by the consultant, Bechtel Western Power Corporation. Therefore, an interface exists between Georgia Power design control procedures and those of PFEO.
Some design changes will be handled through the corporate Engineering Liaison staff; others will be handled directly between the site staff and PFEO, depending on the complexity of the work and availability of onsite expertise. Based on a review of the five procedures referenced above, adequate interface controls between the plant staff and PFE0 as well as between plant staff and the corporate Engineering Liaison staff appear to be established.
Due to the decision to eliminate plant staff-initiated design change development, procedures delineating site design requests and independent design verification were no longer needed.
Therefore, procedure 50007-C, Engineering Review of Design Change Packages, does not contain provisions for independent design verification.
Independent design verification will'
be performed by PFE0 or other design organizations.
Documented safety reviews, required by 10 CFR 50.59, will also be performed by PFE0 and
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reviewed by the onsite review committee prior to implementing any safety-related projects.
Nevertheless, the plant staff has a procedure (00056-C,
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Safety Evaluation) to perform safety reviews when they are not provided by the design organization.
Procedure 50010-C, originally planned as " Site Design Requests," was changed to " Field Change Requests," moving the
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controls for field changes out of procedure 50008-C.
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Based on the inspector's review of the newly issued procedures, it appears that the portion of the design control program relative to these procedures I
adequately implements the requirements of 10 CFR 50 Appendix B, Regulatory Guide 1.33, and ANSI N45.2.11, Quality Assurance Requirements for the Design of Nuclear Power Plants.
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Within this area, no violations or deviations were identified.
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8.
Licensee Action on Previously Identified Inspection Findings (92701)
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(Closed) Inspector Followup Item 424/86-89-04:
Design Change Implementing Procedures Were Not Available or Approved.
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This item is closed based on information provided in pa'ragraph 7 of this l
report.
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