IR 05000424/1986127
| ML20212G233 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/31/1986 |
| From: | Belisle G, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20212G231 | List: |
| References | |
| 50-424-86-127, NUDOCS 8701120360 | |
| Download: ML20212G233 (9) | |
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UNITED STATES o
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101 MARIETTA STREET, N.W.
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Report No.:
50-424/86-127 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.:
50-424 License No.: CPPR-108 Facility Name: Vogtle 1
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Inspection Conducted: December 1-5, 1986 Inspector:
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/1)?d 9 LP R.' Moore Ddte Signed Approved by: [ A / b v
/ 2.- K I - W6, D'A." Belisle, Sdc ion Chief Date Signed Division of React Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of design control and licensee actions on previously identified inspection findings.
Results: No violations or deviations were identified.
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8701120360 870107 PDR ADOCK 05000424 Q
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Agold, Supervisor, Southern Company Services
- C. Belflower, Quality Assurance (QA) Site Manager - Operations J. Bowden, Surveillance Tracking Coordinator
- J. Curtis, Engineering Support Consultant
- J. D'Amico, Nuclear Safety and Licensing (NSAL) Manager
- J. Daniel, Radwaste Supervisor
- R. Dudley, Training G. Frederick, QA Engineering Support Supervisor W. Gabbard, Senior Regulatory Specialist
- E. Groover, QA Site Manager - Construction
- C. Hayes, Vogtle Quality Assurance Manager
- R. Healey, Senior Non-Destructive Examination (NDE) Inspector C. Jones, Vogtle Engineering Manager (Corporate)
- R. Keck, NDE Inspector
- I. Kochery, Health Physics-Plant Engineering Supervisor
- R. McManus, Assistant Plant Construction Manager II R. Porter Surveillance Specialist - Operations
- P. Rice, Vice President - Project Engineering H. Soulia, Nuclear Safety and Compliance Consultant - United Energy Services R. Walker, QA Senior Field Representative Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on December 5, 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 reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items were not identified during the inspection.
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5.
Licensee Actions on Previously Identified Inspection Findings (92701)
a.
(Closed) Inspector Followup Item 424/86-89-01:
Revise Lower-Tier Measuring and Test Equipment (M&TE) Procedures to Require Documentation of National Bureau of Standards (NBS) Traceability The inspector reviewed the lower-tier M&TE procedures and verified the statements relating to NBS traceability were corrected such that they were stated as requirements rather than recommendations (shall instead of should).
b.
(0 pen) Inspector Followup Item 424/86-89-02:
Central Administrative Control for Temporary Changes to Procedures Procedure No. 00052-C, Temporary Changes to Procedures, was identified as inadequate for controlling temporary changes to procedures (AFR OP18/19-86/15 #38-II). The procedure had been revised to correct this finding identified by site QA.
At the date of this inspection the corrective action had not been evaluated and accepted by the auditing.
organization.
c.
(0 pen) Inspector Followup Item 424/86-89-03:
Corporate Design Change Manual Not Available for Review The Design Change Control Program was in the earlier development stage at the time this item was identified (NRC Inspection Report No. 50-42.4/86-89, conducted September 22-26, 1986) and the inspector identified the corporate Design Change Manual as a major component of this program. This manual was also in the initial development stage.
Additionally, many of the procedures to implement the design change control regulatory requirements were also being developed; therefore, the actual impact of the Corporate Design Change Manual on the Design Change Program was unclear.
At the date of this inspection the majority of the administrative and implementing procedures were complete and the Corporate Design Change Manual was still in develop-mental stages.
The inspector reviewed the design change program delineated by approved procedures and determined the program to be adequate with the exception of those items which will be noted. The following references and documents were reviewed to determine the adequacy of the design change program:
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) Vogtle Electric Generating Plant (VEGP) Final Safety Analysis Report, Amendment 19
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(d) Regulatory Guide 1.33, Quality Assurance Require-ments(Operations)
(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (g) Regulatory Guide 1.64, Quality Assurance Require-ments for the Design of Nuclear Power Plants (h) VEGP -Quality Assurance Manual, Section 3, Revision 9 The inspector reviewed the licensee's design change program required by references (a) through (h) 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:
Procedures have been established to control design changes which
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include assurance that a proposed change does not involve an unreviewed safety question or change in Technical Specifications as required by 10 CFR 50.59.
Procedures and responsibilities for design control have been
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established including responsibilities and methods for conducting safety evaluations.
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Administrative controls for design document control have been established for the following:
Controlling changes to approved design change documents Controlling or recalling obsolete design change documents such as revised drawings and modification procedures Release distribution of approved design change documents Administrative controls and responsibilities have been established
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commensurate with the time frame for implementation to assure that design changes will be incorporated into:
riant procedures Operator training programs
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Plant drawings to reflect implemented design changes and modifications
Design controls require that implementation will be in accordance
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with approved procedures.
Design controls require assigning responsibility for identifying
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post-modification testing requirements and acceptance criteria in approved test procedures and for evaluation of test results.
Procedures assign responsibility to delineate the method for
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reporting design changes to the NRC in accordance with 10 CFR 50.59.
The documents listed below were reviewed to verify that these criteria had been incorporated into the licensee design program:
VEGP Project Reference Manual (PRM), Appendix 3, Operations Phase Engineering Procedures, Revision 0 00350-C Maintenance Program, Revision 4 00400-C Plant Modifications, Revision 1 50000-C Conduct of Operations of Engineering Support, Revision 1 50002-C Processing Requests for Engineering Reviews, Revision 3 50004-C Certification of Plant Engineering and Services Department Qualified Reviewers, Revision 1 50005-C Request for Engineering Assistance, Revision 1 50006-C Preparation of Design Change Requests, Revision 1 50007-C Engineering Review of Design Change Packages, Revision 0 50008-C Design Change Package (DCP) Implementation and Closure, Revision 0
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50009-C As-Built Notices, Revision 1 50010-C Field Change Requests, Revision 0 50012-C Facilities Indices Change Request, Revision 0 50014-C Test or Experiment Request, Revision 1
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The plant staff engineering group, Engineering Support (ES) was assigned the basic administrative responsibility for plant modification development and implementation as outlined in the previously listed procedures.
The onsite engineering department, Project Field Engineering - Operations (PFE-0), was responsible for assisting Engineering Support department personnel in the development of design change packages (DCPs) associated with proposed plant modifications.
Guidance for the PFE-0 was provided in the PRM, Appendix 3.
Offsite engineering assistance was provided by Georgia Power Company, Engineering Liaison (EL) which is a corporate contingent at the corporate headquarters.
The EL group also coordinated obtaining assistance from offsite architectural engineering firms.
Interface between the onsite and offsite engineering contingents was via a Request for Engineering Assistance. The design change program at Plant Vogtle appeared to adequately meet regulatory requirements with the following exceptions:
(1) PFE-0 required procedures to process changes to DCP required during implementation, i.e., Field Change Requests.
(2) Modification Procedure 00400-C, required a triggering mechanism to ensure 10 CFR 50.59 reportability requirements of design changes /
modifications.
(3) Responsibility needs to be delineated for ensuring proper distribution / incorporation of Field Changes in DCP documentation and maintenance work orders.
Presently, a large amount of design resources are allocated to the Vogtle site due to continued construction of Unit 2.
As Unit 2 is completed and design engineering resources are redistributed, the capabilities / scope of the onsite design contingent will change. At present, the onsite engineering group maintains ready access to offsite design resources, i.e., Bechtel Power and Southern Company Services.
Eventually the interface to offsite groups will be restricted to interface through the corporate engineering group only.
Discussion with corporate and onsite engineering contingents' manage-ment indicated that the approval of the Corporate Design Change Manual will have little impact on the Plant Vogtle Design Change / Modification Program.
The purpose of the manual was to provide standardization between Plant Hatch and Plant Vogtle on documentation and administra-tive format in this program. As both the corporate manual and the Vogtle Design Change Program are undergoing simultaneous development, contradictions were minimized.
This inspector followup item will De closed when the three exceptions previously noted in this report are adequately correcte.
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d.
(0 pen) Inspector Followup Item 424/86-89-05: Change to Approved Design Change Packages The temporary modification procedure 00307-C, step t. 3.3 stated that if a temporary modification malfunctions, correct the malfunction. The procedure did not require documenting approval / review of changes to approved packages nor did the procedure provide a requirement for the same level of review as the original temporary modification package.
The inspector reviewed the proposed correction in the draft revision of the procedure which appeared adequate. The procedure was undergoing a larger scope revision at the date of this inspection, resulting in a delay in incorporation of the correction addressed by this finding.
This IFI may be closed when the revision incorporating this item is approved by the licensee and reviewed by the NRC.
e.
(0 pen) Inspector Follo..up Item 424/86-89-06:
Revise Upper and Lower Tier QA Program Documents to Show Reorganization of Nuclear Operations The inspector reviewed Amendments 26 and 29 to the Final Safety Analysis Report and verified adequate incorporation of this reorgani-zation.
Temporary procedure T-ADM-86-1, Revision 0 described this organizational transition and was being employed to update existing procedures.
Startup manual procedures, administrative procedures, and departmental procedures were in the process of review.
This item may be closed when those procedures affected by the reorganization are identified and evaluated for impact resulting from this change.
f.
(Closed) Inspector Followup Item 424/86-96-01:
Master Surveillance Schedule Incomplete The final draft of the Technical Specifications was received on November 21, 1986.
The master schedule was verified against the Technical Specifications.
Based on this review and discussions with personnel responsible for surveillance scheduling, this item is closed.
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(Closed) Inspector Followup Item 424/86-96-02: Surveillance Scheduling and Tracking Procedure (80012-C) Incomplete This item is closed based on procedure approval dated 10/13/86.
h.
(Cicsed) Inspector Followup Item 424/86-96-03: Surveillance Internal Monitoring Inadequate This Inspector Followup Item addressed the following items:
(1) Potential to exceed 3.25 surveillance inters 11
(2) Short surveillance intervals (weekly) could exceed grace period due to documentation of time in units of days rather than hours and minutes.
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The first item is closed based on review of the calculation method for surveillance, described in the scheduling and tracking procedure, 80012-C.
The surveillance next due date is calculated from the earliest of either the performance date or due date.
This is a conservative method of calculation, as no grace period is accumulated, and appears to preclude the potential for exceeding the 3.25 interval.
The second item is closed based on the establishment of a one day grace period for weekly surveillance and the previously discussed method of eliminating grace period accumulation.
Table 1 of the Surveillance Test Program administrative procedure, 00404-C, delineates the one day grace period for weekly surveillances.
Based on the conservative method for surveillance calculations delineated in plant procedures, this inspector followup item is closed.
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(Closed) Inspector Followup Item 424/86-96-04:
Surveillance Data Trending and Evaluation Procedure Incomplete This finding is closed based on approval of the Surveillance Data Trending and Evaluation Procedure, SC029-C, dated November 25, 1986.
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(0 pen) Inspector Followup Item 424/86-96-05:
Surveillance Procedures Incomplete The status of surveillance procedures on December 1, 1986, in accordance with the current Surveillance Procedure Status Report was 97 percent complete.
The Maintenance Engineering and Engineering departments were responsible for the 15 procedures not yet fully approved.
Discussion with surveillance planning personnel indicated these procedures were anticipated to be completed by mid-December.
This item will be closed when the surveillance procedures are-verified complete.
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(Closed) Inspector Followup Item 424/86-102-01: QA Inspection Plans for Startup Testing This item was identified prior to the approval of the onsite QA 1987 audit schedule. Therefore, the inspector was unable to review the QA inspection plan for startup tesi.ing at that time. The item is closed based on review of onsite QA inspection plans for startup testing which include the following:
(1) Audit schedule for 1987 approved on November 14, 1986, by the Vogtle Project QA Manager (2) Generic surveillance checklist for Startup Test Program based on the administrative procedures for startup testing.
(3) A fuel handling audit which utilizes a checklist based on startup test procedures. This audit is continuous from November 20, 1986, to the point when all fuel is loaded and the reactor vessel head is installed.
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The inspector's review of these inspection plans indicates an adequate surveillance of activities for the period of preoperational testing through operations.
1.
(Closed) Inspector Followup Item 424/85-41-01:
QA Verification of Readiness Review Module 3A Corrective Actions for Findings i
This item is closed based on a review of audits OP 21-85/07 and
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OP 21-86/50 which address open items from Modules 3A and 5.
Audit OP 21-86/50 was underway at the date of this inspection and addressed the remaining open Readiness Review items which are as follows:
4-63 7-4 5-2 7-5 5-5 7-9 6-16 9A-14 The onsite QA group appeared to be adequately verifying and tracking Readiness Review finding corrective actions for Module 3A.
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(Closed) Inspector Followup Item 424/85-44-01:
QA Verification of Readiness Review Module 5 Corrective Actions for Findings This item is closed based on a review of audits described in (1) above and a review of a memorandum dated September 12, 1986, from the Senior QA Field Representative to the Site Manager of QA operations.
This memorandum addressed Module 5 corrective actions and their status. The onsite QA staff appeared to be adequately verifying and tracking Readiness Review Module 5 corrective actions.
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