IR 05000424/1986133

Insp Rept 50-424/86-133 on 861215-19.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previously Identified Findings,Preoperational Test Records & Preoperational Test QA

ML20210A571
Person / Time
Site:	Vogtle
Issue date:	01/22/1987
From:	Belisle A, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210A556	List: IR 05000424/1986133 ML20210A550
References
50-424-86-133, NUDOCS 8702060498
Download: ML20210A571 (8)

Text

UNITED STATES

,f<, ' P f 8 Cog *%, NUCLEAR RETlULATORY COMMISSION 2 o REGION 81 5 $ 101 MARIETTA STREET, N.W., SUITE 2900

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o ATLANTA, GEORGIA 30323

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Report No.: 50-424/86-133 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1 Inspection Conducted: December 15-19, 1986 Inspect :

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/Da te/Signbd Approved by: M_ 4 ~~ //2 L f A.'Belisle,-Sect' ion Chief /Date/ Signed Division of Reactor Safety SUMMARY Scope- This routine, unannounced inspection was conducted in the areas of licensee action on previously identified findings, preoperational test records and preoperational test quality assurance (QA).

Results: No violations or deviations were identifie .

8702060498 870130 PDR ADOCK 05000424 O PDR

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REPORT DETAILS Persons Contacted Licensee Employees

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• Barrett, Quality Assurance Specialist I

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• Bellamy, Plant Support Manager

• Bellflower, Quality Assurance Manager-0perations

• Dannemiller, Technical Assistant to General Manager

• Gabbard, Senior Regulatory Specialist

• Hairston, Plant Engineer

• Hudson, Senior Plant Engineer

• Jaynes, Plant Engineering Supervisor

• Kitchens, Manager - Operations

• Mosbaugh, Assistant Plant Support Manager

• Quick, Document Control Supervisor

• Woodley, Fire Protection Coordinator Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on December 19, 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.

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The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

Licensee Action on Previous Enforcement Matters This subject was not addressed during the inspectio . Unresolved Items Unresolved items were not addressed during the inspectio . Licensee Action on Previously Identified Inspection Findings (92701)

The following items were reviewed by the inspector for closures:

l (OPEN) Inspector Followup item (IFI) 424/86-89-02: Central Administrative Control for Temporary Change to Procedures

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2 (OPEN) IFI 424/86-89-03: Corporate Design Change Manual not Available for Review (OPEN) IFI 424/86-89-05: Change to Approved Design Change Packages (Temporary Modifications) (OPEN) IFI 424/86-89-06: Revise Upper and Lower Tier QA Program Documents to Show Reorganization of Nuclear Operations

, (OPEN)IFI 424/86-96-05: Surveillance Procedures Incomplete These items remain open until corrective action can be verified complete.

, Corrective action for a majority of the items was delayed due to time

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constraints of the procedure revision and approval process,

i Preoperational Testing Quality Assurance. (35301)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

(b) Regulatory Guide 1.28, Quality Assurance Program

Requirements (Design and Construction)

! (c) ANSI N45.2-1971, Quality Assurance Program Requirements

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for Nuclear Power Plants

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! (d) Regulatory Guide 1.144, Auditing of Quality Assurance i Programs for Nuclear Power Plants

j (e) ANSI N45.2.12-1977, Auditing of Quality Assurance

Programs for Nuclear Power Plants l (f) Regulatory Guide 1.58, Qualification of ;iuclear Plant

! Inspection, Examination and Testing Personnel.

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(g) ANSI N45.2.6-1978, Qualification of Inspection,

, Examination and Testing Personnel for Nuclear Power l

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Plants

! The inspector reviewed the licensee's preoperational testing QA program

! required by references (a) through (g) to determine if the program had been

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developed and implemented in accordance with regulatory requirements, industry guides and standards, and proposed Technical Specifications. The j following criteria were used during this review to assess the overall l acceptability of the progra Procedures have been developed to conduct audits and surveillances of l licensed activitie Responsible management personnel have been assigned authorities and responsibilities to implement the QA progra .

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Management has knowledge of the QA program and understand their responsibilitie Minimum qualifications and training requirements have been developed for QA personne Systems for handling deficiencies have been established and are functionin The following documents were reviewed to determine if the above criteria had been incorporated into the licensee's QA progra SUM-2 Preoperational Test Program Organization, Responsibilities and Interfaces, Revision 3 SUM-13 Preoperational and Acceptance Test Procedure, Preparation, Review and Approval, Revision 3 QA-04-02 Significant Deficiency / Defect Reporting - (10 CFR 50.55(e)/

10 CFR 21), Revision 9 QA-03-05 Qualification of Auditors, Revision 13 QA-05-01 Field Audits, Revision 15 QA-05-17 QA Surveillance, Revision 2 The preoperational test phase consisted of construction acceptance testing, system flushing, heating, ventilation and air conditioning (HVAC) balancing and preoperational testing. QA program management during preoperational testing is assigned to the nuclear operations department. There were two mechanisms of QA coverage for the preoperational test phase of operations; audits and surveillances. Generally, audits verify regulatory commitments after performance of a test and tend to address across the board programatic issues rather than specific activity performanc Surveillances observe conduct of tests and adherence to test and administrative procedure Surveillances were less formal than audits and findings were resolved on a less formal level but could be escalated if resolution was untimely or unsatisfactor Escalation could either be to establish the surveillance finding as an audit finding report (AFR) on a current audit, schedule an

audit of the area in question, or enter the item as a checklist item on a future audi The operations QA organization consisted of an audit group and a surveill-ance group. There were four auditors assigned to the operations audit group j and two auditors shared with the construction audit group. All auditors i were Georgia Power Company (GPC) personnel and qualified as lead auditors in i

accordance with ANSI N45.2.23. The surveillance group consisted of four

! surveillance specialists and a supervisor with lead auditor qualifications.

l The surveillance specialists were startup engineers contracted from Bechtel l Power Corporation (BPC). These personnel were qualified as Level III l

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surveillance specialists based on academics, technical training, testing and nuclear plant experience. The personnel were knowledgeable of the test program and based on training and experience, appeared capable of adequately monitoring test activitie Audits were performed in accordance with an approved yearly audit schedule or as need was determined from surveillances or other program weakness identification methods. Procedural guidance for audits was provided by QA-05-01, Field Audits. Audit checklists were specifically tailored to the audited activity and generally utilized a Technical Specification commitment matrix to determine checklist items. Surveillances were performed on individual preoperational tests as the tests were performe Prior to performance the inspector reviewed the test to determine specific items to be monitored. These review items were used in conjunction with a generic checklist provided in procedure QA-05-1 The insp(ector Program reviewed the following ITP)/Preoperational audits which addressed Initial Test Test activities:

Audit No.: TP01-84/04 Audit Date: December 3-14, 1984 Scope: System Turnover and Initial Test Program Audit No.: TP01-85/01 Audit Date: January 15-28, 1985 Scope: Initial Test Program Training Activities Audit No.: TP 01/02/03/05-85/02 Audit Date: February 11-22, 1985 Scope: Construction Acceptance Tests and Preoperational Tests Audit No.: TP 01/04-85/03 Audit Date: March 11-21, 1985 Scope: Flushing and Cleanliness Verification Audit No.: TP02-85/04 Audit Date: March 21-28, 1985 Scope: Mechanical Documentation Turnover Audit No.: TP01/02-85/05 Audit Date: June 4-27, 1985 Scope: Turnover Process Implementation Equipment Protection During ITP Audit No.: TP02-85/06 Audit Date: October 15 - November 8, 1985 Scope: Turnover Package Review

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s Audit No.: TP05-85/07 Audit Date: November 11, 1985 - January 23, 1986 Scope: ITP Conformance to Applicable Standards and Corrective l Actions

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Audit No.: TP01-86/02

. Audit Date: May 6-10, 1986

Scope: Review of Test Activities Following Identification of Programatic Weaknesses Audit No.: TP05-86/03 Audit Date: February 20 - March 17, 1986

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Scope: Primary Hydrostatic Test Activities Audit No.: TP02-86/16 i Audit Date: June 10-24, 1986 Scope: Fire Protection - Fuel Receipt and Handling Areas

Audit No.

TP02-86/18

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July 1-9, 1986

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Audit Date:

l Scope: Review of Turnover Packages

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! Audit No.: TP03-86/22 j Audit Date: July 1-10, 1986

Scope: Construction Acceptance Test Program 1 Audit No.: TP05-86/30

, Audit Date: September 8-23, 1986

! Scope: Preoperational Test Program

Audit No.: TP02/CP09-86/37

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Audit Date: July 7-23, 1986 ,

Scope: Electrical Systems Audit (Performed by Construction QA) t

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l These audits provided an overview of activities and identified problems j which could have been missed by the narrower scope surveillance reviews.

l The audits identified significant findings in most cases and followup to l resolution appeared adequate. At the date of this inspection there was one l open audit finding from GPC audits.

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i Approximately 430 preoperational surveillances had been performed since

February 198 At the date of this inspection, of 32 surviellance findings l that were entered into the tracking system, 7 remained unresolved. Many j surveillance findings were corrected immediately upon identification and  ;

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were therefore not entered into the surveillance tracking syste The surveillance group supervisor reviewed all findings to identify adverse trends. Identification of an adverse trend could have resulted in an audit of the identified area to determine the extent of the problem.

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The dual compliance mechanisms, audits and surveillances, appeared to appropriately address both narrow scope implementation and large scope programmatic review of the preoperational test phase. Identification of problems and corrective actions appeared adequate for those audits and surveillances reviewed by the inspector, and sufficient overview was provided to identify adverse trend . Preoperational Test Records (39301)

References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory Guide 1.33, Quality Assurance Program Requirements (c) ANSI N18.7-1976 Administrative Control and Quality Assurance for the Operation Phase of Nuclear Power Plants (d) Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records (e) ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records The inspector reviewed the licensee's administrative controls for records generated during the preoperational test program as required by references (a) through (e) to determine if administrative controls were in accordance with regulatory requirements, industry guides and standards and Technical Specifications. The following criteria were used during this review:

- Administrative controls have been established for maintaining records for the following types of activities during the preoperational test period:

Preoperational test procedures and results Corrective and preventive maintenance QA/QC audits and surveillances Personnel training Personnel qualifications Components, systems and structure turnover

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Responsibilities have been assigned to assure that the records identi-fied above will be maintained and the retention periods have been specified. Record storage controls have been established which accomplish the following:

Define the record storage location for the types of records identified abov *

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Designate a custodian (s) in charge of storage for each class of record Describe the filing system (s) to be used to allow for record retrieva Establish a method for verifying that records received for storage are in agreement with any attendant transmittal document Make provisions for governing access to files and for maintaining an accountability of records removed from the storage facilit The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedures for records control:

VEGP Quality Assurance Manual, Section 17, Revision 9 SUM-13 Preoperational and Acceptance Test Procedure Prepara-tion, Review and Approval 00100-C Quality Assurance Records Administration, Revision 4 00103-C Document Distribution and Control, Revision 0 00101-C Drawing Control, Revision 2 The inspector's review of record storage facilities verified that adequate measures had been incorporated to meet regulatory requirements for record storag The inspector reviewed approximately ten percent of the completed preoperational test record The major criteria of this review was to verify retrievability, legibility and completeness of the stored records. All records requested by the inspector were readily retrieved, legible and complete. The licensee's program for preoperational test records appeared adequate to meet the specified regulatory requirements ar.d industry guides and standards.