IR 05000425/1988025

Insp Rept 50-425/88-25 on 880502-06 & 16-20.No Violations or Deviations Noted.Major Areas Inspected:Design Changes & Mods,Tests & Experiments,Measuring & Test Equipment,Document Control & Surveillance Testing & Calibr Control

ML20151C726
Person / Time
Site:	Vogtle
Issue date:	06/23/1988
From:	Belisle G, Moore L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151C723	List: IR 05000425/1988025 ML20151C720
References
50-425-88-25, NUDOCS 8807220140
Download: ML20151C726 (16)

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NUCLEAR REGULATORY COMM190N o, REGION ll g e,,,, [ 101 MARtETTA ST., ATLANTA. GEORGIA 30323 Report No.: 50-425/88-25 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-425 License No.: CPPR-109 Facility Name: Vogtle 2 Inspection Conducted: May 2 - 6, 16 - 20, 1988 Inspecto h & $71LLs

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Approved by: W g 6 [

Date/ Signed G.'A. Belislet chief Quality Assurance Programs Section Division of Reactor Saft.ty SUM 4ARY Scope: This routine, unannounced inspection was conducted in the areas of design changes and modifications, tests and experiments, measuring and test equipment, surveillance testing and calibration control, and document contro Results: Adequate programs existed for Unit 2 activities related to design changes and modifications, tests and experiments , measuring and test equipment, and document con trol . The surveillance testing and calibration control program is currently being developed. Due to its not being fully established, IFIs were identified in the following areas:

Master surveillance schedule incomplete, paragraph Surveillance task procedures incomplete, paragraph TS/LC0 component Ifst and incorporation into calibration control program incomplete, paragraph Operations procedures for surveillances of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less incomplete, paragraph In the areas inspected, violations or deviations were not identifie PDR ADOCK 05000425 O PDC

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REPORT DETAILS Persons Contacted Licensee Employees J. Aufdenkampf, Deputy Superintendent - Engineering Support

• M. Bellamy, Plant Manager

• G. Bockhold, General Manager J. Bowden, Surveillance Tracking Coordinator E. Burns, ISI Valve Test Coordinator A. Caudill, Senior Engineer, ISI

• T. Greene, Plant Support Manager

~*M. Griffis, Maintenance Manager

• E. Groover, QA Site Manager-Construction M. Hobbs, I&C Superintendent

• R. Lide, Engineering Support Superintendent

• A. Mosbaugh, Assistant Plant Support Manager B. Quick, Document Control Supervisor B. Wyre, PM Coordinator Other licensee employees contacted during this inspection included engineers, mechanics, technicians, and administrative personne NRC Resident Inspectors

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• Aiello

• Rogge

• Attended exit interview Design Changes and Modifications (35744)

References: CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, CFR 50.59, Changes, Tests and Experiments Regulatory Guide 1.33, Quality Assurance Requirements .

(Operations) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operations Phase of Nuclear Power Plants, Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants

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2 FSAR Section 17, Quality Assurance Program, Amendment 3 VEGP Quality Assurance Manual, Section 3, Design Control, Revision 10 The inspector program requiredreviewed the licensee's by references desig(n (a) through change h) to and modification detemine if these activities were conducted in accordance with regulatory requirements, industry guides and standards, and TS. The following criteria were used during the review to determine the overall acceptability of the established program:

- Procedures iave been established to control design changes and modifications which include assurance that a proposed change does not involve an unreviewed safety question or change in TS as required by 10 CFR 50.5 Procedures and responsibilities for design control have been established including:

Identification of organizations or persons responsible for performing design work and conducting safety evaluation Procedures and responsibilities for identifying, reviewing and approving design input requirement Methods, procedures, and responsibilities for performing independent design verification Design interfaces (internal and/or external) are established in writin ' Responsibility for final approval of design document Review of design change is commensurate with the original design revie Administrative controls for design document control have been established for the following:

Controlling changes to approved design change document Release and distribution of approved design change document Controlling or recalling obsolete design change document Administrative controls and responsibilities have been established comensurate with the time frame for implementation to assure that design changes will be incorporated into:

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Operator training program Plant drawings to reflect implemented design changes and modi fication ' Design controls require that implementation will be in accordance with approved procedure Design controls require- assigning responsibility for identifying post-modification testing requirements and acceptance criteria in approved test procedures and for evaluation of test result ,

- Procedures assign responsibility to delineate the method for reporting design changes to the NRC in accordance with 10 CFR 50.5 Controls require review and approval of temporary modifications in accordance with 10 CFR 50.5 Controls require that a formal record be maintained of the status of temporary modifications, lif ted leads and jumpers, temporary trip points of control equip, et Controls require periodic reviews of lifted leads and jumper The documents listed below were reviewed to verify that these criteria had been incorporated into the licensee's design program:

Nuclear Operations Modification Manual, Revision 0 00001-C Plant Organization; Management Staff Responsibilities and Authority, Revision 3 00002-C Plant Review Board Duties and Responsibilities, Revision 4 00056-C Safety and Environmental Evaluations, Revision 6T 00101-C Drawing Control, Revision 5 00100-C Quality Assurance Records Administratioii, Revision 7 00306-C Temporary Jumper and lifted Wire Control, Revision 6T 00307-C Temporary Modifications, Revision 3

.00350-C Maintenance Program, Revision 8 00400-C Plant Modifications, Revision 7 50002-C Processing Requests for Engineering Reviews, Revision 3

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50005-C Requests for Engineering Assistance, Revision 1 50006-C Preparation for Design Change Requests, Revision 2 50007-C - Engineering Review of Design Change Packages, Revision 2 50008-C DCP Implementation and Closure, Revision 2 50010-C Field Change Requests, Revision 1 SCS 010604.4-9 Design Verification, October 31, 1987 SCS 010604.4-1 Establishment of Design Input Requirements, October 31, 1987 The onsite design group, Engineering Support, functions primarily to provide engineering assistance to onsite groups, i.e. Deficiency Report resolutions, and the implementation and approval of corporate developed DCP Discussions with the Engineering Support management indicated that all DCP development is accomplished by the corporate design group, PFE-0, in conjunction with the A/E, Bechtel Power Corporation and Southern Company Services. The procedure to provide guidance for onsite development of DCPs, 50016-C, which would implement ANSI N45.2.11 requirements for the design process, is in the draf t stag The Design Change Request procedur C, therefore directs all DCPs to the corporate design organization for development. Following approval of procedure 50016-C, minor design changes,."noncomplex changes which do not change the system as described in the FSAR," will be accomplished by the onsite design grou The internal and external interface mechanisms utilized are RERs, REAs, and DCRs. The associated procedures for these mechanisms in conjuncticn with the Modifications Administrative Procedure, 00400-C, and the Nuclear Operations Modifications Manual provide adequate delineation of interface activities and responsibilitie A DCP received from the corporate design organization is assigned to an implementation coordinator from the ES staff. The coordinator implements the DCP by developing post modification test procedures to meet the specified acceptance criteria, initiates MW0s to authorize work to implement the necessary changes, and verifies DCP completion including drawing revisions, training requirements, and required documentation. The work planning group develops schedules and procedures to implement require-ments of the MW0s generated by the I&C group. Procedures reviewed by the inspector provided adequate guidance for the onsite DCP implementation and approval proces Within this area, no violations or deviations were identifie ;

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5 Test and Experiments (35749)

References: CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants CFR 50.59, Changes, Tests and Experiments Regulatory Guide 1.33, Quality Assurance Requirements (0perations) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plant ANSI N45.2.8-1985, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construc-tion Phase of Nuclear Power Plants FSAR Section 17 and 14, QA Program and Start-up Test Procedures, Amer.dment 35 VEGP QA Manual, Revision 10 The inspector reviewed the licensee's test and experiments program required by references (a) through (g) to determine if the program was in conformance with regulatory requirements and industry guides and standard The following criteria were used during this review to assess the acceptability of the program:

- A formal method has been established to handle all requests or proposals for conducting plant tests involving safety-related componen ts .

- Provisions have been made to assure that all tests will be performed in accordance with approved written procedure Responsibilities have been assigned for reviewing and approving test procedure A formal system, including assignment of responsibility, has been established to assure that all proposed tests will be reviewed to determine whether they are as described in the FSA Responsibilities have been assigned to assure that a written safety evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specifications.

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- Responsibilities have been assigned to assure that all test and experiments are reported as required by applicable guidelines and instruction The documents listed below were reviewed to determine if the previously listed ' criteria had been incorporated into the licensee's test and experiments progra C Plant Review Board - Duties and Responsibilities Revision 7 00053-C Temporary Procedures, Revision 1 50002-C Processing Requests for Engineering Reviews, Revision 3 50005-C Requests for Engineering Assistance, Revision 1 50014-C Test or Experiment Request, Revision 1

'0056-C Safety Evaluations. Revision 6T 00157-C Routine Annual Reports, Revision 1 The inspector's review of applicable procedures indicated an adequate program was approved and in place for special test and experiment Discussions with engineering management indicated that site pcrsonnel were knowledgeable of the test and experiments program, its requirtments, and applicability to plant activitie Within the area, no violations or deviations were identifie . MeasuringandTestEquipment(35750)

References: CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants VEGP FSAR Amendment 35 Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations) ANSI-1976, Adminis tra tive Controls and Quality Assurance for the Operations Phase of Nuclear Power Plants Regulatory Guide 1.30 Quality Assurance Requirements i for the Installation. Inspection and Testing of Instrumentation and Electrical Equipment ANSI N45.2.4-1972 IEEE Standard, Installation, Inspection, and Testing Requirements for

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Instrumentation and Electrical Equipment During the

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The Inspector reviewed the M&TE program required by references (a) through (f) to determine if the program had been established in accordance with regulatory-requirements and industry guides and standards. The following criteria were used during this ~ review to determine the overall acceptability of the program being established:

- Responsibility was delegated and criteria established to assign and adjust calibration frequency for each type of M&T An equipment inventory list identified each specific piece of M&TE, its ic ation, and the reference standard used for calibratio A method was delineated for ' documenting M&TE calibration history including:

Traceability to the calibration source As-found and as-calibrated data Identification of calibration procedure used Date of calibration Date of next calibration Name of person performing calibratio Identification of calibration standard used and their traceability to nationally recognized standards or basis for calibration if no national standard exist Formal requirements exist for marking the latest calibration deta on each piece of equipmen The program required that each piece of equipment was calibrated on 4 or before the date specified or stored in a location separate from inservice M&T Written requirements prohibited the use of M&TE which had not been calibrated within the prescribed frequenc When M&TE was found out of calibration, the program required documented evaluations to determine the cause of the out-of-calibration condition and the acceptability of items previously teste The program assured that new M&TE was added to the inventory list and calibrated prior to us The documents listed below were reviewed to determine if these criteria had been incorporated into the M&TE program:

00100-C QA Records Administration, Revision 7 00208-C Control of M&TE, Revision 3

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20230-C Control of Instrument Shop M&TE, Revision 6T 20235-C M&TE Comparison Calculation, Revision 0 31005-C Test Standard Calibration Scheduling Program, Revision 2 31025-C Control of Chemistry M&TE, Revision 7 i

85303-C Quality Control of M&TE Calibration Control, Revision 3 43500-C Health Physics Instrument Calibration and Control Program, Revision The M&TE administrative procedure, 00208-C, specifically stated that the M&TE calibration program did not include permanently installed plant instrumentation. Discussicns with maintenance management indicated that permanently installed instrumentation utilized to verify TS or LC0 requirements would be included in the PM program for calibration control ,

The site procurement manual required the purchase of M&TE equipment and services to be from a vendor en the qualified suppliers lis The ,

inspector reviewed a sample of M&TE calibration procedures to determine the adequacy of calibration instructions. The guidance provided was adequate for performing designated calibration tasks and the required data sheets sufficiently documented calibration performance. The Unit 2 calibration program in place was adequate for plant calibration activit !

Within this area, no violations or deviations were identifie . Surveillance Testing And Calibration Control (35745) ,

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References: CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations) VEGP-FSAR, Section 17, Amendment 35 VEGP-QA Manual, Section 11, Test Control, Revision 10 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 TS. The following criteria were used during this review to determine the overall acceptability of the estab-lished program:

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- The master schedule for surveillance testing and calibration control delineated test frequency, current status, and responsibilities for performanc Fonnal requirements were established for conducting surveillance tests, calibrations, and inspections in accordance with approved procedures which include acceptance criteri Formal methods and responsibilities were established for review and evaluation of surveillance test data including procedures for reporting deficiencies, failures, malfunctions, et Responsibilities were assigned to maintain the master schedule up-to-date and to ensure th? required tests are performe Fonnal methods and responsibilities were established for calibrating components associated with safety-related systems or functions but which are not specified in TS as requiring calibratio A master schedule or equivalent for those components was established that includes:

Calibration frequency for each componen Plant group responsible for calibratio Calibration statu Responsibility was established for maintaining the TS component list calibration schedule and procedures were utilized to perfonn calibration The documents listed below were reviewed to determine if these criteria were incorporated into the surveillance testing and calibration ccatrol program:

00404-C Surveillance Test Program, Revision 8 00411-C Preservice and Inservice Inspection Program, Revision 3 00412-C Preservice and Inservice Testing Program, Revision 4 20015-C Planned Maintenance, Revision 8 20100-C ASME Section XI Repair / Replacement Program, Revision 1 20150-C Deficiency Reports, Revision 8 50029-C Trending and Evaluation of Pump and Valve Test Data, Revision 2

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1 50013-C Engineering Surveillance Procedure Writer's Guide, Revision 3 30090-C Chemistry TS Surveillance -Performance Coordination, I Revision 5 The inspector reviewed the surveillance testing and calibration control l program established by those procedures reviewed. The administrative aspects of the program were adequate; however, the Unit 2 applicability i

- has not been fully identified in several area The licensee is in the process of identifying all Unit 2 systems and components that are required to be in the surveillance testing progra These are being entered into the Unit 2 Master Surveillance Schedule and until the Unit 2 Master Surveillance Schedule is completed, this is identified as IFI 425/88-25-0 The licensee is in the process of preparing Unit 2 procedures for system

! and componelt surveillances and until these procedures are completed, this l- is identified as IFI 425/88-25-02 Safety-related instrumentation required by TS but not specifically identified in TS were in the process of being identified and entered into the calibration control progra Discussions with maintenance management personnel indicated that once identified, these instruments would be entered into the PM calibration control program.

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The identification of these specific TS/LC0 instruments for Unit 2 had not been completed and until they have been identified and entered into the PM calibration control program, this is identified as IFI 425/88-25-03 Surveillances with frequencies greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are the administrative responsibility of NSAC. Surveillance requirements of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less are the responsibility of various plant groups. The operations group's procedures for surveillance activities for Unit 2 had not been completed and until these procedures are completed and the surveillances are identified, this is identified as IFI 425/88-25-0 Administrative controls for the Inservice Inspection program were approved and in place. The Unit 2 components have been identified which were to be included in this program. Tracking and scheduling of this program will be via the Master Surveillance Schedule. These components had not been entered into the master scheduling; completion of the master surveillance schedule will encompass the incorporation of the Unit 2 ISI/IST progra ;1e Unit 2 surveillance testing and calibration control program was inadequate to support Unit 2 operations at this tim Within this area, no violations or deviation', were identifie _ _ _ _ - _ - _ _ _ . __

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11 Document Control (35742)

References: CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants Regulatory Guide 1.33, Quality Assurance Program Requirements ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power-Plants Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records ANSI N45.2.9-1974 Requirements for Collection. Storage and -Maintenance of Quality Assurance Records for Nuclear Power Plants VEGP-FSAR, Chapter 17, Quality Assurance Program, Amendment 35 VEGP Quality Assurance Manual, Revision 10 The inspector reviewed the licensee's document control program required by references (a) through (g) to determine if the program had been established in accordance with regulatory requirements and industry guides and standard The following criteria were used during this review to determine the overall acceptability of the established program:

- Administrative controls had been established for drawing issuance, drawing change review, obsolete drawing control and as-constructed /

as-built drawing updatin ResponsiS111 ties assigned for drawing control and document control

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program Master indices maintained for drawings, manuals, TS, FSARs, and procedures indicate the current revision and are periodically reviewe Administrative controls had been established which designate responsibility, specific time periods for use, and adequate evaluation and review of temporary procedure Administrative controls had been established for temporary changes to procedure _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _ _ . __ _ _ _ . _

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The following documents were reviewed to determine if these criteria had been incorporated into the licensee's QA program for document control C$ Procedure Development, Revision 8 00051-C. Procedure Review and Approval, Revision 9 00052-C. Temporary Changes to Procedures, Revision 4 00053-C) Temporary Procedures, Revision 1 00101-C$ Drawing Control, Revision 5 00103-CI Document Distribution and Control, Revision 5 00108-C. Control, Review, Approval and Use of Vendor Manuals and 4 Revisions, Revision 6T 70402-C Nuclear Operating Records Management System Revision 3

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Distribution and control of drawings, procedures, and vendor manuals was maintained by the site document control group. A computer data base system, NORMS, functioned as the master indices for these document Unit 2 drawings, procedures, and manuals were being entered into NORMS as they were approved. Distribution and control of Unit 2 TS and FSAR were the responsibility of SCS in Birmingham, Alabama. Vogtle will assume responsibilty for these documents af ter licensin The inspector's review of procedures and master indices and discussions with document control personnel indicated the document control program for Unit 2 was establishe Within this area, no violations or deviations were identifie . Licensee Action On Previous Inspection Findings (92701, 92702) (Closed) Violation 50-424/87-69-01: Failure to Return EQ Equipment

! To A Qualified Condition Following Maintenance. The licensee's response dated March 14, 1988, was considered ac'.eptable by Region II. The inspector reviewed documentation, MWO 18704972, which returned the EQ equipment to a qualified condition and a training program completion record dated November 23, 1987, which addressed this issu The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct conditions and developed corrective actions needed to preclude recurrence of similar problems. Corrective actions stated in the licensee response have i been implemented.

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b. (Closed) Violation 50-424/87-69-02: Failure To Follow Procedure 00150-C, Deficiency Control . The licensee's response dated March 14, 1988, was considered acceptable by Region II. The inspector reviewed training documentation for deficiency reporting system scope and us Additionally reviewed was a site memorandum dated December 17, 1987, requiring the MWO review by the Work Planning Group to include screening for deficiency report item The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct conditions, and developed corrective actions needed to preclude recurrence of similar problems. Corrective actions stated in the licensee's response have been implemente c. (Closed) Violation 50-424/87-69-03: Failure To Perform Post-Modification Testing. The licensee response dated May 14, 1988 was considered acceptable by Region II. The inspector reviewed the implementation of the Design Change Program, specifically verifying that a review for post-modification functional test determination and performance was included in the design change package closecut process. This violation occurred during the start-up test phase before the Design Change Program was fully implemente The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems. Corrective actions stated in the licensee response have been implemented, (Closed) Inspector Followup Item 50-424/86-89-02: Assignment of Administrative Responsibili ty for Temporary Change Procedure (00052-C). This item identified administrative inadequacies in the temporary change procedure which were initially identified by the Vogtle QA staff (AFR No. OP18/19-86/15 #38 II). The AFR was closed on March 27, 1987. Action for AFR closure included Revision 3 to 00052-C which provided process flow charts, and a review of previously issued TCPs. These actions provide adequate administrative guidance for the temporary change procedure activit (Closed) Inspector Followup Item 50-424/86-89-03: Corporate Design Change Manual Not Approved. The Corporate Design Change Manual was approved and issued on March 3,1987. This manual provided general guidance for GPC modification activity with specific delineation of interfaces for onsite and offsite activities. Design change program deficiencies regarding field change request processing and 10 CFR 50.59 reportability requirements were resolved in corporate and site administrative procedure _ _ _ _ _ .

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14 (Closed) Inspector Followup Item 50-424/86-89-05: Changes to Approved Design Change Package This item identified the potential for temporary modifications to be changed without adequate review, for example, the applicable procedure stated that if a temporary modification was an inadequate resolution then the installer was to

"correct" the problem. The instruction did not specify a review process for the required field change to the temporary modificatio Revision 4 of the Temporary Modifications Procedure, 00307-C, included a requirement to identify this type of condition as a deficiency and utilize the deficiency reporting process. The controls in the deficiency reporting program provide adequate assurance that unauthorized changes to temporary modifications will not occur, (Closed) Inspector Followup Item 50-424/86-89-06: Revise Upper-Tier (FSAR) and Lower-Tier (Procedures) QA Program Documents. This item addressed the incorporation of the 1986 Nuclear Operations management reorganization into site implementing procedures. The FSAR revision no. 35 addressed the reorganization changes. The inspector reviewed the tracking documentation for the revisions to the 64 site procedures which were impacted by the management change. The documentation indicated that the reorganization had been implemented into upper and lower tier QA program document . Exit Interview The inspection scope and results were summarized on May 20, 1988, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed belo Proprietary information is not contained in this report. Dissenting comra!nts were not received from the license Item Number Discription and Reference 425/88-25-01 IFI - Surveillance master schedule incomplete, paragraph /88-25-02 IFI - Surveillance task procedures incomplete, paragraph /88-25-03 IFI - TS component list and incorporation into calibration program incomplete, paragraph /88-25-04 IFI - Operations Department procedures for surveillance requirements of 72-hours or less incomplete, paragraph __ - _ - - _ _ _ _ _ _ .

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15 9.- Acronyms and Initialism A/E' Architect / Engineer ASME American Society of Mechanical Engineerc DCP Design Change Package DCR Design Change Request EQ Environmental Qualification FSAR Final Safety Analysis Report GPC Georgia Power Company I&C Instrumentation and Control IFI Inspector Followup Itsu-ISI Inservice Inspection IST Inservice Testing LC0 Limiting Condition for Operation M&TE Measuring and Test Equipment MWO Maintenance Work Order-NORMS Nuclear Operations Record Management System NSAC Nuclear Safety and Compliance PFE-0 Project Field Engineering-Operations PM Planned Maintenance QA Quality Assurance REA Request for Engineering Assistance RER . Request for Engineering Review SCS Southern Company Services TS Technical Specifications VEGP Vogtle Electric Generating Plant

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