ML19225C862

Forwards Response to NRC 790525 Ltr as Clarification of Info Provided to NRC During 790522 & 0613 Meetings.Discusses IE Issues Re Corporate QA Direction,Psar Requirements & Training Program

ML19225C862
Person / Time
Site:	Vogtle
Issue date:	06/15/1979
From:	Ehrensperger W GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 7908030031
Download: ML19225C862 (5)

Text

1. -e

? Gem a Pccer Company n I

)

• ' F a* 0" :e E:s 45M I M Pt a .~ c e 5"tei NW

/ s~a Gw; a 3:G::

h k[ j

[ Teree d'A L 2h U 3 N E C R E G!" *.

i TI. *. N T A . r -

UN.UTEiL l9 JUN 20 P2; 22 F;o r Lw;,

June 15 ,1979 Mr. James P. O'Reilly, Director United States Nuclear Regulatory Cormission Region II 101 Marietta St., N.W., Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: Enforcement Inspection Report Nos. 50-424/

79-10 and 50- 425/79-10 The attached is in response to your May 25, 1979 letter and confirms the inforration provided to your staff during a June 13, 1979 meeting at the NRC Region II office relative to that letter.

We appreciated the opportunity to meet and offer our clarifications to the inspection and enforcement issues that have recently been raised concerning the Vogtle Nuclear Plant. Both the June 13 and the earlier Fay 22 meeting referred to in your Fay 25 letter were, we believe, beneficial excnanges that will lead to better assurances on behalf of all concerned that the Vogtle facility is being constructed in accordance with all applicable requirements.

This reply contains no proprietary inforration and may be placed in the NRC's Public Document Rooms upon receipt.

Very truly yours, fDL W. E. Ehrensper r v n

WEE:db Attachment cc: J. H. Miller, Jr. D. E. Dutton R. E. Conway K. M. Gillespie R. J. Kelly E. D. Groover F. G. Mitchell, Jr. L. T. Gucwa f 4,r} jth, C. W. Hayes a v i U tV R. A. Thomas C. F. Whitmer M. Z. Jeric J. A. Bailey R. W. Staffa .

? @dd WI AI' N 790803003)

s The following is Georgia Power Company's response to Mr. James P. O'Reilly's May 25, 1979 letter and confirms information provided to his staff during May 22, 1979 and June 13, 1979 meetings in the fiRC Region II office:

1. Corporate QA Direction:

(a) The attached QA/QC notice from Georgia Power Company's president, Mr. R. W. Scherer, has been posted at the Vogtle jobsite. This notice emphasizes QA/QC responsibilities and establishes the " Hot-line" mechanisn requested by the Connission to have construction problems directed to GPC top management.

(b) The attached June 8,1979 notice fron the Vogtle Project General Panager to the Managers of QA and Construction for the Vontle Project reaffirms and reenforces the "Stop Work" authority of both OA and QC personnel.

2. PSAR Requirements:

As discussed in the fiRC Region 11 office during our meetings of May 22 and June 13, 1979, we have a continuing program within the Vogtle design operations to assure that our construction specifications, drawings and procedures comply with the provisions of the Preliminary Safety Analysis Report (PSAR). Inasmuch as the PSAR does not cc,ntain final information in many instances while in others containing typical details and superseded codes and standards, it may require clarifications where more definitive or updated inforration is developed in our construction specifications, drawings, etc. that is different than the PSAR itsel f. In answer to the f4RC's request to study and resolve these differences, we conducted a very rigorous review within the civil area of the PSAR as related to concrete work and reviewed a compilation of the results at the June 13 neeting. We found that in every case the differences were equivalent or better to the original provisions of the PSAR. Further, limited reviews of differences have been initiated for the other disciplines cited in the fiRC's May 25 letter, the results of which were discussed at the June 13 meeting. Again, the clarifi-cations presented showed that in all cases the differences were equivalent or better than provided in the PSAR.

As a matter of practice and enforcerent of applicable portions of several project procedures and through good engineering judgment, all differences, before implementation, are evaluated and categorized as to their significance ranging from nere evolution of design details to those differences that warrant a fornal change to the PSAR via a supplement, amendment, etc. transnitted to the fiRC's Licensing organization. The substantive differences not submitted as formal changes to the PSAR will be incorporated into the FSAR. Furthermore, our work on the FSAR is scheduled to commence in July 1979 with a first working draft available in early 1930 - this effort, as indicated above, is the fornal process for collection and notification of changes to the PSAR.

In conclusion and as discussed with the fiRC's Renion 11 staff, we do not plan to develop a comprehensive compilation of all dif ferences for all disciplines at this tire apart from our FSAR work. Rather, since the dif ferences are available in other approved engineering documentation, any necessary clarifica-tions or justifications will be provided to Region 11 Inspection and Enforcenent 440 163 a.

2 2

personnel upon request during their audits of the Vogtle facility. This infoma-tion will be available on an as-regaired basis through the site resident repre-sentives of our central design organization.

3. Training:

We do have a very comprehensive training program established at the Vogtle job-site. This program has prinarily been oriented toward assuring that our inspection personnel are knowledgeable and certified commensurate with the areas for which they are responsible. Planning was initiated some time ago for expanding the program to include QA/QC program training of our site contractor personnel involved in all areas of the work. The program will include indoctrination on all phases of QA/QC for these personnel to strengthen our comitment and their understanding that QA and QC are Project-wide policies noc just restricted to limited areas of the work. The expanded program is expected to commence within six to eight weeks.

We would lik? to reaffirm that our commitment to total Quality Assurance is of continuing concern to the corporate ranagement of Georgia Power Company as evidenced by the activities listed below and discussed with your staff during our May 22, 1979 and June 13, 1979 meetings:

A. Projt.ct Managemen* Board - As discussed in Chapter 17 of the PSAR, the Project Panagement for Plont Vogtle is headed by a Project Management Board. Each month, the Project General Manager (also discussed in Chapter 17 of the PSAR) reports on the status of QA Audit Findings whether generated internally or as a result of an NRC I&E Inspection. In addition, top management serving on the Board also receives monthly reports of all open QA items. These mechanisms enable them to monitor the QA program on a continuing basis, establish priori-ties and initiate corrective action as necessary. Their direction is implemented through the Project General Manager to the remaining portion of the Project organization.

B. Quality Assurance Comittee - The Quality Assurance Comittee, again as described in Chapter 17 of the PSAR, meets throughout each year for the sole purpose of reviewing the QA/QC program s'atus of all plants including Plant Vogtle.

C. Site Visits - In addition to the items listed above, periodic visits are made to the jobsite by the Project General Panager, Project Executive and other top management personnel specifically to review QA program status and implementation.

We have a very positive program that subjects all activities to rigorous reviews and are confident that Plant Vogtle will be constructed in accordance with applicable NRC regulations.

440 16

t t t ' 3a Ib.' :t u nTn.f 2 70 l'a !.tn > I, rn!

I'( .t 0:' c e Iia U.r.,

W va.ct c p NO32 (

(

' le't;.t.v.e c4 ,72 cm.o

/m7

(

n. U.tclitter I cmtcut Geoy;ialbwer i.., .,...t,..,..

11 0 / , - _C .);

f. CONTRACTOII)

(A1,L P)n$ONN1:L - GP.ORGI A POWI R COMPA12Y Plant Vogtle in being conn'.ructed in accordance d fuith a Quality Lucurance Program ubich comp]ien uith the Co e o Title 3 0, Par t 50, Appendix 11, *Ouality Pederal 1:egu3at ions, Ynin program in Annurance Crit eria for 1:aclear Power dr P3m:ing o , and instruc-ant.n."

impleiront.ed through manual'n , proceduren, reliable p3 ant.

annure a nafe, d tions which raunt be fol]o, ed 1.0 Por the }3rograta to be nuccennful it requiren t.he nupport hey an be t

cooparation of a31 pornonnel uorking on site wh Pany Georgin Pouer Company and contractor'employcen ien -

have been annigned specific tanhn to .cnnure t. hatf- allOtionn r-rt carry out the qualit.y ancurance andandquality cont.rolThen auditing our t.rol of the program.

pernonnel vill be inonitoring, All employcen have anintpecting, individual renponsibilityi to work. And, ner in accordance \eit.h approved drauings t all thonc bic thera an each 3 evel of supervision in renponnibic to nec tha vorhing for him are given the proper inntruct. ions to ena .

to carry out. the program. in Anyone uho in not sure of his renponnihilitien tionsor should not provided adeguat.e approved proceduren or innt.rucIf that in at an not.ify his nupervisor. h ld din or believe you are being direct.ed to uork in a m i If you be-cuns this mat.t.cr with the next. 3cvel of !.upervin on.

3deve nit.e supervision in not responnive toi yourou should concerns o are conce, ned about ret aliation by nite r,upervis on, yCor.ipany Co

.C i a f f a , the Georgia Pouci ca11 Mr. ):. U. at. e>:tennion 2CG7 in the Georgia Po ear Company Annurance Managtn All ca])n u.ill be held in General Of f ice, 3tl ant a, coorgia.and v3 3 3 be inves.t igated and re otr.ict confidence ,

per management..

VvGodLM

e l u m w\u R JGS A40 pfg 0/07/79

(fV;* .

Georg a Power Company Post OMe Das 4545 g

Atan:c.. Georg;a 30332 Telephone 404 C,2M>Go Vogtle Project Loo",ern Coc any Lervices, b:

Post C**.:c Don 2c25 Ikmng%m, Alza ra as202 T okphone 205 670 6olf DATE: June 8, 1979 RE: Plant Vogtle - Units 1 & 2

~ Quality 15sur,]ance/Giility Control Authortty File:<ZbiG02 X7DG02 Log: G-4150 TO: K. M. Gillespie

. W. Hayes I have reviewed the comitments of the PSAR, QAM, and Field Procedure Manual outlining the authority and duties of Quality Assurance and Quality Control. These manuals adequately detail the requirements The and stop controls work that must be implemented to assure 3 safe reliable plant.

authority of both QA and DC is clearly defined in Section 17.1.1 of the PSAR,Section I of the QAM, ard Field Procedure GD-T-07.

To highlight the importance of QA/QC, and to reinforce the QA/QC authority outlined in the above documents, I am requesting that the QA/QC duties and authorities be given added emphasis in future cra and training programs. Craft orientations should that both QA and QC have "stop work" authority.

also stress the importance of each individual following the policies and Each individual should realize the importance of precedures established. complying with the QA Program and unders I

co~nitted to the program.

M 4J'5k Doug Dutt n Project G2neral llanager DED/aaw xc: W. E. Ehrer.sperger P.. E. Conway J. H. Miller, Jr.

R. W. Staffa D.11. Fiquett E. D. Groover R. R. Allen MD 4