ML20027C030

Forwards Request for Addl Info Re QA Controls for Field Change Notices.Response Due by 821020

ML20027C030
Person / Time
Site:	Vogtle
Issue date:	09/20/1982
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Dutton D GEORGIA POWER CO.
References
NUDOCS 8210120341
Download: ML20027C030 (6)

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• Document: Control (50-4M/425)

NRC PDR LPDR TERA SEP 2 01982 LB#1 Rdg.

CUpright, REG-II JGrant VBrownlee, REG-II MRushbrook TDorian Docket Hos.: 50-424 Attorney, OELD ECase and 50-425 OIE ACRS (16)

RVollmer (tr. Doug E. Dutton WHaass Vice President - Generating Plant Projects JSpraul Georgia Power Cogany JGilray Post Office Sox 4545 EGallagher Atlants, Georgia 30302 CHale, REG-IV

Subject:

Controls for Field Change Notices - Request for Additional Information Alvin W. Vogtle Nuclear Plant, Units 1 and 2 On October 15, 1931, after conference calls with NRC Headquarters and Region 11 and IV and at !!.e request of the NRC, Georgia Power Cosapany (CPC) submitted a description of the Field Change Notice (FCH) nodification of the Yogtle PSAR l

and the related cuntrols. The normal method of handling field changes by the i

Field Change Request (FCR) system and the FCH system was described as follow; in the October 15, 1931 GPC submittal *

" Georgia Power Company's (GPC) normal nathod for site originated changes l

to approved design documents is the Field Change Request (FCR). The FCR j

is transmitted to Engineering and no work relating to the change is authorized until the FCR is approved. The change reqacsted by an FCR.

if approved, is incorporated into tha design by a design change notice (DCN) which is-forwarded to GPC for its use. The provisions of the DCN are than routinely incorporated into other approved design documents as they are revised. This method will continue to be the preferred method for toplementing field originated changes.

"The Field Change Hotice (FCM) will be used only when GPC must begin in?lementing a change prior to final Engineering approval. The construc-tion site field procedures establish the required approval for FCH's.

Only individuals (Assistant Prcject Section Supervisor level or above) authorized in writing by the Manager of Field Operations may approve FCH's.

Authorized personnel may only approve FCH's within their respective discipline. These authorized individuals are experienced in nuclear power plant construction engineering. They are knowledgable with and have access to the Engineering criteria and procedures.

"Once the FCH is approved by GI-C it is telecopied to the Engineering home office for revies and approval. FCN's are controlled and tracked by use of logs at both the site and the Engineering office. Engineering is to notify GPC within five (working) days af ter issue if their review indicated the FCH is not acceptable.

In such cases GPC will place the affected work on hold as required by our nonconformance report (kCR)

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6 St Mr. Doug E.. Dutton SEP 2 01982 Checks and audits of the system, which has been in use for approxinately one year, are nade by GPC's QA/QC organization.

Concern has been expressed within NRC regarding GPC's FCN system. One concern is that because the revised systea permits construction to proceed prior to 1

final engineering approval, it can lead to implenentation of marginally accepta31e design changes and general abuse of the process. A second concern is that the FCN systea may be contrary to the following requirements of 10 CFR 50 Appendix B*

a)

Criterion VI. Docuacnt control neasures "shall assure that documents, including chanpes, are reviewed for adequacy and approved for release by t.uthorized personnel and are distributed to and used at the lucation where the prescribed activity is perfonned. Changes to docuaents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization."

b)

Criterion V.

" Activities affecting quality shall be prescribed by docunent instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in i

accordance with these instructions, procedares, or drawings."

c)

Criterion Ill.

"Jesign changes, including field changes, shall be subject to design control measures comensurate with those applied to the original design and be approved by the organization that perforned the original design unless the applicant designates another responsible organization."

Because of the differences in viewpoint regarding the acceptability of GPC's FCN systen, a meeting was held in Bethesda on August 3,1982 to discuss these concerns. The meeting was attended by representatives of NRR (LBil and QAB),

IE (QAS), OELD, a d NRC Regions II and IV.

j As a result of the August 3rd necting, we find that additional information is required to permit the staff to further assess the acceptability of GPC's FCH systen. Therefore, we request your response to the enclosed questions by October 20, 1982.

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SEP 2 01982 Mr. Doug E. Dutton Please contact J. Grant, Project Manager, at 301-492-7793 if you have any questions concerning the enclosed request.

Originni Sicned By:

Lc:;ter L. Kintner B. J. Youngblood, Chief Licensing 3 ranch 140. 1 i

Division of Licensing i

Enclosure:

Request for Additional Information j

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Mr. Doug Dutton Vice President - Project Management Georgia Power Company P. O. Box-4545 Atlanta, Georgia 30302

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cc: Mr. L. T..

ucwa Chief Nuclear Engineer ~

Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Vice President Southern Services, Inc.

P. O. Box 2625 Birmingham, A1:bama 35202 Mr! J. A. Bailey Project Licensing Manager Southern Company Services. Inc.

P. O. Box 2625 Birmingham, Alabama 35202 George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.

Washington, D. C.

20036 Mr. D. O. Foster Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. James D. O'Rei'lly Nuclear Regulatory Commission

. Region II Atla ta Ge rg a 3b303 Mr. William S. Sanders Resident Inspe: tor / Nuclear Regulatory Commission Post Office Box 572 Waynesboro, Georgia 30830 M

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q Request for Additional Information Georgia Power Company - Vogtle Field Change Notices

260~

Quality Assurance Branch C

260.1 Discuss how GPC's FCN system-satisfies the following requirements of Opendix B to 10 CFR Part 50:

a)

Criterion VI.

Document control measures "shall assure that documents, including changes, are reviewed for adequacy and -

approved for release by authorized' personnel and are distri-buted to and used at the location where the prescribed activity is performed. Changes 'to documerits shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization."

b)

Criterion V.

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or. drawings."

c)

Criterion III. " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that perfonned the original design unless the applicant designates another responsible organization."

260.2 Describe the criteria established by GPC for restricting the types of design changes that can be approved under the field change notice (FCN) systerr..

260.3 Describe in more detail the criteria for Bechtel notifying GPC of acceptable FCNs and unacceptable FCNs.

260.4 Provide a detailed summary of the pertinent experience under the field change l

request (FCR) method and the FCN method of handling field changes since initiating the FCN method.

i 260.5 Describe the GPC organizational' arrangement at the site including the position, responsibilities, and authority of the individuals authorized to approve FCNs, i.e., Assistant Project Section Supervisor level or above.

Describe the extent that these individuals are isolated from the pressures of construction schedules and cost.

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- 260.6 Describe in greater detail the qualifications of the individuals at the Assistant Project Section Supervisor level or above who are authorized to approve FCNs.

260.7 Discuss the advisability of GPC individuals authorized to approve FCNs contacting Bechtel Project Engineering in Los Angeles by telephone /telefax to obtain preliminary approval before implementing FCNs, of using Bechtel on-site engineering personnel to assist or perform the FCN activities currently performed by GPC, or of Bechtel Project Engineering being represented on-site to the extent that they can accomodate field changes in an expeditious manner.

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