IR 05000321/1985031

Insp Repts 50-321/85-31 & 50-366/85-31 on 851007-11.No Violation or Deviation Noted.Major Areas Inspected:Qa Program,Qa/Qc Administration & Tests & Experiments

ML20136B200
Person / Time
Site:	Hatch
Issue date:	10/31/1985
From:	Belisle G, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20136B168	List: IR 05000321/1985031 ML20136B165
References
50-321-85-31, 50-366-85-31, NUDOCS 8511200155
Download: ML20136B200 (10)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

[" n REGION ll 101 MARIETTA STREET, j

• * ATLANTA, GEORGIA 3o323

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Report Nos.: 50-321/85-31 and 50-366/85-31 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Condu ted- October 7-11, 1985 Inspector:

M. M ) ~

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{ Date Signed Approved by: / /O -3 /-M G. A.'Bef/sle, Acting Sg tion Chief Date Signed DivistorFof Reactor SaMty SUMMARY Scope: This routine, unannounced inspection involved 32 inspector-hours on site in the a reas of quality assurance (QA) program, QA/ quality control (QC)

administration, and tests and experiment Results: No violations or deviations were identifie .

8g1200155851108 a ADOCM 05000321 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• L. Byrnes, Senior QA Engineer P. Fornel, Manager, QA

• G. Goode, Supervisor, Plant Engineering and Services

• C. Goodman, Regulatory Compliance

"T. Green, Deputy General Manager M. Kehoe, Supervisor, Design Change and Modification Control Program Implementation

• D. McCusker, Superintendent, QC J. Newton, Supervisor, Maintenance

• S. Tipps, Superintendent, Regulatory Compliance

• D. Vaughn, Senior QA Field Representative

"J. Wilkes, Manager, Special Projects Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspectors

• P. Holmas-Ray, Senior Resident Inspector

• Nejfelt, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 11, 1985, with those persons indicated in paragraph I above. The inspector described the areas inspected and discussed in detail the inspection finding 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-inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio Abbreviations used in this report are as follows:

BOP - Balance of Plant-DCR - Design Change and Modification Control Program EPM - Engineering Practices Manual FLAR - Final Safety Analysis Report

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FT - Functional Test MAC - Management Analysis Company MWO - Maintenance Work Order QAM - Quality Assurance Manual PUP - Procedure Upgrade Program SPES - Supervisor Plant Engineering and Services SRB - Site Review Board TER - Test and Experiment Request TS - Technical Specification WCC - Work Control Center / Work Planning Group WPS - Work Process Sheet QA Program Review (35701)

Reference's: (a) 10 CFR 50.54(a)(1) Condition of Licenses (b) FSAR Section 17.2, Quality Assurance (QA) During the Operating phase, Revision 3 (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The inspector reviewed the licensee QA Program required by the above references (a) through (c) to determine if activities were conducted in accordance with regulatory requirement The following criteria were used during this review to assess the overall acceptability of the established program:

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Personnel responsible for preparing implementing procedures understand the significance of changes to these procedure Licensee procedures are in conformance with the QA Progra The procedures discussed throughout this report and those listed below wer reviewed to determined conformance with the QA Program:

QAM- Revision 36:

QA-04-01 QA Department Procedures and QA Manuals, Revision 4

' The inspector discussed Quality Assurance Program implementation and other

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. topics with three QA ~ auditors, the QA Supervisor, Regulatory Compliance personnel, ' and the QC Superintendent. Although the . QA office interfaces effectively with other' plant functionaries, the inspector determined that QA personnel work sufficiently independent of other site groups. The inspector also determined that QA personnel are working with written procedures 'in lieu of memorandum or guidelines which could be. transitory or-ineffective in nature.- QA personnel utilize expertise within their . group during performance of procedure reviews, surveillances, and other. Job-specific functions. -QA: personnel actively oversee that regulatory requirements such as TS changes are incorporated-into lower tier document _ - . _ . . _ .

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The inspector rev'iewed general onsite QA Program implementation as a part of the inspection. Each specific area is detailed in other paragraphs of this report. Problem areas, i f identified, are detailed in the specific area inspecte . QA/QC Administration (35751)

. References: (a) 10 CFR 50.54(a)(1), Condition of Licenses (b) FSAR Section 17.2, Quality Assurance (QA) During the Operating Phase

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(c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

(d) Regulatory Guide 1.33, Quality Assurance Program j Requirements (Operations)

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(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Technical Specifications, Section 6 s

The inspector reviewed the licensee QA/QC administration program required by references (a) through (f) to determine if QA/QC administration activities were conducted in accordance with regulatory requirements, industry guides i and standards, and Technical Specifications. The following- criteria were used during 'this review to access the overall acceptability of the established program:

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QA documents clearly identified those structures, systems, components,.

documents, and activities to which the QA program applie Procedures and responsibilities were e'stablished for making changes to QA program documents, e

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Administrative controls' were established for QA/QC procedures which assure procedure review and approval prior to implementation, control of changes.and revisions, and control of distribution and recal Responsibilities were assigned to assure .overall review of QA program effectivenes '

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Methods existed to. modify the QA program to provide increased emphasis

.on identified problem areas.

1 Specific comments addressing criteria one, two, and five above are detailed later.in this paragraph.

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The documents listed below were reviewed to determine if these criteria had been incorporated into QA/QC administration activities:

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i QAM Revision 36

- Section 1, Organization

- Section 2, QA Program

- Section 6, Document Control i- - Section 16, Corrective Action

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- Section 17, QA Records 10AC-MGR003-0 Preparation and Control of Procedures, Revision 2

10AC-MGR01-0 Plant Organization, Staff Responsibilities, and

Authorities,. Revision 1 i- 10AC-MGR02-0 Plant Review Board Administrative Procedure, j Revision 0

( -20AC-DCX01-0 Document Distribution and Control, Revision 0 i

QA-04-01 QA Department Procedures and QA Manuals, Revision 4

l, QA-04-17 Procedure-Review, Revision 2

'QA-05-01 Field Audits, Revision 13

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QA-05-17 QA Surveillance, Revision 1

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Through plant management discussions and QA audit . findings (audit report 85-QCA-1 dated March' 15, .1985), the -inspector determined that the QC

functional work scope is being decreased in the . area of DCR package implementation. The DCR provides 'information for1 modification construction.

i and testing ~to the plant Previously, QC had injected additional 4 engineering type information to the DCRl package during their review. Under

- the 1 forthcoming system, QC will review the package for- completeness, add their inspection hold points, and return the package to engineering should

- questions or problems be identified'in the packag The QC group adds their inspection hold points to. the DCR and MWO prior to-work - being performed. Hold points are work stoppage points 'within a procedure or chronology of a work sequence where the work crew must contact

' - QC ~ personnel 1 prior to continuing so 'that a QC inspection can perform .thec

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specified inspection. In Audit Report 85-QCA-1, dated - March 15,:1985, the

.following. problems with hold points were-identified:

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'In~ consistent hold point identification 'in- repetition of procedures orf

'similar-work sequences;

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Lack of hold point assignment.'at certain critical steps; I

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QC inspectors not performing the desired inspection at the hold points due to misunderstanding the step or lack of definition of the requirement; and

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Written criteria for hold point assignment was not establishe Corrective action for these problems is being addressed by the QC group, SRB, and Engineering which is the umbrella organization over QC. There is a possibility that Engineering may get involved with hold point assignment and criteria creation for DCR QA Audit 85-SA-7 dated November 30, 1984, addressed the fact that QC had not been performing minor surveillances in accordance with its own schedul These surveillances involved work practices and QC activity overview Management and QC were satisfactorily tracking this problem and surveil-lances should resume in the near futur Under the site QA Manager, two new supervisory positions have been described and fille These positions are the Audit and the Engineering / Support

Supervisor. The inspector interviewed the QA "anager and Audit Supervisor about organization, multiple tier document changes, goals, problem areas,

! and plant improvement areas. The above points were again discussed with QA auditors and other site functionarie The scope of QA activities has changed within the past yea The audit

depth has increase Audit personnel ~ are more than reviewing site programmatic aspects by having auditors overviewing site work activitie Checklists which are used by the QA group to define audit bounds have been expanded. A spot surveillance program which checks selected on going work has been institute During the inspection, the inspector identified certain concerns. When the inspector stated these concerns to site personnel, they informed the inspector that these concerns were already being tracked as audit finding The inspector confirmed that corrective action was occurring on these concerns which were addressed in this report and that site management was-involved in the corrective actio Section 17.2 of the FSAR contains QA program requirements. The inspector reviewed selected Revision 2 and 3 changes and ensured that those changes were implemented on sit According to QA and compliance personnel, consideration is being given to change the QAM format. The QAM is one document tier below the FSAR and has not been revised since 1982. Most changes to the FSAR, Section 17.2, are organizational in nature; driven by alterations in management at the corporate level. Technical Specifications are lagging behind the FSAR in these organizational areas. Section 17.2 of the FSAR may become a Topical _ Report which would address Hatch and Vogtle quality programs. Revision 4 of Section 17.2 is being developed and should contain the PUP new procedure numbering system and the latest organizational changes.

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The inspector was informed that the PUP was on going at the site. A new procedure numbering system was being inacted with this procedure upgrade attempt which was being carried out by site and MAC personnel. Older, satisfactory procedures were renumbered while new procedures are being written. QC and other site personnel expressed concerns about the new program and QA stated that they were actively monitoring the transitio The inspector did not review this program except to the extent where programmatic change interfaced with inspection area MW0s were being processed and controlled by the WCC. MW0s were assigned for all work on the plant inclusive of BOP and DCR except FTs and TERs. The WCC consisted of personnel from the majority of the site's functional groups such as QC, Operations, Health Physics, Mainter.ance, and Engineering. The WCC provided paperwork enclosures on MW0s except as indicated in paragraph 6. Hold point establishment and initial QC review occurred at the WCC. QA and QC were monitoring the critical work of the WC Within this area, no violations or deviations were identifie . Tests and Experiments (37703)

Reference: (a) 10 CFR 50 54(a)(1), Condition of Licenses (b) FSAR Section 17.2, Quality Assurance (QA) During the Operating Phase (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) 10 CFR 50.59, Changes, Tests, and Experiments (e) Regulatory Guide 1.33, Quality Assurance Program

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Requirements (f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants-The inspector reviewed aspects of the licensee's test and experiment program required by references (a) through (f) to determined if the program was in accordance with regulatory requirements, commitments in the application, and

industry. guides and standards. .The inspector specifically looked at post modification tests, tests and experiments outside of the scope of the FSAR, and functional tests performed post maintenance. The following criteria were used during this review to assess the overall acceptability of the established program:

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A formal method was established to handle all requests or proposals for conducting plant tests involving safety-related component ._ -

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Provisions were made to assure that all tests will be performed in accordance with approved written procedure Responsibilities were assigned for reviewing and approving test procedure Responsibilities were 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 (TS).

Comments regarding criteria above are addressed later in this paragrap The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's tests and experiments progra QAM Revision 36

- Section 3, Design Control

- Section 10, Inspection

- Section 11, Test Control

, - Section 14, Inspection, Test, and Operating Status EPM Dated July 19,'1984

- Section 2, Work Process Controls

- Section 3,. Inspection and Test Plans

- Section 4, Functional Testing Guidelines a

40AC-ENG03-0 Design Control, Revision 0 t

50AC-MNT01-0 Maintenance Program, Revision 2 40AC-QCX01-0 -Quality Control Inspection Program, Revision 0 40QC-QCX02-0 Quality Control Inspection Plans, Revision 0 42EN-ENG08-0 Test or Experiment Request 42EN-ENG01-0 DCR Processing-10AC-MGR02-0 Plant Review Board Administrative Procedure, Revision 6

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DI-ENG-04-0284 DCR Forms Instructions, Revision 1 The inspector reviewed functional tests for the following DCRs:

DCR 84-201 Automatic Depressurization System Bypass Logic

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DCR 84-165 H and 0 Analyzer Logic Modification The inspector compared the site's final version of the tests with Architect / Engineer's draft of the tests. Where differences occurred, the inspector had licensee personnel detail the reasons. The inspector further reviewed these tests for intent and completeness. An attempt was not made by the inspector to determine if the tests were qualification tests as indicated in ANSI N45.2.1 The inspector reviewed the following tests and experiments performed on site since the last inspection in this area:

Test Unit Revision Date TER 84-01 2 0 February 7,1984 TER 84-16 1 0 October 10, 1984 TER 85-09 1 and 2 0 March 1985 TER 85-10 1 0 May 17, 1985 TER 85-11 2 0 May 20, 1985 TER 85-12 1 0 July 1985 TERs packages consisted of test requests, safety analyses, and the test Completed test requests were reviewed for proper authorization. Safety analyses were reviewed for content, criteria, and proper management evaluatio Tests were reviewed for intent, acceptance criteria, authorization, results, and proper closur TERs and post DCR construction functional and operability tests were not controlled by MW0s and the WCC. Both were controlled by the responsible engineer and operations. For DCRs, the responsible engineer signs for satisfactory test completion and WCC signs for the remainder of the DCR packag The inspector discussed with cognizant personnel potential weaknesses in that no single person reports to management for completion of the DCR prior to system operation. Additionally, there is no written verification that required drawings have been changed or necessary training has occurred prior to DCR acceptance. These usually occur informally prior to DCR acceptanc Outside of the historical, preoperational test manual, there was no specific, site operational test control document. The general requirements for testing control can be found dispersed in site procedures. Specific I problems related to incorporation of ANSI N18.7 and N45.2.11 requirements into procedures were identified in Audit QA-85-SA-3, dated June 14, 198 This audit also identified problems with post maintenance FTs. With a large !

sample size, the QA group identified that a significant number of MW0s had )

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inadequate or missing FTs. An SRB subcommittee is sampling MW0s over a longer period for trending and will make recommendations based on its sampling results. Corrective action ' for these problem areas is being monitored by Q Dispersed. test control requirements have also caused minor problems on sit Audit report 85-DCR-1, dated May 20, 1985, identified these problems in the DCR functional test area. This audit, however, only reviewed FTS and did not consider dynamic system testing. QA is scheduled to reaudit the DCR area during the November 1985 outage. Corrective action for these problems

.is also being monitored by Q Within this area, no violations or deviations were identifie . _ _ _ _ _ _ _ . - . _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ ____- ____ _ _ _____ - - -