ML20150B588
| ML20150B588 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/16/1988 |
| From: | Belisle G, Matt Thomas, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20150B558 | List: |
| References | |
| 50-425-88-28, NUDOCS 8807120081 | |
| Download: ML20150B588 (9) | |
See also: IR 05000425/1988028
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UNITEC STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST N.W.
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ATLANTA, GEORGIA 30323
Report No.:
50-425/88-28
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 9-13 and 23-26, 1988
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Inspectors:
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R. W. Wright
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Approved By:
G. A.-Belisle, Chief
Date Signed
Quality Assurance Programs Section
Operations Branch
Division of Reactor Safety
SUMMARY
Scope:
This special, announced inspection was conducted in the area of
Readiness Review Module Appendix F, Inspector Qualification.
Results:
Appendix F presents an accurate description and evaluation of the
Unit 2 inspector qualification and certification program with the following
exception.
One violation was identified in this area (Failure to utilize certified Field
Level III inspectors as required by ANSI N45.2.6 - 1978, paragraph 5).
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REPORT DETAILS
- 1.
Licensee Dnployees Contacted
- D. M. Fiquett, Assistant Project Construction Manager II
- A. B. Gallant, Project Compliance Coordinator, and Technical Support
Group Supervisor
- L. R. Glenn, Quality Control Manager
E. D. Groover, Quality Assurance Site Manager - Construction
- S. D. Halton, Quality Assurance Support Supervisor
D. C. McAffee, Technical Support Group Engineer and Appendix F Readiness
Review Member
- R. W. McManus, Assistant Project Construction Manager II, and Readiness
Review Manager
- P. D. Rice, Vice President, and Vogtle Project Director
-0ther licensee employees contacted during this inspection included various
disciplined GPC/ contractor technical and NDE QC inspection personnel.
- Attended exit interview
2.
Introduction
The scope of this Appendix F assessment plan (submitted to NRC on
March 30, 1988) is to evaluate the acceptability of programs for
qualifying and certifying all GPC and site contractor QC personnel
involved in constructing Unit 2 after June 1985.
Unit l's RR Appendix F (submitted to NRC on February 7,1986) evaluated
the acceptability of programs and inspector qualifications for both Unit 1
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and Unit 2 prior to June 1985.
VEGP was designed and constructed as an
integrate facility and construction personnel involved in the inspecting
Unit 1 alsc performed Unit 2 inspections.
NRC Inspection Report
No. 50-424/86-24 dated October 1,
1986, concluded that the Unit 1
Appendix F assessment of VEGP IQC programs was satisfactory.
The RR assessment program for evaluating the qualifications and
certifications of post June 1985 Unit 2 QC inspectors consisted of three
major activities.
These activities evaluated the project IQC procedures,
evaluated project training programs, and evaluated project QC inspector
certification records.
The RRT review used a specific checklist for each
assessment activity.
The ccmmitments assassed for implementation are
current through November 1,1987, and Amendment 34 of the FSAR.
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3.
. Methodology-
The-NRC Unit 2 technical Appendix F review and evaluation was conducted in -
the Region II office during May 2 - 6 and May 16 - 19 and was supported by
onsite inspection activity during May 9 - 13, and May 23 - 26, 1988.
The Region II inspection review effnrt for Unit 2's Appendix F consisted
of the following:
Reviewing all VEGP IQC licensing commitments to insure completeness
Reviewing all GPC and site contractor IQC procedures revised since
June 1985 to insure proper commitment implementation therein
Reviewing GPC or contractor QC inspector certification records to '
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ascertain agreement with current project procedures and RG 1.58
Reviewing VEGP IQC training programs for acceptebility
Reviewing the Unit 2 NRC inspection program at VEGP for its adequacy
Interviews with severa'l contractur and GPC inspection personnel
concerning the adequacy of their IQC programs
Summary of conclusions
4.
Licensee Commitments And NRC Requirements
RR maintained the Unit 1 connitment matrix current for design and
construction by reviewing FSAR Anendments, responses to Inspection and
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Enforcement Bulletins, and correspondence to the NRC.
Additionally,
during the Unit 1 RR assessment, the task force identified project
controls (construction procedures, etc.) that implemented the commitment
requirements and listed them on a document called the implementation
matrix.
The Unit 1 implementation matrix was reexamined by appropriate
project organizations for updating the matrix data to reflect the latest
implementing documents for Unit 2.
The RR group verified the updated
implementing matrix accuracy.
The RR group examined all audits conducted
by GPC QA and Bechtel Western Power Company QA.
They also examined NRC
inspection results performed in the area of IQC that were conducted
subsequent to the Unit 1 Appendix F date.
These audits resulted in four
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findings which identified discrepancies in documentation requirements or
use of a wrong code edition.
The findings did not identify deficiencies
in inspector qualifications.
NRC violations were not identified.
The
above resulting findings applicable to this apperJix were factored into
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the licensee's review and assessment of the Unt' 2 IQC program.
Additionally, former Unit 1 Appendix F findings wre evaluated to
determine if they were still applicable to Unit 2 and, if s), were they
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being properly addressed in Unit 2 programs.
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As described in Section 3, the project is committed to ensure that GPC's
and the contractor's IQC programs conform to RG 1.58, R1-1980.
In
accordance with RG 1.58-1980, technical inspectors were qualified and
certified according to requirements established by ANSI Standard
N45.2.6-1978. NDT examiners are qualified and certified according to ASNT
Recommended Practice'No. SNT-TC-1A-1975.
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The only-substantial change to the above mentioned commitments since the
Unit 1 Appendix F review appeared in Amendment 16 discussed in
Section 1.9.58.2 of the FSAR.
In lieu of SNT-TC-1A-1975, the licensee
elected to endorse SNT-TC-1A-1980 for qualifying GPC construction and
nuclear operations personnel performing nondestructive examinations.
Additionally, most of the "shoulds" contained in the 1980 edition were
replaced with "shalls" except for two instances which are clearly denoted.
This change applied only to GPC NDT personnel and did not affect VEGP site
contractors comitted to SNT-TC-1A-1975.
The inspectors reviewed all the commitments identified in the Appendix F
Commitment Matrix and confirmed they were the same as those in Vogtle FSAR
Amendment 34. The inspector's review of Generic Letters and NRC Bulletins
written since 1985, and examination of the Vogtle SER did not identify any
questions pertinent to the licensee's IQC program commitments.
The
inspectors ascertained that the Unit 2 IQC commitments satisfied
NUREG-0800 Guideline Areas 20, Provisions To Assure Adequacy Of Personnel
Qualifications, and 108, Organizational Responsibilities And Qualification
Established For Individuals Or Groups Performing Inspections.
The
inspectors concluded that the Unit 2 Appendix F Comitment Matrix as
submitted is correct, complete, and adequate for VEGP IQC programs.
5.
GPC Implementation Programs And Precedures Review
The NRC inspectors reviewed the Unit 2 Implementation Matrix contained in
Section 3 to ascertain if it reflected the current implementing documents
and to verify that the program and procedures established to implemeat the
requirements of the Comitment Matrix were identified and appeared
reasonable.
Additionally, the inspectors extmined the GPC/ Contractor
programs and implementing procedures described in Sections 4 and 6.4.1 to
determine that they conformed to the requirements of the matrix.
The RRT developed three comprehensive inspection checklists which included
all the rcquirements of ANSI N 45.2.6 SNT-TC-1A-1975 and SNT-TC-1A-1980
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respectively.
These checklists were used in assessing GPC/ Contractor IQC
programs and for verifying procedure conformance to licensing commitments.
The- assessment resulted in three RR findings (2RRF-21F-001, 002, 003) for
procedures that lacked details or contained errors.
GPC's corporate NDE
Procedure GEN-12750, R3 did not reouire NDE personnel to have a high
school diploma or GED diploma, nor was that requirement present in NISCO
Procedure ES-116-2, R1, for Levels II and III technical inspectors.
Subsequent examination of certification files for the GPC NDE, and NISCO
Levels II and III technical inspectors confirmed that all personnel had
either high schoci diplomas or a GED diploma.
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Procedure GEN-12750, R3, also specified on Exhibit 01, that the required
training for leak testing Level II was 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> whereas tne 1980 edition of
SNT-TC-1A recomend- 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of training.
The Project was found to be
giving c 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> leak' test training course making this deficiency an
administrative type error.
- PPPLProcedure II-2,= revision dated August 15, 1986, did not address the
SNT-TC-1A-1975 requirement to find at least 90 percent of the known
indications. . Although this specific requirement' was not specified by
procedure it was being adhered to by NDE examiners.
The NRC .. inspectors reviewed the' above RR findings .and verified that
affected procedures were revised to incorporate the above mentioned
requirements.
The NRC inspectors reviewed the subject check lists
(iontained in Section 8) to assure they contained all the requirements of
th. above mentioned ANSI Standard and ANST Recommended Practices.
The
inspectors- cross . referenced all (100 Percent) of the RRT checklist item
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'results to the applicable GPC/ Contractor implementing IQC procedures to
ensure their findings were correct and that no conflicting procedural
revisions had been incorporated since the Appendix F review.
-Based on this 100 Percent NRC inspector review of all GPC/ Contractor
implementing procedures (described in Tables 4-1 and 6-2) that had been
revised since June 1985, the inspectors concluded that all the VEGP IQC
commitments and regulatory requirements were conteined within these
procedures with the following exception.
FSAR, Section 1.9.58, specifies that VEGP commits to RG 1.58, R1, which
endorses ANSI N45.2.6-1978 with a few exceptions that are discussed in
detail.
Procedure QC-A-01, Qualification and Certification of Techrfcal
Inspectors, is GPC's construction proc '>re for implementing of ANSI
N45.2.6-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. requirements.
Procedure Qo-A-01, RS, (Sections 4.5 ed
Exhibit 15) allows an Administrative Level III person to pe rforra the
functions specified in ANSI N45.2.6-1978 (Petion 4 and Table :) as Field
Level III responsibilities although the administrator's education anc
experience qualifications may or may not be equivalent.
Level III
Administrators are appcf.;ted by the Manager of Quality Control by
memorandum.
Review of the FSAR exceptions to ANSI 45.2.6-1978 revealed
that GPC did not mention the use of an Administrative Level III position
in lieu of a Field Level III inspector to perform these functions.
Since
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no exception was taken, a commitment to comply with the ANSI Standard
means the specific education and experience recomendation of the standard
has to be followed.
This item was identified as violation 425/88-28-01,
Failcre to Utilize A Field Le'rel III Inspector As Committed Per ANSI
N45.2.6-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
This violation cnly applies to GPC technical inspectors and
does not affect GPC NDE nor any contractcr inspection personnel.
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During the procedural inspection review, one other isolated deficiency of
no safety significance was identified. While reviewing Procedure QC-A-01,
R5, the inspector found that FPCN No. 7 was not _ incorporated as indicated
by the procedure's cover page.
Discussions with' cognizant personnel and
subsequent documentation reviews revealed that before Revision 5 was
issued, FPCN No. 7 was reviewed and modi fied.
The' personnel on the
approval cycle for Revision 5 were all_ familiar with the above
modification and approved it for issue on April 6,1987, but failed to
notice that the description of the revision on the cover page.had not been
corrected.
Prior to leaving the site the licensee issued a new cover page
to QC-A-01, RS, which stated it incorporated FPCN No. 7 as Modified.
6.
Inspector Certification Records
.The RRT examined 37-GPC/ Contractor QC inspector certification files which
contained a total of 235 certifications using the inspector certification
checklists found in Section 8.
The RRT identified three deficient record
findings (2RRF-21F-004, 005, 006), two of which involved GPC and WPS' QC
inspector personnel receiving physical eye examinations by persons for
which had no documented evidence of their quf ' rications or training in
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this area. The third finding involved some k
inspecter certification
forms that were not entirely completed.
The
inspector examined the
remedial actions and actions taken to prevent recurrence for these
findings and found. them satisfactory.
NRC site verificatica activities performed included reviewing a sampling
of both the GPC and site contractor inspection certification files that
were examined by the RRT and the expansion of that sample to others not
examined by the RRT.
This NRC inspection effort resulted in one finding.
Examination of five PPP QC inspector certification files not previously
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reviewed by the RRT revealed one that was missing a letter of certifica-
tion for UT Thickness Measurement.
NRC examination of other supporting
documentation (training, attendance, and testing records) verified the
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subject inspector was certified in the area but for some reason the letter
of certification was inadvertently left out of his certification file.
The PPP Training Officer corrected this oversite prior to the NRC
inssactor leaving the site.
7.
Evaluation Project Training Programs
During the Unit 2 RR assessment, the inspector training programs were
reviewed using a training program checklist (see Section 8) that addressed
nine issues.
Attributes for the evaluation checklist were based on broad
industry issues that were extracted from the concerns expressed in NRC
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Construction Assessment Team Inspection Reports from different facilit*es
under construction.
The NRC inspectors examined the above completed checklists and supporting
procedural evidence and ascertained that VEGP IQS program was not affected
by the above industry training issues.
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8.
NRC Inspection Prograin And Inspection Reports
The NRC inspectors examined the NRC's Construction Inspection Program
implemented for Unit 2 since June 1985, and concluded that the VEGP IQC
activities and programs have continued to be sat ';factorily covered and
generally in accordance with requirements.
This was accomplished by
examining a random sample of Hegion II Inspection Reports covering
procedures ending in xxx53 and xxx55 (work observatf or and records
review), procedure 35061 (QA inspection of work activities) and resident
inspection reports.
The inspector examined previous NRC inspection findings as of April 4,
1988; for Unit 2 in the area of IQC. This examination disclosed that one
Severi ty Level V violation was issued since June 1985.
Violation
425/86-45-02 was issued for failure to provide training for electrical
engineers and QC staff on the - use of Raychem Products.
However,
subsequent NRC followup of this violation (NRC Inspection Report No.
425/87-06) disclosed that the training deficiency only applied to Project
Field Engineers and not to QC personnel. Consequently, no IQC violations
have been identified since June 1985.
Review of the above mentioned
inspection reports and previous findings indicated that no adverse trends
existed in Unit 2 IQC program.
9.
Inspection Personnel Interviews
The NRC inspector conducted interviews with several Contractor (3-PPP,
2-WPS, 1-NISCO, 1-P/K-F) and GPC (5) inspection / testing oersonnel
concerning:
their training, education and qualifications
the capabilities and qualifications of their fellow inspector type
co-workers
their opinion of the adeqJacy of the inspection procedures in the
areas they are certified to inspect
how problems are identified and handled
their opinion of management's handling of problems identified
their opinion of management's attitude toward quality
The NRC inspector received generally positive and favorable responses to
all of the above questions asked.
There were no negative comments or
opi. dons expre; sed concerning their inspection programs, and no one was
aware of any existing plant hardware problems that had not been adequately
addre; sed.
All inspectors felt their co-workers (both present and past)
were teli qualified to handle their respective inspection responsibilities
and continue to do so. Several inspectors stated that some inspectors may
be more conscientious and do their job better than others, but all
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inspection requirements are enforced and inspected prope'rly by everyone.
-The crafts go beyond minimum acceptable construction requirements to
ensure their work task receives QC acceptance.'
They stated that their
inspection programs (implementing procedures) have been continually-
revised, generally for the better as construction progressed to the point
that they- are now rather fine tuned.
They stated that the. training
inspectors.have received has been good, more than adequate to handle their
l Job and may be useful in securing another line of work when Unit 2 construc-
tion is completed.
They .also stated that management is understanding and
attentive to the problems they identify, takes time to explain differences
of opinion on issues, and appears to have
'avorable attitude toward
quality.
10. Conclusions
The Appendix F executive summary states, "RR concludes that adequate.
programs exist to ensure that the quality of inspector certifications and-
' the licensing cow 'tments within the scope of this appendix have been
implemented." Section 6.3 further states, "The review team found that
project programs as implemented meet licensing ccmmitments.
Inspector
certifications were acceptable and records were la good order with the
exception of a few record keeping, or administrative errors."
As'a result of the NRC verification activities conducted and discussed in
this report, the inspectors concluded that Appendix F (including-the above
summary statements) reflect an accurate description and evaluation of the
Vogtle Unit 2 IQC program with the one exception taken as noted in
paragraph 5.
Subsequent examination of the GPC QC Manager appointed
Level III Administretors disclosed that most met the education and
experience requirements of a Field Level III inspector or were college
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engineering graduates with conalderable engineering experience.
GPC
currently has and has had a viable working IQC program.
The NRC also
concluded that Unit 2, Appendix F.is adequate.
11.
Exit Interview
The inspection scope and results were summarized on May 26, 1988, with
those persons indicated in paragraph 1.
The inspector described the areas
inspected and discussed in detail the inspection results . listed below.
Proprietary information is not contained in this report.
Dissenting
comments were act received from the licensee.
Violation 50-425/88-28-01, Failure to utilize certified Field Level III
inspectors as committed per ANSI N45.2.6-1978, paragraph 5.
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~ 12'.- Acronyms And Initialisms -
ANSI
American National Standards Institute
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American Society for Nondestructive Testing
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ASNT
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Field Procedure Change Notice
.FPCN
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Final Safety. Analysis Report
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General Education Development -
GED
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Georgia Power Company
GPC
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Inspector _QualificeAion and Certification
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IQC
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Nondestructive Testing
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NDT'
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Nuclear Installation Services Company-
NISCO
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Nuclear Regulatory Commission
NRC
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Pullman Construction Industries /Kenith-Fortson, Inc.
P/K-F
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PPP
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Pullman Power Products
Quality Assurance
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Quality Control
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Regulatory Guide
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Readiness Ret'ew
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RRT
Readiness Review Team
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Safety Evaluation Report
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SER_
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Ultrasonic
'UT
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Vegtle Electric Generatirg Plant
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Williams Power Services
WPS
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