ML20198G903

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Informs That SALP Board Repts 50-321/85-21,50-366/85-21, 50-424/85-27 & 50-425/85-26 Accurately Reflect Performance Level Area of Maint,In Response to Request for Reconsideration of Category 3 Rating
ML20198G903
Person / Time
Site: Hatch, Vogtle, 05000000
Issue date: 01/15/1986
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Kelly R
GEORGIA POWER CO.
References
NUDOCS 8601300008
Download: ML20198G903 (6)


See also: IR 05000321/1985021

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JAN 15 1986

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Georgia Power Company

LATIN:

Mr. R. J. Kelly

Executive Vice President

P. O. Box 4545

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Atlanta, GA 30302

Gentlemen:

SUBJECT:

SYSTEMATIC ASSESSMENf 0F LICENSEE PERFORMANCE REPORT N05. 50-321/85-21,

50-366/85-21, 50-424/85-27, AND 50-425/85-26

This refers to the NRC's Systematic Assessment nf Licensee Performance (SALP)

Board Reports for your E. I. Hatch and A. W. Vogtle facilities which were sent to

you on October 23, 1985; our meeting of November 4,1985, at which we discussed

these Reports; and your written comments dated December 2,1985, relative to

these SALP Reports.

Af ter careful review of the comments contained in your response to the E. I. Hatch

SALP Report, I concur that actions taken or underway in the functional area of

training should be offective.

Your comments also raised certain issues regarding the conclub sons reached by the

SALP Board in the functional area of maintenance.

I have carefully reviewed

these comments and, although I acknowledge your reasons for requesting our

reconsideration of the Category 3 rating in the maintenance functional area, I

have concluded that the SALP Board Report accurately reflects your performance

level in this area.

The 15 violations identified in the maintenance area indi-

cated significant problems in adherence to procedures, proper assignment of

functional testing following maintenance, proper identification of root causes,

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and involvement of quality control.

These problems, although to a lesser extent,

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were still apparent at the end of the SALP period.

The SALP Board recognized

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that you had shown improvement over the SALP period as evidenced by the increasing

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trend indicated in the Report.

However, the rating was for the entire period,

and the weaknesses still present and the problems as originally identified were

factors in the Category 3 rating.

As you are aware, the Category 3 ratings in training and maintenance classify the

conduct of nuclear activities as acceptable; however, the ratings represent staff

findings that these functional areas did not receive proper management attention

and that additional involvement by management is needed.

No reply to this letter is required; however, should you have any questions

concerning these matters, I will be pleased to discuss them with you.

Sincerely,

Original Signed by

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J. N. Graec

PDH

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J. Nelson Grace

Regional Administrator

Enclosures:

(see page 2)

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Georgia Power Company

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JAN 15 1900

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Enclosures:

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1.

Appendix to Georgia Power Company,

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E. I. Hatch Units 1 and 2 SALP

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Board Report (dated October 23, 1985)

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2.

Appendix to Georgia Power Company,

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A. W. Vogtle Units 1 and 2 SALP

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Board Report (dated October 23, 1985)

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3.

SALP Board Report Errata Sheet

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cc w/encIs-

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diT.Beckham,VicePresidentand

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General Manager-Nuclear Operation

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f. C. Nix, Site General Manager

L (.' E. fornel, Site QA Supervisor

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LL 'T. Gucwa, Chief, Nuclear Engineer

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g R. E. Conway, Senior Vice President

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~ Nuclear Power

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vD. O. Foster, Vice President

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and General Manager Vogtle Project

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pH;' H. Gregory, III, General

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Manager, Vogtle Nuclear Construction

g,Gt Bockhold, Jr. , Vogtle

Plant Manager

pRuble A. Thomas,

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Vice President-Licensing Vogtle

Project

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61 Groover, Quality

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Assurance Site Manager

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-C. W. Hayes, QA Manager

tJ. T. Beckham, Vice President

& General Manager - Operations

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Pd. A. Bailey, Project Licensing

Manager

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(George F. Trowbridge, Esq.

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Shaw, Pittman, Potts and Trowbridge

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b8ruceW. Churchill,Esq.

Shaw, Pittman, Potts and Trowbridge

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Ernest L. Blake, Jr., Esq.

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Shaw, Pittman, Potts and Trowbridge

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(James E. Joiner, Troutman, Sanders,

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Lockerman and Ashmore

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dames G. Ledbetter, Commissioner

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. Department of Human Resources

tharles H. Badger, Of fice of

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Planning and Budget, Management

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Review Division

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(Cont'd page 3)

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JAN 15 1986

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(Cont'd)

(Deppish Kirkland, III, Counsel

Of fice of the Consumer's Utility

Cour.cil

Douglas C. Teper, Georgians Against

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Nuclear Energy

Jaurie Fowler, Esq., Legal Environmental

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Assistance Foundation

v Tim Johnson, Executive Director

Campaign for a Prosperous Georgia

Morton B. Margulies, Esq., Chairman

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Administrative Judge, Atomic Safety

and Licensing Board Panel

LDr. Oscar H. Paris, Administrative Judge

. Atomic Safety and Licensing Board Panel

pGustave A. Linenberger, Jr. , Administrative

Judge, Atomic Safety and Licensing Board

Panel

Jillie Pirner Garde, Citizens

Clinic Director, Government

Accountability Project

bcc w/encIs:

Whairman Palladino

t. Commissioner Roberts

Commissioner Asselstine

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Commissioner Zech

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5U 1986

ENCLOSURE 1

APPENDIX TO GEORGIA POWER COMPANY

E. 1. HATCH UNITS 1 AND 2

SALP BOARD REPORT

(DATED OCTOBER 23, 1985)

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Enclosure 1

2

JAN 15 W86

I.

Meeting Summary

A.

A meeting was held at 1:30 p.m. , on November 4,1985, at your corporate

offices in Atlanta, Georgia to discuss the SALP Board report.

B.

Licensee Attendees

R. W. Scherer, Chairman of the Board and Chief Executive Officer

J. H. Miller, Jr. , President

R. J. Kelly, Executive Vice President, Power Supply

J. T. Beckham, Jr. , Vice President and General Manager, Nuclear

Operations

Harvey Nix, General Manager, Plant Hatch

M. B. Hobby, Assistant to President

Don Crowe, Nuclear Safety Manager

L. T. Gucwa, Manager, Nuclear Safety and Licensing

J. J. Badgett, Manager, Nuclear Training

R. D. Baker, Nuclear Licensing Manager, Plant Hatch

S. C. Ewald, Manager, Radiological Safety

Max Manry, Manager, Nuclear Performance and Analysis

A. W. Benson, Manager, Security

D. S. Read, Deputy General Manager, Quality Assurance

David R. Altman, Nuclear Information Manager

J. R. Roberts, Superintendent, Uniform Security, Nuclear

C.

NRC Attendees

J. A. 01shinski, Deputy Regional Administrator, Region II (RII)

R. D. Walker, Director, Division of Reactor Projects (DRP), RII

A. F. Gibson, Director, Division of Reactor Safety (DRS), RII

V. L. Brownlee, Chief, Reactor Projects Branch 2, DRP, RII

J. F. Stolz, Chief, Operating Reactors Branch 4, Division of Licensing

(DL)

G. W. Rivenbark, Project Manager, Operating Reactors Branch 4 DL

P. Holmes-Ray, Senior Resident Inspector, Plant Hatch

G. M. Nejfelt, Resident inspector, Plant Hatch

R. E. Carroll, Jr. , Project inspector, Reactor Projects Section 28,

DRP, RI!

D. B. Gruber, Technical Support Inspector, Technical Support Section,

DRP, RII

II.

Licensee Comments

Licensee comments submitted in iesponse to the SALP Board Report for

E.I. Hatch follow,

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J +4 M.Her Jr

NED-85-875

2351N

December 2,1985

U. S. Nuclear Regulatory Commission

REFERENCE:

Office of Inspection and Enforcement

RII: JNG

Region II - Suite 2900

Inspection Reports

101 Marietta Street, NW

50-321-50-366 85-21)

Atlanta, Georgia 30323

50-424-50-425 85-27)

.

ATTENTION: Dr. J. Nelson Grace

Gentlemen:

By letter dated October 23, 1985, the Nuclear Regulatory Connission

(NRC) transmitted the Systematic Assessment of Licensee Performance (SALP)

report for Plant Hatch and Plant Vogtle and requested connents from the

Georgia Power Company (GPC).

The SALP assessment covered a period of twenty

months from November 1, 1983 through June 30, 1985.

On November 4,1985, a

public meeting between the NRC and GPC was held to discuss the details of

this important report.

GPC recognizes and appreciates the observations made in your report

regarding the performance of Plant Hatch and Plant Vogtle.

GPC believes

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that such evaluations of licensee performance benefit GPC and the public by

focusing attention on matters important to plant safety.

GPC is committed

to

the

safe

operation

and

construction

of

its

nuclear

facilities.

Accordingly, we intend to be fully responsive to the observations discussed

in your report.

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Enclosed are GPC's responses to the evaluations.

Enclosure I addresses

Plant Hatch and Enclosure 2 addresses Plant Vogtle.

In our response for

Plant Hatch, we identify a disagreement with your evaluation of Category 3

in the functional area of Maintenance.

We request that you reconsider this

specific evaluation based on our connents and the volume of activities that

took place during the twenty month evaluation period.

We believe a Category

2 evaluation

is justified.

Notwithstanding, our corrective action to

further improve our maintenance program is proceeding on a high priority

basis.

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U. S. Nuclear Regulatory Comission

Offica of Inspection and Enforcement

Region !! - Suite 2900

December 2, 1985

Page Two

We would be pleased to discuss this response or answer questions you may

have.

Yours very truly,

m

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J.

illey, Jr.

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Enclosure 1

Coments on SALP Report for Plant Hatch

Enclosure 2

Coments on SALP Report for Plant Vogtle

c:

Mr. R. E. Conway

Mr. J. T. Beckham, Jr.

Mr. D. O. Foster

Mr. G. Bockhold, Jr.

Mr. H. C. Nix, Jr.

SeniorResidentInspector(Hatch)

Senior Resident inspector (Vogtle)

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ENCLOSURE 1

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COMMENTS ON SALP REPORT FOR PLANT HATCH

INTRODUCTION

Georgia Power Company (GPC) has concluded that the ratings presented in

the SALP report for Plant Hatch reflect the Plant's level of performance,

except in the functional area of Maintenance.

GPC has carefully reviewed

the SALP report and has several coments on each of the functional areas.

Special attention has been directed to the functional areas of Maintenance

and Training.

OPERATIONS

Our performance was evaluated as a Category 2 (Management attention and

involvement are evident and resources are adequate).

We are pleased

that the NRC recognized an improvement in this period.

GPC has been and

is

devoting

management

attention

to

this

most

important

area.

Specifically, GPC has substantially increased its corporate office

nuclear staff, applied additional resources to procedural development,

and placed plant emphasis on improving procedural compliance by both

operations and maintenance personnel.

RADIOLOGICAL CONTROLS

Our performance was evaluated as Category 1 (Management attention and

involvement are aggressive and oriented toward nuclear safety and

resources are ef fectively used).

GPC is very sensitive to the need to

protect our employees, as well as the public, from unnecessary radiation

exposure.

In this regard, we are proud of the NRC's evaluation.

Our

company will continue to apply the necessary resources to further

improve Radiological Controls.

MAINTENANCE

Our performance was evaluated as Category 3

(Licensee management

attention or involvement is acceptable and considers nuclear safety, but

weaknesses are evident).

In our view, the NRC rating reflects a

disproportionate reliance on a number of relatively minor violations.

Plant Hatch's maintenance program has improved significantly because of

actions which were under development and partially implemented during

the SALP period.

Thus, GPC requests reconsideration of the Category 3

evaluation.

We believe that it is important to recognize that during this evaluation

period. Plant Hatch scheduled and successfully managed one of the most

extensive and difficult maintenance efforts ever implemented at the

Plant,

It was, in our view, one of the more dif ficult ptriods relative

to other nuclear power plants. At times the Plant undertook an

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ENCLOSURE I (Continued)

COMENTS ON SALP REPORT FOR PLANT HATCH

appearance that resembled initial construction-like efforts,

(e.g.,

those activities associated with recirculation pipe replacement and

repairs, torus modifications and replacement of electrical equipment).

In

spite

of

such

expanded

maintenance

activities,

maintenance

performance improved and only minor deficiencies were identified by the

NRC. Our evaluation of the overall situation leads us to conclude that

a fair evaluation is Category 2.

Notwithstanding our view of the NRC

evaluation, the following actions are being taken:

1.

As discussed with your staff, GPC will schedule quarterly meetings

with NRC Region

!!

to

include

the detailed status of our

maintenance activities.

We believe this type of meeting will

enhance comunications and improve performance.

2.

As discussed in the SALP meeting, GPC will, in the near future,

complete its staffing in the Maintenance and Outage Planning Areas

in the General Office.

We believe this level of additional

professional support to our plants will substantially enhance

performance.

3.

GPC will continue to address the following items:

a.

Adherence to procedures / Attention to detail:

(1) Procedure upgrade program is in progress to improve the

quality of the procedures.

This will be a major ongoing

effort with expected completion by the end of 1987.

(2) Efforts to achieve Accreditation are in progress for

maintenance with both current specific equipment and

certification training to begin in the second quarter of

1986.

(3)

Increased

involvement

of

supervisory

personnel

was

accomplished during the course of the SALP review period

by adding six maintenance foremen, three !&C foremen and

one maintenance supervisor.

b.

Proper assignment of functional testing following maintensicc:

(1) A Work Planning Group was established during the SALP

review period to ensure that functional testing will to

adequately performed folloning maintenance,

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ENCLOSURE 1(Continued)

ComENTS ON SALP REPORT FOR PLANT HATCH

(2) As the maintenance procedures are upgraded, required

functional tests will be more clearly identified and

formally documented procedurally.

These actions will

further

assure

that

required

functional

tests

are

properly conducted.

c.

Proper identification of " root causes":

(1) There continues to be increased emphasis on root cause

determination by site personnel with increasing corporate

support.

Maintenance engineering currently reviews plant

equipment maintenance work orders (MWO's) and provides

trending of problem areas for management review and

follow-up.

(2) A corporate maintenance group, already recruited, will

review significant or recurring corrective maintenance

activities and will provide strong site support.

(3) A computerized MWO tracking system

is

currently

in

place.

It is the primary tool for supporting these

trending and " root cause" efforts.

d.

Quality control involvement and QC functions for major jobs

will be conducted by GPC as a general rule.

When QC must be

contracted out for specific activities, site QC will be more

directly involved in the control of these activities.

SURVEILLANCE

Our performance was evaluated as Category 2.

GPC agrees with the NRC's

evaluation of the Plant Hatch surveillance program.

In order to ensure

that the surveillance program continues to be an effective one and that

further

improvements

are

made,

GPC

has

initiated

a

Technical

Specification

surveillance

review,

devoting

increased

Company

and

consultant resources to improve Plant Hatch's surveillance program.

FIRE PROTECTION

Our performance was evaluated as Category 2.

Plant Hatch has continued

to demonstrate improved performance in the fire protection functional

area.

Special

measures have been

taken to

improve

surveillance,

training, and maintenance.

As the final Appendix R retrofits are

complet*..

the

fire

protection

performance

should

show

further

improvements.

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ENCLOSURE 1 (Continued)

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COMMENTS ON SALP REPORT FOR PLANT HATCH

EMERGENCY PREPAREDNESS

Our performance was evaluated as Category 2.

GPC agrees with the NRC's

evaluation.

Additional training has been conducted for operations

supervisors and other key emergency planning positions.

Additional

training

and drills will

be

conducted to ensure

that

Emergency

Preparedness is maintained at high standards.

GPC sincerely believes

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that emergency planning and preparedness is an important part of our

defense-in-depth philosophy relative to public safety and comits to

achieving improvements.

SECURITY

Our performance was evaluated as Category 2.

GPC agrees that a Category

2 evaluation is appropriate.

We are disturbed with the NRC's reported

declining trend.

Improvements will be implemented to attain better

performance

such

as

state-of-the-art

equipment,

reviews

of

the

organization and staffing levels, and reconsideration of modification to

our security building.

REFUELING /0UTAGES

Our performance was evaluated as Category 2.

Again, GPC notes that

during this SALP period

Hatch experienced two major outages, including

a 7-1/2 month outage to replace Unit 2 recirculation piping.

In

addition, major improvements and retrofits were implemented without

significant events.

We have added to our site maintenance and outage

staffs and are creating a new corporate Maintenance and Outage Planning

Group to improve the refueling and outage programs further.

The Hatch

ALARA record and the satisfactory performance of major outage activities

are results of improvements already implemented.

TRAINING

Our performance was evaluated as Category 3.

GPC recognizes that its

operator requalification program experienced programatic deficiencies

and has attached the highest priority to that program's improvement.

We

are pleased that you recognize the upward trend

in our training

performance and acknowledge the NRC staff efforts to work closely with

us.

We have every expectation that the next SALP report will reflect

the results of our program improvements.

These improvements are:

1.

Special instruction has been provicec to assist our students in the

cevelopment of improved study hatits ar.c test-taking methods.

One-on-one tutoring has been anc v.ill te continuously available on

c.

student request and as deemeo necessary by training management.

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ENCLOSURE 1 (Continued) _

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COP 9 TENTS ON SALP REPORT FOR PLANT HATCH

3.

The Plant Hatch training staff has increased and the corporate

training staff has doubled.

4.

GPC is aggressively pursuing accreditation of its training programs

by the Institute of Nuclear Power Operations (INPO) with the

following actions:

a.

Seven of ten program self-evaluations have been submitted, and

an accreditation team visit is scheduled for early 1986.

b.

All training programs are being converted to performance-based

programs

and

a

multi-million

dollar

training

program

development contract has been signed to help the prompt

improvement and development of training programs at Plant

Hatch.

c.

GPC is upgrading the instructor training programs to improve

the caliber of classroom and

practical

instruction.

An

instructor upgrade program has been initiated to improve the

comunication, technical,

and development skills of Hatch

instructors.

d.

A

quality

on-the-job

training

program

for

Maintenance

personnel is being developed and near completion.

5.

Other significant training initiatives being implemented, include:

a.

The Hatch operator performance standards have been upgraded.

Observations already indicate a more professional control room

performance.

Operators who could not meet the upgraded

standards have been reassigned.

b.

While some of the senior operators already have college

degrees,

GPC

is

implementing

degree-programs

for

those

operators who do not have a technical degree.

c.

The emergency operating procedures have been reviewed, with a

training perspective, to avoia unnecessary memorization or

inappropriate immediate operator actions.

6.

A new requalification program has been submitted to the NRC for

' review.

GPC has already seen tangible returns from the upgraded

program in the performance of operators.

The higher standards are

being strictly applied as reassignments of several experienced

operators have already taken place.

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ENCLOSUREI(Continued)

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COMMENTS ON SALP REPORT FOR PLANT HATCH

7.

Other training improvements have been implemented.

These are:

a.

A formal eleven week training program for support engineers

has been recently implemented.

This program should enhance

overall plant knowledge.

b.

Deficiencies in emergency planning training for operations

supervisors have been corrected by additional training.

This

matter will be monitored during drills and exercises.

Future

performance-based training will focus on dificiencies.

It is unfortunate that, while the SALP report covered a twenty month

period, the period was terminated two weeks before initiation of

engineering training and the completion of our requalification upgrade

program.

Considering the strides made in training at Plant Hatch in

1985, it is disappointing that the report grade did not recognize the

progress in the same manner as the report narrative.

GPC will continue

our efforts into the future.

QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY

Our performance was evaluated as Category 2.

GPC agrees with the basic

components of the evaluation.

However, we believe that our program

performance is improving.

Some of the major improvements initiated

during this rating period include:

a comprehensive zero based audit

matrix system;

increased use of work in progress

and

contractor

surveillances; and revised, expanded, radiological controls monitoring

procedures.

We believe we have a large and aggressive QA staff which

has been charged with responsibility to continue aggressive program

implementation and the use of the newly developed zero-based audit

matrix system.

We intend to look more at work-in-progress, to place

greater emphasis on the use of technical specialists in key audit

program activities, and to review a broad range of other programs to

ensure that quality is built-in and maintained.

LICENSING ACTIVITIES

Our performance was evaluated as Category 2.

GPC has expanded its

licensing staff.

This will result in GPC being more active in planning

future HNP licensing activities, in industry-wide licensing activities,

and in identifying and clarifying license commitments.

GPC recognizes

past concerns over timeliness, and has taken action to correct this

problem, such as implementing a computerized tracking system, and by

upgrading its cemitment management systen.

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ENCLOSURE 1(Continued)

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COMMENTS ON SALP REPORT FOR PLANT HATCH

GPC is working to have a competent, forward looking, and receptive

licensing organization.

Recent organizational changes will result in a

more assertive licensing approach.

We believe that company-generated

initiatives have and will result in improvements.

We fully expect to

have those improvements visibly manifest themselves to NRC in the future

and that these improvements will be reflected in the next SALP rating.

CONCLUSION

We

feel

this

SALP evaluation

was

representative

of

the

Plant's

performance except in the area of maintenance.

GPC is committed to

further enhance all our programs.

We are taking appropriate action to

address their concerns and plan to keep you informed during our

quarterly meetings.

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JAti 15 1935

ENCLOSURE 2

APPENDIX TO GEORGIA POWER COMPANY

,

A. W. V0GTLE UNITS 1 AND 2

SALP BOARD REPORT

(DATED OCTOBER 23, 1985)

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JAN 15 1986

Enclosure 2

2

I.

Meeting Summary

A.

A meeting was held at 1:30 p.m. , on November 4,1985, at your corporate

offices in Atlanta, Georgia to discuss the SALP Board report.

B.

Licensee Attendees

R. W. Scherer, Chairman of the Board and Chief Executive Officer

J. H. Miller, Jr. , President

R. J. Kelly, Executive Vice President, Power Supply

R. E. Conway, Senior Vice President and Project Director - Vogtle

J. T. Beckham, Jr. , Vice President and General Manager, Nuclear

Operations

D. O. Foster, Vice President Project Support - Vogtle

R. H. Pinson, Vice President Project Construction - Vogtle

P. D. Rice, Vice President Project Engineering - Vogtle

Ruble A. Thomas, Vice President, Project Licensing, Plant Vogtle

George Bockhold, Jr., General Manager, Plant Vogtle Nuclear Operations

M. B. Hobby, Assistant to President

Don Crowe, Nuclear Safety Manager

L. T. Gucwa, Manager, Nuclear Safety and Licensing

J. J. Badgett, Manager, Nuclear Training

W. E. Burns, Nuclear Licensing Manager, Plant Vogtle

S. C. Ewald, Manager, Radiological Safety

Max Manry, Manager, Nuclear Performance and Analysis

A. W. Benson, Manager, Security

D. S. Read, Deputy General Manager, Quality Assurance

M. H. Googe, Project Construction Manager

R. L. George, Manager, Vogtle Support Group, Southern Company Services

Inc. (SCSI)

G. D. McGaha, Manager, Mechanical Engineering - Nuclear Plant Support,

(SCSI)

David R. Altman, Nuclear Information Manager

Ken Pointer, Plant Engineer, Vogtle Regulatory Compliance

J. R. Roberts, Superintendent, Uniform Security, Nuclear

C.

NRC Attendees

J. A. Olshinski, Deputy Regional Administrator, Region II (RII)

R. D. Walker, Director, Division of Reactor Projects (DRP), RII

A. F. Gibson, Director, Division of Reactor Safety (DRS), RII

V. L. Brownlee, Chief, Reactor Projects Branch 2, DRP

J. F. Stolz, Chief, Operating Reactors Branch 4, Division of Licensing

(DL)

M. V. Sinkule, Chief, Reactor Projects Section 20, DRP, RII

M. A. Miller, Project manager, Licensing Branch 4, DL

H. H. Livermore, Senior Resident Inspector (Construction), Plant Vogtle

J. F. Rogge, Senior Resident Inspector (Operations), Plant Vogtle

R. J. Schepens, Resident Inspector (Construction), Plant Vogtle

W. H. Rankin, Project Inspector, Reactor Projects Section 2D, DRP, RII

D. B. Gruber, Technical Support Inspector, Technical Support Section,

DRP, RII

Enclosure 2

3

JAN 15 1986

II.

Licensee Comments

Licensee comments submitted in response to the SALP Board Report for

A. W. Vogtle follow.

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J 64 M.Iler Jr

NED-85-875

2351N

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December 2, 1985

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U. S. Nuclear Regulatory Commission

REFERENCE.

,

Office of Inspection and Enforcement

RII:

JNG

Region II - Suite 2900

Inspection Reports

l

101 Marietta Street, NW

50-321-50-366 (85-21)

Atlanta, Georgia 30323

50-424-50-425 (85-27)

i

.

ATTENTION: Dr. J. Nelson Grace

Gentlemen:

By letter dated October 23, 1985, the Nuclear Regulatory Consnission

(NRC) transmitted the Systematic Assessment of Licensee Performance (SALP)

.

report for Plant Hatch and Plant Vogtle and requested comments from the

Georgia Power Company (GPC).

The SALP assessment covered a period of twenty

l

months from November 1, 1983 through June 30, 1985.

On November 4,1985, a

public meeting between the NRC and GPC was held to discuss the details of

this important report.

.

GPC recognizes and appreciates the observations made in your report

'

regarding the performance of Plant Hatch and Plant Vogtle.

GPC believes

<

that such evaluations of licensee performance benefit GPC and the public by

focuslag attention on matters important to plant safety.

GPC is conynitted

I

to

the

safe

operation

and

construction

of

its

nuclear

facilities.

.

Accordingly, we intend to be fully responsive to the observations discussed

in your report.

Enclosed are GPC's responses to the evaluations.

Enclosure 1 addresses

Plant Hatch and Enclosure 2 addresses Plant Vogtle.

In our response for

Plant Hatch, we identify a disagreement with your evaluation of Category 3

in the functional area of Maintenance.

We request that you reconsider this

specific evaluation based on our consnents and the volume of activities that

took place during the twenty month evaluation period.

We bclieve a Category

2 evaluation is justified.

Notwithstanding, our

corrective action to

further improve our maintenance program is proceecing on a high priority

!

basis.

.

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_

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U. S. Nuclear Regulatory Comission

Office of Inspection and Enforcement

Region II - Suite 2900

December 2,1985

Page Two

We would be pleased to discuss this response or answer questions you may

have.

Yours very truly,

n

y

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J.

iller, Jr.

.

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DMC/mb

/

Enclosure 1

Conments on SALP Report for Plant Hatch

Enclosure 2

Comants on SALP Report for Plant Vogtle

c:

Mr. R. E. Cc nway

Mr. J. T. Bf ckham, Jr.

Mr. D. O. Foster

Mr. G. Bock 101d, Jr.

Mr . H. C. t i x , Jr .

Senior Resident Inspector (Hatch)

Senior Resident ,1nspector (Vogtle)

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ENCLOSURE 2

11

COMMENTS ON SALP REPORT FOR PLANT V0GTLE

INTRODUCTION

Georgia Power Company has reviewed the SALP Report for Plant Vogtle and

[

endorses the observation regarding Plant Vogtle's performance.

We feel the

report accurately and effectively appraised Plant Vogtle's performance.

We

agree with the overall evaluation:

(

J

"The licensee continues to implement a vigorous construction

(

project management effort with well qualified and experienced

'

personnel.

Licensee programs have been effective in the

identification and resolution of problems.

Major strengths

have been identified in areas of Soils and Foundations,

Safety-Related Components - Mechanical, and Quality Programs

and Administrative Controls Affecting Quality.

No major

weaknesses were identified."

Even though no major weaknesses were identified, GPC intends to further

enhance our programs by making the following improvements.

EXCAVATION AND BACKFILL

Our performane.e was. evaluated as Category 1 (Management attention and

involvement are aggressive and oriented toward nucler safety and resources

are effectively used).

We are committed to continue to devote the same

level of management attention and resources to this area to ensure the high

level of performance is continued.

CONTAINMENT, SAFETY-RELATED STRUCTURES AND MAJOR STEEL SUPPORTS

Our performance was evaluated as Category 2, with an improving trend

(Management

attention

and

involvement

are

evident

and

resources

are

adequate).

GPC recognizes

the

importance

of

welding

activities

and

continues to enhance our program.

We have improved our visual weld

acceptance criteria and increased our QA ano QC overview of welding

activities.

PIPING SYSTEMS AND SUPPORTS

Our

performance

was

evaluated

as

Category

2.

We

are

further

strengthening our programs in this area.

We have implemented the following

programs to further enhance our performance:

1.

Pre-engineering walkdowns to assure the craft has the necessary

information to do the job right the first time.

A foreman accountability program to assist our training program in

c.

improving potential weak areas.

2-1

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ENCLOSURE 2 (Continued)

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3.

Increased surveillance reverification where selected contractor

work is reinspected by GPC Quality Control inspectors to assure

adequacy of the contractor's inspection activity.

SAFETY-RELATED COMP 0NENTS - MECHANICAL

Our performance was evaluated as Category 1.

We are taking steps to

!

further enhance this area.

We have recently organized our equipment

maintenance and storage group and are verifying the status of the equipment

j

in our preventive maintenance program.

We have also designated areas of

6

cleanliness throughout the plant to further strengthen this program.

]

FIRE PROTECTION / PREVENTION SYSTEMS

i

l

Our performance was evaluated as Category 2.

We have addressed the

,

unresolved issues identified in the report and will continue to enhance our

fire protection program.

We have revised our fire protection program and

!

clarified the procedures.

The fire dampers are now tested both prior to and

!

after installation and the Work-In Progress (WIP) packages utilized by the

HVAC contractor provide better instructions for installat 4on.

Improvements

have also been made to further enhance our records system.

ELECTRICAL EQUIPMENT AND CABLES

Our performance was evaluated as Category 2 with performance improving

throughout the report period.

We intend to assure performance continues to

improve. As NRC noted, we have' increased our management involvement in this

area

and

a

reorganization

has

increased

our

supervisor / lead

inspector-to-inspector ratio.

The quality control technical support group

has been established and provides a broad experience base to support the

inspection effort.

CUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY

Our performance was evaluated as Category 1.

As noted in the report,

our

Quality Concerns

Program has been

effective

in

identifying

and

correcting employees' concerns.

Quality concerns, as well as readiness

review findings, are evaluated by quality assurance for incorporation into

the audit programs to ensure programmatic problems are addressed and assure

root causes are corrected.

Many of the supervisory type issues addressed in

quality concerns would not have been otherwise identified in our previous

audits and surveillances.

We have strengthened our ongoing audit program by

performing annual

assessments

of contractor

programs

and broad-scoped

assessments of particular concerns such as the electrical and welding areas.

2-2

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ENCLOSURE 2 (Continued)

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COPHENTS ON SALP REPORT FOR PLANT V0GTLE

i

LICENSING ACTIVITIES

Our performance was evaluated as Category 2.

We have increased the

1

staff of the project licensing manager and have relocated a staff member to

the job site to better coordinate site licensing activities and further

enhance our overall licensing effort.

'

CONCLUSION

>

We feel

this SALP evaluation was representative of the Project's

-

performance and we are cbmitted to further enhance our programs to make our

performance even better,

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JAN 15 1986

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ENCLOSURE 3

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SALP BOARD REPORT ERRATA SHEET

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Page/Line

Now Reads

Should Read

1

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Cover Letter

50-425/85-27

50-425/85-26

Basis:

Typographical error which incorrectly listed the inspection report

i

number for Unit 2.

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UNITE 3 ST ATES

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NUCLEAR REGULAT!RY COMMISSION

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REGloN 11

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101 MARIETTA STREET.N.W.

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ATL ANTA. GEORGI A 30323

7

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OCT 2 3 1985

-

Georg

Power Ccmpany

ATTN:

r. R. J. Kelly

cutive Vice President

P. O. Box 545

Atlanta, GA 30302

Gentlemen:

SUBJECT:

REPORT

5. 50-321/85-21, 50-366/85-21, 50-424/85-27, AND 50-425/85-27

f

The NRC Systematic A esgment of Licensee Performance (SALP) Board has completed

its periodic evaluatio 4( your E. I. Hatch and A. W. Vogtle facilities. These

facilities were eval g

f

the period November 1, 1983 through June 30, 1985.

The results of the evp

are documented in the enclosed SALP Board Reports

l

(Enclosures 1 and 2). 1

orts will be discussed with you at your offices

in Atlanta, Georgia on No

4, 1985.

The performance of your E.

h facility was evaluated in the functional

>

areas of plant operations, r

ogical controls, maintenance, surveillance,

fire protection, emergency pre

e ness, security, refueling / outages, training,

quality programs and administratf?pe

ontrols affecting quality, and licensing

activities.

l

The performance of your A. W. Vogtle fa

lity was evaluated in the functional

areas of soils and foundations, containmen

safety related structures and major

steel supports, piping systems and supports, safety related components-mechanical,

auxiliary systems, electrical equipment an

cables, quality programs and

6

administrative controls affecting quality, and icensing activities.

!

The overall Georgia Power Company performance w s satisfactory.

Management

f

attention and involvement were evident at both your

. I. Hatch and A. W. Vogtle

facilities. At the Vogtle facility no weaknesses wer identified, with strengths

identified in the areas of soils and foundations, sa ety related components-

I

mechanical, quality programs and administrative contr is affecting quality.

Licensee programs initiated, relating to these strengt

were the Quality

,

Concerns Program and the Readiness Review Program.

Concern g the Hatch facility,

a strength was identified in the radiological controls ar

with weaknesses

identified in the maintenance and training areai. Also, more

tention to detail

would enhance the performance of all departments.

g

Any comments you have concerning our evaluation of the performa e of your

facilities should be submitted to this office within 30 days follow g the date

r

of our meeting in Atlanta, Georgia. We specifically request that y

advise

!

us of actions you have taken or plan to take to address the weakness i

ntified

!

in the Hatch maintenance and training programs. Your comments, a summary f our

November 4,

1985 meeting, and my disposition of your comments will be i

ued

as appendices to the enclosed SALP Board Reports.

I

UNITED STATES

[ @ 88 4 *o

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET.N.W.

ATLANTA, GEORGI A 30323

'g.....

OCT 2 81985

Georgia Power Company

ATTN: Mr. R. J. Kelly

Executive Vice President

P. O. Box 4545

Atlanta, GA 30302

Gentlemen:

SUBJECT:

REPORT NOS. 50-321/85-21, 50-366/85-21, 50-424/85-27, AND 50-425/85-26

The NRC Systematic Assessment of Licensee Performance (SALP) Board has completed

its periodic evaluation of your E. I. Hatch and A. W. Vogtle facilities. These

facilities were evaluated for the period November 1, 1983 through June 30, 1985.

The results of the evaluation are documented in the enclosed SALP Board Reports

(Enclosures 1 and 2). These reports will be discussed with you at your offices

in Atlanta, Georgia on November 4,1985.

The performance of your E. I. Hatch facility was evaluated in the functional

areas of plant operations, radiological controls, maintenance, surveillance,

fire protection, emergency preparedness, security, refueling / outages, training,

quality programs and administrative controls affecting quality, and licensing

activities.

The performance of your A. W. Vogtle facility was evaluated in the functional

areas of soils and foundations, containment, safety related structures and major

steel supports, piping systems and supports, safety related components-mechanical,

auxiliary systems, electrical equipment and cables, quality programs and

administrative controls affecting quality, and licensing activities.

The overall Georgia Power Company performance was satisfactory.

Management

attention and involvement were evident at both your E. I. Hatch and A. W. Vogtle

facilities. At the Vogtle facility no weaknesses were identified, with strengths

identified in the areas of soils and foundations, safety related components-

mechanical, quality programs and administrative controls affecting quality.

Licensee programs initiated, relating to these strengths, were the Quality

Concerns Program and the Readiness Review Program.

Concerning the Hatch facility,

a strength was identified in the radiological controls area with weaknesses

identified in the maintenance and training areas. Also, more atten*4on to detail

would enhance the performance of all departments.

Any comments you have concerning our evaluation of the performance of your

facilities should be submitted to this office within 30 days following the date

of our meeting in Atlanta, Georgia. We specifically request that you advise

us of actions you have taken or plan to take to address the weakness identified

in the Hatch maintenance and training programs. Your comments, a summary of our

November 4,

1985 meeting, and my disposition of your comments will be issued

as appendices to the enclosed SALP Board Reports.