ML20206C554
| ML20206C554 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/03/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20206C534 | List: |
| References | |
| 50-424-86-85, 50-425-86-42, NUDOCS 8704130086 | |
| Download: ML20206C554 (8) | |
See also: IR 05000424/1986085
Text
{{#Wiki_filter:_ - _ _ - _ - _ _ _ . _ _ _ - .. April 3, 1987 ENCLOSURE APPENDIX TO GEORGIA POWER COMPANY PLANT V0GTLE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) BOARD REPORT NOS. 50-424/86-85 AND 50-425/86-42 (DATED DECEMBER 12,1986) i '! $[041Soo@k$8 24
. . I. Meeting Summary A. A meeting was held at 1:00 p.m. on December 19, 1986, at the Region II Office in Atlanta, Georgia, to discuss the SALP Board Report for the Plant Vogtle facility. B. Licensee Attendees: R. W. Scherer, Chairman of the Board and Chief Executive Officer H. G. Baker, Jr. , Senior Executive Vice President R. E. Conway, Senior Vice President - Nuclear Power and Vogtle Project Director P. D. Rice, Vice President - Vogtle Project Engineering G. Bockhold, Jr. , Vogtle General Manager R. A. Thomas, Executive Consultant C. T. Jones, Manager - Vogtle Engineering C. W. Hayes, Vogtle Quality Assurance Manager E. M. Howard, Manager - Nuclear Training and Emergency Preparedness D. G. Smith, Manager - Nuclear Perfomance and Analysis M. P. Walker, Assistant to Senior Via President W. Whitney, General Manager - Project Support s. L T. Cucwa, Manager - Nuclear Safety and Licensing J. H. Lukehart, Nuclear Security Manager C. L. Cross, Senior Regulatory Specialist W. E. Burns, Nuclear Licensing Manager - Vogtle J. L. Leamon, Project Licensing Engineer Aziz Yilmaz, Construction Engineer, Ogelthorpe Power Corporation C. NRC Attendees: J. N. Grace, Regional Administrator, Region II (RII) M. L. Ernst, Deputy Regional Administrator, RII A. F. Gibson, Director, Division of Reactor Safety, RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards (DRSS),RII V. L. Brownlee, Chief, Reactor Projects Branch 2, Division of Reactor Projects (DRP), RII D. M. Collins, Chief, Emergency Preparedness and Radiation Protection Branch, DRSS, RII W. E. Cline, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS, RII M. V. Sinkule. Chief, Reactor Projects Section 2C, DRP, RII D. R. McGuire, Chief, Physical Security Section, DRSS, RII K. D. Landis, Chief, Technical Support Staff, DRP, RII J. F. Rogge, Senior Resident Inspector (Operations), Vogtle R. J. Schepens, Resident Inspector (Operations), Vogtle E. F. Christnot, Project Engineer, Reactor Projects Section 2C, DRP
i l . , l II. NRC Response to the Licensee's January 28, 1987, Specific Written Comments A. Fire Protection We acknowledge that the seismic gap sealant and structural steel fireproofing were installed under the licensee's QA/QC program; however, the program utilized was different than that discussed in the FSAR. We acknowledge the licensee's statement that they have four permanent fire protection employees and will change page 35 of the report accordingly. It is also noted that the licensee is firmly committed to providing sufficient personnel to implement the fire protection program. B. Securitj We have reviewed our assessment of security with respect to the licensee's comments and conclude that the Category 3 in this area is appropriate. III. Errata Sheet - Vogtle SALP Page Li.ne Now Reads Should Read 35 . . . fire protection program. . . . fire protection The licensee has only one . . . program. Basis for Change: To acknowledge that the licensee has four permanent fire protection employees. 36 The Board is concerned. . . None. Basis for Change: No comment is necessary due to the acknowledgement of four permanent fire protection employees. l -- .,- ,
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, 35 material; however, this installation was not being perform under ' a QA/QC program as committed by the FSAR. This_was ident' ied as i a deviation listed below. A number of large- cable penetrations were identifi d which ' - exceeded the' maximum size permitted by the penetr tion seal manufacturer's design. .This departure from NRC idelines-is under review by the NRC. Appropriate corrective ction was being i reviewed by the licensee. ~ The structural steel fire proofing was revie ed, and although the steel appeared to be' properly. coated, it w not being installed .' under a QA/QC program as stated by the AR. This was also identified as a deviation. Each of the eactor' coolant pumps have , ' an oil collection system arranged to 11ect oil leaks from the pumps.and drain the oil into a colle ion tank. This system was inspected and found to meet the FS commitments and NRC guide- lines. The licensee's management has veloped a program to review and verify that the installed fir protection systems and features'at
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the facility were' adequate nd meet the NRC guidelines. This program exceeds NRC requir ents and was in addition to the normal ' plant construction inspe ion and QA/QC. programs provided. The licensee's approach to e resolution of technical fire protection 2 issues indicates an un erstanding of the issues and was generally sound and timely, ho ver, the design and installation of some of the fire protection systems and features contained discrepancies. ! These problems a e to be resolved by the licensee. Also,. portions of the fire pr ection features were not installed under a QA/QC program as c itted by the FSAR. The responsiveness to NRC initiatives as generally timely and thorough. . Fire protection ' related vi ations have been rare, since the plant is not
licensed. However, when discrepancies were found, corrective action as promptly taken. The licensee's identified fire i protec ion related events or discrepancies were not normally repo ed to the NRC, but appear to be properly analyzed and eff ctive corrective action taken. taffing for tiie permanent plant fire protection program appears / adequate to accomplish the goals of the position during the preoperational phase. Personnel appear qualified for their [4 assigned duties, however, consultants and contractors were used
extensively in the preoperational. testing and implementation of the permanent plant-fire protection program. The licensee has cf Only one permanent fire protection Georgia Power Company employee. i !-
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. 35 material; however, this installation was not being performed under a QA/QC program as committed by the FSAR. This was identified as a deviation listed below. A number of large cable penetrations were identified which exceeded the maximum size permitted by the penetration seal manufacturer's design. This departure from NRC guidelines is under review by the NRC. Appropriate corrective action was being reviewed by the licensee. The structural steel fire proofing was reviewed, and although the steel appeared to be properly coated, it was not being installed under a QA/QC program as stated by the FSAR. This was also identified as a deviation. Each of the reactor coolant pumps have an oil collection system arranged to collect oil leaks from the pumps and drain the oil into a collection tank. This system was inspected and found to meet the FSAR commitments and NRC guide- lines. The licensee's management has developed a program to review and verify that the installed fire protection systems and features at the facility were adequate and meet the NRC guidelines. This , program exceeds NRC requirements and was in addition to the normal plant construction inspection and QA/QC programs provided. The licensee's approach to the resolution of technical fire protection issues indicates an understanding of the issues and was generally sound and timely, however, the design and installation of some of the fire protection systems and features contained discrepancies. These problems are to be resolved by the licensee. Also, portions of the fire protection features were not installed under a QA/QC program as committed by the FSAR. The responsiveness to NRC initiatives was generally timely and thorough. Fire protection related violations have been rare, since the plant is not licensed. However, when discrepancies were found, corrective action was promptly taken. The licensee's identified fire protection related events or discrepancies were not normally reported to the NRC, but appear to be properly analyzed and effective corrective action taken. Staffing for the permanent plant fire protection program appears adequate to accomplish the goals of the position during the preoperational phase. Personnel appear qualified for their assigned duties, however, consultants and contractors were used ' extensively in the preoperational testing and implementation of the permanent plant fire protect;on program.
.. - _ - _ _ _ _ . . 36 One deviation was identified: Deviation involving the failure to provide a QA progr m for all fire protection system installations as described b the FSAR. (50-424/86-64-05; 50-425/86-30-01) 2. Conclusicr Category: 2 3. Board Comments: The Board is concerned that licensee r sources were not effec- tively utilized in this area. The li nsee has only one engineer assigned in this area and is depend'ng on contractors for the majority of engineering work. This may result in a low level of plant specific expertise remainin on site. E. Emergency Preparedness 1. Analysis During this evaluation' .riod, the following inspections and related activities were performed by the regional and resident inspection staffs: tw emergency preparedness (EP) pre-appraisal inspections to confir the licensee s readiness for an emergency preparedness implem tation appraisal; an emergency preparedness appraisal; an eva ation of Near Term Operating License (NT0L) full scale emer ncy preparedness exercise; and an initial EP appraisal follo up inspection to verify adequacy and completion of licensee's co rective actions in response to improvement and incomplete i ems identified during the appraisals. The appra'sals, inspections, and exercise evaluation disclased no signifi nt problems regarding the plant site emergency response organi tions and staffing. The corporate Emergency Response Orga 'zation was adequately staffed and provided required support to e plant concistent with plant and corporate emergency plans. K positions, with assigned alternates, in the corporate and ant response organizations were filled. Corporate management demonstrated a strong and effective commitment to the emergency response program. Senior corporate officials were directly $ involved in the pre licensing emergency preparedness exercise, related drills, and followup critiques. The NRC appraisal conducted disclosed items which required further j evaluation and improvement as well as items which were incomplete l and could not be fully evaluated. During the initial appraisal followup inspection, many items directly addressing the EP program were closed. The licensee was involved in a concerted effort to resolve the remaining open items. I . _ - - . _ . _. _. .-
. . . 36 One deviation was identified: Deviation involving the failure to provide a QA program for all fire protection system installations as described by the FSAR. (50-424/86-64-05; 50-425/86-30-01) ' 2. Conclusion Category: 2 3. Board Comments: None. E. Emergency Preparedness 1. Analysis During this evaluation period, the following inspections and related activities were performed by the regional and resident ' inspection staffs: two emergency preparedness (EP) pre-appraisal inspections to confirm the licensee s readiness for an emergency preparedness implementation appraisal; an emergency preparedness appraisal; an evaluation of Near Term Operating License (NTOL) full scale emergency preparedness exercise; and an initial EP appraisal followup inspection to verify adequacy and completion of licensee's corrective actions in response to improvement and incomplete items identified during the appraisals. The appraisals, inspections, and exercise evaluation disclosed no significant problems regarding the plant site emergency response organizations and staffing. The corporate Emergency Response i Organization was adequately staffed and provided required support i to the pi:nt consistent with plant and corporate emergency plans. Key positions, with assigned alternates, in the corporate and plant response organizations were filled. Corporate management 1 demonstrated a strong and effective commitment to the emergency response program. Senior ' corporate officials were directly involved in the pre-licensing emergency preparedness exercise, related drills, and followup critiques. The NRC appraisal conducted disclosed items which required further evaluation and improvement as well as items which were incomplete and could not be fully evaluated. During the initial appraisal followup irspection, many items directly addressing the EP program were closed. The licensee was involved in a concerted effort to resolve the remaining open items. .- - . - ,. . -
- - - - k . . IV. Licensee Comments Licensee comments submitted in response. to the Vogtle SALP Board Report follow. < t
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h osPo^e'Comr n , o* 331 Pectae A,e % . , At ac'a fi*m a 303Cf- -- % r -.3 r,; f 3 1 ;; I ya ~ a wm Ps Ca e Sm 4:.;r r A- 7, qm ,3 y -{* [* U ' h a , i R.E.Conway s. .. .,;;... .~ January 28, 1987 United States Nuclear Regulatory Commission File: .X78G10 Office of Inspection and Enforcement Log: GN-1342 Region II - Suite 2900 101 fiarietta Street, NW Atlanta, GA 30323 Reference: Vogtle Electric Generating Plant Units 1 & 2, 50-424, - 50-425; Systematic Assessment of Licensee Performance Report Nos. 50-424/86-85 and 50-425/86-42 Attention: Mr. J. Nelson Grace As discussed at our meeting on December 19, 1986, we are generally very pleased with the SALP report for the Vogtle Project. There are some areas where we believe additional infomation or comments should be provided, and these are provided as follows: " 1. Piping Systems and Supports This area of the report raised the issue of accuracy of infomation. (SALP, Page 9). We believe this incident was an aberration and an isolated deviation from normal practice. I wish to reiterate 4 that we are firmly committed to providing only the most accurate factual information to the NRC and have taken steps that require more specific attention to the details on future submittals. 2. Quality Programs and Administrative Controls Affecting Quality This area of the report raised the issue of QA staffing (SALP, Pages 19, 20, 41 & 42). As we discussed at the NRC SALP meeting, the senior management of the Company closely monitors the QA staffing needs and requirements in each area to assure an adequate level of manpower. The-transfer of QA personnel to other functions and the coincident transfer of high-performance, future potential managers into QA is part of our overall plan to have all of the organizations involved in and knowledgeable of the QA functions ! and philosophy. We will continue to closely monitor this area to ensure our overall objectives are met. ' _ 1# . . . - . - . .
. _ __ _ .- . Georgiit Poner Page Two Regarding yore general concern over extensive use of contractor yA personnel, we would point out that the three contractors assigned to our construction QA group were selected based on their broad nuclear background and previous Plant Vogtle experience. Further, the three to four contractor people used in the operational QA group were specifically obtained for their extensive and - broad i test experience at other plants. Of key importance is the fact that all contractor personnel work under GPC policies, procedures and supervision. 3. Fire Protection j Two issues were identified in this section of the report. a. Both the seismic gap sealant and the structural steel, fireproofing were being installed under a QA/QC program (SALP, Page 35). The inspection techniques being utilized were different than those in other areas, but the program was adequate in controlling the work product. b. As a correction to the statement on Page 35 of the SALP report, we have four permanent fire protection employees. We think this misunderstanding was a result of a review of the preoperational test program personnel assignments. We are - firmly committed to provide sufficient personnel for our fire protection program. 4. Physical Security / Material Control and Accountability During the construction of any project of this magnitude, priorities for completion of various systems are established. The security system completion followd the completion of several of the 'other plant systems. There was a great deal of effort put into this system completion. In conjunction with system completion and turnover, we established a completion team made up of cMstruction, testing, securi ty, engineering and vendor representatives. This team, which was similar to other teams for various systems, was tasked to take the lead in completing the system and resolving issues as they arose. They identified many issues in both the construction and testing areas and worked diligently to achieve resolutions. The NRC also helped identify issues. During all of this period, Vogtle security management was involved. . Also, Georgia Power company has taken action to strengthen security ' management and supervfsion to ensure that we respond to issues prior to fuel load.
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, .. .. Georgial'oner d Page Three \\ , ' The system enhancement regarding the location of the detection equipment was a specific concern identified by the NRC and, upon review by GPC management, prompt decisions were made to assure resolution. It should be noted that the enhancement was completed in a considerably shorter time than would normally be expected. We believe that the completion of the security system received its full share of management attention especially as problems were discovered to assure completion to support our plan. All pro.iect functions have been involved from early in the process, and a successful installation has resulted. We do not believe the Category 3 rating takes into account all of the facts and ask for reconsideration on this sub.iect. 5. Training and Qualification Effectiveness Following the results of the operator examinations in August, 1986, we took immediate action to improve our training program. The results of the December examination (29 passes out of 33 candidates) indicate that our efforts were successful. We will continue to give this area our highest level of attention. . R. E. Conway \\_ REC:.f c xc: U. S. Nuclear Regulatory Comission Document Control Desk Washington, D.C. PD555 Melanie A. Miller J. H. Miller H. G. Baker, Jr. J. P. O'Reilly P. D. Rice R. H. Pinson R. A. Thomas C. W. Whitney G. Bockhold, Jr. C. W. Hayes NORMS i ,-y . -. e. }}