ML20209F472

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Insp Repts 50-424/86-60 & 50-425/86-27 on 860701-0811. Violation Noted:Failure to Implement Adequate Design Control,In That Design Criteria Omitted from Bechtel Spec & Not Part of Westinghouse Criteria
ML20209F472
Person / Time
Site: Vogtle  
Issue date: 08/29/1986
From: Livermore H, Rogge J, Schepens R, Scheppens R, Sinkule M, Skinner P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209F400 List:
References
50-424-86-60, 50-425-86-27, NUDOCS 8609120166
Download: ML20209F472 (53)


See also: IR 05000424/1986060

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET.N.W.

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ATLANT A. GEORGI A 30323

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Report Nos.:

50-424/86-60 and 50-425/86-27

Licensee: Georgia Power Company

P.O. Box 4545

Atlanta, GA 30302

Docket Nos.:

50-424 and 50-425

License Nos.: CPPR-108 and CPPR-109

Facility Name: Vogtle 1 and 2

Inspection Conducted: July 1 - August 11, 1986

Inspectors: [

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Date Signed

h{H.H.Livermore,SeniorResidentInspector

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B/2.8/as

r',4/_ J. F. Rogge, Senior Resident Inspector

Date Signed

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Operati

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9/2e/86

R. J. Schepens, Resident Inspector

Date Signed

% Operations & Construction

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P. H. Skinner, Senior Resident Inspector

Date Signed

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Cata a (15-18 July, 4-8 August)

Approved By:

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M.~ V. Sinkule, Section Chief

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Division of Reactor Projects

SUMMARY

Scope: This routine, unannounced inspection entailed Resident Inspection in t_he

following areas: containment and safety related structures, piping systems and

supports, safety related components, auxiliary systems, electrical equipment and

cables, instrumentation, preoperational test program, quality programs and

administrative controls affecting quality, and follow-up on previous inspection

identified items.

Readiness Review Module 7 was examined.

Results: One violation was identified " Failure to Implement Adequate Design

Control"

paragraphs 20 & 22.

8609120166 860904

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DETAILS

1.

Persons Contacted

Licensee Employees

  • R. E. Conway, Senior Vice-President, Vogtle Project Director
  • D. O. Foster, Vice-President, Project Support
  • R. H. Pinson, Vice-President, Project Construction
  • C. W. Whitney, Project Management, Legal
  • W.

T. Nickerson, Assistant to the Project Director

  • R. W. McManus, Readiness Review

M. H. Googe, Project Construction Manager

  • G. Bockhold, Jr. , General Manager Nuclear Operations
  • H. P. Walker, Manager Unit Operations

R. M. Bellamy, Manager Test & Outage

D. S. Read, General Manager QA

  • C. W. Hayes, Vogtle Quality Assurance Manager
  • C. E. Belflower, Quality Assurance Site Manager - Operations

E. D. Groover, Quality Assurance Site Manager - Construction

  • W. E. Mundy, Quality Assurance Audit Supervisor
  • D. M. Fiquett, Project Construction Manager - Unit 2
  • B. C. Harbin, Manager Quality Control
  • G. A. McCarley, Project Compliance Coordinator
  • W. C. Gabbard, Regulatory Specialist

C. F. Meyer, Operations Superintendent

R. M. Odom, Plant Engineering Supervisor

  • C. L. Coursey, Maintenance Superintendent
  • M. A. Griffis, Superintendent - Maintenance

N. R. Harris, Quality Control Assistant Manager

W. R. Duncan, Readiness Review

D. McCary, Engineering Supervisor, GPC/PKF

G. E. Spell, Quality Assurance Engineer / Support Supervisor

  • R. E. Spinnato, ISEG Supervisor

S. A. Bradley, ISEG Member

J. F. D' Amico, Superintendent Regulatory Compliance

V. J. Agro, Superintendent Administration

T. Brewer, Assistant QC Manager

  • G. R. Frederick, Senior QA Engineer

Other licensee employees contacted

included craftsmen,

technicians,

supervision, engineers, inspectors, and office personnel.

Other Organizations

  • F. B. Marsh, Project Engineering Manager - Bechtel

H. M. Handfinger, Preoperational Test Superintendent - Bechtel

D. L. Kinnsch, Project Engineering - Bechtel

G. Introcaso, Administration Manager, Pullman Power Products

B. Edwards, Project Manager, Pullman Power Products

J. Miller, QA Manager, Pullman Power Products

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  • Attended Exit Interview

2.

Exit Interview (30703C)

The inspection scope and findings were summarized on August 11, 1986

with those persons indicated in paragraph 1 above. The inspector described

the areas inspected and discussed in detail the inspection finding listed

below.

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 inspection.

(0 pen) Violation 50-424/86-60-01 & 50-425/86-27-01 " Failure to Implement

Adequate Design Control." - Paragraph 20 & 22

(0 pen) Unresolved Item 50-424/86-60-02 " Inadequate Instruction and Training

for RayChem Electrical Splice Installations." - Paragraph 6a

(0 pen) Inspector Followup Item (IFI) 50-424/86-60-03 " Review Technical

Specification Surveillance 4.8.1.1.1 Implementation Procedure for Proper

Verification of AC Independent Power Sources." - Paragraph 23a1

(0 pen) IFI 50-424/86-60-04 " Review Results of Baselining the Regulatory

Compliance Computer Database with the Readiness Review Module 7 Database." -

Paragraph 23a1

(0 pen) IFI 50-424/86-60-05 " Review the Inspection Status Regarding Plant

Housekeeping and Cleanliness Control." - Paragraph 23d

(0 pen) IFI 50-424/86-60-06 " Review the Establishment of a Plan to Collect

and Evaluate Transient or Operational Cycles." - Paragraph 23m

(0 pen) IFI 50-424/86-60-07 " Review Corrective Action Regarding Item #7-5 and

  1. 7-9 of Readiness Review Module 7." - Paragraph 23m

(0 pen) IFI 50-424/86-60-08 " Review Operations Procedure 17012-1, Annunciator

Response Procedure, for Resolution of Comments." - Paragraph 22

(0 pen) IFI 50-424/86-60-09 "QC Reinspection - Anti Drug Program" - Paragraph

6f

(0 pen) IFI 50-424/86-60-10 " Review Compliance with TMI Item I .C.2."

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Paragraph 22

(0 pen) IFI 50-424/86-60-11 " Review Licensee Response to the Locking of Four

RHR Valves" pursuant to FSAR Section 7.6.2.2.D" - Paragraph 23a

(Closed) Violation 50-424/85-37-02, " Failure to Establish Appropriate

Acceptance Criteria to Verify Pump Internal Cleanliness." - Paragraph 3

(Closed) Violation 50-424/85-43-01, and 50-425/85-32-01, " Failure to Provide

Adequate Protection to Safety Related Components." - Paragraph 3

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(Closed) Violation 50-424/85-52-01, " Failure to Provide Adequate Maintenance

Procedures." - Paragraph 3

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(Closed) Construction Deficiency Report (CDR) CDR 50-424&425/84-62 " Quality

Concerns Involving Erroneous Liquid Penetrant Testing Records." - Paragraph

5

(0 pen) CDR 50-424/86-121, "NSCW Stainless Steel Pipe Fitup" - Paragraph 5

(Closed) CDR 50-424/425 CDR 80-09 " Charging Pumps." - Paragraph 5

(Closed) IFI 50-424/86-09-04 " Review Projects Revised Response to Quality

Concern No. 85V0582." - Paragraph 5

(Closed) IFI 50-424/85-13-03 " Review the Results of Additional Re-examina-

tions of Weld Liquid Penetrant Examinations." - Paragraph 5

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(0 pen) IFI I.C.2 " Shift Relief and Turnover Procedures." - Paragraph 22

(0 pen) .IFI II.D.3 " Direct Indication of Relief-and Safety-Valve Position."

Paragraph 22

(Closed) IFI II.G.1 " Emergency Power for Pressurizer Equipment." - Paragraph

22

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The following NRC exit interviews were attended during the inspection period

by a resident inspector:

Date

Name

July 2

M. D. Hunt, T. F. McElhenney

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July 11

L. H. Jackson, R. D. Gibbs

July 18

W. Ross, W. Gloerson

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W. Kleinsorge

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July 25

N. Merriweather

W. H. Miller, G. R. Wiseman

M. D. Hunt, et. al.

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J. D. Harris

July 31

J. York, S. J. Vias

August 08

H. Philips, D. Ferd

B. Crowley, J. Menning

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L. Nicholson

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On August 7, 1986, Mr. P. H. Skinner presented the results of his inspection

pertaining to allegations.

The licensee was informed that his inspection

items would be documented in the resident inspector report. (See paragraph

6c, d, & e)

3.

Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation, 50-424/85-37-02 " Failure to Establish Appropriate

Acceptance Criteria to Verify Pump Internal Cleanliness". This violation

identified discrepancies between the cleanliness criteria of Pullman Power

Products used in the disassembly, cleanliness verification, and reassembly

of Unit 1 Train B Safety Injection Pump, and Revision 9 of Westinghouse-

Specification No. 292722. The Westinghouse document requires a wipe test in

accordance with ASTM-A-380 to verify equipment internal cleanliness prior to

reassembly. The PPP procedure did not contain this requirement. Georgia

Power Company's (GPC) response contained in Letter No. X7BG10, GN-723, dated

October 23, 1985 outlined the corrective action-to be taken. The inspector

has reviewed Rev. 12/16/85 of PPP Procedure No. XIII-4 which incorporates

the cleanliness' verification requirements of Westinghouse Process Specifica-

tion No. 292722.

In addition, a review was conducted of Operational

Deviation Report No's. T-2-85-1535, T-1-85-1648, and T-1-85-1647 which

identified and dispositioned all Westinghouse equipment which had been

disassembled and reassembled and was subject to cleanliness verification

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requirements of Process Specification No. 292722. Based on the above review

the inspector determined that the corrective actions have been adequately

addressed and are complete.

(Closed) Violation 50-424/85-52-01 " Failure to Provide Adequate Maintenance

Procedures".

This violation identified a failure to adequately prescribe

maintenance activities relative to the preplanning, review, and execution of

Maintenance Work Orders (MW0's) associated with the disassembly and

reassembly of the Unit 1 Chemical and Volume Control System Centrifugal

Charging Pumps. Georgia Power Company's (GPC) response contained in Letter

No. X7BG10, GN-790, dated February 11, 1986 outlined the corrective action

to be taken. The insper*ar has reviewed internal correspondence documenting

the me.eting held with c.ht maintenance planners, Quality Control inspectors,

and maintenance ret tme

in regard to corrective action. The maintenance

planners were irit m.tm

.o identify MWO's requiring additional preplanning

detail and to fo u ra v e to the maintenance foreman assigned to the job so

as to involve / include him in the preplanning process. Also, guidelines

were given as criteria to use for determining which MW0's require additional

preplanning.

The Quality Control (QC) inspectors were instructed on the

assignment of QC hold points and to assure hold points are applicable to the

work activity being conducted and that they can be used to verify quality.

Also, guidelines were established and reinforced as to process of the

waiving QC hold points.

The maintenance personnel were retrained in

procedural requirements, compliance and the importance of agreement between

verbal instructions and procedural requirements. In addition, the inspector

has observed the implementation of the preplanning process and maintenance

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activities.on various safety related components sir.ce the occurrence of the

violation. Based on the above reviews and field observations the inspector

has determined that the corrective actions hava been adequately addressed

and are complete.

(Closed) Violation 50-424/85-43-01 and 50-425/85-32-01 " Failure to Provide

Adequate Protection to Safety-Related Components." This violation identi-

fied five

(5) valves and one (1) electrical panel which were not

adequately protected from damage or contamination in accordance with

established procedures.

Georgia Power Company's (GPC) response contained

in Letter No. X78G10, GN-756, dated December 10,19.5 outlined the correc-

tive action to be taken. The inspector has reviewed internal correspondence

documenting the following action taken:

Quality Control has assigned full

time Quality Control inspectors to conduct plant housekeeping and storage

inspections; Pullman Power Products (PPP) have assigned personnel to monitor

construction field storage conditions for valves and other equipment during

each shift to ensure that covers and other protective methods are properly

maintained; and a Standing Order No. 1-86-05 was written to implement an

area access control plan which requires joint participation with construc-

tion to ensure equipment protection and cleanliness is maintained. The plan

applies to all areas of the plant not turned over to operations and areas

not specifically designated as a controlled area by Construction. The plan

classifies areas as Level I, II, or III as appropriate for the type and

Class of equipment in the area; with Level I requiring the most restrictive

access control. Examples of Level I areas are Class 1E large motor or pump

areas, Class 1E instrument or control panel areas, DC battery rooms and

switchgear rooms, etc.

In addition, the inspector has observed the

implementation of the area access control plan since initiation of the

program. Based on the above reviews and field observation of area access

control plan, the inspector has determined that corrective actions have been

adequately addressed and are complete.

4.

Unresolved Items (92701)

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

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deviations. One unresolved item was identified which involved inadequate

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instruction and training for RayChem electrical splice installations. This

item is discussed in paragraph 6a of this report.

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S.

Followup on Licensee and Inspector Identified Inspection Items (92701)

(92712) (92700)

(Closed) CDR 50-424 and 425/80-09 " Charging Pumps" This item was inspected

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to complete the previous action as documented in NRC reports 50-424 and

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425/85-05 and 50-424 and 425/85-13.

The inspector completed walkdowns at

the auxiliary mini-flow path installation and reviewed the emergency

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operating procedures governing the use of this flow path.

This item is

considered closed.

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(Closed) CDR 50-424 and 425/84-62 " Quality Concerns Involving Erroneous

Liquid Penetrant Testing Records" This item was initially reported as a

potential deficiency on April 24, 1984, which involved an incident where an

Liquid Penetrant Test (LPT) examiner was suspected of falsifying liquid

penetrant inspection -reports. - Subsequent to this incident, another examiner

was also suspected of submitting erroneous liquid penetrant examination

reports, resulting in additional reinspections of both individuals. The two

situations, for reporting purposes pursuant to the requirements of 10 CFR 50.55(e), were combined and documented in this CDR.

The final report was

submitted on April 18, 1985 which documented the licensee's evaluation of

this matter as not reportable pursuant to the requirements of 10 CFR 21 and

10 CFR 50.55(e).

A review was made of the licensee program for the

reinspection of selected welds related to a qualify concern involving

erroneous liquid penetrant examination (LPE) records.

The reinspection

plans for each individual were developed specifically for the particular

person and circumstances to determine if test had been falsified and if so,

what period in their working tenure at the site did this start.

Pullman

Power Products initiated the first inspection plan consisting of a 100%

reinspection of accessible welds within a specified time frame.

Georgia

Power Company (GPC) initiated a second inspection per Mil-Std-105D Sample

Reinspection Plan. The re examination results were plotted in graphic form

to show the percentage of tests performed and the resultant discrepancies as

percent re-examined each month.

The Resident Inspector reviewed these

graphs in a meeting with the licensee.

The results of the meeting

determined that additional welds were to be liquid penetrant tested within a

specified time frame.

As a result of these reinspections the licensee

subsequently conducted a 100% reinspection of all accessible ASME welds

requiring LP inspection by both individuals (i.e. ASME Code Class 3 2" and

smaller and ANSI B31.1 welds which were originally LP inspected were not

reinspected as part of the reinspection program since they are not required

to be inspected initially in accordance with the Code). The inspector held

discussions with

responsible licensee representatives and reviewed

supporting documentation to verify implementation of the reinspection

program. The reinspection of these inspector's work was documented as being

complete in a letter from Pullman Power Products, dated 5/29/86.

The

irspector also reviewed the licensee's engineering evaluation which

concluded in both instances analyzed that a reportable condition did not

exist. The licensee also identified other inspections conducted by these

individuals which consisted of ultrasonic testing for thickness measure-

ments. A reinspection program per Mil-Std-1050 was implemented by PPP and

the results were found to be acceptable.

The inspector concurs with the

licensee's evaluation.

(0 pen) CDR 50-424/86-121 "NSCW Stainless Steel Pump Fitup" The licensee

reported a potential deficiency pertaining to the Unit 2 Nuclear Service

Cooling Water (NSCW) ASME Class III 14" and larger Schedule 10 stainless

steel pipe welding.

The resident inspectors attended several license

meetings pertaining to the status of their investigation of this matter.

Also the resident inspectors conducted a visual inspection of the inside

diameter of the following pipe welds as part of this item.

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ISO No.

Weld No.

2K5-1202-006-02

006-W-25

2K5-1202-006-01

006-W-22

2K5-1202-006-01

006-W-21

The resident inspectors will continue to follow the progress of the licensee

evaluation of the item.

This matter will be followed up by the Region

Materials and Processes Section upon receipt of the licensee's final report.

(Closed) IFI 50-424/85-13-03 " Review the Results of Additional Re-examina-

tions of Weld Liquid Penetrant Examinations"

The licensee conducted a

re-examination of additional welds selected within a specified time frame.

As a result of these reinspections the licensee subsequently conducted a

100% reinspection of all accessible ASME welds requiring LP inspection by

both individuals (i.e. ASME Code Class 3 2" and smaller and ANSI B31.1 welds

which were originally LP inspected were not reinspected as part of the

reinspection program since they are not required to be inspected annually in

accordance with the Code).

The reinspection of these inspector's work was

documented as being complete in a letter from Pullman Power Products, dated

5/29/86.

The inspector held discussions with responsible licensee

representatives and reviewed supporting documentation to verify implementa-

tion of the reinspection program. The inspector concurs with the licensee's

evaluation. This item is considered closed.

(Closed) IFI 50-424/86-09-04 " Review Projects Revised Response to Quality

Concern No. 85V0582". The inspector has conducted a review of the Project's

response contained in a letter dated May 16, 1986 which acceptably addressed

all of the Resident Inspector's questions. The inspector has no further

questions therefore, this item is considered closed.

6.

Allegations

a.

On July 3, 1986, the inspector requested a meeting with GPC QA, QC and'

Engineering in regards to a concern with the field design and installa-

tion of electrical RayChem splice kits.

IE Information Notice 86-53,

discussion of past problems at other sites with RayChem electrical kit

installations, was also distributed to and discussed with the

attendees. The gist of the concern was that there may be inadequate

detail instructions and training provided to the craft and QC for the

splicing and inspection of electrical cable. The concern specifically

applies when a RayChem "make-up kit" or a " field designed kit" is

authorized for a specific splice configuration.

Without detailed

installation instructions, the potential for installation error is

magnified, furthermore, errors may be hidden by the subsequent boot

installation. Inadequate instructions may also place the QC Inspector

in an incorrect role as having to direct the craft workers how to

install the s~ lice kit. At present, there are no identified examples

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of faulty hardware although the potential is present. The licensee was

asked to address the concern in regard to hardware status (past problem

identification), procedure upgrade, and personnel training (QC and

craft).

The concern applies to Construction as well as Operation

departments.

Subsequently, the licensee has issued a Construction Desk-Top DT-E-33

that presents a detail method for issuing and controlling field

designed electrical splice configurations.

Since more information is

required, this is considered as Unresolved Item 50-424/86-60-02.

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Allegation RII-84-A-0181,

Investigation Concerning Nondestructive

Examination (NDE) Technician Falsifying NDE Reports.

Concern

The Senior Resident Inspector (SRI) at Vogtle was notified by Pullman

Power Product (PPP) management that they had fired a NDE technician for

allegedly falsifying liquid penetrant testing.

The individual was

terminated from employment on 8/22/84 after being confronted by PPP

management to point out location of welds recently inspected and then

not being able to do so.

The licensee (GPC) and PPP advised the SRI

that an investigation into this matter would be conducted.

Discussion

The inspector conducted a review of PPP's interoffice correspondence

which documented their justification for terminating the subject

individual for serious misconduct in preparing and submitting incorrect

QA records falsely indicatino that he had performed certain tests. A

review was also conducted of the generic corrective actions implemented

as a result of this finding which are documented in a memo to file

dated 8/22/84 by the PPP QA/QC Manager. These actions consisted of 1.)

Assigning NDT technicians a unique number with a stamp, 2.) Imple-

menting a program of reinspection of randomly selecting work from work

sheets, 3.) Requiring each PT and MT technician to list acceptable

relevant indications on the inspection report, 4.) Randomly selecting

fifteen (15) welds from all PT technicians for reinspection for

evidence of being previously examined and for adequacy of work

performed, 5.) Meetings were held with all NDE technicians on 8/17 and

8/20/84 to advise them of problems associated with failure to perform

adequately and possible consequences, 6.) Changed in the method of

scheduling NDE work to assure accurate assignments, 7.) Relocation of

NDE supervisor to the field to allow more involvement in direct work

assignments and manpower supervision, and 8.) Changes to the lead

technician position on

"C"

shift.

The inspector conducted several

interviews with the PPP QA/QC Manager and licensee representatives

pertaining to this matter,

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The inspector followed and reviewed the PPP and GPC reinspection

program for the subject inspector's work. This review consisted of

reviewing interoffice correspondence with documented the status and

findings of the reinspection program at various phases during the

reinspection process, reviewing liquid penetrant examination records

documenting the reinspection of ISO / Weld No's 2K2-1592-007-01/007-W-06;

2K2-1592-007-01/007-W-05; 2K2-1202-447-01/005-W-22;

2K2-1592-064-01/

064-W-06X; and 2K3-1202-134-01/134-W-17, and reviewing Deviation Report

No's PPP DR-07401, and SQ- 0060 which documented the weld repair for

deficient conditions identified during the reinspection program.

Conclusion

The licensee identified all welds inspected by the subject individual

during his period of employment from 1/16/84 to 8/22/84. This list

consisted of safety and non safety related piping welds in accordance

with ASME and ANSI B31.1 power piping codes as applicable.

After

conducting several random sampling plan reinspections per Mil-Std-105

the licensee decided to reinspect 100% of all accessible ASME welds

requiring LP inspection by Code (i.e. ASME Code Class 3 2" and smaller

and ANSI 831.1 welds which were originally LP inspected were not

reinspected as part of the reinspection program since they are not

required to be inspected initially in accordance with the Code) by this

individual.

This was documented in a letter by the- Unit #1 PPP QA

Manager dated 5/29/86. The licensee also identified other inspections

conducted by this individual which consisted of ultrasonic testing for

thickness measurements. A reinspection program per Mil-Std-105D was

implemented by PPP and the results were found to be acceptable. Based

on the above review, the inspector concludes that the licensee's

corrective action is acceptable, therefore, this concern is considered

closed.

c.

Allegation RII-85-A-0016-023 Concerning Use of Uncertified Inspectors

to Conduct Inspections

Concern

An alleger stated that a section supervisor in charge of inspecting

electrical terminations at the site had sent unqualified inspectors out

into the field during the summer of 1984. The alleger heard that these

uncertified inspectors would conduct inspections without being

accompanied by certified inspectors.

The alleger stated that the

supervisor would then sign the QC inspection paperwork to reflect that

he had either performed the inspection or he had been with the

uncertified inspector while he performed the inspection. The alleger

stated that one inspector complained about this to the head of the QC

Department, who then relieved the supervisor. The alleger expressed

concern as to whether or not the inspections performed by the uncerti-

fied inspectors 4ere ever reinspected by certified inspectors.

The

alleger heard that the inspector was chastised by other workers for

reporting this problem.

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Discussion

The inspector interviewed the Quality Control inspector that voiced his

concern over being assigned to inspect areas in which he was not

qualified and the head of the QA Department at that time. .The problem

did occur as stated by the alleger except it occurred earlier than the

summer of 1984.

Upon notification of this concern by the Quality

Control inspector, the head of the QA Department immediately initiated

an investigation into the concerns of.the inspector. The supervisor in

question was transferred out of the Quality Control group. The areas

that had been inspected by the ' unqualified personnel were areas

containing non safety related equipment, but were nevertheless

reinspected by certified inspectors.

This investigation by the

licensee is documented in a memorandum to Robert McManus from

M. Upchurch and T. Weatherspoon dated March 15, 1984 and filed in the -

Quality Concern Program file.

Discussions with the Quality Control

inspector indicates there was one isolated case of harassment by

another worker but that was corrected by supervision. There appears to

be no antagonistic view by management and in fact inspector concerns

are encouraged.

Conclusion

Although the allegation was as described, the licensee had taken

adequate corrective action and the inspector considers the action taken

to be adequate.

This concern is closed.

d.

Allegation RII-85-A-0016-019 Investigation of Missing Deviation Report

Concern

An allegation was received that concerned DR (Deviation Report) 06310.

The allegation was that the inspector who wrote the DR took it 'to his

supervisor who would not permit the DR to be issued.

The alleger stated another person said everyone was looking for the DR

and no-one was able to find it. A11eger further stated that when the

DR was later found, only the cover page could be found and the four

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pages that were attached could not be located. The alleger provided a

copy of the DR and expressed concern as to what happened to the DR.

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Discussion

The inspector requested a copy of DR 06310 from the licensee. A copy

was provided by QC Department. The inspector verified the completed

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official copy was in the Operations Department Quality Control vault.

The copy of the DR obtained from the alleger was compared to that

obtained from the licensee. The pages provided by the alleger matched

those from the licensee except that the alleger's copy was incomplete,

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1.e. pages 5 through 11 were not included and corrective action not

documented.

The inspector also interviewed the individual who

initiated the DR. This individual stated his supervision at first did

not want to process the DR but after the details were explained to him

by the inspector there was no hesitation in the approval process. The

initiating inspector stated he had written several other DR's

concerning the same subject matter (different examples) and he had

reviewed the corrective actions of all and was satisfied.

It appears

from documents reviewed that the DR was issued on 10/21/84 and sent to

the Engineering Section the same day.

Conclusion

The inspector could not substantiate this allegation. It appears that

a licensee inspector identified a process in effect that was not

working properly.

He issued several DR's to identify the problem.

Supervision took action to modify the process and Engineering specified

the disposition of the activities previously accomplished by the old

process. Based on this review, the inspector considers this

item closed.

e.

Allegation RII-85-A-0016-029 Investigation Concerning Falsification of

Inspector Certifications

Concern

An alleger stated that two specific Quality Control (QC) inspectors

were not qualified to be inspectors.

In addition the alleger stated

that their certifications have been falsified.

Discussion

The inspector reviewed all training records of both individuals. These

records indicate that these individuals have had the required training

and have been examined in the areas in which they perform inspections.

Documentation is available showing dates of training, eye examinations,

specific graded examinations taken and documentation of continuing

satisfactory job performance.

The examinations reviewed appear to be

in the individual's own handwriting and there is no apparent indication

of record falsification. Education requirements were also reviewed and

met program requirements.

Conclusion

!

Based on this review, the inspector considers this item closed.

i

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12

I

f.

Allegation RII-85-A-0016-015 Concerning Employee Terminations Due to

Drug Use.

Concern

<

i

The alleger is concerned that when employees are terminated for drug

abuse activity that Georgia Power Company (GPC) does not list the

reason for the termination in the individual's work records as drug

1

abuse activity. The alleger stated that the reason for the termination

is usually listed as misconduct or insubordination.

The reason that

this is placed in the records is because GPC is concerned that the NRC

'

will make GPC go back and reinspect all of the work that was performed

by the worker.

Discussion

By letter dated June 5,1986, US NRC Region II assigned the subject

allegation to Georgia Power Co. for action and disposition. A reply

'

was received on July 3 and 10, 1986.

The inspector performed a

preliminary review of the Vogtle Drug Program in order to obtain a base

to investigate and disposition this allegation. The GPC QC Re-inspec-

tion Procedure was reviewed as was the Vogtle Drug Program Manual.

<

Numerous interviews were conducted with the program constituents

including QC, contractors, and the GPC legal representative.

Conclusion

From a procedural aspect, the program is lacking some continuity and

detail to insure standardization in the areas of: the formal QC

1

notification process of those called in on the Drug Abuse Hot Line;

those who will be addressed by QC for re-inspection (field engineers,

QC, etc.); and detail decision making guidelines as to how a supervisor

decides who will be tested or not.

Since more review and information

is required, .this is considered Inspector Followup Item 50-424/

,

'

86-60-09.

7.

General Construction Inspection - Units 1 & 2

,

Periodic random surveillance inspections were made throughout this reporting

l

period in the form of general type inspections in different areas of both

i

facilities. The areas were selected on the basis of- the scheduled activi-

ties and were varied to provide wide coverage. Observations were made of

,

!

activities in progress to note defective items or items of noncompliance

with the required codes and regulatory requirements. On these inspections,

particular note was made of the presence of quality control inspectors,

supervisors, and quality control evidence in the form of available process

'

sheets, drawings, material identification, material protection, performance

of tests, and housekeeping. Interviews were conducted with craft personnel,

j

supervisors, coordinators, quality control inspectors, and others as they

i

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.

.

13

were available in the work areas.

The inspector reviewed numerous

construction deviation reports to determine if requirements were met in the

areas of documentation, action to resolve, justification, and approval

signatures in accordance with GPC Field Procedure No. GD-T-01.

No violations or deviations were identified.

8.

Fire Prevention / Protection and Housekeeping Measures - tinits 1 & 2 (42051C)

The inspector observed fire prevention / protection measures throughout the

inspection period. Welders were using welding permits with fire watches and

extinguishers.

Post indicator valves were being maintained in the open

position. Fire fighting equipment is in its designated areas throughout the

plant.

The inspector reviewed and examined portions of the following procedures

pertaining to the fire prevention / protection measures and housekeeping

measures to determine whether they comply with applicable codes, standards,

NRC Regulatory Guides and licensee commitments.

-

SD-T-05, Rev. 6 Fire-Protection Equipment Inspection and Testing

-

GD-T-15, Rev. 5 Welding and Cutting

GD-T-17, Rev. 3 Housekeeping

-

The inspector observed fire prevention / protection measures in work areas

containing safety related equipment during the inspection period to verify

the following:

Combustible waste material and rubbish was removed from the work areas

-

as rapidly as practicable to avoid unnecessary accumulation of

combustibles

Flammable liquids are stored in appropriate containers and in

-

designated areas throughout the plant

-

Cutting and welding operations in progress have been authorized by an

i

appropriate permit, combustibles have been moved away or safely

j

covered, and a fire watch and extinguisher was posted as required

i

'

Fire protection / suppression equipment was provided and controlled in

-

accordance with applicable requirements

,

i

No violations or deviations were identified.

,

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9.

Structural Concrete - Unit 2 (47053C)

a.

Procedure and Document Review

The inspector reviewed and examined portions of the following

procedures pertaining to the placement of concrete to determine whether

they comply with applicable codes, standards, NRC Regulatory Guides and

licensee commitments.

-

CD-T-02, Rev. 17

Concrete Quality Control

-

CD-T-06, Rev.

9

Rebar and Cadweld Quality Control

-

CD-T-07, Rev.

8

Embed Installation and Inspection

-

CD-T-20, Rev.

6

Installation and Inspection of Trumpets,

Rigid Extensions, and Duct Sheathing

b.

Installation Activities

The inspector witnessed portions of the concrete placement to verify

the following:

(1) Forms, Embedment, and Reinforcing Steel Installation

-

Forms were properly placed, secure, leak tight and clean.

-

Rebar and other embedment installation was installed in

accordance with construction specifications and drawings,

secured, free of concrete and excessive rust, specified

distance from forms, proper on-site rebar bending (where

applicable) and clearances consistent with aggregate size.

(2) Delivery, Placement and Curing

Preplacement inspection was completed and approved prior to

-

placement

utilizing

a

Pour Card

(Procedure

Exhibit

CD-T-02*18).

-

Construction joints were prepared as specified.

Proper mix was specified and delivered.

-

Temperature control of the mix, mating surfaces, and ambient

-

were monitored.

Consolidation was performed correctly.

-

Testing at placement location was properly performed in

-

accordance with the acceptance criteria and recorded on a

Concrete Placement Pour Log (Procedure Exhibit CD-T-02*20).

Adequate crew, equipment and techniques were utilized.

-

L

_ _ _ _ - _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

,

15

-

Inspections during placements were conducted effectively by a

sufficient number of qualified personnel.

-

Curing methods and temperature was monitored.

(3) Rebar Splicing

>

The inspector witnessed cadwelding operations to verify the

following:

Inspections are performed during and after splicing by

-

qualified QC inspection personnel.

Each splice was defined by a unique number consisting of the

-

bar size, splice type, the position, the operator's symbol,

and a sequential. number.

-

Process and crews are qualified.

-

The sequential number and the operator's symbol are marked on

all completed cadwelds.

The inspector also conducted random inspections of completed

cadwelds to verify the following:

Tap hole does not contain slag, blow out, or porous metal.

-

Filler metal was visible at both ends of the splice sleeve

-

and at the tap hole in the center of the sleeve.

No voids

were detected at the ends of the sleeves.

The sequential number and the operator's symbol are marked on

-

all completed cadwelds.

No violations or deviations were identified.

10.

Containment (Steel Structures and Supports) - Unit 2 (48053C)

Periodic inspections were conducted to observe containment steel and support

installation activities in progress, to verify the following:

Components were being properly handled (included bending or straigh-

-

tening).

Specified clearances were being maintained.

-

Edge finishes and hole sizes were within tolerances.

-

Control, marking, protection and segregation were maintained during

-

storage.

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16

i

Fit-up/ alignment ' meets the tolerances in the specifications and

-

drawings.

No violations or deviations were identified.

11. . Safety-Related Structures (Structural Steel and Supports) - Units 1 & 2

(48063C)

Periodic inspections were conducted to observe construction activities of

safety-related structures / equipment supports for major equipment outside the

containment to verify that:

,

Materials and components were being properly handled to prevent damage.

-

Fit-up/ alignment were within tolerances in specifications and drawing

-

l

requirements.

Bolting was in accordance with specifications and procedures.

!

-

Specified clearances from adjacent components were being met.

-

No violations or deviations were identified.

12.

Reactor Coolant Pressure Boundary and Safety Related Piping - Unit 1 & 2

(49053C) (49063C) (37301)

Periodic inspections were conducted to observe construction activities of

the Reactor Coolant Boundary and other safety-related piping installations

l

inside and outside Containments.

Verifications included but were not

limited to the following:

Material and components were being properly handled and stored in order

-

l

to prevent damage.

Fit-ups and alignments were within tolerances per specifications and

-

drawings.

Specified clearances from pipe to pipe and adjacent components were

-

met.

Piping was installed and inspected in accordance with applicable

-

drawings, specifications, and procedures.

Those people engaged in the activity are qualified to perform the

-

applicable function.

Drawing and specification changes (revisions) are being handled and

-

used correctly.

No violations or deviations were identified.

,

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17

{

13.

Reactor Coolant Pressure Boundary and Safety Related Piping Welding

Unit 1 & 2 (55073C) (55083C) Periodic inspections were conducted during

daily plant surveillances on safety-related pipe welding at various stages

of weld completion. The purpose of the inspection was to determine whether

the requirements of applicable specifications, codes, standards, work

performance procedures and QC procedures are being met as follows:

Work was conducted in accordance with a process sheet which identifies

-

the weld and its location by system, references procedures or instruc-

tions, and provides for production and QC signoffs.

Welding procedures, detailed drawings and instructions, were readily

-

available in the immediate work area and technically adequate for the

welds being made.

Welding procedure specification (WPS) were in accordance with the

-

applicable Code requirements and that a Procedure Qualification Record

(PQR) is referenced and exists for the type of weld being made.

Base metals, welding filler materials, fluxes, gases, and insert

-

materials were of the specified type and grade, have been properly

inspected, tested and were traceable to test reports or certifications.

Purge and/or shielding gas flow and composition were as specified in

-

the welding procedure specification and that protection was provided to

shield the welding operation from adverse environmental conditions.

Weld joint geometry including pipe wall thickness was specified and

-

that surfaces to be welded have been prepared, cleaned and inspected in

accordance with applicable procedures or instructions.

A sufficient number of adequately qualified QA and QC inspection

-

personnel were present at the work site, commensurate with the work in

progress.

The weld area cleanliness was maintained and that pipe alignment and

-

fit-up tolerances were within specified limits.

Weld filler material being used was in accordance with welding

-

specifications, unused filler material was separated from other types

of material and was stored properly and that weld rod stubs were

properly removed from the work location.

That there were no evident signs of cracks, excessive heat input,

-

sugaring, or excessive crown on welds.

Welders were qualified to the applicable process and thickness, and

-

that necessary controls and records were in place.

..

.--

-

.--

._

_

-

,

18

No violations or deviations were identified.

14.

Reactor Vessel, Integrated Head Package, and Internals - Unit 1 & 2 (50053C

and 50063C)

Periodic Unit 1 inspections consisted of examinations of the Reactor Vessel

and the installed integrated head package.

The Unit 2 inspections consisted of examinations of the Reactor Vessel

installed in containment, the Reactor Vessel head with the installed control

rod drive mechanisms located on the refueling floor, and the upper internals

in its designated laydown area.

Inspections also determined that proper

storage protection practices were in place and that entry of foreign objects

and debris _was prevented.

,

'

No violations or deviations were identified.

15.

Safety Related Components - Units 1 & 2 (50073C)

i

l

The inspection consisted of plant tours to observe storage, handling, and

!

protection; installation; and preventive maintenance after installation of

safety-related components to determine that work is being performed in

accordance with applicable codes, NRC Regulatory Guides, and licensee

commitments.

,

During the inspection the below listed areas were inspected at various times

during the inspection period to verify the following:

!

Storage, environment, and protection of components were in accordance

-

with manufacturer's instructions and/or established procedures.

Implementation of special storage and maintenance requirements such as:

-

rotation of motors, pumps, lubrication, insulation testing (elec-

trical), cleanliness,etc.

>

Performance

of

licensee / contractor

surveillance

activities

and

-

documentation thereof was being accomplished.

Installation requirements were met such as: proper location, placement,

-

orientation, alignment, mounting (torquing of bolts and expansion

anchors), flow direction, tolerances, and expansion clearance.

Appropriate stamps, tags, markings, etc. were in use to prevent

-

oversight of required inspections, completion of tests, acceptance, and

the prevention of inadvertent operation.

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Safety-Related piping, valves, pumps, heat exchangers, and instrumentation

were inspected in the following Unit 1 and 2 -areas on a random sampling

basis throughout the inspection period:

Residual Heat Removal Pump Rooms

-

Diesel Generator Building

-

Auxiliary Feedwater Pumphouse

-

Containment Spray Pump Rooms

-

Pressurizer Rooms

-

Main Coolant Pump Areas

-

-

Steam Generator Areas

Safety Injection Pump Rooms

-

RHR and CS Containment Penetration Encapsulation Vessel Rooms

-

Component Cooling Water (CCW) Heat Exchangers, Surge Tanks & Pump Rooms

-

-

Cable Spreading Rooms

Accumulator Tank Areas

-

Chemical and Volume Control System (CVCS) Letdown Heat Exchanger Pump

-

Room

Battery & Charger Rooms

-

Nuclear Grade Piping, Valves & Fittings Storage Areas

-

Spent Fuel Pool Heat Exchanger Rooms

-

Pressurizer Relief Tank Area

-

CVCS Centrifugal Charging Pumps & Positive Displacement Pump Rooms

-

Bottom Mounted Instrumentation (BMI) Tunnel and Seal Table Area

-

-

BMI and Supports Under Reactor Vessel

NSCW Tower Pump Rooms and Pipe Tunnels

-

Containment, Auxiliary Building, Control Building, and Fuel Handling

-

Building auxiliary (secondary) areas

No violations or deviations were identified.

16.

Safety Related Pipe Support and Restraint Systems - Units 1 & 2 (50090C)

Periodic random inspections were conducted during the inspection period to

observe construction activities during installation of safety-related pipe

supports to determine that the following work was performed in accordance

with applicable codes, NRC Regulatory Guides, and licensee commitments:

Spring hangers were provided with indicators to show the approximate

-

" hot" or " cold" position, as appropriate.

No deformation or forced bending was evident.

-

Where pipe clamps are used to support vertical lines, shear lugs were

-

welded to the pipe (if required by Installation Drawings) to prevent

slippage.

Sliding or rolling supports were provided with material and/or

-

lubricants suitable for the environment and compatible with sliding

contact surfaces.

Supports are located and installed as specified.

-

_.

-

---

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I

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20

s

b

The surface of welds meet applicable code requirements and are free

-

from unacceptable grooves, abrupt ridges, valleys, undercuts, cracks,

discontinuities, or other indications which can be observed on the

welded surface.

No violations or deviations were identified.

17.

Electrical and Instrumentation Components and Systems - Units 1 & 2 (51053C)

(52153C)

Periodic inspections were conducted during the inspection period to observe

safety-related electrical equipment in order to verify that the storage,

installation, and preventive maintenance was accomplished in accordance with

applicable codes, NRC Regulatory Guides, and licensee commitments.

Inspections were performed on various pieces of electrical equipment in

order to verify the following as applicable:

-

Location and alignment

Type and size of anchor bolts

-

-

Identification

-

Segregation and identification of nonconforming items

-

Location, separation and redundancy requirements

Equipment space heating

-

Cable identification

-

Proper lugs used

-

Condition of wire (not nicked, etc.), tightness of connection

-

-

Bending radius not exceeded

Cable entry to terminal point

-

Separation

-

No violations or deviations were identified.

18.

Electrical and Instrumentation Cables and Terminations - Unit 1 & 2 (51063C)

(52063C)

a.

Raceway / Cable Installation

The inspector reviewed and examined portions of the following

procedures pertaining to raceway / cable installation to determine

whether they comply with applicable codes, NRC Regulatory Guides and

licensee commitments.

EO-T-02, Rev. 8 Raceway Installation

-

ED-T-07, Rev. 9 Cable Installation

-

periodic inspections were conducted to observe construction activities

of Safety Related Raceway / Cable Installation.

In reference to the raceway installation, the following areas were

inspected to verify compliance with the applicable requirements:

4

,

21

Identification

-

-

Alignment

-

Bushings (Conduit)

Grounding

-

-

Supports and Anchorages

'

In reference to the cable installation the following areas were

inspected to verify compliance with the applicable requirements:

Protection from adjacent construction activities (welding, etc.)

-

-

Coiled cable ends properly secured

Non-terminated cable ends taped

-

Cable trays, junction boxes, etc., reasonably free of debris

-

-

Conduit capped, if no cable installed

Cable supported

-

Bend radius not exceeded

-

Separation

-

b.

Cable Terminations

The inspector reviewed and examined portions of the following

procedures pertaining to cable termination to determine whether they

comply with applicable codes, NRC Regulatory Guides and licensee

commitments.

-

ED-T-08, Rev. 7 Cable Termination

In reference to cable terminations the following areas were inspected

to verify compliance with the applicable requirements.

Cable identification

-

1

Proper lugs used

-

Condition of wire (not nicked, etc.)

-

!

Tightness of connection

-

1

-

Bending radius not exceeded

Cable entry to terminal point

-

-

Separation

,

No violations or deviations were identified.

19.

Containment and Safety Related Structural Steel Welding - Units 1&2

(55053C) (55063C)

Periodic inspections were conducted during daily plant surveillances on

safety-related steel welding at various stages of weld completion.

The purpose of the inspection was to determine whether the requirements of

applicable specifications, codes, standards, work performance procedures and

QC procedures are being met as follows:

L

_

_

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--

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22

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t

-

Work was conducted in accordance with a process sheet or drawing which

!

identifies the weld and its location by system, references, procedures

or instructions, and provides for production and/or QC signoffs.

Welding procedures, detailed drawings and instructions, were readily

-

available in the immediate work area and technically adequate for the

welds being made.

Welding procedure specification (WPS) were in accordance with the

-

-

applicable Code requirements and that a Procedure Qualification Record

(PQR) is referenced and exists for the type of weld being made.

-

Base metals and welding filler materials were of the specified type and

grade, were properly inspected, tested, and were traceable.

Protection was provided to shield the welding operation from adverse

-

environmental conditions.

,

i

Weld joint geometry including thickness was specified and that surfaces

-

to be welded were prepared, cleaned and inspected in accordance with

applicable procedures or instructions.

A sufficient number of adequately qualified QA and QC inspection

-

,

personnel commensurate with the work in progress were present at the

'

work site.

Weld area cleanliness was maintained and that alignment and fit-up

-

tolerances were within specified limits.

'

t

Weld filler material being used was in accordance with welding

'

-

specifications, unused filler material was separated from other types

'

of material and was stored and controlled properly, and stubs were

properly removed from the work location.

1

-

There were no visual signs of cracks, excessive heat input, or

!

excessive crown on welds,

Welders were qualified to the particular process and thickness; and

i

-

that necessary controls and records were in place.

l

No violations or deviations were identified.

20.

Preoperational Test Program Implementation / Verification - Unit 1 (70302)

(71302)

The inspector reviewed the present implementation of the preoperational test

program. Test program attributes inspected included review of administra-

tive requirements, document control, documentation of major test events and

deviations to procedures, operating practices, instrumentation calibrations,

f

and correction of problems revealed by testing.

.

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. , - . - , - , - - - - - - - - - -

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23

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Periodic inspections were conducted of Control Room Operations to assess

plant condition and conduct of shift personnel. The inspector observed that

Control Room operations were being conducted in an orderly and professional

manner.

Shift personnel were knowledgeable of plant conditions,

i.e.,

ongoing testing, systems / equipment in or out of service, and alarm /

annunciator status. In addition, the inspector observed shift turnovers on

various occasions to verify the continuity of plant testing, operational

problems and other pertinent plant information during the turnovers.

Control Room logs were reviewed and various entries were discussed with

operations personnel.

Periodic facility tours were made to assess equipment and plant conditions,

maintenance and preoperational activities in progress.

Schedules for

program completion and progress reports were

routinely monitored.

Discussions were held with responsible personnel, as they were available, to

determine their knowledge of the preoperational program.

The Inspector

reviewed numerous operation deviation reports to determine if requirements

were met in the areas of documentation, action to resolve, justification,

corrective action and approvals. Specific inspections conducted are listed

below:

a.

Preoperational Tests

(1) Test Procedure Review (70300)

The inspector reviewed the following listed preoperational test

procedures.

Each test was reviewed for administrative format and

technical adequacy.

The procedures were compared with licensee

commitments from the applicable FSAR Chapters, Regulatory Guide 1.68 and the Safety Evaluation Report (NUREG-1137). This included

verifying that pertinent prerequisites were identified, initial

test conditions and system status were specified, acceptance

criteria were specified and management approval indicated:

NRC

Procedure

Insp.

Test Title

No.

No.

1-300-07/R1

70308

RCS Hot Functional

1-3AL-03/R1

70338

Auxiliary Feedwater System

Testing During HFT

1-300-14/R0

92706

Initial Turbine Roll

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24

(2) Test Witnessing (70312)

The inspector witnessed selected portions of the following

preoperational test procedures as they were conducted.

The

inspection included attendance at briefings held by the test

supervisor to observe the coordination and general knowledge of

the procedure with the test participants.

Overall crew perform-

ance was evaluated during testing. A preliminary review of the

test results was compared to the inspector's own observations.

Problems encountered during performance of the test were verified

to be adequately documented, evaluated and dispositioned. During

the Hot Functional Test the inspectors noted that a well-coordi-

nated and complete program was being conducted.

Minor and major

equipment problems received appropriate levels of attention by

management to minimize the impact to the overall test program.

Plant maintenance teams were fully supportive in providing quick

turnaround.

Plant operations personnel were also supportive of

the test program, however they demonstrated a weakness in plant

control (See Paragraph 20.b).

Procedure

NRC Insp.

Test Title

Activity Observed

No.

No.

1-300-07

70314

RCS Hot

Various as Testing

Functional

Progressed

1-3 AL-03

70438B

Auxiliary Feed-

-AFW pump B

water System

Full Flow

Testing During

Injection

HFT

-AFW pump A & B

48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> run

-TDAFW pump 48

hour run

1-3AB-01

70437

Main Steam System Operation of

Atmospheric

Relief Valves

During HFT

1-3GD-01

71302

AFW Pumphouse

Operation of the

HVAC System

Train "A"

& "B"

Supply Fan During

HFT

1-3GR-01

70445

CROM, Cavity &

Operation of CRDM

Vessel Support

Fans, Cavity Fans

Cooling

and Vessel Support

Cooling During HFT

i

i

..

- _ _ ---- _ --- ---- _ --__ - - - - - - - - - - - _ . - _ _ _ _ _ . - _ _ - - - - _ - _ - - - - - - - - - - - - - - - - - - - - - - - _ - - - - - - - - - - _ . - - - - - - _ - - - - - _ _ _ _

O'

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25

1-3GN-01

70445

Containment

Operation of Train

Cooling

"A" & "B"

Containment Cooling

Fans and Auxiliary

Containment

Coolers During HFT

1-300-06

70431

Reactor Coolant

Steady State

70370C

System Vibration

Operation-Walkdown

Monitoring

of Portions of

Reactor Coolant

Loops, Pressurizer

Surge Line, and

Pressurizer Relief

Line Piping &

Components to

Ensure No

Structural Damage

During HFT.

1-300-08

71302

Thermal

Heatup from 550 F

70370C

Expansion

Walkdown Conducted

in Containment to

Observe Snubber

Movement. Also,

Walkdown Terry

Turbine Steam

Supply Line During

Initial Heatup.

b.

Followup of Event Occurring During Testing

The inspectors reviewed the following events which occurred as a result

of testing:

(1) Pressurizer Power Operated Reitef Valve (PORV) Lifting - This

involved inadvertent loss of pressure control when spray flow was

lost due to securing the #4 reactor coolant pump.

Review of the

event determined that the source of pressure increase was due to a

failure of the operator to secure the Backup Heaters which were'in

manual control prior to securing the RCP. With heaters on, and

spray flow reduced, the pressurizer pressure slowly increased

,

!

until relieved by the PORV.

[

(2) Steam Generator Relief Lif ting - This involved the lif ting of the

1085 psig relief.

Following the lift the valve was gagged.

!

!

Later, the 1200 psig relief lif ted.

The license had the vendor

!

perform setpoint verification and determined that the sotpoints

l

were correct.

These tests were witnessed by regional based

i

inspectors. The licensee has determined that the operators must

!

have allowed pressure to rise and lift the relief, however, this

could not be confirmed.

!

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26

(3) High Moisture Levels in the Diesel Generator B Building - This

event resulted during testing of the Turbine Auxiliary Feed Pump.

Due to plant design the steam exhaust was pulled into the Diesel

Building by the safety grade HVAC system.

The plant has blanked

off this steam exhaust path and engineering is preparing the

necessary design changes. While no damage was initially noted,

the licensee is currently investigating damage to a failed power

rectifier.

c.

Operation Deficiency Report Review (ODR)

During review of ODR No. T-1-85-1810 the inspector noted that the

Unit 2 change required stamp placed on the attached FCR Nos. EFCRB

14678,14681,14686,14687 and 14688 reflected that the design change

was not applicable to Unit No. 2.

Further review revealed that the

design change should have indicated applicability to Unit 2. Bechtel

Desk Instruction PFE-X3DIO8, Rev. O establishes the method for

documenting and tracking the Unit 1 design changes which are applicable

to Unit 2 design. The method utilized by Bechtel for identifying

applicability is a stamp which identifies a Unit 2 change is or is not

required and whether or not a change has been processed.

The licensee has taken the following action pertaining to this matter.

A Bechtel Corrective Action Request No. VS-86-204 has been written as a

result of a review of a sample of EFCRB's for similar problems.

The foregoing is considered to be in violation of 10CFR Part 50,

Appendix B, Criterion V and will be identified as part 2 of Violation

50-424/86-60-01 & 50-425/86-27-01 " Failure to Implement Adequate Design

Control".

21.

Plant Procedures - Unit 1 and 2 (42400B)

This inspection consists of a procedural review to verify that administra-

tive controls are established and implemented to control safety related

operations. Procedures are selected at random and reviewed for technical

adequacy and incorporation of requirements as appropriate for the proper

operation of a nuclear facility in the startup and operational phase. The

following requirements, guidance and licensee commitment were utilized as

appropriate:

- 10 CFR 50.59

Change, Tests, and Experiments

- 10 CFR 50 Appendix B

Instructions, Procedures and Drawings

Criteria V

- ANSI N18.7-1976

Administrative Controls and Quality

Assurance for the Operational Phase

- Regulatory Guide 1.33

Quality Assurance Requirements for the

Rev 2, 1978

Operational Phase of Nuclear Power Plants

- FSAR Section 13

Conduct of Operations

.

. 3

27

Procedures reviewed were:

a.

-Administrative

Number

Rev-

Title

00008-C

2

Plant Lock and Key Control

00050-C

5

Procedure Development

00056-C

1

Safety Evaluations

00152-C

0

Federal and State Reporting

00254-C

2

Plant Housekeeping and Cleanliness Control

00267-C

0

Safe Work Procedures for Chlorine

00304-C

7

Equipment Clearance and Tagging

00308-C

0

Independent Verification Policy

00420-C

0

Equipment Qualification Program

00851-C

2

Storage, Handling and Shipping Requirements

b.

Startup Manual

Number

Rev

Title

SUM-10

4

Temporary Modification Control

SUM-18

9

Operations Oeficiency Reports (00R)

SUM-19

4

Request for Engineering Assistance

.

c.

Operations

!

l

Number

Rev

Title

10000-C

1

Conduct of Operations

l

10001-C

2

Log Keeping

i

10005-C

1

Operability Status Indication for Plant

'

Safety Systems

i

10010-C

3

Operator Qualification Program

'

10016-C

1

Equipment Labeling Guidelines

l

14900-C

0

Containment Exit Inspection

j

14903-1

0

Containment General Inspection

d.

Maintenance

l

R_ev

Title

Number

e

20409-C

1

Maintenanco Procedure Review Qualification

Checklist

!

20406-C

1

Control of Welding Material

In addition, see procedure reviews listed in paragraph 23 k.

l

No violations or deviations were identified.

.

_ _ _ _ _ _ _ _ _ _

_____ _ ______ - _ _

_ _ _ _ _ _ _

. _ _ _ _ _ _ _ _ _ _ .

__

. _ _ _ _ -

e

.

i

28

i

4

22. Three Mile Island Task Action Plan Followup - Unit 1 (4254018)

'

2

This inspection consists of verification that the licensee has implemented

the requirements of NUREG 0737, " Clarification of TMI Action Plan Require-

'

4

ments" as committed to in the facility FSAR or other appropriate documents.

Verification consisted of one or more of the following attributes, as

appropriate, to determine acceptability for each listed action item:

i

<

i

-

Program or procedure established

Personnel training or qualification

-

,

Completion of item

-

'

Installation of equipment

-

'

Drawings reflect the as-built configuration

-

Component tested and in service or integrated into the preoperational

!

-

,

l

test program

The following documents were utilized in performing the review, as-

appropriate:

i

!

!

NUREG 0578

TMI-2 Lessons Learned Task Force Status Report

l

NUREG 0660

NRC Action Plan Developed as a Result of the

TMI-2 Accident

NUREG 0694

TMI-Related Requirements for New Operating Licenses

4

i

NUREG 0737 and

Clarification of TMI Action Plan Requirements

Supplement 1

FSAR thru

Final Safety Analysis Report

l

Amendment 24

j

NUREG 1137 and

Safety Evaluation Report

Supplements

!

I.C.2. (0 pen) " Shift Relief and Turnover Procedures" This item involves the

establishment of plant procedures for shift relief and turnover which

requires signed checklists and logs to assure that the operating staff

'

(including auxiliary operators and maintenance personnel) possess adequate

knowledge of critical plant parameter status, system status, availability,

i

and alignment. FSAR Section 13.5.1.1.H describes the procedures which will

j

be implemented to ensure that a comprehensive exchange of information takes

!

place between the oncoming and of fgoing shift personnel.

Administrative

!

procedure 00003-C, Rev 0 "Shif t Relief" is the basic implementing document

i

which establishes general guidance to be further implemented by the

'

,

Operations Maintenance,

Health

Physics

and Chemistry

Departments.

i

Operations Procedure 10004-C, Rev 1 "Shif t Relief" establishes the general

'i

i

requirements for shift relief and directs the use of the following

!

checklists:

i

<

!

11869-C, " Balance of Plant Operator Relief Checklist"

11870-C, " Operations Supervisor Checklist"

'

l

11871-C, " Shift Supervisor Relief Checklist"

11872-C, " Plant Operator Relief Checklist"

!

I

i

<

l

i

i

!

!

_ . _ __ _ _ ._ _ ~

_ . , _ . _ . _ . _ . , , _ , _ , _ _ _ . . , , _ _ _ _ , . , _ _

.._,_,_ _ _

.

29

11873-C, " Plant Equipment Status Checklist"

11878-C, " Shift Technical Advisor Relief Checklist"

The latest revision of the above checklists were reviewed against NRC

requirements contained in a November 9,1979 letter to all licensees. The

inspector determined that implementation of this item by the licensee did

not conform to the NRC requirements in that checklists do not include:

(1) Critical plant parameters and allowable limits.

(2) What is to be checked and acceptance criteria to assure the avail-

ability of all systems essential to prevention and mitigation of

operational transients and accidents during a check of the control room

panel.

(3) The requirement to make a separate checklist entry for each system and

component that are in a degraded mode of operation permitted by

Technical Specification.

In addition, no system has been established to evaluate the effectiveness of

the shift and relief turnover procedures.

The licensee is evaluating their program.

This item will be further

inspected when the licensee evaluation is completed.

This item will be

tracked as Inspector Follow-up Item 50-424/86-60-10 " Review Compliance with

TMI Item I.C.2."

(Closed) II.G.1 " Emergency Power for Pressurizer Equipment".

This TMI-2

Action Plan Item requires that the motive and control components of the

power-operated relief valves (PORV's) and associated block valves and the

pressurizer level indication shall be capable of being supplied from the

offsite power source or from the emergency power buses when offsite power is

not available.

FSAR Section 5.4.11 describes that the pressurizer is

equipped with two (2) Class 1E block valves (motor operated). The PORV and

associated block valve on one line are supplied with control and motive

power from Train A, while the other PORV and associated block valve on the

other line are powered from Train B.

The PORV block valves 1HV-8000A and

1HV-80008 are powered from Class IE 486-V buses.

These buses are normally

supplied from offsite power. In the event of a loss of offsite power, these

buses are automatically loaded onto the diesels.

PORV's 455A and 456A are

Class 1E DC solenoid valves and are powered from redundant Class 1E 125-V DC

Trains A and B respectively.

Pressurizer Level Indicators LI-0459,. LI-0460, and LI-0461 are powered from

Channels I, II, and III vital buses respectively.

The vital buses are

capable of being powered from either onsite or offsite power sources. A

fourth level instrument LI-0462, is powered from a non-Class 1E inverter-

backed bus.

--

o

,

30

The inspector conducted a review of the following one line drawings to

verify the capability of supplying offsite and emergency power to the PORV's

(1PV-0455A and IPV-0456A); PORV block valves (1HV-80008) and the pressurizer

level indicators (LI-0459, LI-0460, and LI-0461) as described in the FSAR.

Drawing No.

Valve Instrument No's.

Title

1X3D-AA-A01A, Rev 12 1HV8000A & 1HV8000B

Main One Line-Unit 1

1X3D-AA-K02A, Rev 2

Diesel Generator IA and

"

Train "A" AC Buses

"

1X3D-AA-K02B, Rev 2

Loading Table shts 1 & 2

IX3D-AA-F24A, Rev 8

480V Motor Control Center

"

1ABE(1-1805-S3-ABE)

1X3D-AA-F25A, Rev 6

480V Motor Control Center

"

1BBE(1-1805-S3-BBE)

1X3D-AA-G01A, Rev 4

1PV-455A & 1PV456A

Class 1E 125V DC and 120V

Vital AC Systems

1X30-AA-H01A, Rev 8

125V DC Class 1E Distr

"

Train A (1-1805-S3-DCA)

1X3D-AA-H02A, Rev 9

125V DC Class 1E Distr

"

Train B(1-1805-S3-DCB)

1X3D-AA-F18A, Rev 7

480V Motor Control Center

"

1ABA (1-1805-S3-ABA)

1X3D-AA-F19A, Rev 6

480V Motor Control Center

"

1BBA (1-1805-S3-BBA)

1X30-AA-G01A, Rev 4

ILI-0459, ILI-0460&

Main One Line Class 1E

ILI-0461

125V DC and 120V Vital

AC Systems

IX30-AA-G02A, Rev 9

120V AC Class IE Vital

"

Instr Distr Pnis

IX3D-AA-G02C, Rev 5

120V AC Class 1E Vital

"

Instr Distr Pnis

'

The inspector conducted an inspection of the field installed power supply

sources to the PORV's, PORV block valves, and pressurizer level ' trans-

mitters/ indicators to verify installation as per applicable drawings. Based

on this review and a field inspection of the installed condition the

inspector finds that the licensee has properly implemented the requirement

of NUREG-0737, Item II.G.1, therefore this item is considered closed.

(0 pen) II.D.3 " Direct Indication of Relief-and Safety-Valve Position" This

TMI-2 action plan requires the licensee to provide Reactor Coolant ' System

Relief and Safety Valves with positive indication in the control room

derived from a reliable valve position detection device or a reliable

indication of flow in the discharge pipe.

FSAR Section 5.4.13.2 describes

that position indication on the PORV is accomplished through electrical reed

switches. A magnetic rod, activated by the valve plug, is located inside a

1

.

,

31

projection above the top face of the bonnet and operates the reed switches

contained in a switch assembly mounted externally on the bonnet.

Safety

valve indication is also accomplished through reed switches. NRC Questions

420.8, 440.3, and 440.142 al so address this TMI item and state that

indication is in the control room with appropriate lights on the main

control board. The indication is seismically qualified and safety related

and will be included in operating procedures and training.

SER Section

7.5.2.3 addresses this TMI item also.

The inspector conducted a review of the following elementary diagrams to

verify the PORV and safety valve safety grade positive indication in the

control room.

Drawing No.

Valve No.

IX3D-BD-803H, Rev 7

PORV (1PV-0455A) Train A

1X30-BD-803F, Rev 7

PORV (1PV-0456A) Train B

IX3D-80-803J, Rev 1

Safety Valve (IPSV 8010A, B, &C)

A review was also conducted of the PORV and safety valve indicating switch

assembly.

Drawing No.

Title

'INAAPE167-2

Nozzle Type Safety Valve

1Y6AA06-574-4

Crosby PSV Lift Indicating

1X6AA06-575-4

Switch Assembly

1X6AA06-579-2

Power Operated Relief Valve

An inspection of the field installed condition per the applicable drawings

and FSAR requirements as noted below was conducted.

P&ID 1X408112, Rev.19

Reactor Coolant System

FSAR Section 7.5.3.6

Plant Safety Monitoring System

& Table 7.5.2.1

The PORV's position indication was found to be installed in accordance with

applicable drawings and as stated in the FSAR. The inspector noted that the

Pressurizer Primary Safety Valve position indication status is available on

!

the Emergency Respnse Facility (ERF) Computer however, it is not presently

available on Plasma Display in accordance with applicable drawing and FSAR

requirements. P&ID 1XDB112 shows that direct position indication status for

the safety valves is to be provided on demand on the ERF computer and the

-

Plant Safety Monitoring System (PSMS) computer.

In Addition, FSAR Section

,

7.5.3.6 describes PSMS and Table 7.5.2.1 shows that the pressurizer primary

'

safety valve position indication status is to be provided on demand on

plasma display (i.e. PSMS).

The inspector also conducted a review of the

'

Bechtel design specification No. X5AH01 for the Post Accident Monitoring

.

System and the Westinghouse design specification No. X6AZ02-18-1 for PSMS

-

!

l

l

lL

.

32

and noted that the design criteria did not specify the requirement that the

-

function to display pressurizer primary safety valve position indication on

demand be provided on plasma display. A meeting was held with the licensee

to discuss this item.

The licensee acknowledged that this item had

apparently been missed and that a software change to PSMS would be required

to allow pressuizer primary safety valve indication status on demand on

plasma display.

The foregoing is considered to be in violation of 10CFR50 criterion V and

will be identified as part 1 of Violation 50-424/86-60-01 & 50-425/86-27-01

" Failure to Implement Adequate Design Control".

The inspector also conducted a review of the following Operations Procedures

for incorporation of operator action to determine PORV and safety valve

position.

17012-1, Rev 0

Annunciator Procedures for ALB12

on Panel 101 on MCB

The inspector noted that neither the pressurizer relief discharge hot

temperature (Window E01) nor the pressurizer safety relief discharge high

1

temperature (Window F01) alarms operator actions directed the operator to

look at valve position indication to determine valve position, the operator

actions in the procedure are to look at temperature indication in the PORV &

safety valves discharge line. It should be noted that SER Section 7.5.2.3

it is stated in part that in reply to NRC Question 420.8 the backup methods

available in the control room to determine valve position are temperature

indication in the PORV & safety valve discharge line indication as well as

,

pressurizer relief tank temperature, pressure and level indication. Pending

incorporation of operator action to check direct valve. position indication

to determine which PORV & safety relief valve status identified as IFI

50-424/86-60-08, " Review Operations Procedure 17012-1, Annunciator Response

Procedure, for Resolution of Comments.

.

23.

Readiness Review - Unit 1

a)

Section 3.3, Implementation Matrix and Section 6.1, Verification Plan

During the inspection period the inspectors reviewed the following

commitments as part of Readiness Review Module 7 " Plant Operations and

Support. The commitments were reviewed for accuracy between the source

document, Readiness Review Module and the implementing document.

i

)

._

. _ _ - -

. - -

o

.

33

(1) Operations Area Reviewer

'

Commitmenc

Implementing

Number

Source

Document

i

1207.00

FSAR 9.3.3-5

11211-1 Rev 0

1356.00

FSAR 10.A.2.2

11610-1 Rev 0

1572.00

FSAR 13.1.2.2.2

Procedure in Draft

"

1576.00

FSAR 13.1.2.2.2

"

1577.00

FSAR 13.1.2.2.2

1747.00

FSAR 13.5.1.1.D

10000-C Rev 1

1748.00

FSAR 13.5.1.1.E

10000-C Rev 1

2764.00

FSAR 13.5.1.1.E

10000-C Rev 1

"

1743.00

00301-C Rev 0

1744.00

00301-C Rev 0

"

1745.00

FSAR 13.5.1.1.0

00301-C Rev 0

1746.00

FSAR 13.5.1.1.D

00301-C Rev 0

1749.00

FSAR 13.5.1.1.E

10000-C Rev 1

1750.00

10000-C Rev 1

"

"

"

1751.00

"

"

1752.00

'

"

"

1753.00

"

"

1754.00

"

"

1755.00

"

1760.00

FSAR 13.5 1.1.G

"

"

1761.00

"

"

1762.00

"

"

1763.00

"

"

1764.00

"

"

2766.00

"

"

2767.00

"

2768.00

00005-C Rev 0

1576.00

FSAR 13.1.2.2.2

10000-C Rev 1

"

"

1577.00

1592.00

FSla 13.1.2.3

None

1729.00

FSAR 13.5.1.1.A

00051-C Rev 3

10011-C Rev 7

'

L

10012-C Rev 2

1730.00

FSAR 13.5.1.1.A

00051-C Rev 3

"

"

1731.00

"

"

l

1732.00

I

1733.00

"

"

"

"

1734.00

"

"

l

2755.00

"

"

2756.00

00056-C Rev 0

"

"

2757.00

'

"

"

2758.00

1735.00

FSAR 13.5.1.1.B

00052-C Rev 2

I

1736.00

"

"

l

..

.

- - -

-.

.

- - -.

.

34

1756.00

FSAR 13.5.1.1.F

10002-C Rev 2

"

"

1757.00

"

"

1758.00

"

"

1759.00

1765.00

FSAR 13.5.1.1.H

00003-C Rev 0, 100004-C, Rev 0 &

20020-C Rev 0

"

"

1766.00

"

"

1767.00

"

"

1768.00

"

"

1769.00

"

"

1770.00

1783.00

FSAR 13.5.1.1.M &

00053-C Rev 0

5.2.1.G

1794.00

FSAR 13.5.2.1.P

17000 (Series)

1795.00

17000 (Series)

"

1849.00

FSAR 14.2.5

Procedure in Draft

2280.00

FSAR 18.1.1.1

CROR Program Plan

2281.00

CRDR Program Plan

"

2495.00

NRC Quest Q430.26

19000-1 Rev 1

19010-1 Rev 1

19030-1 Rev 1

2511.00

NRC Quest Q430.60

13427-1 Rev 0

13145-1 Rev 0

13415-1 Rev 2

2912.00

Q430.61

13431-1 Rev 0

"

2515.00

Q430.73

13006-1 Rev 1

"

2516.00

Q430.73

13105-1 Rev 0

"

2522.00

Q440.28

18028-1 Rev 1

"

2523.00

Q440.32

13011-1 Rev 2

"

2524.00

Q440.44

18019-1 Rev 1

"

2527.00

Q440.54

14900-1 Rev 0

"

14903-1 Rev 0

2531.00

Q440.142 II.D.3

"

2553.00

Q480.5

14900-1 Rev 1

"

14903-1 Rev 1

i

2612.00

Ltr Aug 10, 1982

19000-1 Rev 0

2623.00

TS 6.1.2

10000-C Rev 1

4

2624.00

TS Table 6.2-1

10003-C Rev 1

2627.00

TS Table 6.2.1

10003-C Rev 1

2628.00

TS Table 6.2.1

10003-C Rev 1

2629.00

TS 6.2.2.D

10003-C Rev 1

2631,00

TS 6.2.2.F

10000-C Rev 1

2632.00

TS 6.2.4

10000-C Rev 1

2640.00

TS 6.7.1.A

Procedure Not Identified

i

2642.00

TS 6.7.1.B

Procedure In Draft

"

2643.00

TS 6.7.1.8

2646.00

TS 6.7.1.D

Procedure Not Identified

l

2673.00

TS 6.9.1.6

00156-C Rev 0

l

- -

--

._ _ _ _ _ . ,

-

- _ _ _

. . _ .

_,

_

.

.

l

35

l

For Commitments 1768 and 1769 see Paragraph 22 TMI item I.C.2

compliance.

The following commitments utilized the Regulatory Compliance

Tracking system to locate the implementing document.

The

implementation of these commitments were at time of the readiness

review work were mostly listed as being in a draft procedure.

Commitment

Implementing

Number

Source

Document

1344.00

FSAR 10.4.4.4

1-3AB-02

911.00

FSAR 2.5.4.13.2

Procedure in Draft

789.00

FSAR 1.9.45

Procedure in Draft

827.90

FSAR 2.9.93

14230-1 Rev 1

14235-1 Rev 0

1117.00

FSAR 7.5.2.3.3.3.B

Deleted by FSAR Change

1120.00

FSAR 7.6.2.2.D

13011-1 Rev 2

1121.00

FSAR 7.6.4

12002-1 Rev 1

12006-1 Rev 1

2530.00

NRC Q440.116

12006-1 Rev 1

2640.00

TS 6.7.1.A

00152-C Rev 0

2642.00

TS 6.7.1.B

00152-C Rev 0

2724.00

FSAR 10.2.3.6.D

12002-1 Rev 1

1207.00

FSAR 9.3.3.5

11211-1 Rev 0

1094.00

FSAR 7.2.2.2.3.N

10000-C Rev 1

1095.00

FSAR 7.2.2.2.3.R

20000-C Rev 1

1101.00

FSAR 7.2.2.5

No Procedure

1106.00

FSAR 7.3.1.2.2.5.8

14600-1 Rev 0

1061.00

FSAR 6.3.1

00050-C Rev 5

1063.00

FSAR 6.3.2.2.16

12002-1 Rev 1

1064.00

FSAR 6.2.2.2.17

11105-C Rev 0

11011-1 Rev 2

11006-1 Rev 1

11115-1 Rev 0

1065.00

FSAR 6.3.2.2.17

11105-C Rev 0

1066.00

FSAR 6.3.2.2.17

11105-C Rev 0

11115-1 Rev 0

Commitment 827 pertains to proper implementation of a Technical

Specification (TS) for electrical systems per Regulatory Guide 1.9.9.3.

T.S.

Surveillance Item 4.8.1.1.1.a will require that

each independent circuit between the offsite transmission network

and the Onsite Class 1E Distribution System be determined OPERABLE

at least once per 7 days by verifying correct breaker alignment

and indicated power availability.

Procedure 14230-1, "AC Source

Verification", was established to implement this requirement,

L

.

36

however, only verifies independent systems up to the Reserve

Auxiliary Transformers. This procedure needs to include verifi-

cation to the IE Class power to ensure that two independent AC

power sources exist.

The inspector determined that this would

have constituted an NRC violation. A second issue was noted to

the licensee regarding TS surveillance 4.8.1.1.1.b.

This item has

been proposed for deletion by the licensee based on the plant

design not having a typical PWR transfer setup on the class 1E bus

between normal and alternate power supplies.

The inspector

informed the licensee that this surveillance pertains to all

transfer devices that interface with the " independent circuits

between the offsite transmission network and the onsite Class 1E

Distribution System." A review of FSAR Fig. 8.3.1-1 indicates the

following busses would be included in this surveillance:

INAA,

INAB, INA01, INA04, INA03, IAA02 and 1.BA03.

Both items will be

reviewed closer to licensing and tracked as IFI 50-424/86-60-03

" Review Technical Specification Surveillance 4.8.1.1.1 Implementa-

tion Procedure for Proper Verification of independent AC Power

Sources".

Commitment 1120 concerns the implementation of FSAR Section

7.6.2.2.D which states that the bypass of RHRS interlocks at the

local station is under strict administrative control with the

valves locked closed to prevent unauthorized opening of the

valves.

The valves in question are 1-HV-8701A, 1-HV-8701B,

1-HV-8702A and 1-HV-8702B are the RHR isolation valves utilized

during cooldown and must be maintained shut during Modes 1, 2 and

3.

The implementing document 13011-1, "Re sidt.al Heat Removal

System" controls the opening and locking of the power supplies to

prevent operation from the control room as part of placing RHR in

standby. The inspector questioned the licensee why the manual

handwheels were not locked and what procedure controls this

evolution. The inspector noted that P&ID 1X4D122 does not denote

these valves as being locked closed. In order to track this item

the following is identified IFI 50-424/86-60-11 " Review Licensee

Response to the Locking of Four RHR Valves Pursuant to FSAR

Section 7.6.2.2.0".

During the process of locating the above commitments the inspector

was informed that the Readiness Review data base had not been

baselined into the Regulatory Compliance Commitment data base.

The baseline process would ensure that the Regulatory Compliance

data base contains all commitments in order to prevent maintaining

two data bases.

In order to ensure that the baseline process is

completed the following inspector follow-up item is identified.

IFI 50-424/86-60-04 " Review Results of Baselining the Regulatory

Compliance Computer database with the Readiness Review Module 7

Database".

,

f

1

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.

37

(2) Maintenance Area Reviewer

Commitment

Implementing

Number

Source

Document

949

FSAR 3.9.8

00412-C, Rev. I

14801-1, Rev. 0

14802-1, Rev. 0

14803-1, Rev. 0

14807-1, Rev. 0

14809-1, Rev. 0

14810-1, Rev. 0

964

FSAR 3.11.B

00350-C, Rev. 1

00420-C, Rev 0

967

FSAR 3.11.B.3-1

00420-C, Rev. O

1003

FSAR 5.2.3.4.1

00851-C, Rev. 2

'

20004-C, Rev. I

1004

FSAR 5.2.3.4.6

20406-C, Rev. 1

1005

FSAR 5.2.4

00411-C, Rev. 1

1024

FSAR 6.2.2.2.4.2.2

14806-1, Rev. 0

1089

FSAR 6.6.1

20100-C, Rev. 1

00411-C, Rev. O

i-

00412-C, Rev. I

1101

FSAR 7.2.2.5

00100-C, Rev. 4

1105

FSAR 7.3.1.2.2.5.2

25731-C, Rev. 4

1141

FSAR 8.3.1.1.3.3.K

25505-C, Rev. 0

1153

FSAR 8.3.2.2

00851-C, Rev. 2

2725

FSAR 10.4.9.4

11610-1, Rev. 1

00304-C, Rev. 7

,

00308-C, Rev. O

00350-C, Rev. I

1500

FSAR 12.5.3.2.9

00254-C, Rev. 2

00350-C, Rev. I

1564

FSAR 13.1.1.1.2.4

003500C, Rev. 1

1565

FSAR 13.1 1 1 2.4

00350-C, Rev. 1

'

1566

FSAR 13.1.1.1.2.4

00350-C, Rev. I

4

1567

FSAR 13.1.1.1.2.4

00350-C, Rev. 1

1802

FSAR 13.5.2.2

00050-C, REv. 5, 00400-C, Rev. 0

1803

FSAR 13.5.2.2

00050-C, Rev. 5

2354

Generic Letter

10006-C, Rev. 1

83-28

2355

Generic Letter

14420-1, Rev. 1

83-28

2369

IEB 74-09

Commitment Tracking #3021

2370

IEB 76-03

Commitment Tracking #3022

2371

IEB 76-05

Commitment Tracking #3023

2372

IEB 76-05

Commitment Tracking #3023

2383

IEB 76-02

Commitment Tracking #3024

2374

IEB 77-01

Commitment Tracking #3025

2375

IEB 77-03

.-

-

- - _ _ _

__

_

_ _ _ - . _

_ _ _

_. _ ,

_.

._ _

._.

O

o

38

2376

IEB 77-02

Commitment Tracking #2967

2377

IEB 77-05

Commitment Tracking #2974

2378

IEB 77-05

Commitment Tracking #2974

2379

IEB 77-07

Commitment Tracking #3028

2381

IEB 78-02

Commitment Tracking #2968

2382

IEB 78-01

Commitment Tracking #2969

2888

IEB 78-06

Discussed with Reg. Compl.

2383

IEB 78-05

Commitment Tracking 2971

2889

IEB 78-10

Commitment Tracking 9657

2488

NRC Q430.17

13146-1, Rev. 0

2495

NRC Q430.26

19000-1, Rev. 0

19010-1, Rev. 0

19030-1, Rev. 0

2507

NRC Q430.45

25505-C, Rev. 0

2508

NRC Q430.45

25505-C, Rev. 0

2512

NRC Q430.62

28908-C, Rev. 1

26909-C, Rev. 0

2513

NRC Q430.62

27740-C, Rev. 2

2519

NRC Q440.10

00350-C, Rev. 1

20015-C, Rev. 4

2609

NRC Q730.1

14900-C, Rev. 0

2651

Tech Spec. 6.8.1.A 00050-C, Rev. 5

2660

Tech Spec. 6.8.4.A

55010-1, Rev. 0

55011-1, Rev. 1

55012-1, Rev. 0

55013-1, Rev. 0

55014-1, Rev. 0

55016-1, Rev. 0

2661

Tech Spec. 6.8.4.A 55010-1, Rev. 0

55011-1, Rev. 1

55012-1, Rev. 0

55013-1, Rev. 0

55014-1, Rev. 0

55016-1, Rev. 0

2662

Tech Spec 6.8.4.A.I 20015-C, Rev. 4

2691

Tech Spec 6.10.2.B 00100-C, Rev. 4

00350-C, Rev. 1

2692

Tech Spec 6.10.2.0 00100-C, Rev. 4

00404-C, Rev.

2693

Tech Spec 6.10.2.E 00100-C, Rev. 4

2695

Tech Spec 6.10.3.A 00100-C, Rev. 4

b)

Section 4.1.1.5, Logkeeping

This section describes the types of logs, who maintains the logs and in

general what information is contained within the logs.

Procedure

10001-C, Rev 2 "Logkeeping" was reviewed.

This procedure contains

additional detail on specific activities which would be recorded.

Logkeeping practices in the control room were reviewed on various days

to determine compliance with this procedure.

In general, compliance

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39

was noted, however, to have a complete understanding of the activities

being logged one has to review . test logs.

An example of this was

repeated logging of Reactor Coolant Pump stopping and starting without

stating the purpose or test in progress.

Management attention is

needed to improve performance in this area.

c)

Section 4.1.2, Equipment and Plant Status Controls

This section describes the methods by which operators remain aware of

and control equipment and plant status. There are seven subparts to

this section.

Each subpart was reviewed against the applicable plant

procedure as listed below. Plant tours were conducted to determine the

level of compliance commensurate with the test status and plant

conditions.

Section

Procedure

4.1.2.1 Operability Status Indication

10005-C

4.1.2.2 Clearance and Tagging

00304-C

4.1.2.3 System Alignments

10000-C

4.1.2.4 Independent Verification

00308-C

4.1.2.5 Key Control

00008-C

4.1.2.6 Rounds Sheets

10001-C

4.1.2.7 Equipment Labeling

10016-C

The review of the procedures and practices determined that basic

implementation has occurred except for independent verification and

that the Readiness Review Module reflects these procedural programs.

d)

Section 4.1.3, Housekeeping and Cleanliness

This section describes controls established to ensure plant areas meet

established cleanliness.

Procedure 00254-C, Rev 2 " Plant Housekeeping

and Cleanliness Control" establishes a program of monthly inspections

to be performed by the superintendents of the various departments. The

inspector reviewed the results of the inspections by examining the data

forms in Document Control. The inspector noted that only the Warehouse

and Warehouse Receiving Building were being consistently inspected.

Areas such as the Maintenance Building and Service Building, and River

Intake Structure have been inspected at least once but appear to have

not been inspected for at least three months. Other areas such as the

Water Treatment Building, Fire Pumphouses, Administration Building,

Nuclear Training Center, and Meteorological Tower should have been

inspected but no records exist.

The remaining areas in the procedure

are under construction control and inspection by operations is not

necessary. The licensee was requested to review the item to determine

the current status of inspection. This item will be tracked as IFI

50-424/86-60-05 " Review the Inspection Status of Regarding Plant

Housekeeping and Cleanliness Control".

._.

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40

e)

Section 4.1.4, Fire Prevention and Firefighting

This section describes the measures to be established as part of the

fire protection program. This area will not be evaluated as ,part of

this module but will be inspected during the NRC fire protection team

inspection. This will allow time for construction to be completed and

the procedures to be established to support a more meaningful review.

f)

Section 4.1.5, Control Room Design Review

This section describes the basic effort to upgrade the control room,

emergency response facilities and procedures.

This area will be

evaluated by the Office of Nuclear Reactor Regulation and not as a part

of this module,

g)

Section 4.2.1, Control of Maintenance

This section of the module described the process by which maintenance

activities are identified, controlled, and documented to ensure proper

implementation.

<

The following procedures were reviewed which implement requirements

pertaining to the above areas:

Procedure No.

Revision

Title

00304-C

7

Equipment Clearance and Tagging

00306-C

1

Temporary Jumper and Lifted

Wire Control

00350-C

1

Maintenance Program

00420-C

0

Equipment Qualification Program

00853-C

4

Material Identification, Control

and Issue

85301-C

0

Work Planning Group and Hold

Point Assignment

Based on this review the inspector has determined that commitments made

in this area appeared to be implemented.

!

The licensee has implemented a maintenance program in accordance with

the startup manual during the preoperational test phase. This program

is similar to the programs being established for operations.

The

inspector has observed the implementation of this program during this

readiness review.

To date approximately 558 of 568 maintenance

mechanical & electrical procedures have been issued.

The licensee

intends to work as many of these procedures as possible during the

preoperational test program to ensure their workability.

These

procedures combined with the additional programatic elements required

of a plant in the operational phase should comprise an adequate

maintenance program.

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.

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-

.

..

.

41

These procedures combined with the additional programatic elements

required of a plant in the operational phase should comprise an

adequate maintenance program.

h)

Section 4.2.2 Control of Modifications

This section of the module describes the process by which planned

changes in plant structure, systems, or components are accomplished to

ensure that implementaticn is in accordance with the requirements and

limitations of applicable procedures, codes, standards, specifications,

licenses, and predetermined safety restrictions.

The following procedures were reviewed which inplement requirements

pertaining to the above areas:

Procedure No.

Revised

Title

00056-C

1

Safety Evaluations

00400-C

0

Plant Modifications

00307-C

0

Temporary Modifications

50005-C

0

Request for Engineering

Assistance

Based on this review the inspector has determined that commitments made

in this area appeared to be implemented.

The licensee has implemented a modification control program during the

preoperational test phase. The inspector has observed implementation

of this program during the readiness review.

These procedures combined with the additional programatic elements

required of a plant in the operational phase should comprise an

adequate plant modification control program.

1)

Section 4.2.6.1, Preventive Maintenance

This section of the module describes the program by which equipment

maintenance is to be conducted to minimize unplanned outages due to

breakdown, to maintain equipment in a satisfactory condition for safe

operation, and to assure equipment operates at its maximum efficiency.

Preventive maintenance includes, but is not limited to, tasks such as

inspection, lubrication, megger testing, calibration, and verification

of operability.

Preventive maintenance also incorporates scheduling

equipment qualifiction requirements for plant equipment and components.

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The folowing procedures were reviewed which implement requirements

pertaining to the above areas:

Procedure No.

Revision-

Title

00350-C

1

Maintenance Program

20015-C

4

Planned Maintenance

Based on this review the inspector has determined that commitments made

in this area appeared to be implemneted.

The license has implemented a preventive maintenance program in

accordance with the startup manual procedure no. SUM-25 during the

preoperational test phase. This program is consistent with preventive

and storage maintenance identified and performed by construction

personnel. The inspector has observed implementation of this program

during the readiness review.

Preventive maintenance checklist are presently being generated for the

operations phase.

These will be implemented upon system release to

operations.

j)

Section 4.2.6.2, Predictive Maintenance

This section of the module describes a program which is an extension of

the preventive maintenance program. .This program consists of

monitoring key parameters such as vibration analysis, fluid analysis,

infrared surveillance, and failure anlysis as appropriate to diagnose

impending equipment failure and to schedule maintenance at the most

appropriate time.

The following procedures were reviewed which implement requirements

pertaining to the above areas:

Procedure No.

Revision

Title

00350-C

1

Maintenance Program

20016-C

0

Predictive Maintenance Program

The liscensee is presently developing the predictive maintenance data

base.

Implementation of the program to obtain base line -data is

scheduled to begin once equipment is up and running for an extended

period of time.

k)

Section 4.4, Coordination Activities

This section describes the activities which coordinate plant operations

and support. There are four subparts as follows:

4.4.1

Procedures

4.4.2 Manuals and Drawings

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4.4.3

Data Processing

4.4.4

Planning and Scheduling

Section 4.4.1 was evaluated by reviewing the plant . procedures which

establish the format, terminology, component identification, and

writing styles for the various type procedures. Procedures reviewed in

conjunction with the evaluation of commitments were noted as being in

conformance with the guidelines. One problem was noted between the

body of procedures and data forms where the required signatures for

each completed step were not consistent. This item had been identified

by the licensee as part of this readiness review area and corrective

action is in progress. The following plant procedures were reviewed

which govern the writing, and control the use of procedures.

00050-C Rev 5

Procedure Development

00051-C Rev 3

Procedure Review and Approval

00052-C Rev 2

Temporary Changes to Procedures

00053-C Rev 0

Temporary Procedures

00054-C Rev 0

Rules for Performing Procedures

10011-C Rev 8

Operations Procedure Preparation and

Review Guidelines

10012-C Rev 2

E0P and AOP Writers Guide

10013-C Rev 1

Writing E0P from the Westinghouse ERG

10014-C Rev 0

Verification of E0P

20409-C Rev 0

Maintenance Procedure Review and

Qualification Checklist

A random sample of department procedures were reviewed for compliance

with Plant Administrative Guidelines, Regulatory Guides, and applicable

codes and standards listed below:

-

Regulatory Guide 1.33, Rev. 2

-

ANSI N 18.7-1976 Administrative Controls and Quality Assurance

for the Operational Phase of Nuclear Power Plants

-

IEEE Standard 338-1977

-

00050-C, Rev 5, Procedure Development

-

00051-C, Rev 3, Procedures Review and Approval

-

00052-C, Rev 2, Temporary Changes to Procedures

-

00053-C, Rev 0, Temporary Procedures

-

00054-C, Rev 0, Rules for Performing Procedures

-

00056-C, Rev 0, Safety Evaluation

The following procedures were reviewed for compliance:

System Operating Procedures:

13115-1, Rev 0, Containment Spray System

13130-1, Rev 0, Post-Accident Hydrogen Control

13146-1, Rev 0, Diesel Generator Fuel Oil Transfer System

_

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44

13150-1, Rev 0, Nuclear Service Cooling Water System

13610-1, Rev 0, Auxiliary Feedwater System

Operations Surveillance Procedures:

14465-1, Rev 0, Accumulator Isolation M0V Power Disconnect

Verification

14485-1, Rev 0, Containment Spray System Flow Path

Verification

14505-1, Rev 0, Main Feedwater Isolation Valves Partial

Stroke Functional Test

14495-1, Rev 0, Auxiliary Feedwater System Flow Path

Verification

14804-1, Rev 0, Safety Injection Pump Inservice Test

14842-1, Rev 0, Main Steam Isolation Valves Partial Stroke

Functional Test

14845-1, Rev 0, Containment Spray System Valves Quarterly

Inservice Test

14910-1, Rev 1, RCS Leakage Inspection

Instrumentation and Control Surveillance Procedures:

24204-1, Rev 0, Feedwater Pump Speed Control P-509 Channel

Calibration

24221-1, Rev 0, Nuclear Service Cooling Water (NSCW) Train B

Supply and Return Flow Loops F-1641A and

F-1641B Channel Calibration

24238-1, Rev 1, NSCW Flow for Diesel Generator F-1650A and

F-16508 Channel Calibration

24342-1, Rev 0, Pressurizer Level Control F-121 Channel

Calibration

24363-1, Rev 1, RHR Heat Exchanger #1 Outlet H-606

Channel Calibration

24376-1, Rev 0, Main Steam Atmospheric Relief Valve

Control Loop 3000 Channel Calibration

24484-1, Rev 0, Steam Generator #3 Level Control F-531

Loop Functional Test and Calibration

l.

24528-1, Rev 0, Pressurizer Pressure Protection

Channel IV Loop P-458 Analog Channel

Operational Test and Channel Calibration

The inspector concluded that an adequate program has been established

to develop procedures and procedures are being developed to the

program. The inspector notes that due to the status of construction

and testing the majority of procedures have not been in actual use.

The plant test program does utilize plant procedures to the maximum

extent practicable for operating and maintenance procedures.

It is

expected that operations surveillance and maintenance surveillance

procedures will be utilized as much as possible prior to fuel load.

.

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_

_

_

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.

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45

The inspector also notes that the inadequacy of procedure 00051-C need

to be resolved as addressed in paragraph 23 o.

1)

Section 4.4.2 references Readiness Review Module 5 and Appendix 0 and

this was not reviewed.

m)

Section 4.4.3 pertains to the following Data Processing systems:

Nuclear Plant Management Information System

Nuclear Plant Reliability Data System

Nuclear Network

Nuclear Operations Records Management System

The evaluation of this section was performed by having the licensee

discuss the input / output features and through discussions with plant

staff.

In addition to the above computer systems the Technical

Specifications Surveillance Tracking System was also reviewed.

The Nuclear Plant Management Information System provides computer

control for maintenance work orders, plant equipment, preventative

maintenance and inventory control.

Each display format and data base

structure was reviewed with the licensee. Maintenance work order (MWO)

processing flow was discussed in detail. As an MWO is reviewed by the

various disciplines various support data files can be accessed, such

as, a three year history, applicable procedures, technical specifica-

tion, vendor and equipment data.

These files provide for a more

in-depth review capability.

The MWO are each statused as they are

processed to completion.

This system also provides the necessary

failure data to the Nuclear Plant Reliability Data System. Inventory

control is also a major portion of this system, however was not

reviewed in detail.

Future improvements to the system will include a

clearance tagging and control system.

The inspector concluded that

this computer system is a major benefit for the licensee, greatly

enhances the level of research and review which can be conducted by the

plant staff and should provide the necessary level of support to meet

the needs of the plant in the future. It was noted, however, that data

is still being loaded to the support files. One area of particular

note is the technical specification (TS) surveillance file. This file

is waiting finalization of the TS. While the impact at this point is

minimal, the lack of data hinders the overall system capabilities.

The Nuclear Plant Reliability Data System was found to not be in actual

use.

Procedures are being developed to control the use of the system

l

at the Plant level.

Engineering is currently making entries to

!

baseline the data base with component and system data.

Component

failure data should start at the time the plant reaches commercial

,

!

operation.

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46

The Nuclear Network was found to be in use at the Plant. Information

is being distributed to various department coordinators for use.

Important information such as INPO significant event reports are

incorporated into the Operational Assessment Program in order to

achieve traceability and resolution of each item.

The Nuclear Operations Records Management Systen was found to be

implemented at the Plant.

This system is a state-of-the-art type

system to maintain and enhance the retrieval of documents. This system

utilizes multiple cross-referencing schemes to allow for rapid location

of documents.

The data entry process appears to capture sufficient

data to support this function.

The inspector reviewed the various

computer display formats that are utilized by the end user and

determined that the system will be an exceptional tool. Currently a

backlog of maintenance work orders, construction and operations records

need to be entered in order to have full use of the systems capabili-

ties.

The Technical Specification Surveillance Tracking Program was also

demonstrated to the inspector.

The data bases and programming

parameters were discussed.

This system will track the completion

status for all surveillance with one month or longer periodicity.

Department coordinators are established and are providing the necessary

data to support the system. This system, when fully functional, should

support the plant's needs to ensure that technical specification

surveillances are completed at the required periodicities.

The overall conclusion was that the plant has or will have computer

systems which should greatly improve plant performance if fully

utilized by the plant staff, however, data loading time delays degrade

the capabilities.

n)

Section 5.1, Audit Summaries

This section summarizes the various audit activities of the following

groups:

-

GPC Quality Assurance Audits

-

NRC Audits

INP0 Evaluation Visit

-

-

Southern Company Services Audit

Plant E.I. Hatch Management Assistance Visit

-

These audit activities were considered by the applicant to be pertinent

to this module. Table 5.1-1 lists each finding, response and status.

The inspector selected three GPC audit findings and verified the

corrective action implemented agreed with the response.

The NRC

findings were reviewed against the complete NRC list of findings. This

review indicated that the applicant had identified all items pertinent

.

47

to this module.

It was noted that Unresolved Item 50-424/85-07-02 as

described in the module is open vice closed as listed. The GPC project

listing was verified to have this item in an open status.

In order to

evaluate the effectiveness of the GPC QA

organization since the readiness review effort was completed the

inspector reviewed QA audit findings regarding this area.

The

following audits were reviewed:

Audit

Titled

OP15-85/12

Maintenance Program

OP09-85/13

Surveillance Program

SP01-85/14

Readiness Review Module 7

OP21-86/02

Corrective Action Program

OP07-86/06

Material Control

0P09-86/08

Records Management & Document Control

OP13-86/09

Design Control & Plant Modification Control

OP10-86/13

Test Equipment Calibration & Control

0P01-86/14

Administrative Controls & Reporting Requirements

OP15/19-86/15

Procedure Control & Review / Records Management

and Document Control

Of particular note was. audit report OP15/19-86/15 where the QA auditor

reviewed the corrective action of regarding readiness review findings

  1. 7-5, #7-9, #7-12, #7-15 and #7-16 which pertain to this module.

In

this review the auditor determined that items #7-5 and #7-9 were not

fully implemented.

The inspector considered this determination to be

indicative of an objective QA audit.

The results of the audit for

items #7-5 and #7-9 are discussed in. paragraph 7 of this report.

Overall the inspection concluded that this section of the module does

reflect the audits that pertain to this area and that the QA program is

aggressively pursuing an effective. audit program.

o)

Section 6.2, Findings and Responses

This section of the module contains the conclusions of the Readiness

Review Team as a result of the team's findings. The overall evaluation

of the findings determined that four categories exist which charac-

terize the results as follows:

-

Inadequate administrative controls

-

Inadequate procedures

l

-

Inadequate procedure review

'

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Procedure noncompliance

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48

The review of this section consisted of reading the finding as

presented in the module; reviewing the actual documentation which

documents the finding and' project response; verifying selected

commitments are now implemented; and discussions with knowledgeable

project personnel. The following findings were reviewed:

  1. 7-1

Inservice Inspection

  1. 7-3

Startup Procedures

  1. 7-4

Data Collection

  1. 7-5

Procedure Qualifications

  1. 7-6

Procedure Revisions

  1. 7-9

Temporary Procedure Revisions

  1. 7-10

Standing Orders

  1. 7-11

Surveillance Procedure Writing

  1. 7-12

Maintenance Procedures

  1. 7-14

Surveillance Procedure Electrical

  1. 7-15

Housekeeping Requirements

  1. 7-16

Overtime

  1. 7-17

Fire Brigade Leader

  1. 7-18

Fire Hazards

  1. 7-20

Storage, Handling and Shipping

  1. 7-21

Startup Test

The following findings of the Readiness Review Team, classified by the

project as nonfinding, were also examined to determine the validity and

appropriateness of the response:

  1. 7-2

Temporary Modifications

  1. 7-7

Procedure Approval Authority

  1. 7-8

Annunciator Response Procedures

  1. 7-13

Control of Measuring and Test Equipment

  1. 7-19

Source Range Count Rate

Finding #7-4 concerns a finding that no plan or program could be found

in Operations, Maintenance, or Engineering departments to collect data

related to transient or operational cycles for components in Table

5.7-1 of Technical Specification. The project response determined the

root cause to be related to the commitment assignment process and

conducted a program to have commitments evaluated for correct

department assignment. The inspector's review of this item determined

that the project did not address the subject of establishing a plan or

program to collect the data.

In order to ensure that an adequate

program or plan is established the following is identified.

IFI

50-424/86-60-06 " Review the Establishment of a Plan to Collect and

Evaluate Transient or Operational Cycles for Adequacy".

Finding #7-5 concerns a finding that objective evidence that mainten-

ance procedures had been reviewed by appropriately qualified personnel

was not available.

The GPC QA audit OP18/19-86/15 did an indepth

review of the area of reviewer qualification. Programmatic concerns of

the original concern were extended in the audit to other departments.

e ,

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49

A sample of reviewer qualifications resulted in a determination that

problems still exist in providing objective evidence and a final

overall conclusion that the readiness review finding has not been fully

corrected.

The inspector agrees with the results of this audit.

Finding #7-9_ concerns a finding that two of four temporary changes

(TCP) to procedures issued were processed improperly.

GPC QA audit

OP18/19-86/15 attempted to verify that the routing and issuance of

TCP's by selecting seventeen TCP's and reviewing their status. This

'

.

verification instead disclosed numerous discrepancies and overall

process problems.

This resulted in an overall conclusion that

procedure 00051-C, Rev 2 " Temporary Changes to Proc.edures" was

inadequate. The inspector agrees with the results of this audit.

Findings #7-5 and #7-9 both represent a lack of achieving in-depth

corrective action beyond the original

finding.

The inspector

determined that the GPC QA group has done a more extensive job at

determining the root cause.

In order to further evaluate the final

corrective action the following IFI is identified.

50-424/86-60-07

" Review Corrective Action Regarding Item #7-5 and #7-9 of Readiness

Review Module 7".

The inspector concluded, except for the following above listed items,

that project responses to the findings were appropriate and implemented

per commitments contained in the responses.

p)

Section 7.0, Assessment

This section contains a summary of open corrective actions associated

with the readiness review findings. Additionally, statements assessing

the acceptability of the readiness review from the readiness review

quality assurance representative, the nuclear operations organizations,

and the readiness review board are included. Resumes of the personnel

instrumental in the development of Module 7 were also included. This

,

section was reviewed for content only.

(

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, ,

Sgp 9 41986

Docket Nos. 50-424, 50-425

License Nos. CPPR-108, CPPR-109

Georgia. Power Company

ATTN:

Mr. J. H. Miller, Jr.

President

P. O. Box 4545

Atlanta, GA 30302

Gentlemen:

SUBJECT:

NOTICE OF VIOLATION

(NRC INSPECTION REPORT NOS. 50-424/86-60 AND 50-425/86-27)

This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by

Messrs. H. H. Livermore, J. F. Rogge, and R. J. Schepens on July 1 - August 11,

1986.

The inspection included a review of activities authorized for your. Vogtle

facility. At the conclusion of the inspection, the findings were discussed with

those members of your staff identified inthe enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these

areas, the inspection consisted of selective examinations of procedures and

representative records, interviews with personnel, and observation of activities

in progress.

The inspection findings indicate that certain activities violated NRC require-

ments.

The violation, references to pertinent requirements, and elements to be

included in your response are presented in the enclosed Notice of Violation.

Your attention is invited to an unresolved item identified in the inspection

report.

This matter will be pursued during future inspections.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and the enclosures

'

will be placed in the NRC Public Document Room.

The response directed by this letter and the enclosures are not subject to the

clearance procedures of the Office of Management and Budget issued under the

Paperwork Reduction Act of 1980, PL 96-511.

1

Should you have any questions concerning this letter, please contact us.

j

Sincerely,

Original Signed by

Luis A. Reyes /for

Roger D. Walker, Director

,

Division of Reactor Projects

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Enclosures:

'

1.

Notice of Violation

2.

NRC Inspection Report

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cc w/encis:

(See page 2)

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SEP o 11996

* .*

.

Georgia Power Company

,2

cc w/encis:

-J. P. O'Reilly, Senior Vice President

Nuclear Operations

R. E. Conway, Senior Vice President &-

Project Director

D. O. Foster, Vice President, Project

Support

P. D. Rice, Vice President, Project

Engineering

R. H. Pinson, Vice President, Project

Construction

J. T. Beckham,_Vice President &

General Manager - Operations

R. A. Thomas, Vice President,

Licensing

D. S. Read, General Manager,

-Quality Assurance

C. W. Hayes, Vogtle Quality

Assurance Manager

W. C. Ramsey, Manager -

Readiness Review

G. B. Bockhold, General Manager,

Nuclear Operations

L. Gucwa, Manager, Nuclear Safety

and Licensing

M. H. Googe, Project

Construction Manager

E. D. Groover, Quality

Assurance Site Manager -

Construction

J. A. Bailey, Project Licensing

Manager

G. F. Trowbridge, Esq., Shaw,

Pittman, Potts and Trowbridge

-B. W. Churchill, Esq., Shaw,

Pittman, Potts and Trowbridge

E. L. Blake, Jr. , Esq. , Shaw,

Pittman, Potts and Trowbridge

J. E. Joiner, Troutman, Sanders,

Lockerman and Ashmore

J. G. Ledbetter, Commissioner,

Department of Human Resources

C. H. Badger, Office of Planning

and Budget

D. Kirkland, III, Counsel,

Office of the Consumer's Utility

Council

,

D. C. Teper, Georgians Against

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Nuclear Energy

(cc w/encls cont'd - see page 3)

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- * *'

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SEP 0 41956

4

Georgia Power Company

3

(cc-w/encls cont'd)

M. B. Margulies, Esq., Chairman,

Atomic Safety and Licensing Board

Panel

Dr. O. H. Paris, Administrative Judge

Atomic Safety and Licensing Board

Panel

G. A. Linenberger, Jr., Administrative Judge

Atomic Safety and Licensing Board

Panel

B. P. Garde, Citizens Clinic, Director

Government Accountability Project

- bcc w/encls:

E. Reis, ELD

W. M. Hill, IE

M. Miller, NRR

W. Brach, EDO

M. Sinkule, RII

E. Christnot, RII

NRC Resident Inspector

Document Control Desk

State of Georgia

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