ML20235S103

Readiness Review.Assessment of Georgia Power Company Readiness Review Pilot Program

ML20235S103
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Site:	Vogtle
Issue date:	09/30/1987
From:	Lewis G Office of Nuclear Reactor Regulation
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NUREG-1278, NUDOCS 8710080317
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NUREG-1278 Vogtle Unit 1 Readiness Review Assessment of Georgia Power Company Readiness Review Pilot Program U.S. Nuclear Regulatory Commission Offico of Nuclear Reactor Regulation G. Lewis g

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NUREG-1278 Vogtle Unit 1 Readiness Review Assessment of Georgia Power Company Readiness Review Pilot Program Manuscript Completed: July 1987 Date Published: september 1987 G. Lewis Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 ya ....,

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ABSTRACT Georgia Power Company (GPC) performed a readiness review at Vogtle Unit I as a pilot program. The pilot program was a new and innovative approach for the systematic and. disciplined review, with senior management involvement, of GPC's implementation of design, construction, and operational readiness processes.

The program's principal objective was to increase the level of assurance that quality programs at Vogtle Unit I have been accomplished in accordance with regulatory requirements.

i This report assesses the effectiveness of the Georgia Power Company's readiness review pilot program (RRPP) at Vogtle Unit 1. It includes (1) an overview of what was experienced during the program's implementation, (2) an assessment of how well program objectives were met, and (3) lessons learned on the future use  :

of the readiness review concept. l Overall, GPC and the NRC staff believe that the RRPP at Vogtle Unit 1 was a success and that the program provided significant added assurance that Vogtle Unit I licensing commitments and NRC regulations have been adequately '

implemented.

Although altering the NRC licensing review process for the few plants still in the construction pipeline may not be appropriate, licensees may benefit significantly by performing readiness reviews on their own initiative as GPC did for Vogtle.

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TABLE OF CONTENTS Page 111 AB ST RACT ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

vii ACKNOWLEDGMENTS ....................................................

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1. INTRODUCTION ..................................................

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2. BACKGROUND'....................................................

2 3.. DISCUSSION ....................................................

I Vogtle Unit .1 Pilot Program Objectives . . . . . . . . . . . . . . . . . . 2 3.1. I 3.1.1 GPC Program Objectives ........................... 2 3.1.2 NRC Program Objectives ........................... 3 Vogtle Unit.1 Readiness Review Process'.................. 4 3.2.

4 3.2.1 GPC Readiness Review Process ..................... 7 3.2.2 NRC Readiness Review Process .....................

9 3.3. .Vogtle Unit 1 Pilot Program Experience ..................

3.3.1 GPC Experiences .................................. 9 3.3.2 NRC Experiences .................................. 11 l

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Vogtle Unit 1 Pilot Program Assessment .................. 13 3.4.

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3.4.1 Objectives and Degree of Success .................

16 3.4.2 Lessons Learned ..................................

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4. PLANNED STAFF ACTIONS .........................................

21 REFERENCES .........................................................

22 GLOSSARY OF ACRONYMS AND ABBREVIATIONS ............................. l l

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ACKNOWLEDGMENTS Acknowledgment is made to the initiative of the Georgia Power Company during the performance of the pilot program and cooperation during the program assessment at program completion, vii

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ASSESSMENT OF GEORGIA POWER COMPANY READINESS REVIEW PILOT PROGRAM FOR V0GTLE UNIT 1

1. INTRODUCTION ThispaperassessestheeffectivenessoftheGeorgiaPowerCompany's(GPC's) readiness review pilot program (RRPP) at Vogtle Unit 1. It includes (1) an overview of what was experienced during the program's implementation, (2) an assessment of how well program objectives were met, and (3) recommendations on the future use of the readiness review concept. Among the assessments of program results is an evaluation of the added assurance the program provided that Vogtle Unit 1 was ready for low-power licensing.

2. BACKGROUND in recent years, major problems relating to the quality of design and/or construction have arisen at several nuclear power plant construction projects.

Projects receiving widespread cttention in this regard include Marble Hill, Midland, and Zimmer. Because of these quality-related problems and other l problems in the U.S. nuclear industry, many in the public and in Congress I questioned (1) the nuclear industry's ability to design, construct, and operate reactors in a manner consistent with maintaining public health and safety and (2) the Nuclear Regulatory Commission's (NRC's) ability to provide effective regulatory oversight of these activities. As a result of these Congressional concerns,- the NRC was directed by Congress in Section 13(b) of Public Law 97-415 (the NRC Authorization Act for fiscal years 1982 and 1983) to conduct a study of existing and alternative programs for improving quality assurance and quality control in the construction of nuclear power plants.

The Quality Assurance (QA) Report to Congress (NUREG-1055, May 1984), in response to Public Law 97-415, identified the concept of readiness reviews as a practice that should be considered for adoption by the commercial nuclear industry. A readiness review is a formal assessment of the implementation of a program or project to determine the preparedness of the responsible personnel, the plant, and management systems to proceed to the next major phase of the project. The readiness review concept represents a structured management approach for assuring that all the elements required to perform an activity have been identified and are ready to support that activity. For nuclear power plant application, the following phases in a facility's life could be chosen:

1) initial design and site preparation

2) beginning of construction 3 major construction milestones (4 plant licensing for operation (5 major outages (6 plant decommmissionina (7) plantlifeextension(PLEX)

GPC proposed the RRPP for Vogtle Unit 1 in a letter to the NRC dated October 3, 1984. The proposal was for a pilot program of a new and innovative approach for the systematic and disciplined review, with senior management involvement, of GPC's implementation of design, construction, and operational readiness processes. The principal objective was to increase the level of assurance that j

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quality programs at Vogtle Unit I have been accomplished in accordance with regulatory requirements." GPC modified the readiness review concept to include a very detailed reexamination of performance to date. This emphasis on past performance was mandated by the status of Vogtle when the pilot program was initiated. Most construction activities had already begun and were in varying stages of completion. GPC estimated that Unit I was approximately 75% complete j at pilot program initiation.

On November 9, 1984, the NRC informed GPC that the NRC would participate in the Vogtle Unit 1 RRPP. SECY-85-122, dated April 8, 1985, provides an overview of the pilot program plan, the roles and responsibilities of the GPC and the NRC

[ Region II, Office of Nuclear Reactor Regulation (NRR), Office of Inspection and Enforcement (IE), and Office of the General Counsel (0GC)], and the public's involvement in the program. The program was completed in January 1987 and did provide added assurance that Vogtle Unit I licensing commitments had been adequately implemented with the exception of specifically identified corrective actions still in progress. Those corrective actions that were still outstanding were not of a safety significance to require any conditions to the Vogtle Unit 1 full power operating license.

IE had program oversight throughout the pilot program and had responsibility for providing programmatic direction to Region II and NRR in the conduct of the program. .A preliminary program assessment made in the Spring of 1986 included review of program documentation completed at that time and interviews of key participants in the program from GPC, Region II, NRR, and IE. This was followed by a more complete program assessment by a team of IE staff and consultants in October and November 1986. This review examined the completed GPC pilot program except for final resolution of some corrective actions. The assessment included detailed interviews of senior management participants at Region II and GPC, members of the licensee readiness review board, selected members of the GPC task force who performed parts of the readiness review, and selected GPC project personnel for Vogtle Unit I responsible for some of the corrective actions resulting from the review, selected Region II inspectors and NRR reviewers who performed parts of the NRC review of the Vogtle Pilot Program. These assessments provide the bases for this report.

3. DISCUSSION Overall, GPC and the NRC staff believe that the pilot readiness review program at Vogtle Unit 1 was a success and that the program provided significant added assurance that Vogtle Unit I licensing commitments and NRC regulations have been adequately implemented. The following sections describe the program and address benefits realized from the program, areas for improvement in future readiness reviews, and staff recommendation and suggested actions.

3.1. Vogtle Unit 1 Pilot Program Objectives 3.1.1. GPC Program Objectives The GPC Vogtle RRPP proposal indicates that the pilot program would be a management process developed to accomplish the following objectives (reference:

GPC letter to NRC dated October 3, 1984):

_y (1) Clearly define the individual work processes involved-in the quality program at.Vogtle Unit 1 and describe how these processes comply with regulatory commitments.

(2) Provide a phased in-depth self-assessment of all work processes and a separate senior management overview of the self-assessment process, including an expert evaluation of both the readiness review assessment and its conclusions.

(3) Enhance the identification of problems and concerns and ensure their correction in a timely manner.

(4) Provide a mechanism for the early resolution of any differences in the NRC and GPC interpretation of regulatory requirements and the resulting acceptance criteria, providing stability and predictability in the .

licensing process.

(5) Provide a planning system, including GPC-prepared and NRC- accepted milestones for the orderly conduct of the separate actions of GPC and the NRC.

3.1.2. NRC Program Objectives Through establishment of the following objectives, the NRC sought to determine to what extent participation in the Vogtle RRPP could improve the effectiveness and efficiency cf the licensee's and the NRC's review processes.to provide added assurance that licensing commitments had been adequately implemented:

(1) providing a more systematic and structured method and inspectable documentation by which, first, the licensee and, subsequently, the NRC can plan and conduct reviews and inspections to establish that regulatory commitments are adequately fulfilled (2) formally involving significant early senior licensee management at critical incremental stages of a project's licensing process (3) providing predictability of the operating licensing process through early resolution of NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria (4) enabling early identification of regulatory problems and concerns with sufficient time to take appropriate corrective actions without undue delay or disruption of the licensing process (5) providing a planning system with milestones acceptable to both the licensee and the NRC, enabling NRC review and incremental acceptance of the licensee's work.

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3.2. Vogtle Unit 1 Readiness Review Process 3.2.1. GPC Readiness Review Process The GPCL readiness review process divided ' plant design, construction, and operational. readiness activities into four functional areas: civil, mechanical, electrical (including' instrumentation and control). and~ plant operations. All plant activities fit into one of these four functional areas.: For. purposes of.

the readiness review,.GPC divided the work activities into the 22 modules shown-in Table 1. As can be seen in Table 3.1. module 21 consists of seven appendices which encompass activities common to several of the~ other modules. Module 22

~ provides the results of an independent design review, by Stone and Webster Engineering Co., of the design process and design adequacy of the plant.across all four functional areas.

In perfonning .the RRPP, GPC ensured that most plant design, construction, and operational readiness activities necessary to ensure safe operations were .

included in the readiness review modules. Items such as emergency preparedness and security were not covered. GPC also ensured that the implementation of..the readiness review program did not result.in deviations from its commitments and design criteria in the Final Safety Analysis Report (FSAR). GPC was committed ,

to processing any changes to the FSAR by amendments through the normal licensing '

process. Each module provides a trail of documentation and implementation to

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meet pertinent commitments.

The GPC organization for implementing the readiness review program consisted of a readiness-review task force and an independent readiness review board which were dedicated to the program for the two-year Unit 1 readiness review. The readiness review task force consisted of engineering and support personnel independent of the Vogtle Unit'l project, selected from applicable design, construction, operations, and quality assurance disciplines. They reported to the readiness review program manager, who was a member of GPC's senior management.

-The readiness review board consisted of technically experienced, senior GPC managers and independent technical experts from organizations outside GPC. The technical experts were selected on the basis of their broad technical backgrounds in particular disciplines and served on the board for module reviews within their area of expertise. Both the readiness review task force manager and the readiness review board chairman reported to the GPC Senior Vice President-Nuclear.

Each readiness review module was sponsored by a member of GPC's senior management who was not only required to organize the technical review team from the readiness review task force but was also responsible for submitting the module to the readiness review board. Technical specialists preparing the modules, and ultimately the module sponsors, had to prove the correctness of their methods, procedures, implementation, and results to the readiness review task force.

i Typically, the task force conducted a multistage review of the activities within ,

the scope of a module. It began by describing the activities for engineering, f procurement, construction, and operational readiness that translate the FSAR j i

commitments into implementing documents, such as design criteria, drawings, calculations, specifications, and design, construction, and operational readiness procedures. These results were incorporated into a commitments matrix for each module. Readiness review task force groups then reviewed the project records and conducted. inspections and walkdowns to ascertain whether documents that demonstrate compliance with procedures and implementation of commitments existed (documents which demonstrate that compliance was incorporated into an implementation matrix) and whether constructed systems complied with the design requirements.

Five types of reviews were conducted: (1) programmatic review of the desi engineering process, (2) programmatic review of construction planning, (3)gn inspections and walkdowns of selected systems to observe whether hardware correctly complied with design documents, (4) review of completed construction records, and (5) technical review of design documents. In addition, the findings of past audits and special investigations were evaluated for their individual and collective significance in regard to the quality of the systems.

These investigations included GPC audit findings, NRC inspections, Institute of Nuclear Power Operations (INP0) evaluations, and self-initiated evaluations.

6-Table 3.1 Yogtle Readiness Review Modules Module No.* Title 1 Reinforced Concrete Structures 2 Operations Training and Qualification s 3.A Initial Test Program, Preoperational Test Phase 4 Mechanical Equipment, Piping and Components 5 Operations Organization and Administration 6 Electrical Equipment 7.A Plant Operations and Support 8 Structural Steel 9.A Radiological Protection 9.B Chemistry 11 Pipe Stresr and Supports 12 Electrical Cables and Tt.ainations 13.A Foundations and Backfill 13.8 Coatings 13.C Post Tensioned Containment 16 Nuclear Steam Supply System 17 Raceways 18.A Heating, Ventilating, and Air Conditioning System 19 Electrical Supports 20 Instrumentation and Control 21 Appendices 21.C Procurement 21.D Document Control 21.E Material Control 21.F Inspector Qualification / Certification 21.G tieasuring and Test Equipment 21.1 Project Quality Assurance Organization Supplement; Quality Concerns 21.J Equipment Qualification 22 Independent Design Review

• Gaps in module numbering sequence such as 14 and 21A etc.

developed as a result of due to reorganization of the module structure when some modules were deleted as the pilot program developed.

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Each module report contains a list of findings, a description of corrective actions, and a discussion of the safety significance of each finding. After evaluation, the findings were classified by GPC into 3 levels as follows:

Level I Violation of licensing commitments, project procedures, or engineering requirements with indication of safety concerns Level II Violation of licensing commitments or engineering requirements with no safety concerns Level III Violation of project procedures with no safety concerns.

Details of the individual and collective evaluations of findings and resulting corrective actions and corrective actions in progress were included in the module.

Each module was completed by the readiness review task force. It was then sent to the readiness review board for review and acceptance. GPC indicated that its readiness review board performed an extensive review to prepare for each module review. From potential and actual problems discovered by NRC and GPC internal audits, allegations from interveners, and problems encountered at other near-term operating license (NT0L) or former NT0L plants such as Diablo Canyon, Waterford, South Texas, Comanche Peak, Zimmer, and Midland, the GPC board gathered a data base of potential and known problems that could impact each module area. The people who prepared the GPC module were required to demonstrate fully to senior management that these problems did not exist and would not arise at Vogtle. The document, when accepted by the GPC board, was sent to the Vice President and Vogtle Project General Manager, who reviewed the module and the board's recommendations. After GPC management was satisfied that the module was complete, accurate, and acceptable, the module was submitted to the NRC.

3.2.2. NRC Readiness Review Process The key NRC office roles and responsibilities were as stated in SECY 85-122.

These remained the same throughout the program and are described as follows:

(1) Region II:

The Regional Administrator was the NRC Vogtle RRPP manager and, as such, was responsible for managing the NRC participation in the program, identifying problems and deficiencies in the RRPP, readiness review pilot program, notifying GPC, and transmitting NRC evaluations of the readiness review modules to the licensee. Region II was responsible for planning, conducting, and coordinating NRC reviews and inspections for each module. Module evaluation letters were prepared by Region II based on the comments, inputs, and findings of NRR, IE, and 0GC. OGC, NRR, and IE each concurred on these letters and on NRC's acceptance of the module. Finally, Region II was responsible for tracking and resolving the status of corrective action and open issues, both before and after

j the NRC evaluation and acceptance of modules, except those involving either FSAR or Safety Evaluation Report (SER) issues, which was the responsibility of NRR.

(2) NRR:

NRR's role in the RRPP was to review GPC FSAR comitments and interpretation of comitments contained in each readiness review module. Further, NRR reconciled SER positions and conclusions with information in the modules and was responsible for tracking and resolving any FSAR actions or open issues.

(3) IE:

The IE role in the RRPP was to develop and provide programmatic direction to Region II, NRR, and 0GC in conducting the program, including developing procedures for NRC review of the pilot program. IE was also assigned to j reviewing and analyzing the results of the pilot program to assess (a) how well l the objectives were met and (b) the applicability of the readiness review l concept to future nuclear power plants. In addition, IE supported the program I by providing guidance in the development of the scope and depth of the Independent Design Review Module and conducting module reviews, including independent hardware-oriented inspections and design inspections at the site and

, at the offices of the architect-engineer in support of Region II.

(4) OGC:

OGC provided legal advice to support the pilot program. The NRC review began with the receipt of a readiness review module from GPC. Approximately two weeks after NRC had received each module, GPC presented the module in a formal and public meeting attended by representatives from each NRC reviewing organization.

The licensee made a formal presentation of the module, and the NRC staff and GPC representatives discussed issues and questions arising from the NRC staff's preliminary review.

Upon receipt of each module, NRC performed a detailed review of the module by (a) verifying that the comitments identified in the module were in accordance with FSAR comitments and regulatory requirements, (b) checking a representative '

sample of the documents reviewed by the GPC readiness review staff and an independent sample of documents selected by the NRC inspectors, (c) checking preoperational plans and procedures, including testing procedures within the scope of a particular module, (d) inspecting a representative independent sample of installed components and equipment, (e) walking down systems and areas, and (f) reviewing past NRC inspections and INP0 audits of the plant pertaining to the module. The reviews were performed by Region II inspectors, and reviewers from NRR and IE. Region II was the NRC focal point for contacts between NRC and GPC.

The NRC reviewers of each module used a standardized report format which was more in the form of an SER than an inspection report in that the module reports emphasized a review and conclusion as to the acceptability of the work activities covered by the module under review. The report provides the licensee and the public with a detennination of module acceptability, discussion of )

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significant findings, statement of any required followup or evaluation, and the summary of results for the Vogtle Unit 1 work activities covered by that module.

Copies of RRPP correspondence between the NRC and GPC were placed in the NRC Public Document Room.

3.3. Vogtle Unit 1 Pilot Program Experience 3.3.1. GPC Experiences The pilot program was initiated in November 1984 and was completed in January 1967. Significant GPC experiences during the program's execution follow:

(1) GPC indicated that the systematic and structured method, including inspectable documentation, in which the licensee, GPC, identified its regulatory commitments and then tied those commitments to their implementing documents, led to early resolution of FSAR commitment misunderstandings. This, in turn, led to identification of problems and initiation of corrective actions much earlier than would have occurred without the readiness review.

Indicative of the early problem identification and corrective action implementation were the 47 Level I findings identified by the licensee (Level I findings are violations of licensing commitments, project procedures, or engineering requirements with indication of safety concerns). Seventeer of the Level I findings have impacted Vogtle Unit I hardware. Examples of Level I findings by the GPC readiness review program that were found early enough to permit timely resolution were as follows:

(a) There was incorrect implementation of a high energy line break criterion. Longitudinal breaks were not postulated at high stress points. This required hardware modifications to maintain a safe shutdown capability.

(b) A pipe support calculation used smaller loads as an input than design requirements. This required hardware modifications.

(c) The auxiliary feedwater system (AFW) flow orifice design was unacceptable because erroneous vendor cavitation criteria were used.

The orifices have been replaced with hardware acceptable to the NRC.

(d) No overpressure protection was provided for low design pressure of AFW and safety injection system pump suction to protect against discharge check valve backleaks on the non-operating pump. A relief valve has been installed to provide the necessary protection.

(e) Safety injection / residual heat removal systems had manual valves installed which could have inadvertently isolated relief valves. This required hardware modifications.

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i 'I (f) Inadequate seismic separation (spatial) was found between pieces of Class 1E equipment. Six such violations were found. The necessary hardware changes have been made.

(g) Inadequate shielding of technical support center (TSC) filters was identified. Plant modifications are being made to stay within post-LOCA acceptable radiation limits in the TSC.

(h) Sixty-four instruments, including nuclear steam supply system (NSSS) manufactured differential pressure transmitters and pressure transmitters, were found secured by bolts that were not in accordance with specifica- tions. The instruments were reinstalled in accordance with specifications.

(2) The readiness reviews for the Unit 1 operational readiness modules, such as operations training and qualification, were started at the beginning of the development of those programs. This provided an opportunity to test the full potential of the concept. However, GPC reviewed those programs on a "one-time" basis and before an adequate degree of commitment implementation for those areas had occurred. In the opinion of the NRC Region II staff, GPC did not include sufficient in-depth followup reviews in the pilot program to verify that those operational readiness activities were adequately implemented. As a consequence, the operational readiness area was addressed, for the most part, outside the readiness review program by GPC and Region II and determined to be adequate. The routine program formed the basis for licensing in this area. In future readiness reviews, both the licensee and NRC should have planned incremental acceptance points rather than "one time" reviews.

(3) The number and content of the modules originally planned were changed substantially as the pilot program progressed. Also, most of the appandices, which address those areas like document control which relate to several module areas, were submitted relatively late in the program. This reduced their value in supporting related module reviews. The most significant change was to incorporate the independent design reviews into one separate module. This enabled a more thorough check of the adequacy of design interfaces between technical disciplines. The effectiveness of this approach is shown by the resulting findings, discussed in paragraph 3.3.1(1),above. They were originally planned to be separate reviews in each module.

(4) Associated with the independent design review were design program verifications of the programmatic aspects of design. This evaluation was a systematic review of design documents that identified the implementation of licensing commitments and included an assessment of design processes.

These design program verifications also identified and corrected safety problems. An example was the identification of inadequate pipe stress and i pipe support design procedures. GPC subsequently developed adequate procedures which NRC has approved.

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)/ ' (5) The preparation and submittal of modules to the NRC did not follow the originally planned schedule of approximately two a month from May 1985 to June 1986. Five modules and appendices had been delivered to the NRC by February 1986. The remaining 23 modules and appendices were submitted between February 1986 and July 1985. GPC indicated a major cause of the original schedule's slippage was the necessity for revisions and corrective actions by GPC after scrutiny by the readiness review board. GPC required that corrective actions be either completed or in progress before submitting the modules to the NRC.

(6) GPC indicated its initial cost estimate to perform the readiness review of

$10M was exceeded; cost was approximately $13.5M. GPC indicated this was primarily due to GPC underestimating the amount of work required to ensure commitment tracking and the rework required of many of the readiness review modules. GPC initially estimated the cost of performing the necessary corrective actions as a result of all readiness review program activities would be $15M. The actual cost of all readiness review program activities was approximately $30M. '

(7) GPC and NRC readiness review meetings were given public notice, and public interest groups were notified of the submittal and subsequent NRC evalcation of modules. Copies of NRC/GPC correspondence on the Vogtle Readiness Review Pilot Program were sent to the NRC Public Document Room.

Public interest groups, such as Georgians Against Nuclear Energy (GANE) and Georgians for a Safe Environment (GFSE), attended only three meetings with GPC and NRC on the readiness review. Hence, only little public involvement was realized.

3.3.2. NRC Experiences The NRC completed its review of the GPC pilot program in January 1987.

Significant observations by NRC during its participation in the Vogtle RRPP include the following: ,

(1) In general, the NRC found the GPC pilot program to be thorough and accurate. NRC findings were generally discovered during an examination of an independently selected sample of records and an onsite inspection of an independently selected sample of hardware critical elements. Fifteen ~

violations of regulatory commitments were discovered during the NRC review.

These tended to be isolated cases rather than weaknesses in GPC's overall program.

(2) Region 11 inspectors found that the relatively large data base established by the GPC program aided them in the performance of the routine Manual Chapters 2512, 2513, and 2514 inspections of Vogtle Unit 1.

(3) Initially, NRC had an inadequate understanding of the module and appendices interfaces. This was particularly difficult for NRR's tracking of FSAR commitments for the various modules. This was primarily due to differences in module and FSAR structures as well as unclear criteria regarding which _

regulatory commitments pertained to a given module.

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(4) The delay in GPC submittal of the majority of the modules caused NRC to perform 75 percent of its review in the last six months of the program. i This strained resources and had some impact on Region II's routine inspection program during that period.

(5) Despite the delay in module submittals by GPC, the NRC inspectors indicated the GPC reviews had identified licensing problems and instituted corrective actions that would have potentially been discovered much later without the readiness review. . This reduced the risk of needing a.large commitment of resources by both GPC and NRC later in the licensing process and loss of flexibility later-in corrective action solutions.

(6) The NRC reviewers noted that some areas of the Vogtle pilot program, such I as civil / structural areas, were reviewed very late in the project activity.

Si 'e construction of Vogtle Unit I was approximately 75 percent complete when the pilot program was initiated, the program was essentially an after-the-fact review. In other areas, such as operational readiness, GPC I

completed its readiness reviews where there was an inadequate base of actual implementation for NRC review and inspection. In addition, most of the FSAR commitment review performed by NRR had already been completed as pert of NRR's normal SER for an operating license.

(7) In t.any instances, the NRC reviews and the internal concurrence and approval process were delayed within the NRC staff because of competing demands for resources from other priority activities, such as TVA issues.

However, these delays were successfully kept from impairing program effectiveness.

(8) The Region II Administrator was the NRC manager responsible for in coordinating NRC staff efforts in support of the Vogtle pilot program. j This tended to facilitate NRC/ utility communications because of the major '

role of Region II in the program and the proximity of the regicnal office to the GPC corporate office and the Vogtle site. However, the NRC staff concurrence and approval process experienced some delays, primarily because i of the pilot nature of the program.

(9) A comparison was made between the NRC resources expended on the Vogtle ilot program and those NRC resources expended on four other NT0L Unit plants1 p(Perry Unit 1, Nine Mile Point Unit 2, Shearor. Harris Unit 1, and Comanche Peak Unit 1). The comparison is shown in Table 3.2, below. For comparison purposes, the data are for the same period before low-power licensing for each plant, except for Comanche Peak, which is not yet licensed.

Table 3.2 Comparative NRC Resources used for Several NTOL Plants Plants Staff Hours * (K) Contractor K$

IE, RII NR0 Total IE, RII NRR Total Vogtle Unit 1** 47.1 30.2 77.3 362 713 1075 Perry Unit 1** 25.7 14.9 40.6 462 672 1134 Nine Mile Point Unit 2** 22.5 20.9 43.4 253 339 592 Shearon Harris Unit 1** 34.8 15.9 50.7 546 629 1175 Comanche Peak Unit 1*** 29.1 32.9 62.0 1691 5023 6714

• To establish a valid comparison, the same basis was used in the compiling staff hours for each plant. The staff hours shown above include all NRC expenditures associated with each plant for the time period involved.

• • Data fo.r the 2-year period preceding low power licensing of that plant.

• • • Data for FY84 through mid-FY86.

Except for Comanche Peak, which has experienced design and continuous quality and licensing difficulties, NRC expended significantly greater resources in licensing and inspecting Vogtle Unit 1 than in the other recent NTOL cases.

This is attributed to the trial nature of the Vogtle 1 RRPP and the timing of the review well after operating licensing reviews began. Both the specific enhancements made to the Vogtle Unit I licensing review process and the long-term benefits of lessons leerned in the trial program made the additional resources well worthwhile.

(10) Pilot program procedures were established by Region 11 for the NRC review process. Using the pilot program experience, the Quality Assurance Branch of NRR, as part of its program development role, is developing generic readiness review procedures for future applications. A preliminary version of these generic procedures was used successfully in the NRC review of one Vogtle Unit 1 pilot program module.

3.4 Vogtle Unit 1 Pilot Program Assessment As part of its participation in the Vogtle RRPP, the NRC staff had six major objectives. These objectives relate to potential benefits from the use of the readiness review concept as an NRC regulatory tool. The following is an assessment of how well the Vogtle pilot program met these objectives and some of the lessons learned from the experience. ,

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3.4.1. Objectives and Degree of Success j (1) Provide a more systematic and structured method by which, first, the licensee and, subsequently, the NRC can establish that regulatory commitments c e adequately fulfilled.

The modular structure of the program, the procedures developed for its implementation, and the established schedule led to a more precise focus on specific technical issues and commitments. The uti.lity, including its senior management, recognized early in the process that did not have a full understanding of its FSAR commitments. The process provided a mechanism for achieving a common understanding of the commitments between the licensee and the NRC and led GPC to develop a tracking system for monitoring resolution of outstanding issues for use by both the licensee and the NRC. This structuring of the licensee's consnitments and tracking of issues was the keystone for a more systematic review of completed and in process work by both licensee management and NRC staff. In turn, this led to an enhanced assurance of compliance with regulatory commitments. Hence, there is greater assurance for both the licensee and the'NRC that the regulatory requirements were-properly implemented and translated into hardware, programs, trained personnel, and activities. The licensee also indicated that its personnel, especially senior management, gained a better understanding of regulatory requirements by participating in this strutttved, systematic review process. This resulted in the licensee being much more effective in identifying and correcting problems. An example, which was discussed'in paragraph 3.3.1(1)(c), was the early identification and acceptable correction of a hardware problem with AFW flow orifices.

(2) Formally involve senior management in a self-assessment at critical incremental stages of a project's licensing process.

This objective was achieved, particularly in the licensee's organization. Each of the licensee's completed modules was reviewed by the readiness review board. The board was composed of senior managers in GPC, with the chairman of the board reporting to the Senior Vice President-Nuclear. The formal process for reviewing modules ensured that these senior managers were significantly involved throughout the program.

In part, because of how the licensee's review process was actually conducted, the involvement of senior NRC managers at critical, incremental stages was somewhat diminished since all the GPC modules were submitted to NRC in approximately a six-month time period. The NRC's review of the modules was less incremental with respect to time than had been anticipated because of delays in receiving the modules from the licensee. These delays appeared to result, in part, from the licensee's approach of establishing and  ;

incorporating corrective actions for all findings in each module ]

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(3) Provide predictability and stability in the operating licensing i process, enabling early resolution of NRC and GPC differences in-interpretation of regulatory requirements and acceptance criteria.

Many NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria were resolved relatively early 1 in the readiness review process. The differences were resolved I early by establishing effective channels of communication (verbal l and written) between NRC and GPC technical staff. An example involved a GPC commitment in design control of high-energy pipe breaks. The commitment involved a design criterion that no pipe  !

whip restraint is needed if postulated intermediate pipe break i locations in high-energy piping are more than five pipe diameters '

from any welded pipe supports. The readiness review revealed a misunderstanding on the implementation requirements of a safety-related commitment. The matter has been resolved.

(4) Identify regulatory problems and concerns early enough to take appropriate corrective actions without unduly delaying or disrupting of the licensing process.

As discussed earlier, the licensee identified several problems during the readiness review that had potential for disrupting the licensing process. They were detected earlier than they would have been through the normal licensing process. This early identification and correction of problems benefited the licensee and the NRC significantly in reducing licensing delays and last-minute expenditures of resources.

l l (5) Provide a planning system with milestones and schedule acceptable t

to both the licensee and the NRC. The schedule should enable incremental acceptance of the licensee's work by the NRC. l The incremental acceptance of the licensee's work was only marginally successful in part because of the relatively late phase l of construction at Vogtle Unit 1 when the pilot program was initiated. Also, a large number of completed modules were submitted to the NRC simultaneously rather than sequentially. This detracted from the goal of incremental acceptance because so many ,

modules were submitted for review at one time and the modules were '

submitted toward the end of the program.

(6) Improve the effectiveness and efficiency of NRC's review process to provide added assurance that licensing commitments have been adequately implemented.

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There is a consensus among most key participants that the Vogtle Readiness Review Pilot Program provided significant added assurance that Vogtle Unit 1 licensing commitments have been adequately 1 implemented. Although the resources required for both GPC and NRC i exceeded original estimates, the benefits accrued are, in the opinion of the staff, well worth the costs.- In addition, the licensee benefited from the readiness review since the program went i beyond the regulatory requirements and commitments and addressed i the overall adequacy of its design and construction programs. The J concept appears to be a viable approach or adjunct to current i I

nuclear power licensing and inspection practices.

3.4.2 Lessons Learned j (1) The effectiveness and efficiency of NRC's participation could have l been enhanced by a greater degree of planning with the licensee before the program began.

Early program planning was held on a compressed schedule between senior NRC management and senior GPC management. However, it appeared that the NRC was not adequately involved in certain aspects of the early program planning. For example, GPC had not defined the structure of the program in relation to the FSAR format or the NRC inspection programs. This made it difficult for NRC ,

reviewers and inspectors, particularly with regard to interfaces j between modules and appendices. l There were no criteria on how commitments would be chosen for inclusion in each module, and, in some cases, relevant comitments were not included without explanation.

In addition, the approach used for the design reviews was changed well after the program had been initiated. Greater emphasis should be placed on planning future readiness reviews. The NRC staff (NRR l and the Region) should provide input to this planning through audit of the program's scope, structure, and milestones. This should enhance efficiency and program payoff for both the licensee and NRC.

(2) During the early stages of the program, the independent design reviews (IDRs) were being performed on a module-by- module approach. IE recommended this approach be changed to a systems oriented, integrated, design review to enable a review of disciplinary interfaces in addition to design aspects within a i particular discipline. This change was made and enhanced the pilot program's effectiveness.

(3) The full readiness review concept as described above will not work l without significant commitment of both inspection and licensing l resources. Therefore, the readiness review program should be meshed with existing NRC licensing and inspection programs in the

future. The resultant program should incorporate a structured system of incremental work acceptance by the NRC inspection and i licensing programs. A master inspection schedule should be established which is adaptable to the progress of work activities.

More emphasis should be placed on timely planning and the conducting of onsite independent inspections of critical elements by NRC for each module. NRC readiness review procedures should be issued as program guidance.

(4) It appears that communicatic t between the GPC Readiness Review Board and the GPC licensing staff could have been improved in the processing of FSAR changes resulting from the readiness review.

Also, a system to track closure of FSAR issues should be included in future programs.

(5) It is essential that NRC and the licensee agree early to a realistic, flexible schedule permitting an in-depth review by the licensee, yet permitting NRC's incremental acceptance of work. The experience gained in the GPC pilot program will be beneficial in planning schedules for future readiness review programs. More emphasis on onsite hardware and product-oriented inspection of critical elements of the licensee's modules is required.

(6) In summary, building on the Vogtle Unit 1 pilot program and lessons learned from it, the readiness review concept could be incorporated into the operating license review process. In order.to identify and resolve issues at an early time, following licensee self-assessments, the staff would incrementally review and document acceptance of licensee work. NRC acceptance of work at early stages will necessarily be conditional with open items identified for followup. The acceptance would be conditional, because issues of substance could arise in public hearings or from subsequent .

licensee or NRC audits. Instead of a major SER, with supplements, '

prepared by the staff relatively late in the construction / pre-operating license period, the staff would produce a series of acceptance reports issued throughout this period. A final SER integrating program elements would still be necessary, but its l' scope would be substantially reduced from past SERs. Appropriate incremental acceptance points in the program might be:

(a) At the program plan / procedure development stage before work begins. GPC management felt that d.any problems co2hi be avoided if an early detailed review of regulatory commitments and requirements was presented. The review should entail agreement on the commitments and requirements, resolution of NRC and licensee differences in interpretation of regulatory requirements, and acceptance criteria.

(b) After completing approximately 10% of the work activity where there has been significant experience in implementing commitments. In addition to continuing to identify and I

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l resolve questions of interpretation cf regulatory requirements, this. step focuses on implementation of the consnitments in each of the numerous work areas and activities involved in plant design, construction, and operational readiness.

This step is important in that, only after some work is completed and experience is acquired in using work procedures, can confidence be gained that potential problems in work procedures have been discovered. A hard, in-depth look by both the utility and NRC at work products and procedures at about the 10% stage of work completion was suggested by GPC as a point far enough into work.to get needed experience in the activity yet early enough to avoid excessive rework or job disruption if problems are identified.

(c) A final review when work is complete, in this regard, it should be noted that the various work areas or modules, as shown in Table 3.1, will be completed sequentially in accordance with the work progress for the' plant. Many of the civil / structural work areas, such as reinforced concrete, will be completed relatively early in the program; other areas, such as preoperational testing, will be completed late in the program. This aliows for a natural incremental review and acceptance of work by both the licensee and the NRC. Although NRC. acceptance reports might be issued at several discrete points, it should also be noted that the NRC will need to inspect continuously throughout the construction period to ensure commitments.are being met.

Sirailar to staff reviews, ACRS reviews could be performed early and incrementally once the staff completed its acceptance reports. This would be an important step in ensuring that, to the extent practicable, issues are being i identified and resolved early. l l

It must be noted that incremental acceptance of work by the l

' staff would in no way bind the licensing bocrd, should the operating license be contested, nor would it prevent NRC staff from reexamining issues which might, for example, be raised through allegations. i

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(7) The full potential of the readiness review concept would be better realized if started early in the construction phase. Section 3.4.2(6) describes in general terms how NRC could fully incorporate an integrated, incremental licensing and inspection approach into its licensing process. To a large extent, the inspection process is 1 already an incremental one. However, an incremental approach to licensing would be a significant departure from past practice.

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Numerous, important questions about the mechanics of a revised l

' licensing process would have to be addressed before it could be i l

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l successfully implemented. Some questions are: would the licensee j still submit a single FSAR, or would a series of modular reports be required? What would change, if anything, in the sequence and schedules for conducting licensing hearings? What would be the i i

nature and scope of reports documenting incremental acceptance of licensee work? How would the standardized plant concept affect the mechanics of an incremental licensing review process? The Vogtle pilot program, given that it occurred after much of the licensing review was completed, did not provide experience upon which to settle these questions or to estimate what resource impact there would be.

Although the Commission may choose in the future to alter the licensing review process to incorporate an incremental review and acc2ptance methodology, it would be impracticable and unnecessary to radically alter the process for plants currently undergoing licensing review. Relatively few in number, these plants are either in advanced stages of completion or are second units, identical to plants already licensed. Altering the NRC licensing review process for the few plants still in the construction pipeline may not be appropriate, licensees, however, may benefit significantly by performing readiness reviews on their own initiative as GPC did for Vogtle. For this reason, the NRC should encourage any utility expressing interest in the concept. This report will be made available to the utilities constructing plants so the benefits of such a program are known.

4. PLANNED STAFF ACTIONS In response to a request by GPC, the staff is considering plans to participate in a readiness review program being initiated by GPC for Vogtle Unit 2. GPC intends to take credit for work performed during the Unit 1 readiness review, where appropriate, in performance of the Unit 2 pregram. The staff is considering plans to participate with GPC in the planning of the program, including providing inputs to the GPC readiness review team composition, goals, milestones and schedules. A meeting with GPC on its plans for Vogtle Unit 2 was held on March 24, 1987 at the Region 11 offices.

On the basis of the staff's evaluation of the Vogtle pilot program, including interviews of the NRC and GPC management staff and key reviewers, the staff developed a number of recommendations on how the readiness review concept could be incorporated into licensing of future j plants. (See Section 3.4.2(6).) Should a new application for a l construction permit be filed, the staff will take the next step in determining what specific changes, including revisions to regulations, might be necessary to fully incorporate an incremental review and acceptance approach into the licensing and inspection process. However,

i because of the priority that must be given to the safety of operating plants and the remaining plants now under construction, and because the legislative framework for licensing could change before a future generation of plants is licensed, staff resources have'not been-allocated at this time to further activity.

REFERENCES Public Law 37-415, 1982. Section 13(b) The NRC Authorization Act for Fisc,a1 Years 1982 and 1983. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC), NUREG-1055, " Improving Quality and the Assurance of Quality in the Design and Construction of Nuclear Power Plants,"

May 1984.

ED0 letter, " Pilot Operational Readiness Review Program - Vogtle Unit 1,"

November 19, 1984.

-- , SECY #85-122 " Georgia Power Company (Vo Operational Readiness Review Pilot Program " gtle) Initiative to Conduct an 1985.

-- , IE Manual Chapter 2512. " LWR Inspection Program - Construction Phase," 1986.

-- , IE Manual Chapter 2513. " LWR Inspection Program - Preoperational Testing and Operational Preparedness Phase," 1984. 1'

-- , IE Manual Chapter 2514, " LWR Inspection Program - Startup Testing Phase," 1984.

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4 GLOSSARY OF ACRONYMS AND ABBREVIATIONS ACRS Advisory Committee on Reactor Safeguards AFW auxiliary feedwater system FSAR Final Safety Analysis Report GANE Georgians Against Nuclear Energy GFSE Georgians For a Safe Environment GPC Georgia Power' Company IDR Independent Design Review IE Office of~ Inspection and Enforcement INP0 Institute of Nuclear Power Operations LOCA loss-of-coolant accident NRC Nuclear Regulatory Comission NRR Office of Nuclear Reactor Regulation

NSSS nuclear steam supply system NT0L near-term operating license 1

OGC Office of the. General Counsel PLEX plant life extension QA quality assurance RRPP readiness review pilot program SER Safety Evaluation Report TSC technical support center TVA. Tennessee Valley Authority l l i

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Georgia Power Company (GPC) performed a r's in . review at Vogtle Unit 1 as a pilot program. The pilot program was a new and i ative approach for the systematic and disciplined review, with senior management i' olvement, of GPC's implementation of design, construction, and operational readi . p processes. The program's principal objective was to increase the level of ass a that quality programs at Vogtle Unit 1 have been accomplished in accordance wi . re atory requirements.

This report assesses the effectiveness the GP p readiness review pilot program (RRPP) at Vogtle Unit 1. It includes (1) an erview of at was experienced during the program's implementation, (2) an ass sment of hew' 11 program objectives were met, and (3) lessons learned on the futu use of the rea. ness review concept. Overall, GPC and the NRC staff believe that he RRPP at Vogtl the program provided significant ded assurance that nit I was a success and that 9tle Unit i licensing commitments and NRC regulations . ve been adequately i emented.

Although altering the NRC lic sing review process for t dhfew plants still in the construction pipeline may no beappropriate,licenseesmaylbenefitsignificantly j by performing readiness re ews on their own initiative as GPC did for Vogtle. '

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