ML20236D844

Discusses Util Initiative to Conduct Operational Readiness Review Pilot Program at Vogtle

ML20236D844
Person / Time
Site:	Vogtle
Issue date:	04/08/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-85-122, NUDOCS 8903230307
Download: ML20236D844 (13)

Text

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,. *% l April 8,1985 W.....)

POLICY ISSUE 5 " 222

[gr: The Connissioners(Information) i i

i From: William J. Dircks Executive Director for Operations

Subject:

GEORGIA POWER COMPANY (V0GTLE) INITIATIVE TO CONDUCT AN 3 OPERATIONAL READINESS REVIEW PILOT PROGRAM i

Purpose:

To infonn the Commission of a Georgia Power Company proposal to conduct a pilot program of readiness reviews at the Vogtle Unit I nuclear power plant and to infom the Commission of NRC staff agreement to participate in the pilot program.

. Suma ry: This paper discusses the Georgia Power Company's readiness review pilot program at Vogtle. The paper includes an overview' of the pilot program, the roles and responsibilities of Georgia Power Company and NRC (Region II NRR, IE, and ELD), and the role of public involvement in the pilot program. In most j respects, the role of the NRC (licensing and inspection) is not '

changed in the readiness review program.

An infonnation befefing to the Commission on this subject will be planned for the near future.

In response to the NRC commitment to advise Georgia Power Company of how NRC will participate in the pilot program fsee NRC letter of November 9,1984. Enclosure 2 of this paper),

the staff desires to send a copy of this Connission Information Paper to Georgia Power Company. The staff also roccamends that, because of the potential for public interest in the readiness review pilot program, this Commission Infonnation Paper be {

placed in the PDR as soon as possible. 3

Background:

A " readiness review" h a formal assessment of the implementa-

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tion of a program or project to detemine the preparedness of the responsible personnel, the plant, and management systems to proceed to the next major phase of the project and the conform-ance with requirements. The readiness review concept represents a structured management approach for assuring that all the elements required to perfonn a selected activity have been identified and are ready to support omretion. In the QA Report  !

toCongress(NUREG-1055,May1984),tieconceptofreadiness reviews was identified as a practice which should be considered  ;

for adoption by the commercial nuclear industry. i

Contact:

G. Ted Ankrum, IE I

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The Commissioners Discussion: '~ On October 3,1984, Georgia Power Company (GPC) proposed to NRC that a pilot operational ;iediness review program be initiated at the Vogtle Unit I nuclear power plant. The pilot program will test the benefits and feasibility of readiness reviews in conjunction with master inspection plans and incremental NRC acceptance of completed work.~ The pilot readiness review program will enable GPC to provide additional assurance that the design, construction, and operational requirements and the GPC cessaitments have been implemented and that the Vogtle plant is ready to operate safely. GPC believes that the readiness review program can help provide this added assurance and, at the same time, minimize delays in licensing and operation by providing a mechanism for the early identification of problems, issues, and contentions. This program will also give NRC the opportunity to review licensee activities in a more structured and timely manner, and will provide more detailed information on the

-' licensee's implementation. The NRC can then use that informa-tion to support staff findings and socisions on issuing an

, operating license, The October 1984 proposal from GPC followed three earlier meetings on September 6,14 and 21,1984, with GPC managonent (Chaineen, Chief Executive Officer and staff) and NRC management including syself, IE, NRR, Region II, and ELU to discuss' the utility's interest in a readiness review program at Vogtle. A copy of the October 3,1984 letter from GPC is included as Enclosure 1.

Vogtle Unit 1 is approximately 755 complete ar.d fuel loading is presently scheduled for fall of 1986. Vogtle Unit 2 is approximately 50% complete. GPC wants a program in place to assure themselves and the NRC, on a schedule consistent with the licensing schedule for Unit 1, that NRC design, construction, and operations requirements and GPC coussitments have been implemented and that the plant is ready to operate safely.

The NkC staff reviewed the GPC proposed pilot program and con-cluded that the assurance of public health and safety could be enhanced through NRC participation. NRC participation in the pilot program will require an expenditure of staff resources in Region II, NRR and IE to support NRC inspection, review, verification, and acceptance of the GPC readiness review activities. The decision to participate was based on an analysis of the pros and cons of the pilot program. A susunry discussion of the pros and cons follows:

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The Connissioners Pros:

1. Participation in the pilot program represents a positive step by NRC in attempting new and alternative approaches to i the present regulatory process. l A successful pilot program will demonstrate predictability $

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and stability in the operating license process: predictable '

in the sense that the licensee and NRC can come to early agreement that the licensee's process and program meet NRC requirements; stable in the sense that the readiness review program to be implemented throughout the design, construc-tion, and preoperational testing will be well defined and understood at the outset.

3. Participation in the pilot program represents a prudent commitment of NRC resources early in the process to

-' minimize the risk of a larger commitment of resources later

- and less flexibility later in detensining the extent of '

l commitment. Early identification of problems gives NRC i greater flexibility under less time pressure to resolve l 1ssues.

4. The pilot program can be carried out within existing regulations and legislative authority.

5. NRC participation directly responds to findings and recommendations of OA Report to Congress (NUREG-1055) and responds to Congressional requests for NRC to initiate innovative improvements to current nuclear regulatory practices. The program also tests the application of readiness review concept, master inspection plans, and incremental NRC approval of completed work. )

6. NRC participation in the pilot program requires a single i NRC focus on implementation issues between GPC and NRC which

. should improve continuity of GPC/NRC communications and I directions.

Cons:

1. There will be an impact on NRC resources. At present the magnitude of this 1spect is difficult to estimate. (See discussion on page 12)

2. The timing of the pilot p g ram is not optimal in that much of the design and construct <on of Vogtle Unit 1 is well advanced (75% complete). A better test of the readinus k . ..

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The Commissioners review concept would be on a new plant in the planning stages. However, given the current state of the nuclear industry, the test et Vogtle should provide an adequate test of the concept.

On November 9,1984, we informed GPC that NRC would participate in the pilot program. The Regional Administrator Region II, has been assigned responsibility as program manage,r and for ensuring continuity in NRC communications with GPC and coordinating NRC staff effort to support the program to assure timely and responsive NRC actions. A copy of the November 9,1984 NRC letter to GPC is included as Enclosure 2.

The following sections provide an overview of the readiness review pilot program, the roles and responsibilities of GPC and NRC and the role of public involvement in the pilot program.

Readiness Review Program The readiness review pilot program represents a significant "

cosmitment of additional GPC resources to complete and analyze the information necessary to support GPC determinations on readiness to operate the Vogtle plant. The readiness review program includes a detailed review by GPC of all programmatic and technical aspects of Vogtle Unit I to assure that all NRC requirements and GPC commitments have been satisfied. GPC initially estimates that approximately 75 person years of effort are required to successfully complete the pilot program and to develop the expanded data and information required to support the readiness review.

GPC is modifying the readiness review concept to include a very detailed relook at performance to date. The emphasis on performance to date is mandated by the current status of the Vogtle plant in that most construction activities have already teen initiated and are in varying stages of completion. Many preoperational activities have also been initiated.

Due to the size and complexities of a nuclear power pitnt, GPC has developed an approach to stratify the various activities into manageable units which can be addressed by GPC and subsequently reviewed and inspected by MRC. The purpose of this work breakdown structure is to provide a framework for groupin9 the activities in discrete units which can be well characterized and can be reduced to a set of manageable activities. GPC has proposed that the activities at the Vogtle site be categorized in Figure 1 below: in five generic functional areas as depicted

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The Commissioners ' I IReady to Doerate Plant l M

I I I I I 1 Civil] l Mechanical l I ElectricalI Instrumentation Operational and Control Readiness Figure 1, Generic Functional Areas In Vogtle Readiness Review All plant activities fit into one of the above five broad categories. For example, under civil, all concrete, backfill, structural welding, coatings, and structural steel activities would be included. Operational readiness would include, for example, initial test programs for systems turnover, emergency planning, operating procedures and technical specifications, security, health physics and chemistry. The determination by GPC that it is ready to operate the plant would be based on a decision that all the civil, mechanical, electrical, instrumen-tation and control, and operational readiness activities are ready to support operations. This decision would be based on a series of intermediate decisions for each of the five functional areas. Figure 2 gives a schematic of the intermediate decisions required of GPC to assess the readiness of activities in the civil functional area.

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l Rebar and Structural Concrete Welding Cadweld Steel / Embed Post Backfill Coatinos. Tensionina Figure 2, Work Activities Required to Support Readiness of Civil Functional Area l

The Commissioners The schematic in Figure 2 shows that the GPC determination that all civil activities are ready to support plant operations is based on a lower-tiered decision that each of the seven supporting work activities in the civil area satisfy all NRC requirements and commitments to NNC and are res% to support operations. Similar trees have been prepared for each of the four other functional areas identified in Figure 1. GPC has proposed that a readiness review be conducted for each set of work activities required to support the readiness of each of the five functional areas. In the civil functional area, there would be seven readiness reviews, one for each of the work activities listed in Figure 2. In some cases, the mediness reviews for two or more work activities may be combined into one single module for administrative and schedule considerations.

For example, concrete, reber, and caduelds (see Figure 2) will be combined in one readiness review module. Approximately 20 readiness review modules are planned for the five functional areas identified in Figure 1. The October 3.1984 letter from

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GPC (Enclosure 1) lists all the readiness mytows planned for Vogtle Unit 1. -

_ Readiness Review Module Each readiness review addresses a specific and unique set of activities at the Vogtle site. Enclosure 1 identifies each readiness review planned at Vogtle Unit 1. For each readiness review, a module will be prepared by GPC which will deff w the overall scope of work and timeframe covered by the revit'.

The scope of work will include a detailed list of all the W elements included in the readiness review. The timefra for each module will vary depending on the start date for each work element included in the readiness review. For example, in the area of backfill the review will begin with the date of initial site preparation while other reviews may have a later start time such as electrical cable installation which will begin several years after the date of CP issuance.

In addition to defining the review's scope and time, GPC will prepare a set of matrices which will depict:

1. Each work element as a function of regulatory requirements and GPC commitments.

2. Regulatory requirements and GPC commitments as a function of time.

3. Each work element as a function of applicable GPC specifications and procedures.

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The Commissioners 4. GPC specifications and procedures as a function of time.

5. Each work element as a function of contractor.

This set of metrices will be very lengthy. The astrices are necessary, however, to assure that in the M1ook at completed activities, GPC will identify all the applicable requirements, the pantsapp (licable GPC consitments and programs, and the partici-licensee each work element can support a determination on completeness and conformance to requirements. GPC is ausre that this relook i may identify areas where the actual work completion and ,

performance is incomplete or unresolved. GPC believes that this  !

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aspect is oce of the strengths of the readiness review program  !

because these incomplete or unresolved areas will be identified

, such eer11er in the process and can be dealt with in a more timely manner.

The next part of each readiness review module will include a detailed discussion of each work element (or group of elements) ';

and will identify: (1) the specific commitments for each work element (s), (2) criteria for acceptance of work as described in theGPCspecificationandprocedures,(3)organizationand interface msponsibilities and procedures, (4) work process description (5) schedule of key events and status of work activities. (6) refemnce to appropriate documentation (design drawings, procedures, etc.), (7) a discussion of significant ,

problems in the work element area to include, for example. l reportable events as a result of NRC, GPC INP0 and other audits I andinspections,and(8)GPC'sassessmentofthestatusand perfomance of each wort element. A separate independent design verification team has also been established to independently review the design process and provide assurance that the design activities have been performed in accordance with commitments.

This analysis will support GPC's assessment of the readiness review module, identify those areas which may require additional work, and support final GPC management's assessment of readiness to proceed to operations based on the status of each work element in the review module.

When all work elements in the readiness review module have been assessed by GPC and certified as properly accomplished. GPC management will verify that the overall work process has been satisfactorily accomplished and that all readiness review program actions have been properly completed. To accomplish this management review GPC is establishing a Readiness Review Board, composed of GPC, Bechtel, and Southern Company Services management, to review each readiness review package, conduct an independent evaluation, and aske recommendations to GPC manage-ment on the completeness and acceptability of the package.

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The Commissioners After the board has determined that the readiness review module is satisfactory to Georgia Power Company, the Vice President and Project Geceral Manager of the Vogtle Project will make a final determination of the acceptability of the readiness review module, The next sequence of activities for each readiness review module will be the GPC management recommendation to NRC for review and inspection of the work elements included in the module, resolution of any issues, and . subsequent NRC acceptance of the module. GPC expects that in some cases, the review module forwarded to NRC will identify cases in which GPC may have additional work activities planned to correct or complete certain elements or

• in which special NRC review or interpretations are required.

The mediness review system will allow GPC and NRC to more easily identify and track the resolution of open items in an improved manner.

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, Readiness Review Responsib111 ties The readiness review program proposed by GPC does not change the traditional NRC position that the licensee is completely respon-sible for the design, construction, and operation of the r9 clear power plant in accordance with applicable standards, regulations, and licensing cosaritments. The readiness review program does not alter the parallel NRC responsibility to assure that the licensee fulfills its responsibilities for design, construction, and operation of the nuclear power plant in a manner consistent wit $' tne protection of public health and safety. The readiness review program provides a very structured, systematic, and defensible tool for GPC and NRC management to assure that these responsibilities are fully carried out. In the readiness review program, GPC must assure that all plant design, construction, and operation activities necessary to assure safe operation are included in one of the readiness review modules (completeness).

GPC must also assure that the implementation of the readiness review program does not result in deviations from their commitments and design criteria in the Final Safety Analysis Report (FSAR). GPC committed to process any changes to the FSAR by amendment through the normal licensing process.

The readiness review program is structured such that the basis for the final GPC management determination of readiness is clearly defined for each functional area and is inspectable by NRC. The NRC will be responsible to commit management and staff resources to support NRC review inspection, and verification of each readiness review module. The NRC review must be timely in providing feedback to GPC as early as possible on areas requiring further GPC review and/or corrective action. The final NRC responsibility in the readiness review program would be to communicate to GPC the NRC acceptance of the readiness review

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module based on NRC review, inspection, verification, and GPC corrective actions. This acceptance connotes that NRC staff ,a,,

is satisfied that NRC requirements and licensee commitments for the particular set of work elements included in the readiness reviewmodulehavebeencompliedwith(performancetodate)and that the GPC program for ongolog activities in this area is acceptable.

Role of WRC In most respects, the role of the NRC (licensin is not changed in the readiness review program.g and inspection)

NRC licensing reviews of safety analysis reports (Preliminary Safety Analysis Report (PSAR) in support of CF. FSAR in support of 01.) are not changed. NRC resident and regional routine inspections to review and confine the adequacy of ongoing licensed activities continue.

The major impact of the readiness review program for NRC and the v major change from current NRC practices would be the additional

~ effort required to review, resolve, and subsequently accept the readiness review modules and the timing of when NRC carries out' these review and inspection activities. These modules will include a greatly expanded set of data and information for NRC review and will require a more structured and coordinated planning of when certain NRC activities are conducted to support NRC review, inspection and verification of the readiness review modules.

In this regard, the timing and extent of certain regional inspections and NRR review activities (for example, in each of thefivefunctionalareasidentifiedinFigure1)willbe modified to coincide with and support NRC review. ins wetion and verification of the readiness review modules to tie extent possible.

The coordination of the NRC organizations involved in the readiness review process is fundamental to the success of the pilot program. NRC efforts must be scheduled and focused to support the NRC/GPC schedule for the readiness review program.

Each office will participate fully and concur in final decisions to be communicated to GPC. To assure continuity in communica-tions with GPC and coordination of NRC staff efforts in support of the pilot programs, the Regional Administrator. Region II.

has been designated to serve as the responsible manaller for the NRC. The reasons supporting this decision include the following:

(1) the Regional Administrator is the established focal point for GPC for all inspection and enforcement activities (excluding major escalated actions): (2) the Regional Administrator, as director of the Regional Office, already has responsibility for the major bulk of the readiness review prccess - the inspection, verification,andimplementationresponsibilities;and(3)the proximity of the Regional Office to the GPC corporate office and the Vogtle site should foster communications during the pilot program and associated development efforts.

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L _NRC Office Roles and Responsibilities

' Region II: The Regional Administrator will serve as the respon-sible NRC manager to identify problems / deficiencies in the o readiness review pilot program to GPC and to implement subsequent i' final NRC acceptance of the GPC readiness review packages. This t

role will require the Regional Administrator to closely coordi-nate the scheduling of all Regfonal. IE, NRR, and ELO activities

! related to NRC's participation in the readiness review pilot program.

GPC correspondence to NRC on the pilot program will be addressed I' to Region II. Region II will coordinate with IE and NRR, to identify the NFC activities necessary to support NRC review, inspection, resolution and final acceptance of each readiness review module submitted by GPC, For each readiness review e

module Region II will prepare a schedule for Region II. NRR and IE readiness review activities. The schedule will be

. concurred in by NRR and IE. In the review of each module.

Region II will have primary responsibility in the inspection and verification of GPC implementation of programs (hardware installation, testing, etc.) in confomance with GPC comitments and requirements. Region II will also participate in the review of GPC's comitments and compare the comitments against previous NRR approvals (for example SER positions) of GPC programs. For each readiness review module. Region II will forward to NRR the results of the Region II review and the determination on the acceptability of GPC's comitments.

Region II will be the recipient of comments / input / findings of HRR, IE, and ELD review activities related to the readiness review program and will communicate the review findings to GPC.

Region II will be responsible for preparing periodic progress reports on the implementation of the readiness review pilot program including inputs from IE and HRR for these reports as appropriate. Region II will also coordinate scheduled meetings with GPC to discuss NRC review and inspection findings and to discuss GPC's resolution of outstanding items.

When identified issues have been satisfactorily resolved Region II will be responsible for connunicating NRC acceptance of the readiness review module to GPC. The acceptance by HRC of a readiness review module conveys NRC staff acceptance of: (I) the completeness of GPC's commitments (PSAR/FSAR) in confoming to NRC requirements, and (2) GPC's interpretation of comitments and implementation of programs in conformance with requirements and GPC connitments. The NRP. letter to GPC will reflect the current status of any oper se unresolved items. The letter from Region !! to GPC giving NRC staff acceptance of a readiness review module (and identifying, as appropriate any open items andthescheduleforresolution)willbeconcur,redinbyNRR, IE, and ELD.

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,; , 9 The Commissioners l NRR:. The NRR role in the readiness review pilot program will be review of GPC commitments and interpretation of constituents { l contained in each readiness review module. Further. NRR will determine that SER positions and conclusions will not change due to information in the modules. The Region's input in this area will be included, as.. appropriate.

The pilot program will not affect routine contacts and normal processes of NRR and the licensee incident to the established FSAR review and licensing process. NRR.will cooperate with the Region and IE in scheduling its site visits and meetings related to the FSAR review concurrently with related aspects -

of. the readiness review pmgram whenever practicable. Realizing l

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that the Vogtle plant is less than two years away from the i scheduled OL date and that the timing of some module submittals  !

will not necessarily be compatible with the ongoing licensing review, the staff will try to minimize the impact of the program

. on the current FSAR review schedule while providing timely ,

, support of the readiness review program. For future plants, it ]

is expected that the NRR licensing reviews and regional inspections could be tied to the readiness review schedules.

IE: The IE role in the pilot program is to develop and provide FRigramatic direction to IE. NRR, and ELD in conducting the  !

pilot program. IE will be responsible for developing programs and procedures for NRC implementat16n of the pilot program. IE will provide input to the review of the readiness review modules.. -

as appropriate (for example, design reviews, QA, and emergency preparedness). IE will review the results of the pilot program and analyze the results with the purpose and objectives originally intended for the pilot program. IE will exercise its traditional program development and appraisal functions in providing programmatic oversight and direction in the conduct of the pilot program.

An important IE responsibility will be to determine the appli-cability of the readiness review concept as tested at Vogtle to l

future nuclear power plants and as it may be applicable to other existing nuclear power plants (for example, operating plants experiencing major outages or modifications). IE will be-responsible for preparing Commission reports on the program development and applicability of the readiness review concept to future nuclear power plants and for revising regulatory

, guidance and inspection programs as appropriate to reflect the L lessons learned in the pilot program.

ELD: ELD will provide legal advice to support the pilot program as appropriate.

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NRC Resource Requirements The costs to the NRC are difficult to estimate. Some of the NRC review, inspection, and verification of readiness review packages will not necessarily represent new work requirements. Staff will need to consider rescheduling certain Regional or IE inspections as well as NRR reviews to support the overall schedule for review of readiness review modules. The readiness review verification will require the Region to re-examine completed inspections to determine if previously conducted inspections support and verify the GPC statement of readiness in the work areas. These NRC efforts do require the comitment and dedication of resources.

Also, there will be additional resources required, including significantly increased travel costs. In some cases, there will be additional resources required to review, inspect, and verify areas for which NRC had not conducted or planned a review, or to resolve newly identified problems. IE and Region II are presently reprogramming staff to the pilot program. As the pilot program progresses, staff resource requirements for NRR, IE, and Region II can be refined.

The readiness review program, by its nature as a pilot program, will require more resources to implement and support the additional reviews and inspections required. In the possible future implementation of the readiness review process, due to lessons learned during NRC participation in the pilot program, the overall additional NRC resources for future projects and even major modifications to operating units) may, however(, be zero. In addition to the NRR, Region II, and IE resources required to implement the pilot program, additional IE resources will be directed to place special emphasis on utilizing lessons learned in developing a readiness review program which may be applicable to other current plants and to future nuclear plants.

The readiness review program, once successfully demonstrated in its pilot form, offers great potential for improving the regula-tory environment and may well affect future utility decisions regarding new nuclear power plants.

_Public Involvement The readiness review program presents additional opportunities for the public to be involved in the process. NRC will make written communications between GPC and NRC on the pilot program a matter of public record; this will include the GPC submittal of the readiness review uodule and the NRC written comments, resolution, and acceptance of the final module.

Meetings between GPC and NRC to discuss the pilot program status and schedule will be open to the pubite following nonnal NRC practices. During the pilot program, the staff plans to study i

9 The Commissioners the concept of greater public involvement in a readiness review program prccess. Upon completion of the pilot program, the staff will make recommendations to the Cosmission on an expanded role for the public in a readiness review program.

The Commission should be aware that there is an intervention in the Vogtle proceeding.

Future Actions: The readiness review cor. cept is new both to GPC and the NRC.

The staff anticipates that there will be the expected learning and implementation problems in the initial stages of the pilot program. The first GPC readiness review module is scheduled for transmittal to NRC in March 1985. After NRC review of this first module, the staff will better define the NRC r:<ources required and on the real potential benefits to be realized through the readiness review concept. The staff will keep the Comission infomed of the status and progress of the pilot program. I have directed the staff to prepare an initial

. infor1 nation briefing for the Comission on the pilot program purpose, plans, and schedules. I will invite GPC representatives to attend this briefing and to be prepared to discuss their

, pilot program initiative with the Commission.

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.c u Willia . irc s Executive Director for Operations

Enclosures:

1. Georgia Power Company Letter to NRC, October 3,1984

2. NRC Letter to Georgia Power Company, November 0 1984 5 1

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, ENCt.050RE 1 C4 0Ci 3 P3: q R E.conway "

October 3. 1884 United States Nuclear Regulatory Commission Office of Inspection and Enforcement File: 17BD102 Region II - Suite 3100 1,og: GN-424 101 Marietta Street Atlanta, Georgia 30302

Reference:

Readiness Review Program Attention: Mr. James P. O'Reilly

, Gentlemen PURPOSE The purpose of this letter is to propose a pilot program for the }

systematic and disciplined review of Georgia Power Company's implemen-tation of design, construction, and operational preparation proc, esses to increase the level of assurance that Plant Vogtle's -quality programs have been accomplished in accordance with regulatory requirements.

. BACKGROUND Georgia Power Company has long been concerned about the inability of a nunbar of utilities to satisf actorily complete nuclear plants under con-struction on time, within budget, and in compliknee with Nuclear Regulatcry Con::ission requirements. A number of these problems appear to have been the result of major quality-ralated breakdowns in the management of plant construction or the utilities' inability to demonstrate the requisite quality.

In a report to Congress on Improvint Quality and the Assurance of Quality in

' the Design and Construction of Nuclear Power Plants (NUREG-1055). the Nuclear Regulatory Comission addressed these issues. In response to the l

question, 'Vhy have the Nuclear Regulatory Comission and the utilities failed l

or been slow to detect'and/or respond to these quality-related problems?". the '

Nuclear Regulatory Connission defined a number of shortcomings and recon:medad actions. One of the actions recommended for further analysis was the feasi-bility and benefits of Readiness Reviews which would involve formal assess-l ments by the utility of their readiness to proceed at critical phases of a l project and include possible involvement of Nuclear Regulatory Com=ission staff, i

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. Geor.da Poner d ,

Readiness Review Program Paga Two .

DISCUSSION In response to the concerns for past problems and in consideration of j the potential banafits of Readiness Reviews addressed in NUREG-1055, Georgia Power company has developed a proposed Readiness Review Program for Plant vogtle. Attachment 1 to this letter is a Readiness Review Program plan which includes a discussion of objectivas, responsibilities, review process, pro-ceduras, organization and schedules for implementing the plan.

The proposed Readiness Review Program does not alininate or diminish any authorities or regulatory responsibilities now assigned to or axercised by the Nucisar Regulatory Commission or Caorgia Power Company. Purther, the proposed Readiness Review Program does. not fundamentally changa the techniques of inspections or assurance of quality program activities. Rather, the Readiness Review Program is a management systaa which providas for the more orderly planning and predictable' execution of existing authorities and re-sensibilities.

In su= mary, the proposed Readiness Review Program actions include a clear-definition and description of all work activities in terms of governing regu- i latory cot:mitnants, an in-depth Caorgia Power Company'salf-assessment of the '

work activities. Euclear Regulatory Com=ission review and actions on both the programmatic and work implementation aspects of the work activities and a methodology for scheduling the separate Readiness Review Program actions of  !

Georgia Power Company and the Nuclear Regulatory Commission. )

I The proposed plan incorporates savaral important featuras such as a 1 Readiness Review Board, outside technical experts in the various disciplines, )

and a separata design reviev group all of which serve to provida independent j oversight and review of Readiness Review Program actions and results. )

CONCLUSION

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Georgia Power Company considers that the proposed Readiness Reviev j Program including the Nuclear Regulatory Commission's agreement to participate i in the prorram would result in significant banafits. These banafits include  ;

., improven planning which vill enhance the affectiva u,se of critical Nucitar j Regulatory Cbmmission and Caorgia Power Company resources and improved pre- 1 dictability resulting from the early Nuclear Regulatory Commission determina-tion of, program adequacy, Other banafits include enhanced assurance of the overall program acceptability resulting from Georgia Power Company's self-  !

assessment combined with the phased independent Nuclear Regulatory Con =ission l reviews, and improved stability by minimizing the potential for last ninuta l identification of major programmatic problems, l

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, Georgia Poner m.

Readiness Reviev Program Page Three I

In addition, Georgia Power Co=pany considers that the successful demonstration of the proposed pilot Readiness Review Program at Vogtle could be a significant potential benefit to future nuclear projects.

Specifically, the application of readiness reviews to individual critical work activities phased over the entira life of a future project vould be a straightforward extension of the Readiness Review Program proposed for

.Vog tle. In this regard, all key plans, procedures and schedules associated with Vogtle pilot program vill be available as public information for use as desired by the industry or NRC as a tool for future work. ,

PROPOSED ACTION Based on the above, Georgia Power Company requests that the Nuclear Regulatory Com=1ssion agree to participate in the proposed pilot Readiness Reviev Program.

Georgia Power Conpany racemmends that the Nuclear'Regniatory Commission establish a task group from the Office of Inspection and Enforce-ment to assist in the development of the Readiness Review Program procedures and schedules. It is furths. reco= mended that a task group fron the Regional Office of Inspection and Enforcement be established te assist in the develop-cent of program procedures and schedules, and actions associated with verk activity inspection and acceptance. i Yours very truly, M _

R. E. Conway PDR/RIC/j eb Attachment 1 xet J. B. Miller, Jr.

R. W. Scherer R. J. Kelly '

B. H. Guthrie D. O. Foster ,

J. T..Beckham, Jr.

R. A. Thomas -

D. E. Dutton V. F. Sanders P. D. Rica E. L. Blake - Shav Pittman, Potts and Trowbridge D. C. Teper - Georgians Against Nuclear Energy

, L. Fowler - Legal Environmental Assistance Foundation T. Johnson - Education Campaign for a Prosperous Georgia J. I. Joiner - Troutman, Sanders, Lockerman, & Ashmore M M #449g 4

. READINESS REYIDf PROGRAM l

\

l PURPOSE ,

.The purpose of the Readiness Review Program is to provide a systematic  !

and disciplined review of Georgia Power Company's implementation of design, construction an,d operational preparation processes to ine'rtast the assurance that quality program activities at Plant Vogtle have been accom-

,plished in accordance with regulatory requirements. .

OBJECTIVE j The Readiness Review Program is a management system developed to l accomplish the following objectives:

• Clearly define the individual work processes involved in the quality program at Plant Vogtle and describe how these processes comply with regulatory comitments.

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

Enhance the identification of problems or concerns and ensure their correction in a timely manner. .

Provide a mechanism for the early resolution of any differences in the Nuclear Regulatory Comission and Georgia Power Company interpretation of regulatory requirements and the resulting acceptance criteria. ,

Provide a system that will facilitate the Nuclear Regulatory Comission.'s review, inspection, appropriate action and approval of the acceptability of Yogtle work processes on an advanced readiness review basis.  !

Provide a planning system, including Georgia Power Company prepared and Nuclear Regulatory Comission accepted milestone  ;

schedules, for the orderly conduct of the separate actions of Georgia Power Company and Nuclear Regulatory Comission.

AUTHORITIES AND REGULATORY RESPONSIBIt.ITIES 1

Nothing in this program eliminates or diminishes any regulatory responsibilities or authorities now assigned to or exercised by the Nuclear Regulatory Comission or Georgia Power Company. Further, the Readiness Review Program does not fundamentally change the techniques of inspection of quality program ' activities. Rather, the Readiness Review Program provides for the improved planning and execution of existing responsibilities and authorities in a predictable' and orderly manner.

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. READINES$ REVIEW PROGRAM Page 2 READINESS REVIEW PROCESS The scope of the Readiness Review Program encompasses the implementation of all aspects of design, construction and preparations for operation at Plant Vogtle. The overall scope of the program is divided into five broad generic functions: civil, mechanical, electrical, instrumentation and control, and readiness for plant operations (see enclosure 1). These generic fu6ctions are further divided into specific work activities (see enclosure 2 example) and from there into individual work elements (see enclosure 3 exkmple).

The Readiness Review Program actions will generally be conducted at the work element level to review, assess and verify performance. The individual work elements in a specific work activity will be packaged and presented to the Nuclear Regulatory Comission for review and a pproval . Such a package is defined as a readiness review module. The total scope of work will be divided into approximately 25 readiness review modules (see enclosure 4).

The content of the individual modules is based cn considerations such as work process logic, the scheduled sequence of work completich and the time period available for review. The content and structure of these modules will be developed by Georgia Power Company and submitted to the Nuclear Regulatory Comission for coment end acceptance.

READINESS REVIEW PHASES The basic readiness review actions involve each readiness review module

, undergoing a four-phase process of Preparation / Evaluation, Presentation / Module Review, Werk Review, and Resolution / Approval . The following is a description of each phase of the readiness review module process.

Preparation / Evaluation Phase - Phase I This phase of the readiness review process consists of:

Georgia Power Company preparation of the readiness review modules. -

4 Georgia Power Company assessment and certification of the adequacy of all work activities covered in the module, "

Readiness Review Board review and concurrence that all work activities covered by a module were performed satisfactorily, and Vice President and Project General Manager of the Yogth Project approval of the module. 1 3

, READINESS REVIEW PROGRAM Page 3 Each module will include a definition of th*e scope of work covered in the module. This scope is broken down by work activities

, and ultimately into a detailed list of the individual work elements that are involved in the module scope. Each' of the work elements dr group of work elements will be described in terms of subjects such as the following:

- applicable comitments,.

governing specifications.

detailed description of the work process.

timing of work accomplishment.

criteria for acceptance of work.

scope and methods of docum'entation.

responsible organization and interface activitics, ,

nonconformance and corrective action processes.

significant problems,

- reportable events.

applicable Quality Assurance audits, and applicable Nuclear Regulatory Comission inspections.

Matrices will be prepared to identify key review material such as regulatory ccanitments, specifications and procedures as a function of work element and time.

Having so defined anj described each wo'r k element or logical group of elements, GPC will formally assess the elements to determine that the quality program and its impleinentation have complied with Georgia Power Company comitments and Nuclear Regulatory Comission regulatory requirements. Additional reviews, inspections or audits will be conducted wherever necessary to verify proper accomplishment of the work elements.

Each assessment of work elements will be signed off by an individual responsible for the assessment certifying that the work elements have been addressed properly and are ready for iNelear Regulatory Comission review. l ,

In addition to the self-assessment of module work elements discussed above Georgia Power Company will establish a Design Review Group within the Readiness Review Task Force consisting

'of three or more senior experienced design engineers who are

u .

. READfNESS REVIEW PROGRAM Page a independent of those personnel who performed the work. The function of this group will be to conduct a continuing detailed review of the design process to provide added assurance that the design activities defined and described in the readiness review module have been performed in accordance with all comitments. A particular focus of this group will be to examine the interface actions among design disciplines to insure that there are no discontinuities in design work ccvered by the various readiness review modules.

When all work elements in the readiness review module have been assessed and certified as properly implemented, an independent Georgia Power Company Readiness Review Board will conduct an evaluation of the readiness review module to verify that the overall work activities have been addressed satisfactorily and that all Readiness Review Program actions have been completed properly.

Upon satisfactory completion of the Readiness Review Board evaluation, the Vice President and Project General Manager -of the Vogtle Project will make a final determination of acceptability of the readiness review module. -

Presentation / Module Review Phase - Phase II Upon determining that the readiness review nEidule is satisfactory, the Vice President and Project General Manager of the Vogtle Project will formally submit the readiness review module to the Regional Administrator of the Nuclear Regulatory Comission for review and acceptance. The presentation process will include a brief meeting to outline the scope of the readiness review module and identify any particular aspects that Georgia Power Company may want to highlight to the Nucisar Regulatory Comission. It is expected that the readiness review module would thereafter undergo a multi-discipline review by applicable Nuclear Regulatory Comission organizations to verify the effectiveness of the Georgia Power Company quality program for work areas covered in the module. It is expected that this review would examine definition of comitments , adequacy of comitment application and proper interpretation of criteria for work acceptance. Further, it is expected that either a positive find'ing of program adequacy would be identified to .

Georgia Power Company or any concerns with the program defined in the readiness review module would be conveyed for action, as appropriate. -

Work Review Phase - Phase III

' Upon completion of Nuclear Regulatory. Comission review of the readiness review module, it is expected that the Nuclear Regulatory Comission would identify selected work activities l

k ..

, READINESS rey!EW PROGRAM Page 5

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covered by the readiness review module for additional Nuclear Regulatory Comission inspection. For these instances Georgia Power Company would take all necessary actions to support and a'ssist the Nuplear Regulatory Comission inspection including the colintion and assembly of documentation, the supply of requested personnel for interviews or inspection assistance and the resolution of all questions or requests for additional information. Georgia Power Company would make every effort to address all inspector requests and questions during the Nuclear Regulatory comission on-site inspection process.

Resolution / Approval Phase - Phase IV Upon completion of additional Nuclear Regulatory Comission inspections of the readiness review module work activities, it is expected that the Nuclear Regulatory Comission would identify any significant areas of noncompliance in accordance with existing Nucitar Re Comission inspection and enforcement policies (e.g. gulatory 10CFR2, AppendixC). Georgia Power Company will investigate, assess and correct any . items .so identified in a thorough and rigorously scheduled manner in order to promptly and completely resolve all concerns and to -

avoid any recurring questions or concerns in subsequently scheduled areas of readiness review.

Upon sa tisfactory completion of Nuclear Regulatory Com.ission inspections of readiness review module work activities, including satisfactory resolution of any resulting concerns, it is expected that the Nuclear Regulatory Comission would formally identify to Georgia Power Ccmpany that the scope of work covered by the readiness review module had been reviewed programmatically and for implementation and was deemed satisfactory subject to completion of remaining work in full compliance with all comitments. It is further expected that any work covered by the scope of .the readiness review module. that had not yet been completed due to the project work sequence would be factored into normal Nuclear Regulatory Comission si,te inspection activities with the Georgia Power Company comitaent to assist the Nuclear Regulatory Comission in subsequent inspections in the same manner as during the readiness review module inspection activities. The Nuclear Regulatory Comission would be formally notified . of any subsequent si.gnificant changes to .

the quality program that would affect the completed module.

PROCEDURES Formal. procedures will be developed to control the Georgia Power Company actions involved in the Readiness . Review Program. These procedures

.will include requirements and guidance for readiness review organization, readiness review personnel training, module content, module , preparation.

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. RIADINESS REVIEW PROGRAM Page 6 module evaluation including specific criteria for performing the evaluation, criteria for evaluation acceptance, criteria for handling concerns identified during readiness review, preparation and issuance of schedulese -and handling of changes to the readiness review procedures.

These procedures will be approved by the Readiness Review Program hanager.

the Quality Assurance Department and the Readiness Review Board.

Readiness review procedures and their changes will be submitted to the

. Nuclear Regulatory Comission for information.

ORGANIZATION The Georgia Power Company organization for implementing the Readiness Review Program will consist of a Retdiness Review Task Force and an independent Readiness Review Board.

The Readiness Review Task Force will consist of engineering and support personnel selected for their expertise from applicable design, construction, operations and quality disciplines. These personnel will report through readiness review discipline managers who report to the Readiness Review Program Manager.

The Readiness Review Board will consist of Georgia Power Company technically experienced senior managers and one or more independer.t technical experts. These technical experts will. be selected based on ,

their broad technical background in a particular discipline and will rotate on the board to serve for module reviews appropriate to their area of expertise.

Personnel on the task force and the Readiness Review Board will be trained on the Readiness Review Program procedures and their qualifications will be documented.

Both the Readiness Review Task Force Manager and the Readiness Review Board Cha'irman report to the Senior Vice President Nuclear, Georgia Power Company.

READINESS REVIEW SCHEDUI.ES Readiness review modules will be prepared and submitted to the Nuclear Regulatory Comission' at a. rate. of approximately two modules per month. .

Enclosure 5 is a preliminary schedule showing the anticipated sequence.

of module development and issue. Georgia Power Company will develop specific readiness review schedules that will include comitment dates for Georgia Power Company presentation of readiness review modules to the Nuclear Regulatory Commission and agreed upon time frames for subsequent Georgia Power Company and Nuclear Regulatory Comission i Readiness Review Program actions. These schedules will be submitted to the Nuclear Regulatory Comission for approval and Georgia Power Company will update schedules at three month intervals or more frequently if required to make any necessary adjustments resulting from work schedule I changes or unforeseen problems.

O O

. : i r.,  :

' (Enclosure 1)

PLANT V0GTLE GENERIC FUNCTIONS I. CIVIL -

.11. MECHANICAL

!!!. ELECTRICAL ...

IV. INSTRUMENTATION AND CONTROLS Y. PLANT OPERATIONS

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PLANT V0GTLE - WORX ACTIVITIES FOR CIVIL FUNCTIONAL AREA 4

I. CIVIL l

l.

A. CONCRETE B. REBAR AND CADVELDS C. STRUCTURAL STEEL. MISCELLANEOUS STEEL AND EMBEDS D. WELDING E. BACKFILL F. C0ATINGS G. POST TENSIONING 9

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• POLNTV0GTLE-WOR'KELEMENTSFORCIVILC6NCRETC, REBAR AND CADWELD WORK ACTIVITIE5

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!. CIVIL A. CONCRETE ,

1. DES!GN .

a. Design c'iteria r

b. Control procedures

c. Specifications

d. Analysis and calc.ulations ,

e. Interfaces

f. Seismic classification-

g. Drawing types

h. Change control

1. Problem resolution J. Documentation

k. Verification of as-built condition through FCR's, l

DR's and'NCR's .

1. Mix design

- m. Designevaluationreports(DER's) ,

2. MATERIALS ., , , , ,,

a. Identification and specification of materials .

b. Certification and tests by suppliers

c. Procurement

d. Receipt .

e. Storage

f. Release for use

g. Vendor control

3. TRAINING AND QUALIFICATION

a. Receipt and storage inspectors

, b. Batch plant operators and inspectors l c. Laboratory and fresh testing inspectors

d. Placement ins,pectors

e. Survefors

f. Craft personnel

4. FABRICATION AND INSTALLATION l

a. Construction procedures

b. Fonnwork, waterstop and waterproofing -

c. Batching  ;

- d. Placing, finishing and curing i l

e. Core drilling-

f. Equipment pad grouting and drypacking i

5. INSPECTION

a. Receipt and storage i~nspection'

b. Replacement inspection ,

c. Placement and post-placement inspection -

d. Lab inspection

e. Core drill inspection

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(Enclosure 3)

Sheet 2 of 3

6. TESTING

a. Concrete mate < vis receiving (gradation water, cement, fly enh and admixtures)

b. In-erocess mth rials (slump, air content, compressive

, strength)

7. MEASURING AND TEST EOUIPMENT l

a. Calibration

b. Maintenance

8. FIELD DOCUMENT CONTROL

a. Receipt / control

b. Issuance

c. Changes'

9. AUDITS

a. GPC audits and responses

b. NRC inspections and GPC responses

c. Special investigations / evaluations and r'esponses '

o INPO o SIE o Cadweld review o Design control *

10. REPORTABLE DEFICIENCIES B. REBAR AND CADWELD

1. DESIGN

a. Design criteria

b. Control procedures c; Specifications *

d. Analysis and calculations

e. Interfaces

f. Seismic classification

g. Drawing types -

h. Change control

1. Problem resolution

j. Documentation .

k. Verification of as-built condition through FCR's.

DR's and NCR's.

1. Design evaluation reports (DER's)

o , -

. (Enclosure 3)

Sheet 3 of 3 0

2. MATERIALS

a. Identification and specification of materials

b. Certification and tests by suppliers

c. Procurement

. . d. Receipt i

e. Storage '

1. Release for use  !

g. Vendor control

3. TRAINING AND QUALIFICATION

a. Receipt and storage inspectors

b. Iron worker and cadweld operator training j

c. Laboratory and rebar inspector training

4. FABRICATION AND INSTALLATION

a. Site fabrication of rebar

b. Rebar installation .

I c. Cadweld installation i d. Repair procedures

5. INSPECTION

a. Receipt, storage and inspection i

b. Rebar and cadweld inspection ,

I

6. TESTING l

a. Cadweld testing

7. HEA3URING AND TEST E00]PMENT

a. Calibration

b. Maintenance

8. FIELD DOCUMENT CONTROL

a. Receipt / control

b. Issuance

c. Changes -

9. AUDITS .

a. GPC audits' ant responses

b. NRC inspections and GPC responses

c. Special investigations / evaluations and respons.es o INP0 o SIE o Cadweld review o ' Design control

10. REPORTABLE DEFICIENCIES

~~ ~ ~ ~ - - ^ _ _ _ _ _ __ _ _ _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _

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(Enclosure 4)

READINESS REVIEW MODULES

!. CIVIL A. CONCRETE B. REBAR AND CADWELDS C. STRUCTURAL STEEL MISCELLANEOUS STEEL AND EMSEDS D. WELDING

'E. BACXFILL F. COATINGS G. POST TENSIONING II. MECHANICAL IV. INSTRUMENTATION AND CONTROLS l A. f SSS l A. PROCESS I & C . I B. PIPE HANGERS / SUPPORTS B. ELECTRICA1. 1 & C C. PIPING / VALVES / PUMPS C. HVAC I & C D. HVAC AND EQUIPMENT E. FIRE PROTECTION F. INSULATION 111. ELECTRICAL V. PLAhT OPERATIONS lA. RACEWAYS l A. OPERATIONS l B. CABLE INSTALLATION B. MATNTrn w r l l

C. EQUIPMENT C. TECHNICAL SUPPORT

. D. HANGERS / SUPPORTS I D. INITIAL TEST PROGRAM l

E. TERMINATIONS E. EMERGENCY PREPAREDNESS j 1

F. FIRE BARRIERS F. 00ALITY ASSURANCE l G. TRAINikG  !

H. HEALTH PHYSICS / CHEMISTRY l

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1 NUCLEAR REGULATORY COMMISSION O ddE " 4 A wAsmoTow.o.c.aoses ' - Rlq **<

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Docket No. 50-424 NOV 0 91964 Georgia Power Company ATTN: Mr. R. E. Conway Senior Vice President 333 Piedmont Avenue Atlanta, Georgia 30308 Gentlemen:

SUBJECT:

PILOT OPERATIONAL READINESS REVIEW PROGRAM - V0GTLE UNIT 1 Thank you for your letter of October 3,1984 to Mr. James P. O'Reilly, Regional Administrator of Region II, regarding Georgia Power Company's plans to conduct a Pilot Operational Readiness Review Program at Vogtle Unit 1. I appreciate your initiative in proposing and planning such a detailed program to assess Georgia Power Company's compliance with NRC requirements and your comitments to NRC, and to assess your readiness to operate Vogtle Unit 1. This program will potentially provide NRC the opportunity to review Vogtle Unit 1 activities in a more tion and licensing structuredefforts.

and timely manner leading to improvements in our inspec-It also provides the potential for significantly strengthening license. the bases for timely NRC decisions on issuance of an operating In your letter to Mr. O'Reilly, you requested that NRC agree to participate in the pilot readiness review program. We have reviewed your proposal and con-ciude that the assurance of public health and safety would be improved through NRC participation. NRC participation will require Region II and the Offices of Nuclear Reactor Regulation and Inspection and Enforcement to comit additional resources to support the pilot program. We are presently examining our resources and budget to determine how NRC can best participate and support the readiness review.

I will be advising you in the near future of how NRC will participate and audit the Georgia Power Company's readiness review program activities.

Mr. J. P. 0'Reilly, Region II, should continue to be your principal NRC contact on this pilot program. Your normal and routine contacts with the Office of Nuclear Reactor Regulation in matters associated with the licensing process or with the Office of Inspection and Enforcement in matters associated with inspection pilot program, or enforcement should not be affected by NRC participation in the 1 neer y, Will J. Dirck Executive Director for Operations cc: See next page Oil f I *1 I /Y M M

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Georgia Power Company l cc: Mr. L. T. Gucwa Mr. James E. Joiner Chief Nuclear Engineer Troutman, Sanders, Lockerman, Georgia Power Company & Ashmore P. O. Box 4545 Cnadler Building Atlanta, Georgia 30302 127 Peachtree Street, H.E.

Atlanta, Georgia 30303 Mr. Ruble A. Thomas Vice President - Licensing Mr. Douglas C. Teper Vogtle Project Georgians Against Nuclear Energy.

Georgia Power Company / 1253 Lenox Circle Southern Company Services Inc. Atlanta, Georgia 30306 P. Bo. Box 2625 Birmingham, Alabama 35202 Ms. Laurie Fowler Legal Environmental Assistance Foundation Mr. J. A. Bailey 1102 Healy Building

)

Project Licensing Manager Atlanta, Georgia 30303 Southern Company Services, Inc.

P. O. Box 2625 Mr. Tim Johnson ..

Birmingham, Alabama 35202 Executive Director Educational Campaign for  :

Mr. Ernest L. Blake, Jr. a Prosperous Geor Shaw, Pittman, Potts and Trowbridge 175 Trinity Avenue,gia S.W.

1800 M Street. H.W. Atlanta, Georgia 30303 Washington, DC 20036 Mr. William S. Sanders Mr. G. Bockhold, Jr. Resident Inspector / Nuclear Vogtle Plant Manager f Regulatory Comission '

Georgia Power Company P. O. Box 572 Route 2 Box 299-A keynesboro, Georgia 30830 Waynesboro, Georgia 30830

'Mr. Deppish Kirkland III, Counsel Office of the Consumers' Utility Counsel 32 Feachtree Street, N.W.

Suite 225 Atlanta, Georgia 30303 l

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