ML20236X728
| ML20236X728 | |
| Person / Time | |
|---|---|
| Issue date: | 06/18/1987 |
| From: | Remick F Advisory Committee on Reactor Safeguards |
| To: | Moeller D, Reed G Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20236X721 | List: |
| References | |
| REF-WM-1 NUDOCS 8712100181 | |
| Download: ML20236X728 (9) | |
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UNITED STATES
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j NUCLEAR REGULATORY COMMISSION 3
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ADVISORY COMMITTEE ON REACTOR sAFEGUAMDS e
W Ast41NGTON, D. c. 20655
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%*.*f June 18, 1987 MEMORANDUM FOR:
Dade Moeller, Chairman ACRS Subcommittee on Waste Management Glenn Reed, Chairman ACRS Subcommittee on Quality and Quality Assurance (QA) in Design and Construction Subcommittee FROM:
F.
ick, Vice-Chairman, ACRS
SUBJECT:
READINESS REVIEWS FOR t0TIJRE NUCLEAR FACILITIES I recently attended a session on "0A Experiences in Readiness Reviews" sponsored by the Americo Nuclear Society.
Copies of the abstracts of papers presented are attached. These papers focus on the Vogtle experience.
Although Readiness Reviews were utilfred fairly late in the Vogtle project, there appears to be unanimous belief by the licensee and the NRC that the effort was highly worthwhile; they conclude that the licensing process was more predictable, problems were uncovered and corrected at an early stage, no late allegations of poor quality were made, greater assurance was provided, etc.
I'm becoming more convinced that a properly designed Readiness Review process could be a major improvement in assuring quality in future 1.uclear power plant design, construction and operation, and also in the l
high-level waste (HLW) reppsitory program. However, I think that the process will recuire some refinemerfts if the potential benefits are to be fully realized.
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The purpose of this memorandum is to suggest a joint meeting of the ACRS Subcommittees on Duality and Quality Assurance in Design and Construction, and Waste Management, to attempt to get a better understanding of the potential advantages and dis 6dvantages of planned Reacir>ess Reviews in future design and construction of nuclear facilities.
Dr. Nelson Grace, Region II Administrator, is willing to describe the Vogtle experience from the NRC's perspective and would be willing to suggest a person te present the Georgia Power Company's viewpoint. Other possible topics for a joint subcormiittee meeting include:
DOE should describe their Readiness Review process for the monitored retrievable storage (MRS) and HLW repository programs.
NRC should describe their planned involvement in these Readiness Reviews.
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8712100181 870630 i
I D. Moeller/Glenn Reed 2
j DGE has a large amount of experience in conducting Readiness i'.
Reviews for a diverse set of facilities and programs. Howev-er, none of these have ir.yolved satisfying regulatory require
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ments of the NRC. What are DOE and NRC doing to assure that;- '
licensing requirements are being properly addressed in the.. 2 l
Readiness Review prot.ess associated with the MRS and the M.W *#,
repository programs?
Under existing regulations:
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can the NRC utilize multiple QA hold points as part of Readiness Reviews?
upon satisfactory verification as a result of Readiness Reviews, can the NRC " sign-off" on appropriate licensing matters at that time and not have to consider them subsequently at the operating license stage?
If the above are not possible, should rulemaking be initiated to make such use of Readiness Reviews possible?
To be effective in reducing late allegations, who should be involved in the Readiness Review process? For example, does one include seeking input from the crafts, 2ecurity, training, etc. versus seeking input primarily from managers and external ccrsultants.
I believe that by becoming more knowledgeable about the potential benefits of Readiness Reviews, the ACRS might be able to rake a contri-bution to the design and construction of future nuclear facilities, including nuclear power piants and HLW facilities.
Attachments:
As stated cc: ACRS Members ACFS Staff ACRS Fellows I
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QA EXPERIENCES IN READINESS REVIEWS
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Session Organher: M. C. Christensen (Bechtel West Pwr) 1.
Vogtle Electric Generating Plant Unit 1 tistep process that involved estainment of module scope, Readiness Review Prograrn, Robert W. McMa.
idenutication of licensing commitments, verification of imple-m'atation af licea>ias coarit" *"$5 id'at1'i=* " a"*2i'r nus rceorgia power, warnesboro>
assurance audits and NRC mspections, and massasments of work processes covered by the scope of the module. Each in 1964, the Georgia Power Company (GPC) began a pilot mom required acceptance"by the read cess renew board and program for self esa!uation of Plant Vogtle Urut 1 in response the board's technical expert pnor to submittal. Additionally, te the recommendations contamed i.n the U.S. Nuclear Reg-senior project managers were required to concur with the u!atory Commission (NRC) report to the U.S. Congress, results of each module and to :ommit to implementadoh of "Irn; rosing Quahty and the Assurance of Quahty in the De-identified corrective actions.
5:p and Construcoon of Nuclear Power Plants"(NUREG.
10m he program,idenafied as "Vogtle Electric Generating NRC INTERACTION Piani Unit 1 Readmess Reuew Program." was conducted to proude a s>siemsoe and disciphned review of GPC's imple-Upon completion of each readiness review module, GPC mentauon of design, construction, and operational prepara-formally submitted the module to the regional administrator tic n processes to increase the assurance that quali:> program of the NRC for review and acceptance. The module thereafter acouties et Plant Vogtle base been accomphshed in accor-underwent a muludiscipline review by applicable NRC rtson dar,ce with regulator) requirements.
and headquarters organizations to verify the effectiveness of the GPC quality program for work artas covered in the mod-OBJECTIVE ule. The regional review examined the definition of commit-ments, adequacy of commitment application, and proper The GPC's objectnes in undertaking a readm, ess review interpretation of criteria for work acceptance.
progrcm were many. The primary objective was to perform.
Upon completion of their review, the NRC selected work as an owner-initiated effort, an in-depth self assessment that activities ravered by the readiness review module for on-site'
- ould proude both early identificaticm of problem areas and NRC inspection. For these inspections, GPC took all reces-a meenanism for earl > resolution of differences in NRC and sary actions to support and assist the NRC inspectors, includ-GPC interpretatens of regulatory requirements. Saristactcry ing the collection and assembly of document. tion, the supply cemple: ion of this objective would add stability and predict-of requested personnel for interviews or inspection assistance, ahhts to the beensing process and would mimmize risks sn and the resolution of all questions or requests for additional accomplish:ng scheduled project completion.
information.
Upon completion of these NRC inspections of the readi.
IrtEADINESS REVIEW PROCES5 ness review module work activities, the NRC identified any significant areas of noncompliance in accordance with exist.
The GPC organization for implementing the readiness ing NRC inspection and enforcement policies. The GPC inves-reuca program consisted of a readmess renew task force and tigated, assessed, and corrected these items in a thorough and an mdependent readiness review board.
rigorously scheduled manner in ordtr to promptly and com-The tcadiness review task force cohsisted of engineering pletely resolve all concerns arid to avoid recurring questions and support personnel selected for their expertise in a,pplica-or concerns in subsequently scheduled areas of readiness ble de.ign, construction, cperations, and quality disciplines.
reWN These personnel reported to readmess re ties discipline man-Upon satisfactory compledon of NRC inspections of read-agerr.. w ho reponed to the read ness renew program man,ager*
iness review module work activities, including satisfactory The readmess truew board consisted of GPC techmcally resolution of any resulting concerns, the NRC formally iden-experienced senior managers and one or more independent tified to GPC that the scope of work covered by the readiness technical experts. The techrUca] experts were selected based on review module had been reviewed programmatically and for their broad 1echnical background in a particular discipline and implementation and was deemed satisfactory subject to com-tota:ed serung on the board for the module reviews appropri-pier. ion of remaining work in full compliance with all commit-ate to their area of expertise.
- ments, Both the readiness review task force manager and the readmess review board chairman reported independently of RESULTS the project to senior company executives.
The overall scope of the program was divided along tra.
The Unit I pilot readiness review program resulted in the dioonal project functions (i.e., civil, mechanical, electrical, identification of a number of findings and corrective actions operations)into 22 modules,7 appendices, and the indepen-that CPC believes, based on feedback from the independent dent design review that as a whole addressed all aspects of NRC review of readiness review submittah, has confirmed 3
safety rele,ed work on the project. The first module, rein-i that the systematic approach used wat effective in achieving i
forced concrete structures, was submitted to the NRC in program objectives.
March 1985 (20 months prior to fuelload), and the last sub-The GPC considers readiness review one of the ptograms I
rrdttal, the independent design review, was made in July 1986.
that enabled the licensing proce',s for Vogtle Unit I to func-k Preparation of each readiness review module was a mul-tion as a smooth coordmated process between GPC and the r
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m NRC and a!! owed resolution of probicms at a much earlier
' calculations, drawings, and specifications to ascertain the h
stage than has c.ccurred on some other re:ently licensed effectiveness cf c ntrols rpplied 13 the design activities with i
nuclear projects. This ability to avoid "last-minute" problems respect to the implement: tion cf licendng commitments and during the bcensing process is, in GPC's opinion, strong evi-procedurzs.
dence that the readiness review concept as proposed in The selection process of the samples used in the verifica-l NUREG-10H is a viable method for increasing the stability tion attempted to take into account the time history of the
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and predictability of the nuclear design and construction project and tended to focus on areas identified as industry l
process.
problems and on any areas of potential project weaknana as I/
determined by a c:. view of historical intemal or caternal audit l\\
results. The latter was com,*iled into an audit matrix,dmded by m u /a pen for sp L " Readiness Review" as Applied to Nuclear Construction and Design Programs, George C, struction and design program for the Vogtle projectVas not Bell (Bechtel Western, Sanatoga) without its trials and tribulations, as could be expected from a pilot program of this scope and nature. Indeed, the program The purpose of this paper is to analyze the " readiness would have had a smoother course and less icapact to the proj-review" concept as it was applied to the construction and to ect if it could have been phased in earlier in the project's life.
the programmatic aspects of the design of a nuclear power In addition, other lessons learned included the need to plant (Plant Vogtle) by the Georgia Power Company (GPC) structure the program in consideration of reviewers needs, and to examme the ments of ruch a program for future appli-to clearly define module / appendix boundaries in advance,'to cations.
develop the generic work areas (appendixes) first, and to for.
In the fall of 1984, the GPC launched an intensive indus.
mahre project involvement. However,in spite of the disadvan-try pilot program of readiness resiew at its Vogtle project.
tages and obstacles encountered, there is no doubt as to the As this program was apphec to the construction and pro.
benefits garnered through this undenaking. The review of grammatic design efforts, the primary goals weredo cornplete work activities as a function of commitment matrices over the an m depth self assessment to demonstrate compliance with hfe of the comrnitment as employed in the ven0 cation efforts regula'ory commitments and to facilitate U.S. Nuclear Reg.
was instrumentalin identifying certain deficiencies or areas of ulatory Commission (NRC) review, inspection, appropriate weakness while confirming overall program adequacy. Some action, and approval of project uork on an advanced and 20 or more of the deficiencies or weaxnesses identified to the scheduled basis, project for resolution had considerable potential for causing To make the self atse....n and NRC review more licensing delays had they been discovered later in the project manageable, the projcet was dmded into the functional areas life. For example, nienerous administrative errors associated of eml, mechancal, and electrical discaphnes and then further with the records for certification and qualification of inspec-divided into specific work areas called modules. For example:
tion parsonnel were identified. As another example, problems module I encompassed reinforced concrete structures includ-with retnevability of quality records associated with the plaev-ing rebar and cadwelding operations. Additionally, certain ment of concrete were encountered. In both cases, significant actmties generic to many or all modules were assessed as sep.
amounts of time were required for investigation and resolu-arate work areas called appendixes. For example. Appendix tion time that are extremely expensive if delays in licensing are F cosered inspector qualification and certifi ation, encountered.
The basis for the self assessment cam from the commit.
The readiness review process at Vogtle was invaluable in
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ment matrix deseloped by the readiness review task force.
enhancing the assurance to the utility of overall prograrn Commitments were defined as obligations to comply with acceptabinty. The program provided for phased independent industry standards, regulatory guides, branch technical posi.
NRC review and approval, provided a high level of confidence tions, er owner plans of specific zetions. Commitments were in the quality of the plant, and significantly reduced the poten-identined and compiled versus their source throgh reviews of tial for last minute identification of major programmatic the safety anaksis report, responses to generic letters, and problems.
responses to IE Bulletins. Each comrnitment was assigned to An obvious future application of readiness reviews would one or more of the modules or appendaes, based on the scope be in conjunction with a one. step licensing process. As the and boundaries of those work areas. Each commitment was nuclear power industry begins to regain its health in the United then traced to one or more implementing documents to the States over the next few years, clearly, readiness reviews could extent necessary to assure that the cor".trutment was addressed be an important prescription that deserves further study anc by the project. The implementing 4ocuments were compiled
. consideration as a part of the cure.
versus the commitment and source into an implementation matrix for the module /appeodix.
The heart of the self assessment was a formal verifica.
tion process utilizmg an approved review plan and checklists-3.
Operations Readiness Review, Samuel A.
The constructan program veri'ication typically consisted of a commitment implementation assessment and a construction Bradley (Georgio Power, Waynesboro) assessment to determine whether construction activities were consistent with commitments, design requirements, and pro-This paper describes the objectives, methods, and results gram requuements. The verification effort included walk.
of the renew of operations conducted as part of the pilot read-downs of M
i aG P
Cow's m'O reviews ofhardware, review of cuality assurance records, and Vogtle Electric Generating Plant.
procedures, construction specifications, and other Consistent with overall objectives of readiness review, the T e d s gn p ogram verification typically consist!d of a tasks of opuations readness reWew wm to commitment unnementation assessment and a design control
- 1. define and describe activities of the operations organi-program anessment. The comrnitment implementation assess-zation ment was performed to detennine whether design commit-7 g
,7 jy;g ments were addressed in the design critena and/or other mnments design documents. The design control program assessment was conducted by reviewing detailed design doeuruents, such as
- 3. ide*1tify problems and ensure timely correction
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266 QA Experi:nc:s in Re:diness Reviews 4 provide a means for early res;lution cf differences ple ebose primary qualification was experience Ensincering 4
between the U.S. Nuclear Regulitory C:mmission organiza&ns, other utilities, and consuhants provided 49 e f (NRC) and GPC regarding interpretation of commit-66 team members, including 2 of 6 team leaders and the tech-ments Lical experts who assisted the rcadineas review board. Geor-
- 5. provide a means for early NRC review and acceptance sia Power provided the operations disdpline manager,4 seem of operational activities leaders, and the rernammr team members. Team !=ades and a core group of each team were usually the only persons I(
- 6. provide for orderly and timely conduct of the NRC's assigned to readiness review full time, and then only dunas and GPC's acuvities leading to issuance of an operat-module production. The largest need for people ensurred ing license, when activities were verified as bei.ag performed anosedag to commitments.
DESCRIPTION Modules were produced in parallel with hnph of The readiness review of operadons looked at activities that operational activities. Figure ! shows how each anodule pro.
were occurnns I to 2 >T pnor to loadiag fuelinto unit 1. From Eressed. Module producuon generally proceeded along two snapshots determination were mads rete.rding the adequacy paths. Descriptions of operational acdvities were written of both functioning activities and prr.parations for future simuhaneously with the tasks of identifying commitments, actmties. The operations review was dmded into six modules.
crou.nfunicyg them to procedures, and verifying that the Th
- wue ass ciated acuv:ues were being performed correctly. The on-site operations organization was involved throughout by
- 1. Module 2: Operations Training and Qualification reviewing draft versions of the modules and correcting find.
- 2. Module 3A: Initial Test Program, Preoperational Test ings dat the nWew proceu nW. As & d modds, se Phase readiness review board reviewed findings, corrective actions, and the executive summary. Each module received a final
- 3. M;dule 5: Operations Organization and Administration review by oirsite operations management.
L Moduit 7. Plani Operations and Support RESULTS
$. Module 9A: Radiological! Protection rea nen Mew d opera @ns met lu @hes. In
- 6. Modu!c 9B. Chemistry.
the areas of training, radiological protection, and chemtstry.
SecunS and emergency planning were reviewed. However, development of procedures was accelerated. In training, dif-reports were not issued because the security module contained ferences between GPC and the NRC regarding interpretation safeguards infe'rmation, and the emergency planning raodule of commitments were resolved. In engineering, operations, was superseded by esents (i.e., emergency exercises).
and maintenance, surveillance test procedans were improved.
Each module was produced by a team composed of peo-Throughout the organization there was increased attention to Staat Reassaens
- Praser, Het Unst One Ren es Hydro Functional fuel Lose a s.le C - Ocerations
? seaag ses 06414ducation NR*
NRC Suesattal acceptance "or.;e 04 - Initsat test 8 c;*aa, ** operational mRC mRC
- est taase Sve si t t ala acceptance n feie 5 - Doerations e
O';ana:ation aro -
NRC hRC asetnistratace lutsattal acceptance rood e 7 - Flaat Cse ations sac ss o't NR*
NRC Subsattat acceptance mos le sa - healt> h vstcs WRC mRC Subsittal acceptance Rosale es - Cnesistry NRC WRC
.....tt.1 ame,ta,e Jan 85 JUL 85 Jam se JUL 46 Jam 37 I
Fig.1. Schedule of operations readiness review.
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the' quality Of procedures and implementation of commit-rately. The SBTA was based on the results of several SWEC ments. These actions occurred suf ficiently eirly during prepa-reviews conducted in February, March, July, and August cf rations for operation that they were accomplished without 1985.
delaying fuelload.
This was a pilot program, so the d:scussion of results can-SCOl'E OF SBTA not be complete without some lessons learned. The first les-ggg g,
son is thai a commitment to success is required from the NRC the technical adequacy of the VEGP design through a cross-I and the unlity. Some dissension within both orgaruzauons was
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experienced during reainess review. However, commitment aux 2h.ary feedwater system, and on other selected progmq) and i
at the top remained firm and the program was supported at design subjects (e.g., seismic 2/l)..
the working level. Key to support was credibility of the read.
The SBTA included the principal system related design iness re,iew teams. Tius leads to the second lesson: Intelligent, areas (i.e., eystem design; beaung, ventheirts, and air cendi-experieraced, creatise people are necessary for success. Lastly, uorung: piping design and supports; eletrical; mstrumentau,on expect significant expeniture of time and resources. It tock and control; hazards; and structural related interfaces). The 6 to 13 months to produce cach operations module and 6 to SWEC IDR team spent -5000 h reviewmg -1300 design doc.
12 mon:hs for NRC review and acceptance. We underesti.
uments, incluing drawings, calculations, specifications, design mated the task by 300r,
criteria, change control documents, reports, and corre.
e spondence.
SUMMARY
Operanens reainess review was a success. It contributed RESULTS to timei> starts; of the Vogtle Electric Generating Plant b)
In general, the SBTA showed that the plant design was accelerat:n; preparations for operation. The review did not gg gggp replace mspections by the NRC, howeser it contributed to g
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smooth functierung of the licens:ng process.
ments that are used ss a basis for detailed design development, in the majonty of samples reviewed, the design was found to be adequate and to have met these criteria. However, a total 4.
Plant Vogtle-Independent Design Review, of 139 valid observations (discrepancies) were issued and Steven L. Stamm /SWEC) addressed within the SBTA. Of these,27 were judged to have some indication of safety concern, while the remaining 112 observations were judged to have no safety concern but INTRODUCTION l"* Ived some deviations from licensing commitments, engi.
The independent desi n renew (IDR)is a reatured pan of neenng requirements, or procedures.
I the bce'tsmg process for near.tenn operatmg license (NTOI.)
Each SBTA observation has been addrened by the plant plants and a!>o is tecomms a required can of the conunuing design team. The information developed by the team along licensing reuew process for operating plants. This paper with the committed corrective actions has been evaluated and presents a summary of the Plant \\ogtle IDR process and deemed adequate to rewive the specific technicalissues raised.
resv.ts and proudes recommendations for future IDRs based in addition, an analysis of the collective significance of read-on the experience gained from this review.
b review program obsenatius has W performed u An IDR of the \\ ostle Electric Generatmg Plant (VEGP) related to the SBT A and further correcdve action and program j
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Unit I was conducted by Stone & % ebster Engmeermg Cor-enhancements have been mitiated to address generic / program-poranon (SWEC) as part of the Georgia Power Cornpany matic weaknesses identified.
(CPC) reatness review program.The purpose of this review was to preside add: tier.al operanonal reainess assurance to LESSONS LEARNED FOR FUTURE REVIEWS GPC management m support of the \\ EGP Unit I operaung The plant ow1)er has many choices and management deci.
I license.
sions that should be given careful consideration prior to the i
initiation of an IDR. The dectsions that will have a significant IDR Process E*""
The VEGP IDR was a carefulb planned and executed pro-E*"#
- E' * * * " E' lishment of acceptability critena, criteria for.investiga' tion of cess that consisted of the followmg steps:
broadness, and follow up verification responsibility. In each
- 1. inina? scoping case the plant owner has some lautude to establish the guide.
2 review plan preparation lines for review. Proper choices can maxmuze benefit and min.
- 3. reues checklist development and reviewer training imize cost.
4 conduct of resien and issuance of obsenations
- 5. preparation and resolution of project respotises 5.
NRC Implementation of Vogtie Unit 1 Road-l
- 6. esaluanon of obsenations for generic implications iness Review Pilot Program, M. V, Sinkule, W.
Rankin (NRC, Atlanta) invited
'I. corrective acuen completion.
The success of each of these steps requires good communica.
INTRODUCTION tion between the reviewer, the designer, the ple.t owner, and This paper discusses the implementation of the Vogtle Unit U.S. Nuclear Regulatory Commission 1&E. The most difficult 1 readiness review pilot prograrn of readiness review in gen.
and time consuming steps in the VEGP review were the reso-eral, and, more specifica!!y, dacusses the process by which it lution of project responses and the evaluation of observations was performed, and a summary of the results of the program.
for generic implications, The IDR was divided into two pans: civil / structural and Overall, the U.S. Nuclear Regulatory Commission (NRC) a system. based technical assessment (SBT A). The major pot.
expended'an estimated 19 equisalent staff years and an ap-tions of the civil / structural IDR are independent from the proximate editional 1318 000 in contractor support primarily attributes evaluated in the SBTA and were conducted sepa-provided by EGAG Idaho. Establishment of the NRC review 1
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program began in December 1984, and the nyiew was com-
- 8. The systematic and structural approach afforded by plete with the issuance of a low power license on January 16 the readiness review submittals in many cases aided the NRC
. J' 4 198L in perftrming a mire complete, in depth renew.
- 9. The single NRC program manager and point of con.
DISCUSSION tact between GPC and NRC did resuh in more integrated and eUecdn cotamurdcadons.
j The Georgia Power Company (GPC) review process i >
addressed the four functional areas of civil, mechanical, elec-
- 10. The effort was very resource intensive and required i
incal (including instrumentation and control), and plant oper-redirection of limited NRC resources to support.
~l ations and is discussed in Ref.1.
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II. Despite the "open to the-public" aneure of the pro.
1 gram, the program experienced a limited amount of public NRC Ren,ew Process panicipation.
The key NRC office roles and responsibilities (as stated in Ref. 2, which defined the NRC's participation in the Vogtle CONCLUSION readiness review) remained as close to the traditional rein of l
the participating offices as possible. This portion of the pre.
The NRC and GPC evaluations of this program were sentation includes a discussion of the NRC review process, under way at the time this paper was developed. However, internal NRC organizationalinterfaces, GPC/NRC organiza.
there are a number of " lessons learned" as a result of perform-i tionalinterfaces, the extent of NRC review, and the method ing the Vogtle readiness review pilot program. Examples of i
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of documenting the review.
some of these are as follows:
- 1. Despite the heavier than expected costs to conduct the
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Summar> of GPC/NRC Experiences review, the program has been judged a success and wonh the l
Dunng an esaluation of the Vogtle readiness review pilot program. the NRC concluded that GPC experienced a num.
- 2. The self initiated nature of the readiness review concept j
ber of significant factors. Exarnples of these are as follows:
is of paramount importance because it provides the licensee i
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- 1. The program led to early identification and correction of problems that may have otherwise delayed the licensing
- 3. Greater emphasis should be placed on inidal planrdng,
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proceso development of review procedures, and training of the re-l
- 2. Ths number and content of the modules originally planned were chnged substantially as the program progressed
- 4. The readiness review program and the normal licens.
and experience mas ga2ned implementing the program.
ing/ inspection programs should be better integrated in future
- 3. The preparadon and submitta! of modules to the NRC did not follow the originally planned schedule due largely to
- 5. Verification of program implementadon should be' time required to resohe findmgs, accomphshed at more optirnal times durir. the life of the spe-I*
4 The direct program support costs as we!! as indirect project costs were greater than expected for GPC.
The NRC also experienced a number of significant factors.
- 1. R. W. McMANUS,"Vogtle Electric Generating Plant Unit Examples of these are as follows:
1 Readiness Renew Program " Traru. Am. Nucl. Soc.,54, l
264 (1987).
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- 1. In general, the NRC concluded after its review and i
esajuanon of the GPC Vogtle readmess review that the GPC
- 2. " Georgia Power Company (Vogtle)Irdtiative to Conduct
'I reneas were thorough and accurate. Several excepdons to this an Operadonal Readiness Review Program
- SECY 85-122, statement primarily mvohed modules that were completed at Paper 85122. U.S. Nuclear Regulatory Commission (April the besmning of the program before the GPC procedures 8, 1985).
review was fully developed.
- 2. The timing of the readiness review and the NRC rou-tine inspection program were mistnatched, causing some dup!!-
6.
NRC Involvement in Re'ediness Reviews, J.
c ion of NRC effort pnmarily m the civil and mecharuca' Nelson Grace (NRC, Aflanta), invited l
- 3. The interfaces between the modules / appendices were In 1983-1984, the U.S. Nuclear Regulatory Commission comples and not always clear o NRC reviewers. A closer (NRC) conducted a comprehensive study of *1mproving Qual-alignment to the final safety analysis report (FSAR) would ity and the Assurance of Quality in the Design and Construc-hase a2ded the NRC review.
tion of Nuclear Power Plants" published as NUREG 1055 in
- 4. GPC module submittals were usually later than orig.
May 1984. One principal recommendation of that study was 1
inally scheduled and NRC review schedules were impacted.
to pasa t c geept nadmus resws for appucadon to nuclear construeuon.
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- 3. The review s in the civil areas were performed after the Readiness reviews of some sort are often conducted at dif-i design and construction activities were complete, which par.
ferent stages and at completion of construction projects. Such l
tially negated the full potential of the readiness review.
reviews vary in name, application, scope, formaliza tion, par.
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- 6. The reviews in the operational preparedness areas were aho e e ped a i d ap
'do" 8
limited due to the late development of operational procedures by GPC.
reviews for the U.S. Department of Energy (DOE) that was applied successfully to a number of DOE nuclear and non-
'l Most of the commitment reviews were performed by nuclear construction projects including the Fast Flus Test the NRC prior to the teadmess rev>ew due to the earlier FSAR l'acility (FFTF) at Hanford, Washington, the Strategic Petro-l i
review schedule.
leum Reserve (SPR) facihty in Louisiana, the loss of fluid test i
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w-~__
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(I.db') facil;t) in Idaho, and the Tokamak Fusion Test Reac.
have been 19 equivalent staff years and an additional 1318000 ior (TPTR) m Prmeeton, to name a few.
La contract suppon primarily fr:m EG&G Idaho.
d In the summer of 1954, the NRC was working through the The pilot program at Vogtle has been judged by both GPC Institute e Nuclear Power Operations (INPO) to nnd a "vol, and the NRC to be an outstanding success. The degree cf r
unteer" uuht) to participate in a formalized pilot readiness plant hardware, program, procedure, and documentation re-as recerntnended in NUREG 105$. Independently, view by the NRC far surpasses the routine NRC programs.
i' Georgia Power Company (GPC) setzed the opponuruty to The NRC is confident that one of tb6 more significant end reutw take the initia:ive to formulate their own program to review prodacts of the pilot program is much greater confidence and the implementation of design and construction and opera-assurance that the plant, programs, and personnel conform to tional reainess Funhermore, GPC intended to assure full NRC requirements and licensee comtnitments. In reviewmg the comphance with regulatory requirements and comtnitments results of the pilot program, the question was asked as to rnade to the NRC as weu as to assure compliance with their whether the NRC would participate again in similar utgity own programs and procedures at Plant Vogtle. Their incen-readiness review initiatives and the answer was yes. For enam-tive, and rronia: ion wi!! be covered in a companion paper plc, a smauer scoped readmess review program was initiated beit:g pre >ented by Georgia Power.
by the Washington Public Power Supply System for the review in Nosember 1984, the NRC agreed to panicipate in the of the preservation and maintenance of the deferred WNP pilot operanonal readmess review program proposed by GPC Unit 3, and the NRC has participated fuUy in the review, Aho, for P ant Vogile. Unit 1, located near Waynesboro, Georgta.
NRC is presently d5scussing with the GPC tentative plans for The NRC's pnmary mterest in parucipating was to test the a readiness program for Vogtle Unit 2. The lessons learned benefia and feastiat) of applying the rea6 ness review con.
from the pilot progrr,m are presented in Rei.1.
n conjancuen wnh a test of NRC incremental review and Overall, the pilot program demonstrated tha: the readiness a.:ce:,nec cf a bcemee's comp;eted work and acuvities. Also, review concept can bnns predictability and stability to the cept NRC enusioned that the readiness review program would gne inspection and licensing process-predictable in the sense that NRC the oppo< sum!> to resiew licensee activities in a struc.
the licensee and NRC can come to early agreement that the tured and ome!) manner and wou'd preside deta21ed infor-licensee's process and program meet NRC requirements, and manon to support staff fmdmgs, technical positions, and stable in the sense that the NRC licensing and inspection pro-decisiens pursuant to the issuance of an operating license, gram to be implemented throughout the design, construction, The puot readmess review program has been cornpicted at and preoperauona! phases will be well defined and understood Vogfle L' rat !, and a li:ense was issued for loading fuel and at the outset. The pilot program aho demonstrated that the for low. power cperation, as of January 16, 1987 The pro-reainess review concept, while requiring a commitment of NRC resources earlier in the licensing process, is prudent in gram las:cd shsh:1> oser 2 yr (November 1984 to December minitruzmg the risk of a larger cornrnstment of resources later 1986) N1uch of the first year was de&cated to program and procedure development by both GPC and the NRC, the sec-and with the lost flexibility of later determamng the extent and end year included most of the major reainess teview module timing cf the commitment in question. The earlier identifica-tion of problems dunng the Vogtle readiness review also gave prepara: ion and technica) review by the bcenste and the NRC, the NRC greater review flexibility with less time pressure to In total, tr.e NRC reurwed, inspected, commented on, and acceptea, after appropnate bcensee corteetise acuen,22 read-resobe problems and issues before issuance of the operating iness rev.cw rnodales on all aspects of the design. construction, license and without impacting the license schedule.
cnd operanonal reainess of the Vogtle plant, programs, and
- 1. M. V. SINKUL.E, W. RANKIN, *NRC Implementation of personnel. Oserall, GPC espanded $13.8 rrullion in crect sup-Vogtle Unit i Readiness Review Pilot Program." Trans.
port of the pilot program esclusise of larger ind rect proyect costs, while the NRC resource expenditures are estimated to Am. NucL Soc., 54, 267 (1987).
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