ML20155E972

Insp Rept 50-425/88-47 on 880808-19.No Violations or Deviations Noted.Major Areas Inspected:Review of Module Rept,Supporting Documentation & Associated Work Activities

ML20155E972
Person / Time
Site:	Vogtle
Issue date:	09/27/1988
From:	Conlon T, Harris J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155E964	List: ML20155E959 ML20155E972
References
50-425-88-47, NUDOCS 8810130078
Download: ML20155E972 (17)

See also: IR 05000425/1988047

Text

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4' ' UNITED STATES

{o j NUCLEAR REGULATORY COMMISSION

! REGION ll

oE 101 MARIETTA ST N.W.

e,,,,' ATLANTA. GEORGIA 30323

Report No.: 50-425/88-47

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket No.: 50-425 License No.: CPPR-109

Facility Name: Vogtle 2 Module No. 13 8 Coatings

Inspection Conducted: August 8-12 and August 15-19, 1988

Inspector: /e* W r- "L 9 " '4 7 ' 6'?

J. R. Harris ' Date Signed

Approved by: g/77 f- 6/- 2 7 - fY

T. E. Conlon, Chief Date Signed

Plant Systems Section

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This evaluation was perfonned for one of eleven Readiness Review

modules produced as part of a pilot Readiness Review Program being

operated by the licensee pursuant to a recommendation contained in

NUREG 1055. The NRC agreed to participate in the program by

reviewing and commenting on each module.

This evaluation was performed by reviewing the module report,

examining supporting documentation and inspecting associated work

activities. The licensee's review was verified by interviewing

licensee personnel associated with preparing the module, sampling

documentation and hardware examined by the licensee's reviewers and

by sampling documentation and hardware not selected by the licensee's

reviewers and by reviewing records of previous NRC inspections.

Resul ts: In the areas inspected, violations or deviations were not identified.

8010130070 G80920

gDR ADOCK 05000425

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REPORT DETAILS  !

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1. Persons Contacted ,

Licensee Employees

• J. A. Bailey, Project Licensing Manager  ;

J. H. Draggs, GPC Quality Assurance '

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• E. D. Groover, QA Site Manager - Construction

D. A. Lunsford, GPC Quality Assurance

R. McManus, Manager Readiness Review

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Other licensee employees contacted during this inspection included

J craftsmen, engineers, operators, technicians, and administrative  ;

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personnel.

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l Other Organizations ,

• R. R. Thomas, Readiness Review Team Leader, Bechtel Corporation  :

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D. Wiggins, Williams QC Inspector  ;

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NRC Resident Inspector

R. Scheppens, Senior Resident Inspector, Construction l

• Attended exit interview

2. Module 13B Coatings Unit 2

. a. Unit 2 Review ,

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The Unit 2 Headiness Review program is being conducted at the  !

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initiative of Georgia Power Company's (GPC's) management to assure

that all design, construction and preoperational testing have been

properly implemented at the Vogtle Electric Generating Plant Unit 2. l

Module 138 presents an assessment of the design and construction l

l activities associated with protective coatings for Unit 2. This l

evaluation was conducted to determine if the results of the program a

review for coatings presented in this module are an ef fective and

accurate assessment of design and construction requirements, that

these requirements are being properly implemented, and that the

resolution of findings identified in the module were correct and that

the corrections were made,

b. NRC Review Objective

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j The objective of this review and inspection was to evaluate the i

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licensee's VEGP Unit 2 Readiness Review of Coatings. '

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This evaluation was accomplished through a detailed review of all

sections of the module by:

- Verifying that the design and construction commitments listed in

the module are correct anci comply with FSAR commitments and

regulatory requirements

- Reviewing module findings and evaluating the correctness of -

their resolution i

- Review of a comprehensive representative sample of the records

reviewed by the Readiness Review Staff and an independent sample

l of documents

- Walkdown observation of construction activities

) c. Scope of Review

This review which consisted of an examination of each section of the

module was performed by an inspector from the Region II office in

Atlanta. Module Sections 1.0, 2.0, 4.0 and 8.0 which contain

! information concerning the Module Introduction, Company Organization, ,

Program Description, Assessment of Module Adequacy and Assessment  ;

4 Plans and Checklists did not require as detailed a review or

evaluation as the remaining sections. The more significant aspects  :

of the module appear in Sections 3.0, 5.0, and 6.0. These sections ,

discuss Licensee Comitments, Audits, Reportable Deficiencies, '

Special Evaluations, and Methods of Design and Construction

4 Activities related to coatings for Vogtle Electric Generating *

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Plant 2. Review of these sections included a detailed review of the

content, examination of items identified as findings, an examination i'

of a sample of records reviewed by the Readiness Review Staff and an

examination of an independently selected sample of records. [

d. Inspection

The review and evaluation by the Region !! inspector was accomplished

j by reviewing the module :n its entirety in the Atlanta Regional ,

Office beginning on Augus: 11, 1988, and by inspection at the Vogtle '

site on August 15-19, 1988.

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! Section 1.0, Introduction, which presents an introduction to the

intent and content of the module and Section 2.0 organization and

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Division of Responsibility, which presents a description for design

and application of coatings were reviewed for general content and

background data.

i Review of Section 3.0, Comitments, was accomplished by examining the

j Comitment and Implementation matrices and verifying that the

applicable comitments were implemented. Verification that the

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applicable commitments, were referenced and implemented was

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accomplished by reviewing the FSAR, SER, Specifications, procedures,

regulatory guides, applicable industry standards and responses to NRC

generic letters.  ;

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! Review of Section 4.0, Program Description, was accomplished by i

examining the two subsections and comparing the described work l

process used by design and construction with FSAR, specification and

procedure requirements. The inspector also compared the described  !

work process with the understanding of program requirements that were

examined during inspection of coatings conducted during the review of t

this module. 7

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Review of Section 5.0, Audits, Nuclear Regulatory Inspections and -

Special Evcluations, was accomplished by examining the four sub- ,

sections, and reviewing the audits, NRC inspections and special  :

evaluations and findings identified during the audit review. l

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Review of Section 6.0, Program Assessment, was accomplished by  ;

2 reviewing Subsection 6.4.1, Commitment Implementation, and Unit 1  !

followup, Subsection 6.4.2. In process Activities of ongoing design  :

, and construction activities, and Subsection 6.4.3, Construction  !

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Completion Process. Review of Subsection 6.4.1 included a review of i

, design commitments, construction commitments, and corrective actions  !

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taken to prevent recurrence in Unit 2 of the types of problems  !

j identified by the Readinesc Review during the Unit 1 assessment.

Three findings were identified by the Readiness Review Staff which

involved concerns with warehouse records not maintained by the

contractor, conflicting coating requirements in purchase specifica-  !

tion and contract procedure did not meet specification requirements. l

Review of Subsection 6.4.2 included examination of ongoing design and .

! construction processes.  !

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Three findings were identified by the Readiness Review Staff which

involved errors in processing FCRs, contractor procedures which cite

different revision of standards than contractor QA Manual and FSAR

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conflicts in contract procedure for deviation reporting. Review of

Subsection 6.4.3 construction completion process included a review of

applied coatings, quality documentation, material traceability,

inspector qualification and painter certification.

Review of Section 7.0 covered assessment module adequacy and proposed

corrective action taken for findings.

j Review of Section 8.0 covered assessment plan and checklists proposed i

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for evaluating Unit 2 design and construction activities associated

! with protective coatings.

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3. Evaluations

The evaluation of each section reviewed is prov!ded below. For each

section a description of the section that was reviewed and the basis of

acceptance is provided.

a. Section 1.0 - Introduction

This section of the module presented an introdu; tion to the intent

and content of the module organization. This section was reviewed

primarily for content and background information. No additional

followup or evaluation of the section was required.

b. Section 2.0 - Organization

This section presents a description of the organization and division

of responsibility of GPC, bechtel Western Power Company, Williams

Pnwer Services. Inc. for design and construction activities related

to coatings. This section of the module was reviewed for content

only. No additional followup or evaluation of this section was '

required.

c. Section 3.0 - Commitments

(1) This section contains a listing of commitments and implementing

documents which are presented in two matrices. The first matrix

is the commitment matrix which contains a listing of the sources

and subject of licensee commitments. Commitments listed in this

matrix were identified by the Readiness Review Staff through a

review of the FSAR and 6esponie to NRC questions. The second

matrix is the implementation matrix which contains a listing of

documents and features discussed in the FSAR and implementing

documents. The Readiness Review Staff reviewed these documents

to verify compliance with the commitment requirements.

(2) The Region II inspectors review and evaluation of this section

was lerformed by comparing the licensing commitments and

corresponding source documents with the Standard Review Plan,

the NRC Regulatory Guides (RGs), the provisions of Industry Standards

and the FSAR. The review also included an examination of

commitment sources and implementing procedures and specifica-

tions to verify that the FSAR commitments were being properly

implemented in the Readiness Review Program.

(3) Review of this section showed that the Vogtle licensing commit-

ments and implementing documents for the protective coating

systems comply with the requirements of the FSAR Regulatory

Guides and Industry Standards.

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d. Section 4.0 - Program Description

(1) This section of the module, is divided into two subsections

which describes the work process utilized by design and

construction for coatings at Vogtle Unit 2. Subsection 4.1

provides a description of the work flow, documentation and

design control activities for protective coatings for permanent

plant systems. The emphasis is on coating materials and

approved coating systems for areas and equipment inside the

containment building. The architectural group of the Materials

and Quality Services Group of Bechtel, selected coating systems

to meet the requirements of the service areas, the surfare to be

coated and the architectural and special service conditions as

applicable. This subject addresses Design Basis Accident Tests

(DBA), field coating systems, shop coatings, unqualified

coatings, specification development, material specifications,

field coating specification drawings, shop coating program,

quality requirements and the Westinghouse coating program.

Subsection 4.2 construction contains a description of coatings

and inspection activities, a flow chart and a list of codes and

standards applicable to receipt, storage, application and

inspection activities.

(2) Review of this section indicated that the program described in

the subsections is in accordance with the NRC inspector's

understanding of the work processes used by design and

construction for coatings at the Vogtle Plant.

e. Section 5.0 - Audits and Inspections

(1) This section contains a discussion of Quality Assurance Audits,

Nuclear Regulatory Comission inspections and project

reportability evaluations performed in the area of coatings. In

addition a description of special evaluations and a discussion

of the project evaluation of Unit 1 findings are included. The

findings, violations and evaluations applicable to coatings for

Unit 2 were reviewed by the Readiness Review Staff and factored

into the assessment presented in Section 6 of this module.

(2) Review of this section by the inspector included a review of the

four subsections. Review of the referenced audits and review of

the most recent audits conducted by GPC and the Williams

Corporation QA verified that the audits were being conducted within

the correct time and that proper corrective actions were taken

on Audit Findings. Review of the special evaluation concerning

the effect of the inorganic zine lining of the diesel fuel oil

storage on the operability of the diesel generators included

review of the NRC staff response to this item dated Octcber 15,

1987. This response included the NRC staff review of the

licensee's submittals dated July 13, September 30, and October

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i 1987. Based on the "eview of these submittals, the NRC staff

' concluded that the zinc coating in the diesel generator fuel i

oil storage tanks will not affect the operability and reliability i

of the diesel generators. Review of the special evaluation

concerning cracking of concrete floor coatings in the Unit 1

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containment indicated that the most probable cause was a high  !

film thickness in local areas coupled with mechanical damage to i

the coatings. This was based on the fact that samples of the  ;

) cracked coatings exhibited high filler body coating thickness.  !

Recommendations to prevent cracking of coatings included use of

a rubber float, minimal use of needle guns, inspection of coated r

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concrete floors for mechanical damage prior to application,

1 and areas adjacent to damaged areas to be protected or prepared

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to prevent excessive thickness.

The review also covered a review of the findings identified ,

during the Readiness Review of Coatings in Unit 1. The -

i Readiness Review Staff reviewed these findings to verify that l

proper corrective ac

ions were taken and to determine if they ,

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were applicable to Unit 2. This assessment identified two  !

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findings where corrective actions were not entirely effective.

These were identified as Findings 2RRF-13B-002, Errors in

Processing FCRS and Finding 2RRF-138-003, Required Warehouse

i Records Not Maintained by the Contractor. Section 6.0 contains

a more detailed discussion of these findings.

f. Section 6.0 Program Assessment

The assessment was performed to provide added assurance that the l

project continued to comply with licensing commitments. The

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assessment was organized into the following three parts; Part 1, ,

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Comitment Implementation and Unit i finding followup; Part 2, Design '

and Construction program activities; and Part 3, Design and r

Construction completion.  !

The objective of Part 1 of the assessment was to assess implementa- I

tion of licensing commitments with emphasis on those revised or added i

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since Unit 1 Readiness Review by Final Safety Analysis Report l

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amendments or project letters and to assess the adequacy of i

application to Unit 2 of corrective actions resulting from Unit 1 '

i Readiness Review.

During the review of comitment implementation which covered Design

and Construction Requirement and Unit 1 finding followup, several .

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findings were identified. These were: Finding 2RRF-138-004,

! Conflicting Coating requirements in Specification X4A J16; -

Finding 2RR F-13B003, No Contractor Procedure for receipt and

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, issuance of each batch of coating materials; Finding 2RRF-138-005,

I Contractors general procedure for control of application procedures  ;

I allowed exception to the commitment of RG 1.54 which requires that  ;

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application procedures conform with the coating manufactures written

instructions , .

Unit 1 findings were evaluated for continued application of

corrective actions to Unit 2 activities and the Unit 2 assessment

results were reviewed for repetition of Unit 1 findings. For 14 of

the unit findings the corrective action was found to be effective. 3

The corrective action for one Unit 1 finding to establish a >

procedural requirement to maintain a warehouse record was found to be [

not fully effective as described in the discussion of Unit 2 Finding  !

2RRF-138-003. Another element of the finding in Unit 1 was found to

be repeated in Unit 2. This identified that FCRs were making generic j

changes to the coating specification, but FCRs were identified as not  !

requiring incorporation in the specification. This was identified as  !

Finding 2RRF-138-002 which is discussed in Part 2, In Process  ;

Activities. l

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The objective of Part 2 of the assessment was to examine ongoing i

design and construction processes. The design portion of Part 2 [

covered the evaluation of 13 Field Change Requests (FCRs). This  ;

review identified repetitive failure to properly Identify and process t

changes affecting project Class 02c Coatings (Coatings Inside i

Containment). Field Change Requests inside containment were  !

improperly identified as project class 62C and were not sent to l

Quality Assurance (QA) for review. In addition FCRs properly  !

identified as Class 02c were not sent to Quality Assurance for review  !

as required by procedure. This was identified as Finding

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2RRF-138-002, Errors in Processing FCRs. t

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The construction portion of Part 2 of the assessment examined in

process coating application, coating material storage and deviation (

reports. in process application activities were assessed by i

observing preparation, inspection and application activities in the i

field. Attributes assessed included proper environmental testing, j

surface preparation and inspection, documenting and mixing of i

materials and application of coatings. Material storage areas were i

also examined for compliance to procedural requirements. Attributes t

assessed included temperature control, area cleanliness and material l

identification. Review of deviation reports covered the contractor's ,

deviation report procedures and a samole of deviation reports. The l

deviation reports were assessed for compliance to project require- '

ments. The reports were reviewed for adequate description. I

appropriate disposition, proper justification and required approvals.  !

Review of the deviation report procedure identified a deficiency in j

procedural requirements for deviation tracking and conflicts. This ,

was identified as Finding 2RRF-138-008 Conflicts in Contractor l

Procedure for Deviation Reporting. Review of the two contractor

control procedures indicated that they both referenced an incorrect  ;

revision of ANS! N45.2.9. This was identified as Finding l'

2RRF-138-006 Contractor Procedures Cite Different Revision of

Standard than Contractor QA Manual and FSAR.  ;

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The objective of Part 3 of the assessment was to evaluate the

construction completion process. This covered applied coatings,

qu4ity documentation, material traceability, inspector qualification

and painter certification, ,

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Review of Section 6.0 by the Region II inspector included a review of (

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the three activities addressed in the assessment plan. Thic included  !

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) a review of licensing connitment requirements, and Unit 1 finding

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followup, design and construction program activities and design and

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construction completion, and review of findings and corrective l

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actions taken to resolve the findings. This included a review of (

procedura, FSAR requirements, Field Change Requests (FCRs), Work

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i Requests (WRs), training and certification of inspectors and

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painters, Deviation Reports (DRs), storage controls, and a walkdown

j and inspection of ongoing coating work in the Unit 2 containment. r

Review of the findings identified by the Readiness Review Staff and

i the corrective actions associated with the findings are as follows:

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j (1) Finding 2RRF-138-000, Errors in Processing FCRs

i Project Reference Manual Section 17 states in part the

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- 17.5.2.a - After review and dispositf on by Engineering if a

design change is needed in the affected documents, an x is l

! placed in block 2 and/or 6 of the Field Change Request l

j (FCR) form

l - Construction specification change notices (CSCNs) and l

mechanical specification change notices are incorporated in  :

accordance with part C, Section 2a

l - 17.5.3 - Justification con::arrence shall be provided on the  !

j FCR prior to approval of Block 1b l

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- 17.6.2.5 - FCRs initiated for specifications that are Q

l class fire protection or radwaste shall be forwarded to l

l Quality Assurance (QA) for their concurrence prior to l

l submitting the originals to Georgia Power Company.

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i Contrary to the above, of a sample of 13 FCRs reviewed for

i Readiness Review Module 138 coatings, the following

l discrepancies were noted which were written against

j Specification X1AJ07

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- C-FCRB-22524 - Generic Change identified as NA/NA missing QA

! review

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j - C-FCRB-21176 - Missing QA review, incorrect project class

- C-FCRB-21175 - Missing QA review, incorrect project class

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- C-FCRB-19820 - Generic change identified as NA/NA missing QA

review and justification

- C-FCRB-20176 - Missing QA review, incorrect incorporation

- C-FCRB-19891 - Missing QA review

The root cause of this finding was that personnel processing

FCRs had an inadequate understanding of the coating project

class designation and the QA review requirement associated with

the coating 02c class.

Remedial action included correction to the FCRs and

Specification X1AJ07 was revised May 12, 1988. This revision

corrected the revision block to indicate that the FCR was

modified. Action to prevent recurrence included training of

appropriate architectural personnel re the coating

project classification (02c versus 062c)garding

the need for QA review

of FCRs with the project class 02c, and identification of

generic changes requiring incorporation into the specification.

In following upon this finding the inspector reviewed the FCR

identified as having error and verified tFat proper corrective

actions were taken and also reviewed 13 additional FCRs to

verify that similar problems did not exist in other FCRs. The

inspector also verified that proper revisions were made to

specification X1AJ07 and that the proper training had been given

to appropriate t .chitectural personnel.

(2) Finding 2RRF-138-003 - Required Warehouse Record Not Maintained

by Contractor

Specification X1AJ07, paragraph 12.1.1A. 12.7.1 and 12.7.2

require that the documentation requirements of ANSI N 101.4 be

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met and allow alternate forms providing the same degree of

documentation to be used. Example 3 of the Quality Document '

Foms Attachment to Specification X1AJ07 is a warehousing record

documenting the receipt and withdrawal of coating materials for

each batch of coating material received.

Contrary to the above no procedure was found prescribing

preparation and turnover of the warehousing record.

Remedial action included revision of Procedure WC-015-253

Warehouse Coating Records to address the upkeep and turnover of

the warehousing records. In addition the existing warehousing

records have been reviewed by the Williams Quality Control

Ocpartment. The review found thai records were missing for the

period of September 9.1986 to December 10, 1986. The missing

records were addressed in Deviation Report WC-88-0^3 dated

May 26, 1988. The approved disposition was hardware not

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a f fected. The Williams Quality Assurance / Quality Control

(QA/QC) Site Manager concluded after completing the review, ,

that the existing warehouse records are acceptable as quality l

documents, i

The new QC procedure has been approved by GPC Qua11tv tontrol

and is controlled by the Williams QC Department thro p Document i

Control Procedures WC-003 and WC-019. Williams Q M ity Control  !

will monitor the warehousing records closely to assure i

compliance. In following up on this item the HRC inspector l

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reviewed the referenced procedures and current warehouse records

and verified that ANSI N101.4 and specification X1AJ07

requirements were being met.

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(3) Finding ARRF-13B-004, Conflicting Coating Requirements in

Purchase Specifications.

Design Criteria DC-1000A, Section 10, requires that coatings  !

inside the containment meet the requirements of ANSI N101.2. j

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Specification X4AJ16 (Containment Cooling Units), Revision 10, l

dated December 10, 1986, Paragraph 6.3.1 requires that coatings l

be certified to ANSI N101.2. Paragraph 6.3. A requires an j

inorganic Zine primer followed by an epoxy topcoat and also l

lists acceptable suppliers and products. j

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The Ameron and Carboline inorganic Zinc primers listed are not j

their N101.2 qualified products. The products listed are all  !

inorganic Zinc primers. No epoxy topcoat is listed. This i

finding identifies conflicting requirements within Specification i

X4AJ16. Paragraph 6.3.2a of the specification requires  !

documentation in accordance with ANSI N101.4 ar.d Regulatory

Guide 1.54. In the same specification Paragraph 6.3.A.4

requires specific name brand coatings which will not meet these

documentation requirements and makes no allowance for acceptable

al+ernatives. I

To detemine the extent of this problem with conflicting  ;

requirements, a sample of 8 out of approximately 40 specifica- l

tions requiring the ANSI N101.4 and N101.2 documentation was

reviewed. These Specifications were X2AG03, X.!AGOS, X2AG06,

X2AG07, X2AG08, X2AH01, X2AH02 and X2AP01-C9.1. No confifcts or

discrepancies between the approved coating lists and

documentation requirements were identified. The purchase order

document PAY 2-86 was reviewed to determine the quality of paint

actually supplied for items in Specification X4AJ16. The Supplier

Quality Verification Document List - Detailed documents that the

paint meets the requirements of Paragraph 6.3.1.2.a of X4AJ16.

Also the product identity and Quality Assurance certification

record certifies that the paint meets the manufacturing require-

ments of ANS! N101.2, ANSI N101.4 and ANSI N5.12 when properly

mixed. Documentation that the paint was properly mixed and

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applied was also provided. These documents p avide objectivt

evidence that the paint meets the more stringent requirements

of Paragraph 6.3.1.2a of X4AJ16 and that the conflict in the

specification did not degrade the paint quality. The root cause

of the finding was attributed to human error. The specification

writer did not realize that the paint specification contained

conflicting requirements and that the review process failai to

uncover the mistake. Specification X4AJ16 was revised June 8,

1988, to delete Paragraph 6.3.A.4. This will eliminate the

conflict between documentation requirements arid avoid the

procurement of unqualified toatings. This will assure that

future materials procured under X4AJ16 will meet the require-

ments of Paragraph 6.3.1.2.a. During this inspection, the NRC

tr.spector reviewed the revision to Specification X4AJ16 and nine

other specifications to verify that similar errors were not in ,

the specifications.

(4) Finding 2RRF-13B-00-5, Contractor Procedure Does Not Meet

Specification and FSAR Requirements

Final Safety Analysis Report (FSAR) Section 6.1.2.1,

Specification X1AJ07 Section 12.5.1 and Williams QA Manual  ;

Section 5.4.4 and job specific addendum Section 5.4.1 require

, written approval of the manufacturers application procedures. 3

l This finding identified that Williams Procedure WC-300,

i Sections 300.4.1.4 and 300.7 allow exceptions to these i

l rmai rements .

l In following up on this finding Williams QC reviewed all i

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applicat'on procedures and found options or exceptions stated or

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implied in Sections 300.2.2, 300.2.3, 300.4.1.4 and 300.7 of

i Procedure 9C-300.

The cause of this error was due to an effort by Williams  !

Management to provide changes based on oral concurrence prior to

receiving written aporoval from the coating manufacturer. To

prevent recurrence of this item the Williams QA/QC manager vill ,

ensure that the written approval from the coatir.g manufacturers

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is obtained prior to implementation.

Investigation of this item by the NRC inspector showed that in 7

no instance had procedures been issued without the oral approval

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of the manufacturer. All procedures have been submitted to the

manufacturer and have been approved in writing. No coatings

have been unacceptably applied as a consequence of this  ;

discrepancy.

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(5) Finding 2RRF-138-006, Contractor P ccedures Cite Different

Revision of Standard Than the Contractar QA Manual and FSAR.

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FSAR Section 17.1.2 and Williams QA Manual job specific

j addendum, Section 5.10 require confonnance to ANSI N45.2.9-1973 -

eleventh draft. Williams procedure WC-003, "Document Security"

and Procedure WC-019, Controlled Document Revision and

Distribution reference ANSI N45.2.9-1974. i

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The cause of the finding was that no reference i.e the QA ~

i procedures manual would lead the user to the job specific

i addendum of the QA manual as the source of the correct edition

, of referenced standards. Williams QA/QC site manager checked

I the QA procedures to verify that other standards referenced are

the edition stated in the job specific addendum of the QA

manual. All were found to be the edition stated in the job

i specific addendum. Williams revised Procedure WC-003 and WC-019

i to reference ANSI N45.2.9-1973, eleventh draft. These revisions k

) were completed April 19, 1988. To prevent recurrence of this  !

!

error Williams QA/QC site manager will ensure tnat all future  !

) procedure have i.he correct standards referenced.

4

l The NRC inspector reviewed the corrective actions taken on this i

j finding. Review of the 1973 eleventh draft and 1974 revision of  :

ANSI N45.2.9 showed that there were no changes that would have  !

l

adversely affected the quality of Williams documentation. The j

j inspector also checked the Williams QA manual for correct  :

i revisions of referenced standards to further evaluate the  ;

j broadness of this finding. No further discrepancies were found. [

.

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1 (6) Finding 2RRF-138-008 Conflict In Contractor Procedure for  !

Deviation Reporting [

l Vogtle Electric Generating Plant QA manual Section 15.2 states:

d

i

j - The identification, documentation segregation, review,

i

disposition and notification of affected organization of i

'

nonconformance of materials, parts, components or services  !

is controlled.  ;

I

. - Nonconformances concerning departures from design i

l specification and drawing requirements which are [

t dispositioned "use as is" or "repair" are dispositioned  !

j by the responsible engineering organization. [

i i

This finding identified two discrepancies

I

j - Williams Procedure WC-008 contains no provisiv of tracking i

j reworkable deficiencies defined in Secti" 18.5.1.2.  !

Requirements for identifying non-reworkah s :ficiencies i

are conflicting (Sections 008.5.1.3 and 0 0 2.1).  !

l'

- Provisions of Williams Procedure WC-008 for approval of

l

"use as is" or "repair" dispositions are conflicting and ,

! I

! l

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1

1

13

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l

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I

do not identify project engineering as the responsible

engineering organization (Sections 008.5.2.4, 008.5.7.2,

008.6.3.2.1, 008.6.323 and 008.6.3.26).

Investigative action of the first discrepancy confirmed that the

original intent of procedure WC-008 Section 008.5.1.3 was to

cddress the tracking of rejected items which were reworkable. A

typographical error was made and Section 008.5.1.3 in

advertently stated "rejected items which are not reworkable."

Section 008.5.1.3 also addresses an open item 100 Williams QC

l stopped using the log in May of 1986. At that time the

responsibility for keeping the log was moved from the QC clerk

to the QC inspectors. The investigation found that the Williams

QC inspectors failed to use the log and that Williams QC management

l

falled to ensure that the inspectors used the log. The purpose

l

for the open item log was to track reworkable items. Prior to

1 May 1986, the log documented and verified that reworkable items

'

were handled in a timely manner. Williams QC replaced the open

item log with a designated hold file. Willaims QC management

failed to make the appropriate change in procedure WC-008 to

reflect the new method of tocking.

Williams QA/QC management reviewed all reworkable rejected items

reported between May 1986 and April 6,1988. There were 568

l

reworkable, rejected items reported during this period. A random

sampling of 72 of the 568 items were reviewed and it was determined

that 50 were reworked within four days, two within seven days and

20, all of which were on one inspection report, were not reworked

for four months. Although the open item log had not been used

I since May 1986, these 20 rejects were recorded in May 1987 but

were never placed on a Deviation Report. The inspection report

was placed in the designated hold file until it was reworked. l

The Williams QC site manager did not write a Deviation Report i

because the delay was caused by construction restraints which did

not allow the workers back into the area for rework. Williams I

management concluded from this review that items were reworked

in a timely manner except as constrained by other construction

activity. As of April 6, 1988, there were no outstanding

reworkable rejected items in tha designated hold file. The root

cause of this finding was attributed to inappropriate attention

level of Williams QC management.

Investigation of the second part of this finding established

that Section 008.6.3.23 had three editorial errors. The words

"recomended dispositions" are used twice in this section. The i

correct words should be "approved dispositions." The third l

error had the "owner or designee" approving what should have

been the approved disposition. The design engineering group

should approve the approved disposition. The root cause of the

l

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_. . ._. ..

. - . - - _ . __

. - - . .

_-

.,. .. . --- - . . - . - - - . . - .- .. _

< .

-

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i 14 >

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error was inadequate review of the final printed text prior to

final approval.  :

i

The following corrective actions were taken to correct these i

findings. Williams revised Procedure WC-008 Section 008.5.1.3 i

to direct any inspection reports which identify reworkable

deviations to be placed in a designated hold file until the ,

areas have been reworked. This file will be reviewed monthly by t

the QA/QC site manager. Any item over 60 days old shall be

,

i

;

! reported as a deviation report. The inspection report shall remain

in the hold file until it has been closed by the approved  ;

4 disposition on the deviation report. Deviation Report WC-88-002 i

a

has been written to resolve the procedure violation cited and it .

j has been dispositioned "hardware not af fected. " The

t

i typographical error in Section 008.5.1.3 has been corrected.  !

Williams has also revised procedure Section WC-008,

!l Section 008.6.3.23 to state "approved dispositions" instead of

"recommended dispositions" and "design engineering group"

instead of "owner designee."

To prevent recurrence of this finding, Williams QA/QC reviewed

their Quality Control procedures and determined that the QC i

Manager reviews deviation report trends and rejected open items

1 on a monthly basis. No other monthly review requirements were ,

j found. The trend review (Form WC-0080) is in place and a

j checklist for the monthly review of rejected open items (Form

WC-008E) has been added to the nonconfonnance control procedure.

1

! During this in3pection, the NRC inspector reviewed the changes

made to the procedures and reviewed current deviation reports.  !

! This review indicated that appropriate corrective actions have l

'

l

been taken on this finding.

4. Findings

l No NRC findings were identified during the review of Module 138 Unit 2.

Review of this Module showed that the Readiness Review Staff did a

comprehensive review of design and construction activities for ssfety-

i related coatings and that significant findings were identified by the

Readiness Review Staff. This resulted in significant corrections in the

i program that clarified inspectica requirements, documentation requirements

,

and inspection activities.

5. Conclusions

Based upon the review within the scope of Module 138, Coatings the NRC has

reached the following conclusions for coatings for Vogtle Unit 2.

i

4

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

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15

a. Summary of Specific Conclusions , ,

The module has been determined to be acceptable. A summary of the ,

report comments for each module section is as fo' lows: >

(1) Section 1 - Introduction. The module organization and project .

status were correct as of the date of the module publication. l

7

(2) Section 2 - Organization and Division of Responsibilities. The

organization and responsibilities presented in Section 2 of the

< Module were reviewed and verified as being correct.  ;

(3) Section 3 , Commitments. Review of the commitments as listed in "

'

Section 3 of the module indicated that licensing commitments and

implementing documents comply with the FSAR, Regulatory Guides

,

and Industry Standards. l

(4) Section 4 - Program Description. The inspector reviewed the

description of the program as given in Section 4 of the module.

This included a review of the referenced design and construction

controls for coatings. Review of this section indicated that

' the description cf controls of coatings presented in Section 4 '

are correct and is in agreement with the FSAR and project <

i requirements.

i (5) Section 5 - Audits and Inspections. Review of this section

l included a review of audits, NRC inspections, special

) evaluations and followup on Unit 1 findings. This review

indicated that proper corrective actions were taken on the ,

, findings and special evaluations covered in this section, j

t

j (6) Section 6 - Program Assessment. This section covered the  !

l program developed and actions performed to ascertain whether the

1 design and construction activities related to coatings for 1

Unit 2 have been adequately controlled to implement licensing

commitments, to ascertain whether the corrective actions

!

resulting from the Unit 1 Readiness Review were applied to

Unit 2, and to verify that the results of design and l

'

construction activities conform to project procedures and design  !

requirements.

i

The atove assessments resulted in six findings. Five were classified

. as level II and one as a level III. Each of the findings identified .

were evaluated to detemine the extent of the deficiency, the root I

cause of the finding and the impact on hardware or documentation.

Four of the six findings reported involved contractor procedure

deficiencies. In each of the four cases, investigations showed that I

the intent of the requirements addressed in the procedure had been

j met. The investigation also showed the deficiencies to be limited to

j the item or procedure in the finding. One of the remaining two

findings was an isolated case of conflict in a purchase specification

4

and the other finding was due to repetitive errors in processing Field

i

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1

.  ;

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16

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Change Requests. The investigation of the FCR deficiencies sh(wed them  !

to be limited to the coating specification. l

l

None of the findings reported deficiencies in applied coatings of l

inspection documentation. None of the remedial actions involved  !

applied coatings.

Review of the findings by the inspector indicated that the findings  !

were isolated cases of failure to comply with engineering or [

Inspection of coatings by

'

licensing requirements or with procedures.

the inspector indicated that these findings had no effect on applied r

coatings. ,

1

b. General Conclusions

'

This module presents an adequate assessment of the Georgia Power

Company (GPC) process for design and construction of coatings. l

During this review, ft was apparent to the NRC inspector that GPC

management supported the program by their active participation in the *

development of the program. Review and evaluation of Module 13B ,

'

Unit 2 by the NRC inspector indicates that the review performed by

GPC Readiness Review staff was sufficiently comprehensive in scope '

and depth to identify problem areas and that the dispositions of i

Readiness Review findings were proper and satisfactory. The ,

procedures for design construction, and quality control were  !

consistent with commitments and, are therefore acceptable. Based on  !

the review of this module and the results of previous NRC

inspections, the inspector concluded that coating activities were

performed in accordance with the appropriate procedures and that

records reflect quality of the coatings. The inspector concluded ,

that the Vogtle program for the design and construction of Category 1  :

coatings complies with the Final Safety Analysis Report and that l

compliance is verifiable with existing documentation. i

f

The NRC inspector furthermore believes that Module 13B accurately  !

assess the status of design and construction activities for i

Category 1 coatings. This conclusion is based on information )

currently available to the NRC hspector. Should information I

subsequently become available which was not considered during this '

review and which conflicts with earlier information it will be

evaluated to determine what effect it may have on the above

conclusion.

6. Exit Interview

The inspection scope and results were summarized on August 19, 1988,

with those persons indicated in Paragraph 1. The inspector described

the areas inspected and discussed in detail the inspection results.

Dissenting coments were not received from the licensee. The licensee

did not identify as proprietary any of the materials provided to or

reviewed by the inspector during this inspection.

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