ML20205H288

Second Affidavit of Cw Hayes Supporting Applicant Response to Joint Intervenors Motion for Reconsideration of ASLB 851003 Memorandum & Order on Summary Disposition of Contention 8 Re QA Program.Certificate of Svc Encl

ML20205H288
Person / Time
Site:	Vogtle
Issue date:	11/08/1985
From:	Hayes C GEORGIA POWER CO.
To:
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ML20205H244	List: ML20205H238 ML20205H263 ML20205H288
References
OL, NUDOCS 8511150092
Download: ML20205H288 (100)

Text

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION I l

Before the Atomic Safety and Licensina Board In the Matter of )

)

GEORGIA POWER COMPANY, ) Docket Nos. 50-424 et al. ) 50-425 (Vogtle Electric Generating )

Plant, Units 1 and 2) )

EXCOND AFFIDAVIT OF C. W. HAYES Before the undersigned officer duly authorized to cdminister oaths did appear C. W. Hayes, who after being duly sworn, did state as follows:

1. My name is Charles W. Hayes. My business address 10 Vogtle Electric Generating Plant, Route 2, Waynesboro, G orgia 30830. I an employed by Georgia Power Company as Vogtle Quality Assurance Manager. In that position, my primary responsibility has been to assure that the approved Quality Assurance programs are implemented by all Project participants and to manage the Vogtle Quality Assurance organization at Vogtle Electric Generating Plant. A summary of my professional qualifications was attached as Attachment "2A" to my first Affidavit which was filed with this Board on June 24, 1985.

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2. I have read and reviewed Joint Intervenors M; tion for Reconsideration. I submit this Affidavit in support of Applicants' Response to that Motion. The facts set forth h rein are based ~upon my personal knowledge.

3. As part of the function of the VEGP QA Department, all Readiness Review findings are reviewed for rcportability within the meaning of 10 C.F.R. 50.55(e). This rc, view is governed by QA Procedure QA-04-02. In addition to O review hor reportability, each Readiness Review finding is incorporated into the QA audit program to determine whether a generic or programmatic problem exists. Audit procedures ccsure that corrective action, including identification and rcsolution of the basic cause and action to prevent recurrence, is accomplished.

Further Affiant sayeth not.

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Hayes Sworn to p d subscribed before to thief - day of LC + 4 0 ,

1985. ,

/ %Q . .u Y k Notary Public j Notary Public, Geo,sio State at Large. '

% Commission Empires June 23,1984.

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2. , p aneo g UNIT E3 STATES

/ "o, NUCLEAR REGULATODY COMMISSION

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1 Executive Vice President f ,O M 0. Box 4545 )(16bIog E [ i 5 l m eu-

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Gentlemen:

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SUBJECT:

NRC REVIEW OF V0GTLE READINESS REVIEW N00ULE NO. 1, REINFORCED CONCRETE STRUCTURES - REPORT NO. 50-424/85-28 The NRC has completed a detailed, review, inspection, and verification of the subject Module which you submitted to the NRC on March 25, 1985. Periodic inspections were conducted at the Vogtle site and the resultant findings were discussed with members of your staff at the conclusion of these inspections.

Technical reviews were conducted primarily in NRC Bethesda offices and the findings from these reviews have also been discussed with your staff.

Areas contained in the module, which were reviewed, examined, and verified, are identified in the enclosed report. Within these areas, the inspection and verification consisted of selected examinations of procedures and representative records, discussions with personnel, observations of activities in progress, and review of your licensing commitments.

The results of Module No.1 reviews and inspections are summarized into the categories of deficiencies and unresolved items. Your attention is invited to these matters which will be pursued during future licensing reviews and inspections. .

Based upon the NRC review and inspection of those activities identified in the module, we have determined that Reinforced Concrete Structures at Vogtle 1 are acceptable and comply with applicable regulatory requirements with the exception of those items or areas identified in the Report. This decision was based upon information currently available to the inspectors and reviewers. Should informa-tien subsequently become available which was not considered during this review or thich conflicts with earlier information, it will be evaluated to determine what effects it may have on the above conclusion.

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

Sincerely, 4..ti J. Nelson Grace Regional Administrator

Enclosure:

Report No. 50-424/85-28 cc w/ encl: (See page 2)

EXHIBIT "4'

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2 DiaPowerCompany b/ enc 1:

E. Conway, Senior Vice President xlear Power D, F^ ster, Vice President nd General Manager Vogtle Project H. Gregory, III, General Anager,VogtleNuclearConstruction

.Sockhold, Jr... Vogtle

'lant Manager T. Gucwa, Chief luclear Engineer llo A. Thomas, lice President-Licensing Vogtle Project Groover, Quality Assurance Site Manager W. Hayes, QA Manager T. Beckham, Vice President

& General Manager - Operations A. 8ailey, Project Licensing Manager torge F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge ruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge .

rnest L. Blake, Jr., Esq.

'Shaw, Pittman, Potts and Trowbridge ames E. Joiner, Troutman, Sanders, Lockerman and Ashmore ames G. Ledbetter, Commissioner Department of Human Resources

harles H. Badger, Office of Planning and Budget, Management Revicw Division Eppish'Kirkland III, Counsel Of fice of the Consumer's Utility Council Douglas C. Teper, Georgians Against -

Nuclear Energy laurie Fowler, Legal Environmental Assistance Foundation Tia J:hnson, Executive Director Educaticnal Campaign for a Prosperous Ge:rgia cc: (Cont'd on page 3)

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Georgia Power Company 3

-Morten 8. Margulies, Esq., Chairman Administrative Judge, Atomic Safety and Licensing Board Panel Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel

. Gustave A. Linenberger, Jr. , Administrative Judge, Atomic Safety and Licensing Board Panel -

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1 UNITED STATES j g

[ps#4eg } NUCLEAR REGULATORY COMMissic cE282N il a

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• ATLANTA, otoRGt A 30323 oo ...

Rep;rt No.: 50-424/85-28 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 Construction Permit No.: CPPR-108 Facility Name: Vogtle Unit 1 ,

Reviews Conducted: April 2,1985 through June 25,1985 6.

On-SiteInip[etionsConducted: April 15-19 1985; May 6-10, 1985; and May 20-24, 1985 NRC Of f ti:es Participating In Inspections / Reviews: .

Office of Inspection and Enforcement (IE), Bethesda, M0 Office of Nuclear Reactor Regulation (NRR), Bethesda, MO Region II, Atlanta, GA , ,,

i R: viewers: E. V. Imbro, Senior Inspection Specialist, IE R. W. Parkhill, Inspection Specialist,"IE J. D. Kane, Geotechnical Engineer, NRR K. C. Leu, Structural Engineer, NRR Inspectors: J. R. Harris, Reactor Inspector, Region II J. J. Lenahan, Reactor Inspector, Region II R. W. Wright, Reactor Inspector, Region II W. H. Rankin, Project Engineer, Region II T. F, McElhinney, Reacto- Engineer, Region II Acorove r Y JNr J 1 - /<7 - P_ ?

- T. E Conlon, Chief (ModuTe - All Sections) Date Signec Plant Systems Section Division of Reactor Safety ~

Regicn 11 I

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J. L. Milhoan, Cliief (Module Sect *n 6.1& 7)

& F'/z/w D&te Signed Licen ing Sectionl Oivision of Quality Assurance, i

Vendo , and Te cal Trai ing Center Programs, IE

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f lwNv ibN G. E. IAar', Chief (Module Section 3.0-3.4) /Dat( Signed Structuni and Geotechnical Engineering Branch 3

01 istopof Engineering, (NRR)

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f th Date Signed 1.3 f M. V. Tinkule, Chief Projects Section 20

Division of Reactor Projects s

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TABLE OF CONTENTS Topic Page Summary 3 Scope of Review 5 Methodology 5 Evaluations 7 Findings 13 Conclusions 16 O

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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM F

MODULE NO. 1 REIHFORCED CONCRETE STRUCTURES

SUMMARY

Readiness Review Report No.1 is an evaluation of Mocule No.1 of the Readiness

.- Review Program. This program is being conducted as an initiative of Georgia Power Company management to assure that all design, construction, and operational commitments have been p*operly implemented at the Vogtle Electric Generating Plant Unit 1. Module No. 1, which is the first of an anticipated twenty Modules, r presents an assessment of the program for the design and construction of re-

inforced concrete structures. This evaluation was conducted to determine if the results of the program review on reinforced concrete presented in this Module are k an effective and accurate assessment of design and construction requirements,

= that these requirements are being properly implemented, and that the resolutions of findings identified in the Mocule were correct.

- This evaluation was performed by NRC reviewers and inspectors from the Office of

Nuclear Reactor Regulation, Office of Inspection and Enforcement, and Region II.

1 The evaluation was accomplished through a detailed review of all sections of the k module by: 1) verifying that design and construction commitments listed in the Module are correct and comply with FSAR requirements: 2) reviewing the module findings and evaluating the correctness of their resolution; 3) reviewing a

- comprehensive and representative sample of the records reviewed by the Readiness Review Staff, and: 4) selecting and reviewing a comprehensive and representative

- random sample of records on concrete operations.

During the review it was apparent to the NRC reviewers and inspectors that GPC management sucported the program by active particication in the cevelopment and inclementation of tne orogram. Ibis evaluation also ircicates that the licer.see's

_ or grar- review f:* re'9 forced ccecrets was com:*enenshe anc previces adeqcate p assurance that tne reir.forcec concrete structures nave teen designed and constructec in accordanco with NRC requirements and FSAR commitments except for several E programmatic discrepancies which were icentified by the NRC reviewers and inspectors.

y These items are classified as deficiencies or unresolved items. A deficiency is E considered to be an item having no safety significance, but one which should be i evaluated by the licensee to determine what action could be taken to correct the item and thus preclude the possibility of the development of safety problems. An unresolved item is a matter which requires further information and investigation to determine if it is acceptable or may involve a violation or deviation. .A r listing of the deficiencies and unresolved items identified during this evaluation is summarized below: '

Deficiency - Retrievability of Records E

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• Deficiency -

Purchase of Superplasticizer as a non-Q Material

• Deficiency -

Timeliness of Writing and Addressing a Deficiency Report on Cadweld Failures

• Deficiency -

Acceptance of Response to Concern Number 3 Regard- 1 ing Adequacy of Design of Shear Reinforcement Without Reviewing Calculations Unresolved Item -

Review of Results of Testing Performed on Concrete Materials by the Independent Testing Laboratory Unresolved Item -

Review of Civil Open Item Reports Unresolved Item -

Maximum Allowable Water on Batch Tickets Unresolved Item -

Certification of QC Inspectors on Concrete Pour Unresolved Item -

Use of Shear Bars in the Auxiliary Building Base l Mat It does not appear that these deficiencies and. unresolved items will represent significant programmatic weaknesses. ,

Details on these items are discussed in the main body of this report. More l specific details for Region II identified items are provided in supporting Region II Inspection Report No. 50-424, 425/85-19. Resolution of these items will -

be handled in future Region II routine inspections.

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1. Scope of Review This review, which consisted of an Module, was performed by reviewersexamination from the Office of eachof Nuclear section of the Reactor Regulation, Region the Office II. Module of Inspection and Enforcement, and inspectors from Sections on the Module introduction 1.0, 2.0, 4.0, 5.0, anc 8.0, which present data company organization, division of responsi-bilities, work processes, r,esults of audits, special investigations, and conclusions regarding the assessment of the Module, did not require as detailed a review or evaluation as the other sections.

aspects of the Module appear in Sections 3.0, 6.0, and 7.0.The more significant These sections discuss licensee commitments, methods of implementing commitments, methods of design dent designandreview.construction program verification, and results of an indepen-the content; Review of these sections included a detailed review of examination of items identified as findings, concerns, and Readiness Review Staff; observations; an examination of athesample GPC of records r sample of records. and an examination of an independently selected each section are presented in the following paragraphs. Methodology us 4

2. Mathodology -

The review and evaluation by HRR focused on Sections 3.0, 6.0 and 7.0. The raview was conducted in the Bethesda office commencing on April 2,1985.

Review of Section 3 was performed by comparing the applicant's licensing and project commitments -and the corresponding source documents within k 5':ction 3.0 with the Standard Review Plan (SRP) positions, the Regulatory Guides, the provisions of the industrial codes, the NRC questions and answer records, the staff's SER and the Vogtle FSAR documents.

cation activities (Sections 6.1 and 6.2) were reviewed The program verift-

.o verify proper implementation design of commitments and conformarce to projer. procecures ano re::ut rements. Review of the incependent oesign activities (Section 7.0) focused on the Mndirgs of the '-de endent review group ano corrective actions taken to resolve acverse fincings.

The review and Verification, and Section evaluation 7.0,byIndependent IE focused on Section 6.1, Design Program Design Review. The review of both sections was performed by inspections at office of the staff's civil structural consultant.the Vogtle Duringsite the and site at theof visit April 15-18,1985, the IE inspection team interviewed the GPC Readiness Review and 7.0. Staff (viz., Paul W. Koss, John Curtin) a'ssociated with Sections 61 .

of review performed.These interviews were held to determine the methodology and depth referenced sections and Also, at the site the IE inspection team reviewed the related calculations. In addition to the site inspection, the IE team reviewed incependently three calculations identified during tive of the the Independent subject being Design Review that were determined to be representa-assessed. The purpose of this review was to cetermine the cepth of the review performed by the Readiness Review Program Staff with respect to cesign aspects and supporting calculations, i

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6 The review and evaluation by Region II inspectors was accomplished by reviewing the Module in its entirety in the Atlanta Regional Office begin-ning on April 2,1985, and by inspections at the Vogtle site on April 15-19 I

1985 (Inspection Report No. 50-424, 425/85-15), May 6-10, 1985, and May 20-24, 1985 (Inspection Report No. 50-424, 425/85-19). Section 1.0, Introduction, which presents an introduction to the intent and content of the Module and Section 2.0, Organization and Division of Resporsibility, which presents a description of the organization and responsibility for design and construc-tion of concrete structures, were only reviewed for general content and needed background data. Review of Section 3.0, Commitments, centered around the construction commitments anc implementation of these commitments. This was accomplished by reviewing the FSAR and verifying that the correct commitments were referenced in the implementation matrix. The inspectors also reviewed the commitment sources and implementing specifications and procedures to verify that the FSAR commitments were being correctly imple-mented in project documents. Commitment sources examined included American Concrete Institute (ACI) practices and codes, American Society for Testing and Materials (ASTMs) standards, Regulatory Guides, and American N:tional Standard Institute (ANSI) standards. These were reviewed and compared with applicable specifications and procedures.

Review of Section 4.0, Program Descriotion, was accomplished by examining l the four subsections and comparing the program description with FSAR require-l ments, specifications, and procedure requirements. The inspectors also l compared the described program with the inspectors' understanding of program

! requirements that have been ins'pected against and reported in inspection

reports from 1977 to 1985. Review of Section 5.0, Audits and Special l Investigations, was accomplished by examining the five subsections, NRC and l INPO findings, and construction problems identified in Subsections 5.2, 5.4, l and 5.5. Region II inspection reports were aisc reviewed to verify tnat the

identified findings had previously been reviewed and addressed by the NRC.

Audit findings' identified in Section 5.1 were not examined in detail because

! similar type findings were examined and evaluated in review of Sections 6.1 and 6.2. Review of Section 6.0, Program Verification, centered arouno Subsection 6.2, Construction Program Verification. Subsection 6.1, Design Program Verification, was reviewed for content and verification of the l inspectors' understanding of the design process. No in depth evaluation of Subsection 6.3, which covers a visual walkdown inspection of concrete structures, was done as dredit was taken for the numerous walkdowns of concrete structures which have been performed by Region II inspectors during previous routine inspections. Review of Subsection 6.2 was accomplished by reviewing and examining the- corrective actions associated with the resolu-tion of the fifty-five findings and by reviewing pertinent records for two of the 26 vertical slices of concrete operations analyzed by the Readiness Review Staff. In addition Region II reviewed records of three randomly selected vertical slices and one horizontal sitca of concrete operations in the Unit 1 Containment Building. A vertical slice takes into account the major attributes of a concrete pour. If problems are identified with any major attribute, an evaluation is performed of that attribute for several concrete pours (hori: ental slice). Review of the fifty-five findings

! included examinat. ion of quality records, specifications, procedures, industry standards, and FSAR commitments associated with the items identified in the

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7 findings. Records for the vertical sifces were examined to ascertain

.thether the records were in conformance with established procedures and specifications and that the records reflect work acccmplishment consistent with requirements in the following areas:

• Materials Acceptability - Cement, fly ash, fine and coarse aggregates, admixtures, reinforcing steel, and cacweld materials

• Rebar installation, cadweld splicing, and testing activities

• Preplacement, batch plant delivery, and placement operations

• Inprocess testing of fresh concrete Calibration of equipment

• Curing and post placement activities Core drilling and grouting operations

• Qualification of QC inspection personnel

• Handling of deviation reports /nonconformance control ,

Examination of quality records of the horizontal slice of concrete opera-

.tions consisted of examining records for the critical elements of 26 con-crete placements made in the Unit I containment building between August 1981 and September 1984. Critical elements selected for review included slump, air temperature and strength. Review and examination of Section 7.0, Independent Design Review, was limited to reviewing and examining observa-tions 11 through 14, identified by the Independent Design Reviewers in Section 7.5. This included exav.ination of referenced ccr.mitments, procedures, records, interviews with CC irspectors ano engineers, examina-tier of CC inspector training rec 0rcs anc : Jality re:Ords pertinent to the observations. Review of Section 8.0, Pr: gram As sessmer.1/Concl us i on , was reviewed primarily for content and background information. Evaluation of this section was effectively accomplished during review of the Module Sections identified earlier.

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.3. Evaluations -

1 The evaluation . of each section reviewed is previded below. For each section, a description of the section, what was reviewed, and the basis of I acceptance is provided,

a. Section 1.0 - Introduction This section of the medule presents an intrecuttien to the intent and content of the module organization, areas of evaluation, and status of  ;

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the project. This section was reviewed primarily for content and background information. No additional followup or evaluation of the l section was required.

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b. Section 2.0 - Oceani:ation and Division of Rescensibility This section presents a descriotion of the organi:ation and division of respons.ibility of Georgia Power Company. Bechtel, and Southern Ccmpany Services for design, procurement, and construction activities related to concrete structures. 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 of the Module 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, responses to NRC questions, responses to generic letters, and responses to IE letters. 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) NRR reviewer's and Region II inspector's review and evaluation of this section was performed by comparing licensing commitments and corresponding source documents with the SRP, Regulatory Guides, the previsions of the industry codes and standarcs, the NRC cuestion and answer records, the staff's SER and the :SAR deca-ments. The review also included a review of commitment sources and implementing specifications anc procecures to verify that tne FSAR commitments were being correctly implemented in prcject cocuments.

,(3) This review resulted in three questions being generated concerning compliance with FSAR commitments.

(a) Question 1 pertained to ccmpliance with Sections CC-2000, CC-4000, CC-5000, and CC-6000 of the ASME Section III, Division 2 code referenced by Section l'.9.136 of the FSAR.

Discussions with licensee engineers in tnree confe ence calls (Acril 29 May 14, and May 28, 1985) and subsequent documenta-

, tion provided as a followup to these discussions (reference letter - Foster to Grace - August 2, 1935) demonstrated

( that the devtations between ASME code requirements and Vogtle site practices are minor. Based on a review of the cocuments i provided by the licensee, the staff concluded that the applicant has demonstrated compliance with the intent of the ASME Section III Division 2 code.

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9 (b) Question 2 was concerned with whether or not the design of the spent fuel storage facility complied with the referenced requirements of Appendix 0 to the SRP, Section 3.8.4.

Section 3.4 of the Module does not reference the recuirements of Appendix 0 to SRP Section 3.8.4. Discussions with lican-see engineers in conference calls (April 29 and May 3. 1985)

> and a review of FSAR Section 9.1.2.3 showed that the applicant used " Review and Acceptance of Spent Fuel Storage Handling Application" (NRC guidance dated April 14,1978) as guidance for the design of spent fuel racks. Review of this document showed that the current SRP criteria is based primarily on the position in the April 1978 guidance, and therefore, the intent of SRP requirements are being met.

(c) Question 3 was ' concerned with whether or not the total soil damping used in the structural dynamic studies are repre-sented by FSAR figures 3.7.B.1-8 through 3.7.B.1-10 and the tabulated damping values on FSAR Figure 241.12-1. Conference call discussions of July 1 and July 15, 1985 and the licen-see's response of May 17, 1985 and July 5,1985, (reference letter - Foster to Grace - August 2, 1985) verified that the strain-dependent damping curves in the above FSAR figures were the soil damping data used in the soil-structure interaction dynamic studies.

Review of this section by the reviewers and inspectors showed that the Vogtle licensing commitments and implementing documents comply with the FSAR, the SRP, Regulatory Guides, and industry c.1 des and standards,

d. Section 4.0 - Procram Descriotion (1) This section of the module describes work orocesses and controls fer cesign, procurement of materials, training and qualification of insoectors, fabrication and installation, and inspection and testing of reinforced concrete.

(2) Review of this section by Region II inspectors included a detailed  !

i- examination of the four' subsections and a comparison of the l program description with FSAR requirements, specification, and procedure requirements. The described program was also compared with the inspectors' understanding of program requirements that have been inspected against and reported in inspection reports from 1977 to 1985.

(3) Review of this section indicated that the program described in the subsections is generally correct and is in agreement with FSAR and project requirements. One discrepancy in program requirements regarding tne purchasing of the superplasticizing admixture as a non-Q item was identified. Subsequent review of supporting

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10 test data showed that the material meets the requirements specified by the referenced ASTM C-494. This minor discrepancy was identified as a deficiency,

e. Section 5.0 - Audits and Soecial Investications 1

(1) This section contains a discussion of the QA audit process, NRC

. inspections, special inspections by INPO and a self-initiated )

inspection team, and past design and construction problems. This section was reviewed to confirm that the audit process, results of NRC findings and construction problems identified in this section are accurate and correspond to methods that have been observed by Region II inspectors and reported in previous Region II inspection reports.

(2) Review of this section included a review of the five subsections, INPO and NRC findings, and construction problems identified in Subsections 5.2, 5.4 and 5.5. Region II inspection reports were also reviewed to verify that the identified findings had pre-viously been reviewed and addressed by the NRC. Georgia Power audit findings identified in Subsection 5.1 were not examined as similar findings which appear in Sections 6.1 and 6.2 of the Module were examined and evaluated for correct resolution and significance.

(3) Review of this section indicated that it is an accurate presenta-tion of the audit process and previously identified construction problems and NRC inspection results. No findings were identified during the review of this section.

f. Section 6.0 - procram Verification (1) This section discusses methods used to verify conformance to design and construction requirements. The section is divided into Subsections 6.1, 6.2, and 6.3. Subsection 6.1 covers activities related to the design program verification. The design program verification was covered in two phases. In Phase I, the commit-ments, which were identified in Section 3 of the Module, were compared to project design criteria. The second phase involved the verificat' ion of FSAR commitments in calculations, drawings, specifications, change control records and training records. No findings were identified in Phase I. Five findings of a proce-dural nature were identified in Phase II. Section 6.2 which covered activities related to the construction program was also performed in two phases. Phase I was verification of implementa-tion of 43 construction and 23 procurement commitments. Phase II was a technical review of construction records to verify that the work was performed in accordance with project specifications,

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procedures, and drawings. Five findings were identified in Phase I and 50 findings were identified in Phase II. Section 6.3 covers a visual walkdown of concrete structures that was performed

• to observe the overall condition of the concrete.

(2) Review of Section 6.0 was performed by reviewers from NRR, IE and inspectors from Region II. The review by NRR included a review of the program verificatio'n activities listed in Subsections 6.1 and 6.2 and the resolution of the five findings identified in Sub-section 6.1. The review by IE included the methodology used as well as the depth of the review of the design program verification presented in Subsection 6.1. The IE review also included examina-tion and resolution of the five findings identified _ by the Readi-ness Review Staff. Review of the construction verification program in Subsection 6.2 by Region II inspectors included a review and examination of the corrective actions associated with the resolution of the 55 findings, a review of pertinent records for two of the vertical slices of concrete operations analyzed by the Readiness Review Staff, and three randomly selected vertical slices and records for a horizontal slice of concrete operations in the Unit 1 Containment Building.

(3) Review of this section indicated that the review conducted by the Readiness Review Staff for the design and construction verifica-tion program was comprehensive and adequate. Examination of the -

findings indicated that they were of minor significance and that the resolution of the - findings was adequate. Examination of the quality records indicated they were representative evidence of quality controls for concrete operations and indicated that concrete operations were being controlled in accordance with applicable requirements.

The review of this section resulted in two questions being ge-erated oy NRR revie.ers anc sone m cor program oiscrepancies being ioentifiec by Region II inspectors.

Question 1 was related to the sampling method in the design program verification. The intent of the question was to determine how meaningful are the. representative samples selected by the applicant to ensure the proper implementation of licensing commit-ments for the design of concrete . structures. Subsequent discus-sions with licensee engineers (April 29,1985) and further review of the Module indicated that the sampling methods were adequate.

Question 2 stemmed from the statement in Section 6.2.2.1 of the Module that prior to January 1980, the-e was no reouirement to use certified personnel for inspection activities. This statement ap: eared to be in conflict wito Regu'atory Guide 1.58 and the requirements of ANSI N45.2.6. Resolution of this question was achieved by Region 11 inscectors by reviewing Section 17 of the FSAR, procedures for training inspectors, and inspector training

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i a 12 records. Review of section 17 of the FSAR showed that the licen-see stated in the FSAR that they were not able to fully comply j with the requirements of ANSI N45.2.6 because of a shortage of experienced personnel at the time and that a training program for engineers and inspectors was developed to meet the intent of the Regulatory Guide 1.53 which endorses ANSI N45.2.6. Review of training procedures showed that the procedures generally conform to the requirements of ANSI N45.2.6 (197S). One exception noted was that the procedures only required as little as one month on the job training to meet the requirements for Level I certifica-tion which is at variance with any combination of education and experience for Level I certification under the ANSI Standard. As a result of this variance, the records of the QC inspectors who were certified prior to 1980, were examined to establish the level of conformance to ANSI N45.2.6. Review of these records indicated that QC inspectors were trained and certified in accordance with the requirements of ANSI N45.2.6.

The minor program discrepancies identified by Region II inspectors were concerned with retrievability of records, review of test data on concrete materials,. licensee review of civil open item reports, maximum allowable water on batch tickets exceeding design require-ments, and certification of QC inspectors. These discrepancies are classified as either deficiencies or unresolved items.

Details of these findings are presented in 'the findings paragraph and in Region II Inspection Report Number 50-424, 425/85-19.

g. Section 7.0 - Indeoendent Design Review (1) This section describes the independent design review of reinforced concrete structures conducted by the Stone and Webster Engineer.ing Corporation. The three key areas of civil structural desi;n that tne incependent cesign review focused en included reinforced ccccrete structural design, matarials scaci'ications, and casign cnange evaluation. Concrete structures selected for review incluced containment internal structures, auxiliary building, fuel handling building, and control building. Two levels of review were performed on :ne structures selected. Level I review which is overall analysis and load development was performed on all of the four b'uildings. Level 2 review, which is the detail design of structural comoonents within the building, was performed on the containment internal structures and the auxiliary building. The rev.iew by the Indepencent Design Review team yielded three con-cerns and 14 observations.

(2) Both levels of the design review were investigated by the IE inspection team as well as the observations and concerns identi-fied by the Independent Design Review team. The IE inspection team also reviewed incependently calculations to determine the

,.------,.,.-e -

-g ,, - - , . - _

7 13 depth of review performed by the Independent Design Review team.

Reviewers from NRR examined the . findings identified in the Independent Design Review and corrective actions taken to resolve

• the findings. Region If inspectors reviewed the resolution of Observations 11 through 14 which dealt with material specifica-tions and procedures.

(3) Review of this section showed that adequate samples were inspected to determine the adequacy of the concrete structures and that the program developed by the Independent Design Review team was comprehensive and adequate. The reviewers agree with the Independent Design Review team findings and their disposition except for Concern Number 3. This concern deals with the use of shear bars in the auxiliary building mat which do not conform to the ACI 318-71 code. A review of Observation 14, Cadweld Deficiency, indicated that some cadweld failures were not addressed in a timely manner. These items are identified as an unresolved item and a _ deficiency in the findings paragraph.

Review of Concern Number 1 in Section 7.5 resulted in a question from NRR reviewers concerning Bechtel's response on the use of dynamic load factors on jet impingement loads. Discussions with Georgia Power Company and Stone and Webster Engineering Corpora-tion engineers (April 29 and May 31, 19R5) as well as the licensee's response (reference letter - Foster to Grace - August 2, 1985) showed that the proper. dynamic load factor was used and that the effects of dynamic loading on the Vogtle structures have been correctly incorporated in the design. ,

4. Findings The following findings were identified from the reviews by NRR and IE reviewers and Regicn II inscectors. The findings are identified as either a oeficiency or an unresolved item. A deficiency is considered as an item naving no sare:y significance out one snat snoulo ce evaluateo furtner to preclude safety problems. An unresolved item is a matter which requires further information and investigation to determine if it is acceptable or may involve a violation or deviation. Deficiencies will be pursued as an Inspector Followup Item (IFI)-in future routine inspections.

Deficiency - Purchase of Sucerplasticizer As Non-Q Material. Module (IFI 85-28-01) Subsection 4.2, Materials, indicates that superplasti-cizing agents (water reducing admixture used in con-crete) are considered non-Q. Examination of specifi-E

• cation X2AE07, Furnishing Admixtures for Concrete, which

/ is identi fied as Project Class OIC (i.e., safety-I related), indicates that admixtures are to be purchased f and tested as Q materials. Followup of this item

/ indicated that the Superplasticizer Melment, a water h reducing admixture used in the concrete, was purchased

~

as a non-Q material . However, examination of receipt documents did show that the material does meet the standard specification for concrete as specified by ASTM C-494. The statement in the module should have indicated that an error was made in the purchase and

o 14 receipt of the superplastici:er Melment as a non-Q material.

Deficiency -

Retrievability of Records. Review of records ide'ntified (IFI 35-25-02) several examples of problems with missing and misfiled records due to the filing system and lack of retriev-ability. Examples of this proDiem included the finding of the LA abrasion tests for aggregates and cadweld

, A,

/- inspection records by NRC inspectors that were reported

'j ,. . missing by licensee reviewers and the finding of cadweld k, a-tensile test reports filed with concrete strength records. These are examples of a problem concerning the filing and retrievability of records which were identified by the licensee in Section 6.2 of the Module. It is to be noted that the number of missing records are relatively small and other documentation exists to supplement missing records.

Deficiency -

Timeliness of Writino and Addressing a Deficiency (IFI SS-2R a3) Report on Cacweld Failures. Review of Deficiency

.. Report Number DR CD-2276 showed that this deficiency was

,' written in July 1982 to address four cadweld tensile

"'f , , $ . '. '<

/ /' f, , " test failures that had taken place in June and September

+

, , // of 1981. Further review of records did show that a stop work order was issued in September 1981 to address two of the failures and that acditional testing was done.

However, DR CD-2276 did not address the lack of timeli-ness in issuing a DR for these four tensile test failures.

. m iciency -

Accectance of Resconse to Concern Number 3 Without (IFI 35-28-04) Reviewine Revisec Calculations Justifying Resolution of the Concern. Ine incecendent design reviewers accepted the response to Concern Number 3 in Section 7.0 without bgi reviewing tne revisec calculations wnich justifieo tne deviation from ACI .318-71 c de requirements. For this and all similar concerns, the Indeoendent Design Review team should verify the specifics of the response prior to accepting the resolution.

Unresolved Item- Review of Results of Testino performed on Concrete (85-19-01) Matertais by tne Incecencent '_acoratory. Examination of test ::ata by Law Engineering Test Company for air entraining agents (AEA), fine aggregate, coarse aggre-gato and water showed numerous errors in test data results that were not identified by GpC Level II inspec-tors signing and approving the test results.

Unresolved Item-

• Review of Civil Ocen Itee Reoorts. Examination of civil (85-19-02) open item reports on file in the vault disclosed that dispositions and final corrective actions for resolving problems were not indicated on the reports. The inspec-l

)

7 r

[ 15 I

tors could not determine from review of these reports F

whether or not the corrective actions had been complet-ed and whether or not the reports had been reviewed and

[ accepted by engineering.

Unresolved Item- Maximum Allowable Water on Batch Tickets. Review of (85-19-03) batch tickets on concrete pours for cesign mix 411-5 placed between January 1981 and February 1981 showed that the maximum allowable water listed on the tickets exceeded design requirements. Review of the amount of E-water actually used did show that design limits were not exceeded. However, it is felt that this matter should be investigated further to determine the cause of the

_ discrepancy and to determine if a violation of water

[ content occurred in this mix or other mixes.

\ Unresolved Item- Certification of OC Insoectors on Concrete pours (85-19-04) A-118-004 and 008. Review of records concerning the qualifications and certification of QC inspectors involved in concrete placement A-110-004 and 008 dis-f closed the following problems: Records indicate that a c Level I Fresh Tester of concrete on the subject pour failed his requalification test on February 26, 1980, and subsequently had his card revoked. No records were

\. available to' support that the individual was ever redertified. Records indicate that the Batch Plant i Inspector on the subject pour, who evaluated and veri-fied the acceptability of the concrete batch tickets is only a Level I Inspector. ANSI N45.2.6 requires persons evaluating inspection and test results to be certified

- as a Level II or higher.

Unresolved Item- Use of Shear Sars in the Auxiliarv Buildine Base Mat.

(55-28-05) The t.se of sne

r ::a-s in tne a.xiliary but iding case mat deviates from Section 12.13 of ACI 318-71 which is a FSAR commitment. This ceviation from a licensing commitment should haye been identified by the Indepen-dent Design Review team. This issue will be resolved through NRC followup activities.

Resolution of the above listed deficiencies and unresolved items will be g pursued and adoressed in Region II site inspections and inspection reports.

E

?

E M

I

(n 16

5. ' Conclusions Based upon the review within the scope of this module, the NRC has reached the following conclusions for reinforced concrete structures for VogtJe n . Unit 1.

a. Summary of Specific Conclusions With the exceptions of those items / areas discussed earlier, we have~

determined the following to be acceptable:

(1) Commitments - The NRC has reviewed the commitments as listed in Section 3.0 of the Readiness Review Module. We have determined that the licensing commitments and implementing documents comply with the FSAR, the SRP, Regulatory Guides, and industry codes and standards.

(2) Program - The NRC reviewed the description of your program as given in Section 4.0 of the module. The following areas of your program were reviewed:

Design Control Material Procurement Training and Qualifications Fabrication and Installation -

Inspection and Testing We have. determined that your program description in Section 4.0 is generally correct and is in agreement with FSAR and project requirements.

(3) Audit and Special Investigations - We have reviewed Section 5.0~on audits and concluded that this section is an accurate presentation of the audit process and previously icentified construction problems and NRC inspection results.

(4) Program Verification - GPC performed a program verification in the following three parts: design process verification, receipt and construction verification, and a walkdown of concrete areas.

The design process verification examined the implementation of licensing commitments in the design documents. The verification of the procurement and construction processes addressed implemen-tation of 43 construction and 23 procurement commitments and a technical review of construction records. The verification identified fifty-five findings, and these were categorized on the basis of their individual significance and cumulative programmatic effect. The review conducted by the Readiness Review Staff for the design and construction verification program was comprehensive

s

~

17 and adequate. Findings were of minor significance and the resolu-tion of the findings were adequate. Quality records indicated the/ were representative evidence of quality controls for concrete operations and indicated that concrete operations were being o

controlled in accordance with applicable requirements.

The review of this section resulted in some minor program discrep-ancies being identified by Region II inspectors which are included in Paragraph 4 above as deficiencies or unresolved items.

GPC also performed a walkdown of concrete areas to determine the overall condition of the concrete and evaluate the workmanship evident in the concrete surfaces. No in depth evaluation was done as the NRC relied heavily on previous NRC inspections. The inspection reports and documentation relate to the batching, mixing, transporting, and placement of safety-related concrete.

(5) Independent Design Review - GPC contracted an outside organiza-tion, Stone and Webster Engineering Corpcration, to perform an Independent Design Review of the reinforced concrete structures.

This review was performed to assess the technical adequacy of the civil / structural design. This is analogous on a smaller scale to an . Independent Design Verification Program (IDVP) performed by other utilities and accepted by the NRC. With the exception of those items . identified in Paragraph 4, the NRC concluded that the l IDR program for reinforc.ed concrete structures was comprehensive and adequate. The NRC agrees with the findings and their disposi- i tion except for those items listed in Paragraph 4.

b. General Conclusions This module presents an adequate assessment of the GPC process for aesign ano construction of reinforceo concrete structures.

During the review, it was apoarent to the NRC reviewers that GPC management supported the program by their active participation in the development and implementation of the program. Review and evaluation of Module No. I by the NRC indicates that the review performed by the GPC Readiness Review Staff was sufficiently comprehensive in scope and depth to identify problem areas, and that the dispositions of findings were proper and satisfactory, except as noted above. The NRC findings identified as deficiencies appear to be minor and do not represent a breakdown in the quality assurance program. The unresolved items must be evaluated to determine their significance and any subsequent correc-tive actions. The procedures for design, engineering, construction, and cuality control were c:nsistent with commitments and, therefore, acceptable. Based on the review of this module, it appears that construction was performed in accordance with the appropriate proce-dures and re. cords reflect tne quality of that construction.

l l

- , l' 18 Pending resolution of the findings identified above, the NRC finds that the Vogtle Program for the design and construction of Catecory 1 Concrete Structures complies with the Final Safety Analysis Repert and

, that compliance is verifiable with existing documentation.

The NRC furthermore believes that Module .I accurately assesses'the

,, status of design and construction activities for Category I Reinforced Concrete Structures. This conclusion is based on information currently available to the inspectors and reviewers. Should information subse-quently become available which was not considered during this review or previous inspections and which conflicts with earlier information, it i will be evaluated to determine what effect it may have on the above conclusion.

k

%e e

e

~*

UNITED $TATES l

[#C8%q'g' NUCLEAR REGULATORY COMMISSION y' , REGION 11 g j 101 MARIETTA STREET. N.W.

• ATLANTA, GEORGI A 30323 l

\**/

Georgia Power Company OCT 211985 i

, 1 ATTN: Mr. R. J. Kelly Executive'Vice President- I P. O. Box 4545 ~

Atlanta, GA 30302 - '

Gentlemen:

l

SUBJECT:

NRC REVIEW 0F V0GTLE READINESS REVIEW MODULE NO. 3A, INITIAL TEST PROGRAM, PREOPERATIONAL TEST PHASE - REPORT NO. 50-424/85-30 I

Th2 NRC has completed a detailed review, inspection, and verification of the subject Module which you submitted to the NRC on May 14, 1985. Periodic inspec-tions were conducted at the Vogtle site and the resultant findings were discussed with members of your staff at the conclusion of these inspections. Technical reviews were conducted primarily in NRC Bethesda offices and the findings from these reviews have also been di; cussed with your staff.

Areas contained in the module which were reviewed, examined, and verified are i identified in the enclosed report. Within these areas, the inspection and verification consisted of selected examinations of procedures and representative records, discussions with personnel, observations of activities in progress, and review of your licensing commitments. ,

The primary results of Module No. 3A reviews and inspections are provided in the Summary and Conclusions Sections of the enclosed report. Within the Findings Section several deficiencies are identified. Your attention is invited to these mattgrs which will be pursued during future reviews and inspections.

Bastd upon the NRC review and inspection of those activities identified in the.

module, we have determined that the Preoperational Test Program for Vogtle 1 is acceptable and complies with applicable regulatory requirements with the excep-tion of those items or areas identified in the report. . Implementation of the program will be inspected throughout the execution of the test program.

The conclusions within the report are based upon information currently avail-able to the inspectors and reviewers. Should information subsequently become available which was not considered during this review or which conflicts with

earlier information, it will be evaluated to detennine what effects it may have

cn the above conclusion.

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

Sincerely, l

d.

Nelson Grace egional Administrator

Enclosure:

. (See page 2)

EXHIBIT "5"

Georgia Power Company 2 OCT 211985

Enclosure:

R: port No. 50-424/85-30 cc w/ enc 1:

R. E. Conway, Senior Vice President . ,

Nuclear Power l D. O. Foster, Vice President and General Manager Vogtle Project H. H. Gregory, III, General t Manager, Vogtle Nuclear Co'nstruction G. Bockhold, Jr., Vogtle Plant Manager L. T. Gucwa, Chief Nuclear Engineer Ruble A. Thomas, Vice President-Licensing Vogtle Project Ed Groover, Quality Assurance Site Manager C. W. Hayes QA Manager J. T. Beckham, Vice President

& General Manager - Operations J. A. Bailey, Project Licensing  !

Manager George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge.

Ern;st L. Blake, Jr., Esq.

Shaw, Pittman, Potts and Trowbridge James E. Joiner, Troutman, Sanders, Lockerman and Ashmore James G. Ledbetter, Comissioner Department of Human Resources Charles H. Badger, Office of Planning and Budget, Management R; view Division Deppish Kirkland, III, Counsel Office of the Consumer's Utility Council Douglas C. Teper, Georgians Against Nuclear Energy Laurie Fowler, Legal Environmental Assistance Foundation Tia Johnson, Executive Director l Educational Campaign for a Prosperous l Georgia cc: (Cont'd on page 3)  ;

i s

p eo "

OCT 11985 Georgia Power Company 3 Morton B. Margulies, Esq., Chairman Administrative -Judge, Atomic Safety and Licensing Board Panel Dr. Oscar H. Paris, Administrative Judge -

• Atomic-Safety and Licensing Board Panel Gustave A. Linenberger, Jr., Administrative Judge, Atomic Safety and Licensing Board Panel Billie Pirner Garde, Citizens Clinic Director, Government Accountability Project

Atrug UNITED STATES p NUCLEAR REGULATORY COMMISSION j' ' g' 'n REGION 11 g j 101 MARIETTA STREET,N.W.

• ATLANTA, GEORGI A 30323

%,...../

R: port No.: 50-424/85-30

~ '

Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 Construction Permit No.: CPPR-108 Facility Name: Vogtle Unit 1 Reviews Conducted: May 14 - September 6, 1985

On-Site Inspections Conducted

June 10 - 13, 1985; and August 12 - 15, 1985 t NRC Offices Participating In Inspections / Reviews:

Office of Inspection and Enforcement, Bethesda, MD Office of Nuclear Reactor Regulation, Bethesda, MD

Region II, Atlanta, GA i

Reviewers: W. L. Belke, QA Engineer, IE R. A. Becker, Nuclear Engineer, NRR t

W. T. LeFave, Mechanical Engineer, NRR M. R. Hum, Materials Engineer, NRR K. C. Leu, Structural Engineer, NRR H. Balukjian, Nuclear Engineer, NRR C. Y. Li, Nuclear Engineer, NRR

'J. J. Lazevnick, Electrical Engineer NRR F. R.'Allenspach, Nuclear Engineer, NRR J. R. W. Rajan, Mechanical Engineer, NRR R. Pichumani, Mechanical Engineer, NRR J. Wing, Chemical Engineer, NRR A. Serkiz, Task Manager, NRR R. L. Gruel, Pacific Northwest Laboratory, NRR Consultant Inspectors: G. A. Belisle, Reactor Inspector, Region II R. M. Latta,. Reactor Inspector, Region 11 J. F. Rogge, Senior Resident Inspector, Region 11 G. A. Schnebli, Reactor Inspector, Region II l

2

- Approved by: A[ /N  !  ! 5 Mape, Section Chief (/ / Date signed Engineering Branch Division of Reactor Safety Region II - <

lsvw1YSvendo(L HT 5. C yytbn, Acting Chief, '

/0//7/PC Date Signed Procedures and Systems Review Branch Division of Human Factors Safety Office of Nuclear Reactor Regulation 42$

/O / f g,7 P. V. 51nkule, Chief Date Signed Projects Section 20 Division of Reactor Projects Region II p

• 1 1

i i

TABLE OF CONTENTS

. e 4

TOPIC PAGE i

Summary -4 4

Secp2 of Review 5 l Methodology 6 l.. Evaluations 8 Findings 16 i

2 b'

i. Conclusions 18 References 19 i

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1 I

V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM MODULE 3A INITIAL TEST PROGRAM PREOPERATIONAL TEST PHASE 8

SUMMARY

The Readiness Review Program is being conducted at the initiative of Georgia Power Company (GPC) management to assure that all design, construction, and '

operational commitments have been properly identified and implemented at the Vogtle Electric Generating Plant Unit 1. Module 3A, which is the second Module, submitted on May 14, 1985, and the change submittal on July 29, 1985, presents an assessment to ascertain whether the Initial Test Program, Preoperational Test Phase, complies with Final Safety Analysis Report (FSAR) commitments and regula-tory requirements. This evaluation was conducted to determine if the results of the program review of the Preoperational Test Program presented in this Module are an effective and accurate assessment of the requirements, that the require-nents are being properly implemented, and that the resolutions of the findings

) identified in Module 3A were corrected or being corrected.

This evaluation was performed by NRC reviewers from the Offic~e of Nuclear Reactor Regulation (NRR) and the Office of Inspection and Enforcement (IE), and inspec-tors fr6m Region II. The evaluation was accomplished through a detailed review of all sections of the Module by:

1. Verifying that the Preoperational Test Program commitm'nts e identified in the Module are correct and in accordance with FSAR commitments and regulatory requirements.

E 2. Reviewing the Module findings identified by the licensee and evaluating the correctness of their resolution.

3. Reviewing a comprehensive and representative sample of the documents re-viewed by the Readiness Review Staff and an independent sample of documents

.. selected by the inspectors.

During this review, it was apparent to the NRC reviewers and inspectors that GPC management supported the program by active participation in the development and

- implementation of the program. This evaluation also indicates that the licensee's i program review for the preoperational test phase was comprehensive and provides adequate assurance that plant components and systems will be tested in accordance with NRC requirements and FSAR commitments except for several deficiencies which

were identified by the NRC reviewers and inspectors. A deficiency is considered to be an item having minimal safety significance, but one which should be evaluated by the applicant to determine what' action could be taken to

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+ .

5 correct the item and thus preclude the possibility of the development of safety 4

' problems. The findings identified during this evaluation are summarized below:

• Deficiency - Verify Completion of Georgia Power Company QA Audit of the 35 Findings Associated with Module 3A.- e

• Deficiency - List Regulatory Guide 1.95 as a Commitment in Module 3A

• - Deficiency - Limit Reference to Regulatory Guide 1.68 to Module Appropriate for Applicable Test Phase.

. Deficiency - Amend FSAR Concerning Leak Rate and Vibration Testing (five items).

i

• Deficiency - Add General Statement to Future Modules Applying Appropriate QA Controls.

• . Deficiency - Include Commitment to the Code and Standards Rule 10 CFR 50.55a in Module 16 and Response to Q210.47 in Module 7.

It does not appear that these deficiencies represent significant programmatic w aknesses. Details on these ' items are discussed in Section.4 of this report.

Resolution of these items will be handled during future Region II inspections.

Icplementation of the preoperational test program will be inspected during future i '

Region II inspections. This prograa is expected to require approximately 18 months to. complete. .

4

1. Scope of Review This review, which consisted of an examination of each section of the '

Module, was performed by reviewers from NRR, IE, and inspectors from Region II. The scope of the NRC review and the subsequent NRC findings were limited due to the extensive amount of unapproved implementing procedures referenced in this Module. The NRC inspection program will be performed by

. Region II to complete review activities. in the implementation of the l

preoperational test phase prior to licensing.

GPC performed a program verification to ascertain that the preoperational test phase was properly implemented. The program was conducted in three

, parts: verification of commitments, verification of commitment implementa-tion, and a field verification to identify potential problems. The process utilized eight team members and expended approximately 2000 staff hours to

examine the implementation of approximately 700 commitments.

Module Sections 1.0, 2.0, 5.0, and 7.0, which contain information concerning the Module introduction, company organization, division of responsibility, interfaces, audits, special investigations, and conclusions regarding the assessment of the Module, 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, 4.0, and 6.0. These sections discuss applicant i commitments, method of implementing commitments, administrative controls during the test program, scheduling, program implementation and program

6 verification. Review of these sections included a detailed review of the content, examination of items identified as findings, an examination of a sample of documents reviewed by the GPC Readiness Review Staff, and an examination of independently selected sample of documents. .

The scope of the review by NRR predominantly covered the commitment matrix and any impacts the other sections of the Module might have with respect to these commitments. Although NRR - Procedures and Systems Review Branch

, (PSRB) - had the major portion (287 of 391 commitments) of the test program

. review, there were some areas associated with the initial test program where other Branches had primary review responsibility as delineated by the Standard Review Plan (SRP). These areas are noted below and were reviewed by the responsible Branches indicated.

1. Vibration, thermal expansion, and dynamic movement testing covered under SRP Section 3.9.2 were evaluated by the Mechanical Engineering Branch (MEB).

2. Testing of American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components and supports, covered by SRP 3.9.3 were reviewed by MEB.

3. Containment Leakage testing covered by SRP Section 6.2.6 was reviewed by Containment Systems Branch (CSB).

4. Electrical system testing. covered by SRP sections 8.3.1 and 8.3.2 were evaluated by the Power Systems Branch (PSB).

5. Administrative procedures used to develop, review, and approve test procedures' covered by SRP Section 13.5 were reviewed by Licensee Quali-fications Branch (1.08).

6. Administrative procedures governing the review, evaluation, and approv-al of initial test program testing, covered by SRP Sections 13.5 and 17.2 were reviewed by LQB and the Quality Assurance Branch (QAB),

respectively.

2. Methodology The NRR review of Module 3A was conducted in two phases.

Phase I of the review consisted of a comparison of the commitments listed in Section 3.4 of the Module, Commitment Matrix, with the guidance contained in )

SRP Section 14.2, Initial Plant Test Program. This phase of the review l consisted of two parts: conformance with approved FSAR Chapter 14 preopera-tional test abstracts, and conformance with PSRB requests for additional information pertinent to the preoperational test program. This ensured that all commitments necessitated by the SRP were included in the Readiness Review.

Phase II of the review consisted of a comparison of the coinmitments listed in Section 3.4 of the Module with the source FSAR Section listed for each commitment. This phase of the review included the same areas identified in Phase I plus those FSAR sections identified by the matrix as containing i

__ _ - - ~ - - - , - ---

1 1

7 l preoperational testing commitments. Each identified commitment was reviewed for appropriateness and applicability to the preoperational test phase. l As a product of this ' review process, several apparent errors or. omiss. ions were identified. These items were either discussed with or forwarded to the applicant in the form of questions to be answered (Reference 2). The applicant satisfactorily responded to these ques-tions (References 1 and 3) and modified the commitment matrix or committed to revising the FSAR to provide an acceptable NRR/IE scope of the commitment matrix.

The review and evaluation by Region II inspectors was accomplished by reviewing the Module in its entirety in the Region II Office beginning on May 14, 1985, and by inspections at the Vogtle site on June 10 - 13, 1985 (Inspection . Report No. 50-424/85-24) and August 12-15, 1985 (Inspection Report No. 50-424/85-41). Section 1.0, Introduction, which presents an

introduction to the intent and content of .the Module and Section 2.0, Initial Test Program Organization and Division of Responsibility were only reviewed'fo'r general content and needed background data.

Review of Section 3.0, Commitments, was accomplished in two parts. The commit. ment matrix. was briefly reviewed by Region II personnel since NRR performed this review as previously discussed. Review of the implementation 5 matrix concentrated on verification of the preoperational test phase commit-

ments and the?r corresponding implementing documents. The commitment sources reviewed included the FSAR, the Safety Evaluation Report (SER),

Regulatory Guides, American National Standard Institute (ANSI) standards, and the ASME codes. -

Review of Section 4.0, Program Description, was accomplished by examining the three subsections and comparing the program description with regulatory l requirements. Section 5.0, Audits and Special Investigations, was-reviewed for general content as this section contains a description of the audit program and the INP0 evaluation of the preoperational test program. The

inspectors reviewed the seven audits conducted by the Quality Assurance Department of test program activities as well as the audit schedules for 1985 and 1986. Audit findings identified in subsection 5.2 were not exam-ined in detail because similar type findings were examined and evaluated in the review of Section 6.0.

i Review of Section 6.0, Initial Test Program Preoperational Test Phase Verification, centered around Subsection 6.2, Findings, Responses, and Corrective Actions. In Subsection 6.1, Verification Scope and Plan, the inspectors reviewed the established verification process as well as inter-viewing licensee personnel that were directly involved in the findings, responses, and corrective actions of the readiness review. Additionally, the inspectors reviewed the five verification checklists used by GPC during the readiness review of procedures. Review of Subsection 6.2 was accom-

-plished by reviewing and examining the corrective actions associated with the resolution of the 35 Readiness Review Team findings which included examination of records, implementing procedures, industry standards, and FSAR commitments associated with the items identified in the findings.

1

, l 8

, [-

981ew of Section 7.0, Assessment, was reviewed primarily for content and fen kground information. Subsection 7.1, Summary of Open' Corrective Actions, '

was reviewed in conjunction with Subsection 6.2.

3. _ Evaluations -

The evaluation of each section reviewed ,is provided below. For ' each sec-tion, a description of the section, what was reviewed, and the basis of i.; , acceptance.is provided. . t _

a

a. Section 1.0 - Introduction p/ -

. Th'ik section of the' Module presents an introduction to the intent and

's content of thh Module organization, areas of evaluation, and status of

~ the project. ' This sect. ion was reviewed primarily for content and background information. No. additional followup'or evaluation of the section was required.-

-b. Section 2.0 - Oraani ation and Division of Responsibility This section presents.a description of_the organization and divisicn of

. , responsibility of Georgia Power Compafy, Bechtel, and Southern Company Services for their role in the In1Lial Test Program. This section of

'J<+ the Module was reviewed for content' only. No additional followup or

' evaluation of this section was required. _,r l ,

w

c. Section 3 0 - Commitmints 4

m (1) This section of the Modu.le contains a listing _of commitments and

,. A' implementing-documents which are presented in two matrices. The first matrix is the commitment matrix whicn contains a listing of

~

the sources and subject of the applicants commitments. Commit-ments listed in this natrix were identified by .the Readiness Review Staff through 4 review of the FSAR, responses to NRC questions,- responses to generic ' letters, and responses to IE letters. The second matrix ~ is the implementation matrix which cor;tains 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. ,

i s

.,(2) NRR reviewers' and Region II inspectors' review and evaluation of-this section was performed by comparing licensing commitments and

- corresponding source documents -with the SRP, Regulatory Guides,

'ihe provisions of the . industry codes and standards, the NRC-question and answer records, -the staff's SER and the FSAR docu-

.~ . ments. The review also included a review of commitment sources

_ a:.d implementing procedures to verify that the FSAR commitments were being correctly implemented in project documents. Region II 3} '

l y review of the - implementing procedures mainly centered around

!/

review of the Startup Manual (SUM) in regards to the program, as N l' m

! 4

9 the majority of the preoperational test procedures were not completed at the time of the inspection. Review of the program is discussed in paragraph 3.d below. Inspection of program implemen-tation ~will be accomplished throughout the test program dyring routine and special Region II inspections '(see inspection Report No. 50-424/85-24).

(3) When applying the review methodology described above, the staff concluded that the commitment matrix included most of the regula-tory guidance and staff positions for the scope of review.

However, in the course of the review, the staff found two catego-ries of deficiencies: (a) omitted commitments and (b) incorrectly

. or inappropriately identified commitments resulting from a variety of causes or commitments where further clarification was required.

Following is a discussion of these items:

(a) Evaluation by PSRB Questions The apparent omissions were formulated as questions and forwarded to the applicant for response. The apparent omitted commitments were:

FSAR Subsection 1.9.95 (Regulatory Guide 1.95, Protec-tion of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release).

FSAR Subsection 14.2.8.1.20 (Boron Thermal Regeneration System).

FSAR Subsection 14.2.8.1.112 (Main Turbine System).

FSAR Subsection 14.2.8.1.113 (125-Vdc Class 1E Minimum Load Voltage Verification).

FSAR Question 640.3 (Loss of Air Tests on Safety-Related Pneumatically Operated Valves).

FS'AR Question 640.6 (Completion and Approval of Test Results of All Preoperational Tests Prior to Initial Fuel Loading).

These apparent errors in structure or' annotation were formu-lated as questions and forwarded to the applicant for re-sponse. The apparent errors were: ,

l l -

FSAR Subsaction 1.9.68 commitment (3206, p. 5) remarks l l should be deleted as they are in reference to startup j

l. (not preoperational) test exceptions. l l- l l

10 FSAR Subsection 3.1.4, Criterion 37 commitment (3219,

p. 7), states that ECCS functional tests are performed with the pressurizer water level below the safety injection (SI) signal setpoint. This test is no longer applicable as the pressurizer water level SI setpoint has been removed (FSAR Table 7.3.1-1). l

)

FSAR Subsection 6.3.4.1 commitment (2675, p.16) refer - \

ences emergency diesel generator testing. The test items in this section are not all related to the emer-gency diesel generators and do not address specific tests. This commitment is misstated and should there-

, foreibe reworded or deleted.

FSAR Subsection 8.3.1.1.3.H.3.k commitment (3263, p. 20)

+

should be deleted as switching from one diesel fuel oil 3 supply system to another is not part of the normal '

operating procedure to satisfy the 7-day storage re-quirement (FSAR Subsection 9.5.4.2) as contained in Regulatory Guide 1.108, Periodic Testing of Diesel l Generators Used as Onsite Electric Power Systems at  !

Nuclear Power Plants.

FSAR Subsection 9.4.9.2.4 commitment (2714, p. 25) incorrectly addresses testing of the Auxiliary Steam '

System. This corte. ment should be deleted as this FSAR section addrenes the Electrical Tunnel Ventilation System (co N t sci 2727, p. 25). Testing of the Auxil-iary Steaa 4:0 is described in FSAR Subsection 9.5.9.4 (cu.aitn+. 2720, p. 25) .

Resolution

.The applicant responded with corrections in an addenda s to -the Commitment Matrix, Section 3.4, and other sec-tions (Reference 1). These corrections provided suffi-cient information to resolve the above questions with the exception of the following minor clarifications:

The applicant stated that a commitment to Regulatory ~

Guide 1.95 is included in Module 7A, Plant Operations.

It shoulo' also be listed as a commitment in Module 3A, Initial Test Program. (IFI 85-30-01)

The applicant stated Regulatory Guide 1.68 is applicable to both Module 3A, Preoperational Test Phase, and 3B

'Startup Test Phase, and that the same entry will appear in both Modules. The remarks in each Module should be limited to those appropriate for each test phase.

(IFI 85-30-02) y

11 (b) Evaluation by CSB Questions The following clarifications were pequested by CSB" in Reference 2.

It is not clear why fan operation during the Integrated Leak Rate Test (ILRT) is necessary for their protection.

This is counter to current ILRT practice. It is also not clear whether cooling water flow will be terminated during the ILRT. The impact of fan-cooler operation on stabilization of test conditions should also be evaluat-ed (page 13, commitment 3276).

The leakage rate that should be compared to 0.75 La is the upper confidence limit based on the statistical methodology of either BN-TOP-1 or ANSI /ANS 56.8 1981.

The commitment should be more precisely stated to reflect this (page 14, Source Item 4340).

This is a commitment to test all Containment Isolation Valves (CIVs) in the Type C test program individually.

Allowance should be made for the fact that with appro-priate justificatibn, series isolation valves may be leak teste.d simultaneously. The test fluid is a gas (usually air), unless the cbjective is to demonstrate the presence of a water seal that will preclude contain-ment atmosphere leakage under accident conditions, in which case the test fluid is water. Those CIVs to be excluded from the Type C test program would be identi-fied and appropriately justified (i.e., approved by the staff) (page 15, commitment 3285 and 3286).

A commitment to pressurize the Steam Generators (SGs) above containment ; ressure for the ILRT is not accept-able. The secondary side CIVs are not Type C tested because it is judged by the staff that they are not potential containment atmosphere leak paths. This implies that the SG shell/ piping (the first isolation barrier under GDC 57 criteria) has exceptional leakage integrity. For the ILRT, then, the SG air space should l be atmospheric pressure to include the closed system (viewed as an inward protrusion of the containment i boundary) in the ILRT (page 15, commitment 3287). i l

Resolution The applicant responded with proposed corrections to the i FSAR in Reference 3. The corrections in Reference 3 are 1 acceptable responses to the questions raised above by the '

l e-12 staff. The corrections are listed in Section 4.0 of this report under Findings. The licensee will make these corrections to the FSAR and the commitments will be verified in the NRC plant review. The commitment matrix in Readiness Review M6dule<3A will not have'to be revised to incorporate these FSAR changes. (IFI 85-30-03, 85-30-04, 85-30-05, and 85-30-06)

(c) Evaluation by MEB Question The following omission was cited by MEB in Reference 2.

"The applicant's response to Q210.47 relative to the preservice examination. of snubbers is not included in the Module 3A commitment Matrix."

Resolution The applicant's response in Reference 3 states that the commitment for preservice examination (inspection) is assigned to Module 7, Plant Operations and Support. The readiness review verification program for Module 7 is complete and the implementation of th'e commitment for preservice examination was addressed. The verification review found that the commitment for preservice examina-tion was being addressed in draft copies of nuclear operations engineering support procedures. These draft procedures included all of the requirements contained in the re.sponse of FSAR Q210.47 relating to preservice examination of snubbers.

The applicant's response is satisfactory and this commitment will be verified in the review of Module 7.

(IFI 85-30-09)

Question A d' iscrepancy was identified in commitment 3231 (Piping Vibration, Thermal Expansion and Dynamics Effects). The commitment as stated in the Module is as follows. "If steady-state vibrations are observed during initial operations maximum amplitudes are measured. Acceptance criteria-maximum amplitude shall not induce stress in piping greater than 1/2 limit (ASME III) (3.9.B.2.1)."

Resolution As a result of a telephone conversation with the appli-cant on June 18, 1985, the applicant agreed to revise the FSAR to provide criteria that are consistent with the ANSI /ASME OM-3 standard " Requirements for

13 Preoperational and Initial Startup of Vibration Testing of Nuclear Power Plant Piping Systems." The applicant agreed to document the changes and incorporate them in FSAR Amendment 17. The commitment will be verified in the NRC plant review. The coenmitment matrix "in Readiness Review Modu?e 3A will not have to be revised to incorporate these FSAR changes. (IFI 85-30-07)

Question Omission- of the commitment to the Code and Standards Rule 10 CFR 50.55a was brought to the attention of the applicant in a telephone conversation of September 10, 1985.

Resolution The applicant responded that this commitment more appropriately belongs in Module 16 -

Nuclear Steam Supply System and agreed to include it in that Module.

The staff agreed to this action. (IFI 85-30-09)

(d) Evalaution by QAB Question A general question, raised by QAB in Reference 2, was why certain quality assurance' guides were not cited in the commitments to this matrix.

Response

The applicant's response in Reference 3 states that the guides listed in the Module 3A commitment matrix are those deterinined to' be most applicable to the Initial Test Program, Preoperational Test Phase; other QA guides will be included in other readiness review Modules as appropriate. The applicant has committed, in Reference 3, to include a general statement in each Module that would apply the appropriate quality assur-ance controls, including the FSAR referenced quality related Regulatory Guides, exceptions and alternatives thereto to those activities expressed in each Module.

This statement would apply to the program in general and to each Module submitted including all previously submitted Modules. Modules that have been issued (or are in printing) do not have to be revised to include this . statement. The staff finds this acceptable.

(IFI 85-30-08)

14 Review of this section by the reviewers and inspectors showed. except as noted above, that the Vogtle licensing commitments and implementing documents comply with the FSAR, the SRP, Regulatory Guides, and indus-try codes and standards. ,

d. Section 4.0 - program Description (1) This section of tne Module describes the initial test program in detail, including administrative controls, scheduling, and the activities associated with the preoperational test phase.

(2) Review of this section by Region II inspectors included a detailed examination of the three subsections and a comparison of the program description with FSAR requirements. In ' addition, an in-depth review of the Startup Manual and applicable sections of the Plant Administrative Procedures Manual was performed as these documents implement the program requirements.

The areas covered in the overall preoperational test program review included the following:

Verification that the applicant has prepared a detailed description of the preoperational test program.

Verification that the test organization is clearly defined including qualifications, responsibility, lines of authority, and definition of interfaces between organizations.

Verification that formal methods have been established to administer the test program.

Verification that formal measures have been establishedW" control the test procedure process including preparation, review, approval, issuance, and revision.

Verification that a formal program has been established to control design changes and modifications during the test program, including temporary modifications, jumpers and bypasses.

Verification that a program has been established to control maintenance during preoperational testing.

Verification that a program exists for general housekeeping activities, including equipment protection, cleanliness and water chemistry controls.

Verification that controls have been established for test and measurement equipment to be used throughout the test program.

15 Verification that training requirements have been established for personnel involved in the test program.

(3) rogram described.in the Review subsections of this section and is correct indicated that.the ascertains thatp,the overall administra-tive controls for the preoperational test phase have been devel-oped in accordance with FSAR commitments and regulatory require-ments. No findings were identified during the review of this section.

e '. Section 5.0 - Audits and Special Investigations.

(1) This section contains a discussion of the QA audit program, completed audits, and special inspections performed by INPO.

(2) Review of this section included a . review of the two subsections and of seven audits conducted between September 17, 1984 and June 27, 1985. The corrective actions required by INPO evalua-tions were reviewed to ensure adequacy. During the audit review, it was verified that an approved audit checklist was used, that audits were issued as procedurally required, and that corrective action was planned or had been completed for audit findings.

(3) Review of this section indicated that it is an accurate presenta-tion of the audit process.

f. Section 6.0 - Program Verification (1) This section discusses the methods used to verify conformance to ,

the preoperational test program requirements. The section is 4

comprised of two subsections. Subsection 6.1 covers the identifi-cation of commitments, and development of the verification plan and scope. Subsection 6.2 discusses the findings, responses, and corrective actions.

(2) Region II inspectors reviewed the established verification pro-cess. Personnel directly involved in the process were inter-viewed. Additionally, the five verification checklists used by GPC for confirming the stated commitments and listed procedures were reviewed for completeness. The inspectors reviewed each verification process finding and the proposed corrective action for these findings. The proposed corrective actions were judged to be adequate. Corrective action completion was not verified a~s this had not been completed at the time of the inspection. An

. audit is scheduled by the GPC operations QA group .to verify corrective action completion. One Inspector Followup Item (IFI 85-41-01) was identified pending QA completion of this audit and this is discussed in paragraph (3) below.

I i

16 (3) NRC review of Section 6.0 indicated that the review conducted by the GPC Readiness Review Team for the preoperational test program wis comprehensive and adequate. Examination of the findings indicated that they were of minor si_gni fi that the proposed corrective action for the findings,cance was and sufficient. One area of concern was identified in .the review of this section.

Subsection 6.2, contains a list of findings, responses, and corrective actions identified by the readiness review team during

__the preoperational test phase verification. Corrective action for these findings was in process or had been completed and the findings are being tracked by GPC operational QA personnel. An audit has been scheduled to verify corrective action adequacy and completion but, as of this review, the audit had not been started.

Until operations QA have conducted this audit and verified cor-rective action completion, for the readiness review team findings, this item will remain open and is identified as Inspector Followup Item 424/85-41-01.

g. Section 7'.0 - Assessment This'section contains the statements addressing the independent assess-ment of the Module by Georgia Power Company Quality Assurance, Stone

- and Webster Engineering Corporation, the General Manager for Nuclear Operations, the Initial Test Manager, and the Readiness Review Board.

This section was reviewed for content only. No additional followup or evaluation is required.

4. Findings The following findings were identified from the reviews by NRR and IE.

reviewers ; and . Region -II inspectors. The - findings are identified as a deficiency which'is considered as an item having minimal safety significance but one that should : be evaluated further to preclude safety problems.

Deficiencies will be pursued as an Inspector Followup Item (IFI) in future routine inspections.

i Deficiency - Review of Section 6.2 showed that the corrective actions (IFI 85-41-01). for the Readiness Review Teams findings were not yet complete. A QA audit was scheduled to veri fy - the adequacy and completion of the corrective action; however, at the time of this review, the audit had not commenced.

I l Deficiency - The applicant. stated that a commitment to Regulatory l

(IFI 85-30-01) Guide 1.95 is included in Module 7A, Plant Operations.

It should also be listed as a commitment in Module 3A, Initial Test Program.

17 Deficiency -' The applicant. stated Regulatory Guide 1.68 is (IFI 85-30-02). applicable to both Module 3A, Preoperational Test Phase, and 38, Startup Test Phase, and that the'same entry will appear in both Modules. The reparks in each Module-should be limited to those appropriate for each test phase.

Deficiency -- The FSAR will be revised to delete the statement that (IFI 85-30-03) "the containment fan coolers are protected by operating -

them throughout the duration of the ILRT." (commitment 3276)

Deficiency - The FSAR statement will be revised to say, "The measured (IFI 85-30-04) leakage rate shall be less than 0.75 of the maximum

, allowable leakage rate value La. " In addition, the FSAR will be revised in 6.2.6.1 to say, "The actual leakage rate will be determined by using the methods and re-quirements of Appendix J to 10 CFR 50 and ANSI /ANS 56.8,

. 1981." (commitment 4340)

Deficiency - The FSAR will be revised to read as follows: "Contain (IFI~85-30-05) ment isolation valve leakage is determined in accordance with the requirements of 10 CFR 50, Appendix J and

ANSI /ANS 56.8, 1981 for Type C testing. The leakage will be measured in the same direction as would occur in an accident, unless it can be determined that leakage measured in a different direction will provide an equivalent or more conservative results. The test medium used for pressurization is determined by the valve's post-accident condition. All valves which could be exposed to the containment atmosphere subsequent to an accident will be tested with air or nitrogen. ' Valves which are in lines designated to be filled with a liquid for at least 30 days subsequent to an accident may be leakage rate tested with water." (commitment 3285 and 1

3286).

Deficiency - The FSAR statement will be changed as follows: "The (IFI 85-30-06) secondary side of the SGs is subjected to Type A tests

, as shown la Table 6.2.4-1". (commitment 3287).

Deficiency - The FSAR will be revised to provide criteria that are

-(IFI 85-30-07) consistent with the ANSI /ASME OM-'3 standard " Require-ments for Preoperational and Initial Startup of Vibra-tion Testing of Nuclear power Plant Piping Systems."

( This FSAR change has resulted from the review of commit-ment 3231.

i

• f

l 1

i 18 4

)- l

Deficiency - The applicant agreed in Reference 3, to include a (IFI 85-30-08) '

general statement in each Module that would apply the appropri.ite quality assurance controls including the FSAR referenced quality relate,d .repulatory guides,..

exceptions and alternatives thereto tb those activities expressed in each Module. This statement would apply to the program in general and to each Module submitted.

Modules that have been issued (or which are in printing)' ,

do not have to be revised to include this statement.

Deficiency - The applicant agreed to include the commitment to (IFI 85-30-09). the Code and Standards Rule 10 CFR 50.55a in Module 16 and.has stated that the response to Q210.47 with regard to preservice examination of snubbers has been included in Module 7. These commitments will be pursued in the

. review of Modules 7 and 16.

The commitments for the five FSAR changes do not have to be revised in Module ~3A. They will be verified in the normal plant review after the FSAR changes are submitted. Resolution of the above listed findings will be followed and addressed in Region II site inspections and documented in inspection reports.

$. Conclusions Based upon the review within the scope of Module 3A, Initial Test Program, Preoperational Test Phase, which is in an early stage, the NRC has reached the following conclusions for preoperational test phase for Vogtle Unit 1.

(1) The Vogtle licensing commitments and other sections in the Module-scope have demonstrated compliance with the FSAR and applicable sections of staff documents such as the SRP and Regulatory Guides.

The technical findings and the associated corrective actions taken to confirm the technical adequacy of the Preoperational Phase of the l Initial Test Program are acceptable to the staff. Therefore, the staff concludes that the reviewed scope of Module 3A of the Vogtle Electric Generating Plant Readiness Review Program is acceptable.

(2) The . review conducted by the GPC Readiness Review Staff for the preoperational test phase verification program was comprehensive and adequate. Findings were of minor significance and the resolu-tion of the findings adequate, however, some of the corrective actions for'the findings remains to be completed.

(3) During - the review, it was apparent to the NRC reviewers and inspectors that GPC management supported the program by their active participation in the development and implementation of the program'. Review and evaluation of Module 3A. by the NRC indicates j_ that the review performed by the GPC Readiness Review Staff was i

sufficiently comprehensive in scope and depth to identify problem

(

I

. l

19 areas, and that the dispositions of findings were proper and satisfactory, except as noted above. The NRC findings identified appear to be minor and do not represent a breakdown in the program. , ,.

(4) The procedures and documents for the preoperational test phase were consistent with commitments and, therefore, acceptable.

Pending resolution of the findings identified above, the NRC finds that the Vogtle program for the preoperational test phase complies with the Final Safety Analysis Report and that compliance is verifiable with existing documentation. Implementation of the preoperational test phase will be inspected in future Region II inspections.

These conclusions are based on information currently available to the inspectors and reviewers. Should information subsequently become available which was not considered during this review or previous inspections and which conflicts with earlier information, it will be evaluated to determine what effect it may have on the above conclusion.

6.

REFERENCES:

1. Letter to NRC, Region II, J. Nelson Grace, from D. O. Foster, Georgia Power Co.,

Subject:

Vogtle Electric Generating Plant Unit 1, Readiness Review Program Module 3A - Change Submittal, July 29, 1985.

2. Letter to Georgia. Power Co. , R. J. Kelly, from Roger D. Walker, NRC-Region II,

Subject:

Vogtle Readiness Review - Interim Review Questions - Module No. 3A " Initial Test Program - Preoperational Test Phase" dated September 3, 1985.

3. Letter to NRC, Region II, J. Nelson Grace, from D. O. Foster, Georgia Power, Co.,

Subject:

Response to Vogtle Readiness Review Interim 4

Review Questions - Module 3A. File: X780102, dated October 3, 1985.

I

UNITED STATES NUCLEAR REGULATORY COMMISSION J*[po secg%,$

REGION 18 y '*' g 101 MARIETTA STREET.N.W.

• ATLANTA. GdORGI A 30323 4v

.....,/ October 25, 1985 Gesrgia Power Company ATTN: Mr. R. J. Kelly . -

Executive Vice President -

4 P. O. Box 4545 Atlanta, GA 30302 ,,

Gentlemen:-

SUBJECT:

NRC REVIEW OF V0GTLE READINESS REVIEW PROGRAM, APPENDIX I, PROJECT QUALITY ASSURANCE ORGANIZATION - REPORT NO. 50-424/85-31

• Th2 NRC has completed a detailed review, inspection and verification of the subject appendix which was submitted to the NRC on May 24, 1985. Inspections l

wara conducted at the Vogtle site and our findings were discussed with members of your staff at the conclusion of these inspections.

Areas contained in the appendix which'were reviewed, examined, and verified are id:ntified in the enclosed report. Within these areas, the inspection and v3rification consisted of selected examinations of procedures and representative rccords, discussions with personnel, observations of activities in progress, and review of your licensing commitments.

The results of Appendix I reviews and inspections are categorized in the enclosed report as deficiencies or unresolved items. Your attention is invited to these matters which will be pursued during future licensing reviews and inspections.

Based on the NRC review and inspections of these activities identified in the appendix, we have determined that your comitments, program, and implementation are acceptable with the exceptions of those items or areas identified in the rcport summary. This decision was based upon information currently available to the inspectors and reviewers. Should information subsequently become available which was not considered during this review or which conflicts with earlier information, it will be evaluated to determirle what effects it may have on the absve conclusion.

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

Sincerely, L a %ke. /h Nelson Grace i

egional Administrator 0

Enclosure:

Report No. 50-424/85-31 cc w/ encl: (See page 2)

EXHIBIT '6 "

' Georgia Power Company 2 October 25, 1985 l

cc w/ encl:

4 R. E. Conway, Senior Vice President ,

Nuclear Power D. O. Foster, Vice President and General Manager Vogtle Project H. H. Gregory, III, General Manager, Vogtle Nuclear Construction .

k G. Bockhold, Jr. , Vogtle Plant Manager L. T. Gucwa, Chief -

Nuclear Engineer '

L .R'uble A. Thomas,

~Vice President-Licensing Vogtle Project Ed Groover, Quality Assurance Site Manager C. W. Hayes, QA Manager J. T. Beckham, Vice President '

. & General Manager - Operations 4

J. A. Bailey, Project Licensing Manager George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge j Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge Ern:st L. Blake, Jr., Esq.

Shaw, Pittman, Potts and Trowbridge James E. Joiner, Troutman, Sanders, Locker 1 nan and Ashmore l James G. Ledbetter, Comissioner Department of Human Resources Charles H. Badger, Office of Planning and Budget Management R2 view Division Deppish Kirkland, III, Counsel Office of the Consumer's Utility 1 Council ~

Douglas C. Teper, Georgians Against Nuclear Energy

' Laurie Fowler, Esq., Legal Environmental Assistance Foundation Tim Johnson, Executive Director.

Educational Campaign for a Prosperous l

Georgia l Morton B. Margulies, Esq., Chairman Administrative Judge, Atomic Safety and Licensing Board Panel Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel Gustave A. Linenberger., Jr., Administrative Judge, Atomic Safety and Licensing Board Panel Billie P. Garde, Citizens Clinic Director, Government Accountability Project

UNITED STATES

,[SA af og'#o NUCLEAR REGULATORY COMMISSION

',' REGION ll O'

• j .

101 MARIETTA STREET.N.W.

• e ATL ANT A. GEORGI A 30323

=

%,*.w..*/

4 Report No.: 50-424/85-31 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.- CPPR-108 Facility Name: Vogtle Unit 1 Inspection Conducted: July 22-26 and August 5-9, 1985 Inspectors: krl/Y i . I', - ',. /$/6 /.*/

0' ate' Signed L. H. Jackson C '/ /

/  : . j i f' t~, ./ y, ,, i - / j'.if i -

R. W.' Wright cN / Date Signed Approved by: // <, /, e

• n /'4,b.:

G. A. Belisle,7 tting Section Chief Dite Signed Division of Re tor Safety

/ '

U lo 3 5'S M. V. iinkule, Chief, Projects Section 20 Date' Sighed Division of Reactor Projects EXHIBIT "5"

TABLE OF CONTENTS Topic Page p Summary 1 Scope of Review 2 Methodology 3 Evaluation 3 Findings 10 C nclusions 11 h

~

~

s /

V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS' REVIEW PROGRAM

'

• APPENDIX I

-PROJECT QUALITY ASSURANCE ORGANIZATION e

a

SUMMARY

r evaluation of Apoendix I of the Vogtle Readiness Review

- This report is an

_P ro g r *.m . This program is being conducted as an initiative of Georgia Pe.wer P Company (GpC) management to assure that all design, construction, and operational

, commitments have been properly implemented at the Vogtle Electric Generation Plant' Unit 1. Appendix I, which is one of an anticipated eleven appendices,

presents an assessment of the program implemented by the Project Quality Assurance -(QA) Organization for design, construction and operations. This evaluation was conducted to determine if the results of the program review on the

! Project-QA Organization presented in this appendix are an effective and accurate L assessment of design, construction, and operational requirements, that these t' r quirements are being properly implemented, and that the resolutions of findings i, idehtified in the appendix were correct.

! This evaluation was performed by NRC inspectors from Region 'II. The evaluation was accomplished through a ' detailed review of all* sections of the appendix by:

1) verifying that the_ design and construction commitments listed in the appendix.

- are correct: and comply with Final Safety Analysis Report (FSAR) requirements;

2) rev_iewing the appendix findings and evaluating the correctness of their

! rasolution; 3) reviewing a comprehensive and representative sample of the records

- rGviewed ' by the Readiness Review Staff (RRS)'; 4) selecting and reviewing a ccmprehensive and representative random sample of records concerning QA audits;

and 5) review of prior inspection activity in this area.

i

! During the review, it was apparent to the NRC inspectors that GPC management i -supported the program by active participation in the development and implementa-l tion' of the program. This evaluation also indicates that the licensee's program raview Lof the Project QA organization was comprehensive and that the subject pr: gram complies with NRC requirements and FSAR commitments. Some programmatic

~

[ discrepancies were identified by the NRC inspectors. These items are classified as ' deficiencies or unresolved items. A deficiency is considered to be an item having minimal safety significance, but one which should be evaluated by the licensee to determine what action could be taken to correct the item and thus L. preclude the possibility of the development of safety problems. An unresolved

. item is a matter which requires further information and investigation to i

d: termine if_ it is acceptable or may involve a violation or deviation. A listing of the deficiencies and one unresolved item identified during this evaluation is summarized below:

- *- . Deficiency -

Update of Final Safety Analysis Report C. Deficiency -

Unavailable Early Procedure Revisions

• Unresolved Item -

Retrievability of QA Audit Records

l.

2 3:a.ed in A; encix I, F cje:: Cuali.3 As s ra :e Organ':a:ior. :nis arre :'>

Mevelo by five personnel; all having b-cad cactgreeds in cuality gra7:e ped coality centrol, anc nuclear peser riant a::ivities. The a::Lal  !'

ncix verification was conducted by four of tnese five personnel on < J kl11-19, 1955. An arrencix veri'i:ation che:Uist was used curing this v '. t y . Tne verification censisted of feur gnases. Pnase I cete triced isten:y between the wording of six selected G2 CA De;artment prececures and itnert seu :es. Dnase II cete-cined that-37 GO: cens: u:-'en and cre-a:icnal at anc 50 au:it fin:'ng cere-:s compiied wi tr tre imple-er:ation of R;:le e:t ::.= i tne-t s ar.d p e-e: abi'shed p *:: Ed re s . Phase III deternir.ed 5 i ening 49 au:its of centrac:gr5 w'th neir own OA p rog ra:"s trat G?C had l ted ali aspropriate elements of tne subcast-actor site QA p. cgrams. Prase fete-mined by resiewing 33 aJCits Cf b0utne"n CC.9?any Services and in;heJse that these OA pr;;-a rs nere in ;- plian.e nith their programi a".d

<edure s ,

d on this four phase resiew, six findings we.re identified. Inree fincings eventually detern'ined to be nea-findings based on additional information ia:d. Tne remaining inree finoings were cetermined to be two minor ations from procedural requirements and one case needing enhancements to QA

,rtment procedures.

inspectors reviewed Appendix I on site during July 22-26 and August 5-9,

. Approximately 128 inspector hours were used during this review. Review ils are delineated in this report. As previously stated, two deficiencies and unresolved item were identified. It appears that these deficiencies and one solved item will not represent significant programmatic weaknesses.

ils on these items are discussed in the main bocy cf this report.

S:en, of Review This review, which consisted of an exarinatic,r. c' each se: tion e' Aprend'x I was pe 'ermed av irsre:: Ors frem Region I".

. brer11x 1, Sections 1.C. 2.0, 4.0, 6.0 ard S.C wnich present data or tFe artendix s:coe, resoc sic;e organ 4zation, program description, cnanges ano conclusions regarding tne asscssment of the appendix, did not recuire as detailed a review or evalua-tion as the other sectiers. . Ine mere si; 'f t: ant aspects of the a;;encix are in Section 3.0, 5.0 and 7.0. These secticns discuss licensee comnit-T:nts and implementation, audits and inspections, and appendix verification.

Review of the + se::iers in:iuded a cetailed review cf cor.er.: and examira-ticn of items ioentified as fincings regarciess of tneir final level of c W sification. The insps: tors examined a sam;,le of the re:ords revie ed by tne RRS anc examinec an m:eren:ently selectec sam:le of recorcs to asses's tne tnoroughness of tne cserall esaluation. Methocology used for inis revicw and an evaluation of eacn se: tion are presented in the fcllcwing paragraphs.

)

• 3 3

2. Me:hedc nyi The technical review and evaluation of Arpendh : we-e cerca::ed in the Region II office during the week of June 24, U55, and was supportec by e orsite inspection activi t y during the eeks Of Julf 22-27 and Augus: E-9, 19S5.

The offf:e review of Se: tion 3.0 comrared tne arolicant's a::er:ed C t.

- g a r licensing com-i ,erts with the (NUREa-OS00) 5

andarc Review :.an (SRP) p:sitiens, regalatory guides, indm3 trial :cdes, and Vogtle :SG do:urre n t s .

DJring the onsite ins:e:tions, the p-ocra n cescription, Section 4 C. was res t er.ed te ve-i fy that essintial elec.ents of the pr:; ram were aucited in accordance with accepted QA prc:*an criteria and with ANSI N45.2.12 cenmit-ments. P-cject cro:ecares we* evie ed to confirm :nat tney certair.ed implementing requirements necessary to eva' ate the adequacy of the pecgram Audit schedules, planning, preparation, performance, reporting, followup, ano recoras were reviev.ec to evaluate tne acequacy of the auditing process.

Auditor and Lead Auditor qualification records were reviewed to verify that personnel qualifications were in accordance with ANSI N45.2.23-(1978).

Audits covering construction and operations activities performed by GPC, and audit activities performed by Bechtel Power Corporation (BPC) - (the Architect - Engineer (A-E')), Southern Company Services (SCS), and Westing-house (W) - (the Nuclear Safety System Supplier (NSSS)) were reviewed to confirm adequacy and effectiveness of program implementation .

3. Evaluatien The evaluation of each section of Appendix ! is provided below. For each section, a description of each section, what was reviewed, and the basis of acceptance are provid d.

a. Se tior II - 5 cope Inis section encompassed the quality assurance organizations involveo and activities carried out by these organizations for the Vogtle prcject. This section was reviewed for ca:Kground informaticn Only.

No followup or evaluation of this section was required.

5. Section 12 - Rese:cs'bie Oe; art:ations This se: tion presents a description of the crgar,t:ation ar.d division cf res; nsibilities of GDC, EPC, SCS, W, and site contractor organi-

ations for aud'.ing activities relative to design, orocurement, corstruction, creeperational testing, and Oce-ations, condue:ec on behalf of Vogtle.

This section was reviewed to verify implementation responsibilities for audit functions of essential elements of the QA program delegated to otners or retainec cy GPC. Where audit functions were delegatec, GPC

4

= retained primary rescorsibility and selectively provided audit participation wnen contractors performed implementation.

o .

g I The period of August 1982 through July 1954 was selected by the inspectors for review of audited activities of W. Three audits were r viewed to verify that applicable elements of the QA peogram were auditec once in tne life of tne activity or on a triennial basis.

c. S'ction 13 - Commitments and Inplementation (1) The inspectors reviewed commitments to con + . St they were the same as tnose committed to in the FSAR and ics,tiec by the RRS.

Tne review also included an examination of QA prccedures to verify the F3AR commitments were being ccrrectly transposed into these project documents. The historical file of GpC's implementing QA procedures was reviewed to confirm that Regulatory Guice (RG) and American National Standards Institute ( ANSI) standard commitments were updated in these procedures as necessary. The following revisions to these historical procedural documents were not available for the inspectors review:

QA-01-01, R2, R4 QA-01-08, RO QA-01-11; R0 QA-05-02, R1 QA-05-04, RO QA-05-07, R0 All but one of these missing procedural revisions are initial issues of the procedure or pre-1976 revisions that were written essentially prior to any safety-related construction work being accomplished. Revision 4 to GPC procedure QA-01-01 was determined acceptable by confirming that R3 and R5_ contained adequate commit-ments. The licensee is conducting further searches for these missing revisions; however, recovery of these documents appears doubtful. This deficiency for failure to maintain a copy of superceded QA procedural revisiens does not appear to constitute a threat to tne nealtn and safety of the puolic.

(2) BPC audits of W have been conducted in accordance with WCAP 8370, Revision 10A. since aporoval of this document by the NRC on August 29, 1984. However, Chapter 17 of GPC'.s accepted QA program (Supplement 10) still specifies that WCAP 8370, Revision 9A is the applicable W QA precram. This failure to update the QA program appears to be a deficiency to update as required by 10 CFR 50.55f(3) in th4t this change was not reported to Region II until Amendment 18 of the application dated August 9, 1985.

(3) 'The NRC Vendor program Branch (VPB) pericdically inspects Bechtel and Westinghouse, as well as the other major AE and NSSS firms, regarding issues identified through licensee construction

e 5

deficiency and operating reactor evert reports: vender retoets of product deficiencies; allegations received from members of the puolic; and vendor issues icenti fied byg the NRC tnrough- its

> inspection programs. These issues may either pertain to specific reactor plants or be of a generic nature applicable to several plants. Inspection findings are issued as inspection reports (puolished cua-terly as NUREG 0040) and may be the subject of an IE Information Notice or Bulletin. Selective audits were reviewed by tne inspectors to verify implementation of an adequate aucit program.

(4) Chapter 17 of the FSAR states that SCS QA procram commits to RG 1.144(1979), which encorses ANSI N45.2.12(1977) for the concuct of audits and the training and qualification of auditors. SCS implementing procedures (34.2-50 and 34.2-51) also endorse ANSI N45.2.23 requirements for a:citor qualification and certification.

(5) The operations' QA audits are conducted in accordance with the commitments contained in RG 1.144 which are implemented by proce-dures QA-05-01 and QA-05-02. The qualification and certification of auditors was confirmed to meet the requirements of

. RG 1.146-1970 and is implemented by procedure QA-03-05.

Review of this section by the RRS and Region II inspectors identified that Vogtle's licensing commitments and implementing documents comply with the FSAR, SRP, RGs, and industry codes and standards.

d. Section 14 - Program Description This section of-the appendix provides a description of the functions of the Vogtle Project QA organization which includes auditing, . surveil-lance programs, quality evaluations and investigations, and QA engineering support activities. A description and purpose are given for the Vogtle Project Quality Concern Program (QCP) which was self-initiated by GPC in December 1983. This QCP is a licensee enhancement program that is not a commitment in the FSAR. The QCP was reviewed by the.NRC during an inspection conducted July 10-11, 1985.

Results of tnis inspection were occumenteo in Inspection Report Nos.

50-424/85-33 and 50-425/85-28.

' Review of the section confirmed that the subject program description is correct and in agreement with the FSAR and project requirements.

[ e. Section 15 - Audits and Insoections (1) This section contains a discussion of the audits and inspections and mofe' salient findings identified by the NRC, BPC, and GPC concerning Vogtle QA activities. Audits by GPC include self-initiated evaluations conducted in accordance with the Institute of Nuclear Power Operations criteria and annual assessments by the GPC QA Department.

6 (2) This section also includes the results of four NRC Systematic f Assessment of Licensee Performance evaluations,of the QA program. .

(3) Review of this section indicates that it is an accurate presenta-tion of the deficiencies identified against the audit program.

f. Section 16 - Prog-am Chances (1) This section, in conjunction witn referenced Section 12.3, describe majo* events in the evolution of the Vegtle Project QA organi:ational structure and two FSAR commitment changes tnat were reviewed anc a::epted by the NRC. Ine Ceouty General Manager -

Quality Assurance position described in Section 12.3 is not mentioned in the licensee's accepted QA program. Subsequent to this inspection, the licensee notified the NRC by letter dated July 30, 1955, of several organizational changes and additions, one of which was the Deputy General Manager - Quality Assurance position and related responsibilities.

(2) No other findings were identified during the review of this section.

.g. Section 17 - Aependix Verification This section describes- the project QA organization programs verifica-tion, resulting findings, and corrective actions. The Vogtle QA organization verification was approached by RRS in four phases. In Phase I, the commitments which were identified in Section 13 of the appendix were compared to the source document and the implementing proc!dures. Phase II evaluated GPC field construction and operational field audit activities for compliance to Vogtle Project commitments and imp'ementing procedures. Phase III involved GPC site QA evaluation of site contractors with their own QA programs. Phase IV assessed the audits of the QA programs of SCS, BPC, and W to determine if these programs were in compliance with their respective commitments and procedures.

(1) Phase I Phase I of this appendix verification was performed by developing enecklists from 10 CFR 50 Apoendix B. Criterion I. V. VI and XVIII requirements. The RRS then compared these requirements with those contained in implementing procedures to verify by objective evidence that commitments were adequate.

l Examination" of these same documents by the NRC inspectors confirmed that the work by RRS was acceptable, l

7 (2) Phase II Tne RRS. examined the GPC annual audit system plans and schedules, ,

35 field construction audits, 2 field ' operations audits, 50 related audit finding reports, and the certification and oualification of pertinent auditors for comcliance with Vogtle Project commitments and implementing QA procedures.

During a Regional Of fice review of Appendix I, Table 17-1, the Region II inspectors were unable to conclude if all essent.ial elements (such as training, instrumentation, excavation, and backfill) of the Project 0A Program had been audited at least .

annually or at least once within the life of the activity (whichever is shorter) as required. Subsequent discussions with responsible site audit personnel and examinations of a~dditional audits ccnducted in tnese areas convinced the inspectors that all essential elements were being audited.

The inspectors reviewed five field construction audits (conducted during 1980) and the two field operations audits that were previously selected for review by the RRS for examination. These audits were examined to verify that existing QA audit procedures had been properly implemented. The audit report, audit plan, checklist, written replies, audit finding reports and specific corrective actions taken, and auditor certification and qualifica-

-tion records were examined for each audit. This review identified that two lead auditors utilized in the above audits did not have their auditor qualification records maintained and updated annually as required by the licensee's ccmmitment to ANSI

' N45.2.23. The documentation of these auditor requalifications

• had, in some instances, exceeded the required 12-month interval by a few months. However, the subject auditors involved were verified to have been certified and qualified during this interim.

The licensee informed the NRC_ inspectors that this identical deficiency had been previously identified by the NRC and was documented in Inspection Report Nos. 321/82-42 and 366/82-40.

Appropriate record keeping corrective action was taken at that time.

' Examination of the above audits identified that operations QA -

audit TP01-84/01 checklist could not be located. Based on this finding, the inspector increased the sample size of their audit records review to determine if the retrievability of QA audit l

records from project document control was. a more widespread problem. The inspector exanired 100 cercent of the MD 04 (valve)

I anc MD 05 (tank) aucit receros contained in the vault. Several audit reports and checklists were not immediately retrievable, but i

were eventually found. Tney were either misfiled in the vault or in the microfilm files. Although audit checklists were found to exist in the Construction OA Department files for audits MD 04-81/79, 81/47, 80/13 anc MD 05-81/31, these checklists could

! not be located in the vault prior to the exit interview.

8

, (3) Phase III Audits of contractors with their own QA prograg are performed by

. GPC QA department personnel, in addition to those performed by the contractors' own QA organization. The RRS reviewed all audits by GPC associated with the Chicago Bridge and Iron onsite fabrication of containment linen and tanks; and the Pullman Po er Precacts' oipirg system fabrication and installation for large bore pipe during 1983 and 1984, including valves from 1979 - 1983. These audits were reviewed by the NRC Region II inspectors to assure that essential elements of the program were covered, industry icentified probiens were considered, and that GPC had performed audits on a regular basis.

The NRC inspector r iewed all 49 audit reports which were reviewed by the RRS to assure adequate QA coverage onsite. These reviews concentrated on program coverage applicable to ongoing activities such as; procurement, receiving, storage, material i itification and control, welding processes, documentation, nondestructive examination, nonconformance control, records, and audits.

The NRC inspectors evaluated Audit Finding Reports (AFR) identified by the audit process to confirm adequate corrective action. Objective evidence that GPC had reaudited problem areas and confirmed implementation of corrective actions prior to closure of AFR:, were also key elements used to access the GPC QA audit program. Evidence of QA program approval prior to start of activities was also verified by the inspectors. Audit MD 01-84/50 was a QA assessment of Pullman Power Products QA Manual, working procedures, documentation review, and personnel interviews. Audit MD 04-82/87 and MD 04-82/70 reviewed Pullman's program for evalua-tion of NRC Information Notice Nos. 82-20 and 83-80, respectively.

Phase III of the review conducted by the RRS for the audit i verification program was considered adequate.

(4) Phase IV The inspectors performed a detailed review of Phase IV of Appendix I to assess the effectiveness of the licensee's audit program by SCS, BPC, and W. Audits were selected to cover a triennial period in order to evaluate the total program coverage of essential elements as required in Regulatory Guide 1.144 (1979) and ANSI N45.2.12-1977. Chapter 17 of the FSAR was reviewed to ensure that commitments were consistent with those reviewed by the RRS and that*the audit p.ocedures reflected these requirements.

Audit findings associated with the following were reviewed in detail to verify content, adequacy of review, and to ensure closure of findings. l.icensee implementation of corrective action

9 to resolve audit fincings was reviewed and found tc be a::eptaole. g Tne perios of August 1952 through July 1954 was selected by the inspe:t:rs for review of EDC. SCS and GPC audited a:tivit'es of

y. inese trree a d'.ts confirmec that applicable eleme .ts of .ne C2 r-eg-am were aucited once in the life cf :ne a:tivity cr en a triennial oasis.

Ore audit of Westin; house's Tatca. Fle-ida facility, file GN20.1.4 leg V;SI-64, and one aucit of Westingneuse's Persa:ola.

Flcrida facility. 'ile GN20.1.4 log V;52-26 activities were r e , i ++. e: to cenfirm adecuate coverage of essential elements applicable tc tr.e mar.:.f a:turing pr::ess. Essential QA elecer.ts covered during the audits were 10 C:R 50 Appendix B, Criterion III, VI. VII. \!II, IX, X XII XIV, xy, XVI, anc XVII.

Audits of BPC from July 1982 through December 1983 were selected for review oy the inspectors. These aucits were participated in by SCS and two of the audits were participated in by GPC. The ,

scope of the audits confirmed that essential elements of the design process were adequately covered during these audits.

Licensee implementation of corrective action to resolve audit findings was reviewed by the inspectors and determined to be acceptable.

Tne aoove aucits confirmed snat tne aucit process is effective in identifying problems. Also, implementation and reaudit confirma-tion of adequate corrective action verified the program to be a management supported objective.

(5) RRS Findings and Corrective Actions The inspector's examination of the sik RRS findings cetermined that tney were of minor signif t:an:e and the resolution cf these findings, with the exception of Reaciness Review Finding (RRF) 21-5. was adeouate. Three of these findings were determined to be non-findings cases on acditional information p rev i.ced. Of .re remaining three, two were dete'rmined to be minor deviatiens from procedural requirements and one involved enhancement to CA Depart-ment pr::edures.

RRF 21-5 identified and properly resclved the deficiency icentified c:n= erring SCS. aucit finding recort ( AFR) No. 76-1, but failed to identify ancther deviation f om SCS procedural requireients con:erning the subject AFR. SCS Quality Assurance Department Policy and Procedures, Appendix C requires the final accept &ble corrective action taken to be described on all AFRs.

Contrary to this pro:edural reauirement, the corrective action taken was not entered on AFR 76-1. Review of additional 525 AFRs revealed that this deficiency appeared to be an. isolated case and

r i

10

• the licensee had taken corrective action on this AFR prior to our leaving the sit.e. . .-

f Findings Th] following findings, which are identified as either a deficiency or an unr solved item, were identified by the Region II inspectors. A ceficiency is considered as an item having no safety significance but one that should be evaluated further to preclude safety problems. An unresolved item i.s a catter which requires further information and investigation to determine if it is acceptable or may involve a violation or deviation. Deficiencies will be pursued as an Inspector Followup Item (IFI) in future routine inspections.

Deficiency (IFI 85-31-01) Update of Final Safety Analysis Report.

BPC audits of W have been conducted in accordance with WCAP 8370, Revision 10A, since approval of this document by the NRC on August 29, 1984. However, Chapter 17 of GPC accepted QA program (Supplement 10) specifies that WCAP 8370, Revistort 9A, dated October 31, 1979, is

' the applicable program. This failure to -

update the QA program appears to be a deficiency in that this change was not reported to Region II until Amendment 18 of the application for an operating license dated August 9, 1985.

Deftciency (IFI 85-31-02) Unavailable Early Procedure Revisions.

Review of the GPC historical QA procedure i file identified a few initial and very early proc.e. dural revisions that were not available for the inspector's review. It should be noted that six of the seven unavailable procedure revisions were ,

either initial issue (Revision 0) or pre-1976 revisions that were written essentially prior to any safety related Mobilization construction being done.

f for construction and some excavation commenced in 1974 but was stopped and resumed again in 1976 at which time these procedures were immediately revised and enhanced. Revision 4 for procedure QA-01-01 was determined acceptable by confirming that revisions 3 and 5 contained adequate commitments. The licensee is conducting further searches for these missing procedures.

9 11 VI1resolvedItem(UI35-3*-03) Retrievab411tv o' OA Audit _ Records.

Review of ac:it recoe:S for air.e: in tne*- e

> r-eft:t de:u ect cor.:-01 vault iri tiai'y icentified several audit reports and audit checklists which were est imme:iately ret-iev3 Die but were esser-t i ally found eitrer misfiled in tne vau't er in tne micro #ilm (11es. The inspe: tors dis:evere: tnis appa-y t r.reblem near the conclusion of t'eir inspe:: ion! At the conclusien of this despe: tion, f t'.e audit cne:klists were icentified to tre licensee as paisibly still missing frcm the vault. ~he licensee is conducting a search for these '

missing aucit reports.

Appendix D, Document Control, is under development. A comprehensive review of document control will be conducted d.uring this module inspection.

Conc,1 u_s i o n s Eiased upon the review of this appendix and independent review of documenta-tion en site, the NRC concludes the following:

a. Licensing commitments and implementing precedures comply with FSAR, SRp, Regulatory Guides and industry codes and standards.

-b. The li:ensee has implemented an effective audit program which covers essential elements of construction activities.

c. Aucits of essential elements of the design process have been performed in accorcance witn Regulatory Guices and ANSI standards.

d. Audits of the manuf acturino orocess -at W facilities in Tamoa and Fensacola, Florida : overed essential'elemen:.s anc were cetermined to be effective. ,

Audit reports covering various asse:ts of ensi e activities nave beer.

reviewea ey Region 11 inspectors since 1982 and documented in NRC Inspa:: ton Report Nos. 50-404/S0-02, 80-13, S2-05, 82-05, S3-19, St-C5, i anc 54-14 Audits performed by GEC will continue to be evaluated to l assess audit prograg, effectiveness.

t Review and evaluation of Appendix I by the NRC indicate that the review p';rformed by the GPC RR5 was sufficiently comprehensive in scope and depth to identify problem a-eas, and that the dispositions of findings were proper and satisfactory, except a, noted in Section 3.g.(5). The NRC finaings

1

/

12 identified as deficiencies appear to be minor and do not represent a breakdown in the Quality assurance program. .

s Th2 NRC furth'ermore believes that Appendix I accurately assesses the status of design, construction, and operational auditing activities. This conclusion is based on information currently available to the inspectors and rGviewers. Snould information subsequently. become available which was not consicered during this . review or previous insoections and which conflicts-with earlier information, it will be evaluated to determine what ef fect' it ray have on_the above conclusion.

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l ." $[ DN11ED STATES 1:N .

REGULATORY COMMISSION l_ .

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[

IN THE MATTER OF: DOCKET NO:

ADVISORY COMl4ITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 l

LOCATION: AUGUSTA, GEORGIA PAGES: 1 - 173 DATE: THURSDAY, JULY 1.8, 1985 ,,

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ADE-FEDERAL REPORTERS, INC.

..OfjicialReporters 444 Nor2 CapitolStreet Washington, D.C. 20001 (202) 347-3700 EXHIBIT "7 "

NATIONWIDE COVERACE

NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

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.c e

Subcommittee on Vogtle Electric Generating. Plant Units 1 and 2 Augusta, Georgia July 18, 1985 .,

u i

t Present: Mr. Jesse C. Ebersole, Chairm.n Mr. Glenn A. Reed, Member Mr. David A. Ward, Member I

e

$SS Sh S $$ h6 8 m g&&q $ f h h h& ff

--,.-....-~-,.,_.1 , , _ . . , . , __ _ ._ _ _ _ _

70 1 presentation, Mr. Sinkule.

2 We are doing so well on the schedule, I am 3 going to take an opportunity to have Mr. Tim Johnson come 4 up. He has five minutes to make an. ora [ statement about .

5 some problems about the newspaper response.

6 Mr. Tim Johnson.

7 MR. JOHNSON : Thank you.

8 MR. EB ERSOLE: I should have said he 9 represents the Campaign for a Prosperous Georgia. Sounds I

.s 8*' * -^*

• bericus crg niratirn. '!

l 11 i ER. JOHNSON: Thank you, and thank you ror 1 i

i l

I 12 i allowing me to speak. i i

t 13 The concern I had was not with the newspapers, l .

I 14 but with the lack of notice of the meeting. We are an

'" i-'-----a- in the licanning precess and have been forr.all _

16 accepted as an intervenor.

17 The only way we found out about the meeting 18 was one of our members in Augusta sent a photocopy from the 19 newspaper last week which mentioned this was going to 20 occur.

21 But we were never sent formal notice.

22 When I called the regional office and 23 requested,it, af ter talking to about a half dozen other 24 people, I finally got through to one who said, yes, the 25 meeting was happening.

71 1

. When I asked what would happen at the meeting 2 he said the subcommittee would he&r presentations f rom the 3, applicant and staff.

4 - And I asked if intervenors cpuld not also make .c 5 a statement. That wasn't until Monday of this week.

6 And he said, "Yes, provided it addresses 7 specific issues on the agenda'."

8 I asked what the issues were on the agenda and 9 he said he would mail one.

10 I set the copy Tuesday. It was a press ,

11 release and did not tell what was in the, agenda but i i

12 mentioned it h,sd been in tha Federal Register on July 2nd.  ;

t 13 So I went to the library and copied the i

14 notice, which also did not mention the agenda. -

l l

I v a-terdty, 'i-*1'y I c=ad *he staff person  !'

1:

16 who was mentioned in the Federal Register notice at the 17 phone number in Washington and was told that he would be 18 out of town until August.

19 I see he is here today, I guess that is why 20 he was out of town.

21 They read me over the phone the agenda, but it 22 wasn't until yesterday af ternoon.

23 We would like to present written comments on 24 some of the items on the agenda; and I would like to 25 .

summarize some in advance of that, right now.

72 1 MR. EBERSOLE: But your major issue was you 2 were delayed in getting notice of details of the meeting?

MR. JOHNSON: Right. Essentially we were not.

,3 4 We had. to-make a particular ef f ort. _ ,

P 5 MR. EBERSOLE: Is there not some formalized 6 process of getting notice to intervening groups that these 7 things are going to take place?

8 John?

9 MR. McKINLEY: These meetings with the l l

10 , Adviscry Commit;ac cn .~.Jac Or Safaguards are not part of 11 the formal public hearing process. We do know it. They 1 12 i

e are opan to the public. ,

t 13 But they are not part of the hearing process 1

14 where. the utility and the l!RC and the intervenors exchange l 15 to: tin:ny and crc::-sa: ination.

~

16 There will be a public hearing, I believe it 17 is scheduled to begin in November.

18 Bas that been po'stponed?

19 . MS . MILLER: No schedule has been established.

20 MR. THOMAS: Let me mention, a formal request 21 has been made to the Atomic Saf ety and Licensing Board to 22 begin hearings on November 19 of this year.

23 , ,

MR. McKINLEY: The parties to that hearing 24 will be served all of the papers related to that.

25 Proceedings of the ACRS are not part of that;

73 1 and, therefore, we do not make an effort to serve notice on 1

2 all of the parties.

3 MR. JOHNSON: Yes, sir, I understand it is not 4 a part of the licensing process. --

g .

.a S

5 How ever, the ACRS does make recommendat~ ions to 6 .that board in that licensing process.

7 MR. WARD: No.

8 MR. JOHNSON: It does not?

9 MR. WARD: We make recommendations to the 10 Cc= mission. 'i 11 They are available to the board for their use.

i I MR. JOHNSON: I think the committee would be I 12 I I .

i i 13 well-served by receiving points other than those merely l

14 from applicants and staff. I would suggest you do that in 15 future proceedings with other plants.

16 MR. WARD: I think it is a good point. We do 17 count on the notice in the Federal Register.

18 MR. JOHNSON : But it costs $300 a -year to you 19 be subscribe to the Federal Register. Many intervenor 20 groups cannot afford --

21 MR. WARD: You are saying that is not a

22. practical way to spread the word.

2,3 MR. JOHNSON: If there are groups of formal 24 intervenors with a particular plant, and there is going to 25 be a hearing in the town near the plant, it wouldn't, I n emmw- =-o ---- 4.e a o m e _ -- o cam c oo e,oa

p--

74 1 think, be very difficult to send them notice along with the 2 Federal Register.

3 MR. EB ERSOLE: Right. And you had other 4 matters, too? ._

)

5 MR. JOHNSON: Yes, sir. Thank you, very much.

6 One thing that I think is very important, and 7 I think one of the members was addressing that, is to not l 8 misread what the so-called readiness review program is.

9 In fact, if you go back and read you will 10 di::c ter th:1 tha repar tment Of ~n):gy he.d been urging that J I

i 11 Georgia Power and other utilities take this as part of the i i

11 Reagan Administration's goci of so-called licensing ref orm l l

13 for so-called whistle blower allegations. l i

14 That is what this is for, to resolve issues j 15 early in the process.

I l 16 Then workers at the plant come forward and 17 say, "Well, this wasn't solved."

18 Then the long-raEge goal says we can't address 19 this now because it was addressed earlier. .

20 9e have within the last two weeks been 21 approached by former workers who described the readiness 22 review program as pencil whipping.

23 So I think my question about whether it is a 24 paper program or hardware program is very appropriate.

25 Those workers said they have been told over

75 and over for the last two years. never to talk to intervenors in the licensing process.

They said they had taken their complaints to the regional office of the NRC, and more than one g case they . .

(

( were told that the NRC does not have the staff to come make inspections of worker complaints.

In some of these cases, there appeared to be very significant concerns. I hope you will follow up on ..

it.

I Just this morning I came dcWn early to meet '! ,

with two of these former workers at the plant. They gave me sc=e specifics that I will in outline form read very ,

quickly.

And they promised to provide more details to l.

I me in the future. I will certainly forward that to the committee.

These include the -- they said that the containment Unit 2 reactor vessel wa's removed from storage and put in a position such that it accumulated approximately 150 gallons of water.

According to these workers, that that is a violation of ANSI 454.2 concerning receipt, storage and handling of items for the power plants.

And that regulation requires that the vessel remain dry at all times during storage and prior to

1 construction. .

2 They said that resulted f rom poor planing and 3 removing it from its storage before they were really ready 4 to put it.in place. ,_ ..,

5 They said that the welding assemblies used are 6 not coherent and that they don't meet the American Welding 7 Society specifications. They say they would provide copies 8 of that.

9 They said the coatings on domes does not apply  ;

I 1C 3

p?r the prr t f t:- .s. '{ ,

11 Some of this, I apologize, I don't know what I i

12 some of it maacs so I will rsad it. Hopef ully they will  !

-13 provide the details.

14 I

l On that, it says inspector's data for humidity i

i 1" ' # actor and ter.perature does not correlate 'sith other 16 inspectors' data on particular days that they said they 17 would provide.

18 It says if there is an accident, either of the 19 containments releasing excessive heat, it will result in 20 the coatings appealing.

21 And they were applied in less than optimum 22 conditions.

23 ,

Then they said large redheaded female 24 inspector who was not allowed to inspect the area, how she 25 . had brought some of these problems out.

p They told her that she shouldn't have done that.

)

But she is still working there and some of the workers observed this occur. --

t The tendon galleries they said are required to d

have a rabbit pulled through them to confirm clearance, and 7 several of the rabbits are stuck,'due apparently either to 9 damage or unknown obstacles.

-) They said the design of the cooling towers

~

3 could result in '

d- *-o effect in case of an accident. ,

That the --

l l B MP. WARD : Could you tell us what ecoling  !

t 0 towers they are referring to? l 3 MR. JOHNSON: I assume they mean the large --

3 I do not know.

l

~

MR. WARD: There are two sets. It is 3

P important, I think, to know which it is.

8 MR. JOHNSON: I wi1T put a note to find that 9 out.

O They said the heat affected zone, the 1 inspections to welds do not include proper inspection of 2 the heat affected zones. They believe that is not in

<3 compliance with the regulations.

44 They said that a particular individual placed 45 rejected concrete during a pour, knowing it was rej ected.

78 1 - They said their understanding was that the NRC 2 then said he could no longer hold an authoritative position '

,3 on site, and he was transferred off-site. l 4 But since, according to th,e former workers, he

-- . q 5 has returned to the site and is now head of systems 6 turnover.

l 7 They said the on site rebar fabrication, they 8 used so many pins, diameter of the pins is such, 9 fabrication is such that there is a flame cut on the edges I

-l 10 caking it very uneven.

11 They think they all are at least a quarter 12 i.nch off and that there might be violations Of the concrete f .

13 Steel Reenforcing Institute specs on that.

4 14 They said the iso-phase drawings, that there ,

i 15 are designers there. But I understood frem them that there was a halt on that and deviation report. In particular, 16 1

17 there are 120 welds there that are in question.

18 That the manhole hatch covers, the manholes 19 and hatch covers were made different sizes, so they didn't 20 fit. So they have to go back and re-do that.

21' They said that is an example of improper 22 planing and general incompetence.

23' They gave me a photocopy of a handwritten memo 24 that says from Terry to Harry. My understanding is that 25 Terry is, I believe they said, the head of quality control,

79 i

or head of one of the divisions in quality control. Harry ref ers to Mr. Greggory, manager of the proj ect.

In this handwritten photocopy of the memo, it says that the company should allow only compagy employees . . ,

to be put in supervisory or quality control positions because of their loyalty to the company, and that they should not put contractor's employees in such positions because they are not loyal to the company.

I will supply you with copies of that.

I Sgain, I think ycu for allowing me to make '!

I '

1 this oral statement. I will provide written comments. I t I i urge y n to please f ollcw up.  !

MR. EBERSOLE: They are using you as a l

clearing house for numerous allegations, apparently. [

I I guess ry question would be, we heard awhile I

ago, the staff is also a receiver of these, as well as applicant.

Eventually, I guess, th$ question is, have these come around to. you, as well, and to the staff ?

Thank you, very much. We will follow up.

These matters are on record, of course.

MR.-JOHNSON: Thank you.

MR. , EB ERSOLE : We are currently running on schedule quite well.

Let me call a recess for 15 minutes.

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

Route d sca M Waynescoro. Georgia 300,0 ,

• • '* "' M'sl%f 1 .

Vogtle Project August 19, 1985 Mr. Tim Johnson -~

Campaign for a Prosperous Georgia i 175 Trinity Avenue, S.W. .

3 Atlanta, Georgia 30303 h

Dear Mr. Johnson:

I am Manager of the Quality Concern Program at the Vogtle Project.

P In that capacity I had the opportunity to attend portions of the ACRS hearings held in Augusta on Thursday and Friday, July 18 and 19, and to describe the Quality Concern Program to the subcomittee. I was not present at the hearing when you made your presentation. However, I have had a chance to review the transcript from that hearing.

I At you may or may not be . aware, the Vogtle Quality Concern Program ie designed to ensure that any individual involveri or interested -

in the Vogtle Project is given the opportunity and is aware of '

the obligation to raise any questions concerning safety and to have those questions investigated and resolved outside of nomal

$ supervisory channels. Every employee en 'the Project, or involved 1 g with the Project at other locations, is infomed of the Program J

= and is given a letter from Company President James Miller and i F a short Program explanation,. copies of which are attached. Every b attempt is made to interview all employees who are leaving the E Project in order to detemine whether they had any questions y or concern, regarding any safety-related issue.

I have a staff of eight employees, and have access to the resources of the entire Project and several supporting organizations. We i are able to thoroughly investigate any concerns brought to our k attention. Most of the legitimate concerns we receive have previously been identified as part of the Project's Quality "

, Assurance Program, with appropriate corrective action either Z taken or planned. However, some concerns have been brought to our attention which had not been identified elsewhere. In these cases our investigation has resulted in prompt corrective action.

I One important element of our program is our pledge of

=- confidentiality to submitters. We do not disclose the identity g of any submitter to line supervisors or co-workers, or to anyone m else directly involved in any way with the work in question, F unless we receive pemission .to do so from the submitter. Also, r_ quality concerns, can be submitted to us anonymously. If the w

E m.

= EXHIBIT "8..

Page ..

E submitter provides us with identifying infomation, we remain in contact with that submitter during the course of our i investigation and report our findings to the submitter at the g conclusion of the investigation.

I have carefully reviewed your remarks at the ACRS hearing concerning potential safety defects or problems at the Vogtle Project. Based on your remarks, we have or are attempting to ^

conduct an investigation into each of tfie~ iricidents which you

identified. However, with the exception of the allegation of water in the Unit 2 vessel, infomation provided at the hearing g was vague, incomplete, and did not provide enough detail for e us to identify and investigate the allegations.

It is my understanding that you have, on several occasions, indicated that your primary concern was with the safety of the l Vogtle Project. Safety is also our primary concern. If you L have any infomation concerning any potential safety problem t

at Vogtle, we will respond imediately, conduct a full h investigation, will report the results of that investigation bl,(g to the individual submitting the question or concern, and will m.Spj i verify that appropriate corrective action is taken. It is often 1%

$ critical that questions and concerns be raised at, or close to, j ig the time of occurrence so that a complete investigation can be i conducted. In your statements to the ACRS you indicated that M 3:'i you expected to receive further infomation and that you would .lt y provide written infomation to the ACRS concerning each of your W q allegations. I am asking you to provide us with any information .y '-

available to you now which would allow us to identify potential .-f

=

problems and conduct our investigations, and to provide us with M

= any supplemental infomation that you receive in the future. ^- A gn

[ If any individual contacts you with questions or concerns about (([l Vogtle, please provide them with my name, the toll free telephone

.gh 7 I number, and the mailing adcress, all of which are included in ( R-I the attached flyer. If you desire, you can act as an intermediary ..

and provide me with the infomation, questions, and concerns C T;Mi ~

" directly. We will continue to honor the pledge of confidentiality dA..:C.

that I described above and will provide you or individuals in MM contact with you the opportunity of contacting us anonymously. g$ ,p?

M..

w g Also, I want to assure you, and ask that you convey ths assurance .

3 to anyone in contact with you, that we will not tolerate any fom of retaliation against any individual raising a safety or h2

[ g r

quality concern, whether through nomal supervisory channels, h@1; h through the Quality Concern Program, or directly to the Nuclear yg i

} Regulatory Comission. Any individual who feels that he or she .. .E has been retaliated or discriminated against because of safety }#2c.

concerns is urged to imediately contact me. I will personally it j investigate any such claims, and if retaliation has taken place, p?

will insure thst the individual involved is compensated for any M'i loss, will stop the retaliation, and will take decisive action ...f f to insure that the retaliation never reoccurs in the future, f. j

) :h l WE Z

@pi..

w,j

Page Three -

If you are truly interested in the safe construction of Plant Vogtle, I urge you to contact me immedately and provide me with information which will allow us to conduct an investigation into the allegations you made at the ACRS hearing.

Also, in the future, if you receive any complaints, concerns ,

- or questions. I urge you to direct them to my attention. In short, we are inviting you to participate in the Vogtle Quality Concern Program and pledge to you, or to anyone you represent,'

all of the benefits of that Program. If for any reason you do not want us to conduct an investigation of your allegations, please refer your allegations to the NRC. If the allegations-related to safety matters, it is imperative that someone address them at the earliest possible moment. The NRC can be reached at (404) 221-4503. By copy of this letter to Douglas Teper, I am asking that his group, Georgians Against Nuclear Energy, also participate in the Quality Concern Program.

I am aware that your organization is a party to the current operating licensing proceeding and that our lawyers have requested further infonnatian from you concerning your statements at the l ACLU subcomi ttee meeting, as well as the identities of the individuals who made the allega tio.ns. The extent to which you do or do not provide such information to them in the context ,

of those proceedings in no way will affect my pledge of -

confidentiality to those who participate in +.he Quality Concern i

Program.

I will look forward to either hearing from the individuals in contact with you or from you directly. In the interim, if anyone has any further questions about the Quality Concern Program, I urge' you to get in touch with me at 72'4-8114 or 722-8946, extension 3294.

Very truly yours,

- o

[ cl Lee B..Glenn Quality Concern Manager LBG/lcb xc: Douglas C. Teper Dr. Nelson Grace, USNRC Donald O. Foster, V. Pres, & Project General Manager, Vogtle Project Bruce W. Churchilly Charles W. Whitney, Esq.

James E. Joiner, Esq.

O O

h _ _ _ _ _ _ _ _ _ - - .

, _ . . . ~ , , , . , . . . . . . . .

Attente. George 30306 Teaegnene 404 5264S26

- =

Meeng Aekees root Ottee los 4545 Attents. George 30302

^

J. M. see, k une sournom **ectre srsten preensent g February 12, 1985

~

TO ALL PRRSONS INVOLVED WITH THE VOGTLE PROJECT. ,

In June of 1979 and again in July of 1983, notices were E issued which covered your rights and obligations and our r expectations and requirements with respect to the safety and quality of activities on the Vogtle Project. This letter updates those items and reinforces our commitment to safety and quality.

5 You are employed or retained because you possess talents, skills and experience which are positive assets to the Vogtle i Project, and you are important to our success. Your notifying L Georgia Power Company of any conditions that you detect or suspect

! are adverse to either safety or quality is part of the service i g which you are expected to render. In return, you have a right to  ?

be heard, and you deserve a considered response to any expressed ~ '

concerns.

h j Please notify your innediate Supervisor if, at any time, vou i r observe or justifiably suspect any work or other operations that "

E are not in accordance with approved procedures, or which are "-

= contrary to established quality, safety, regulatory requirements, E or good engineering practices. With the knowledge tha.t you are -

E carrying out not only my personal directive, but also the documented objectives of Georgia Power Company, you may bring your concerns to 'the attention of the Quality Assurance Department, the

Quality Concern Program or higher line managers, myself included, if you feel that your concerns are c 't being resolved through normal channels. ~.

$ If, for any reason, you are hesitant to contact your

= immediate supervisor, you may and should contact the next higher level of management, the Quality Assurance Depa rtment or the Quality Concern Program. On site, you should contact the site Quality Assurance Manager, E. D. Groover at ext. 234 , or the Quality Concern Manager, L. B. Glenn at ext. 3294. Mr. Glenn can also be reached, toll free, at 1-800-225-2055. In the corporate

= office, you should contact the Vice President and General Manager of Quality Assurance, Mr. P. D. Rice, at 404-526-7080. Of course,

any of the above contacts can be made anonymously if you prefer.

However, items which are submitted with your name will be answered in writing indicating the disposition of the matter.

5

Continuotien PCgo TWO while working on the vogtle Project, you should feel an cbligction to provide Georgia Power with the first opportunity to cddrocs any concern you may have. However, you may also feel free to bring matters affecting health and safety of the public, ccapliance with regulations and requirements,- gyality, security, -

or oafety to the attention of the U.S. Nuclear Regulatory Cocaission (USNRC). The USNRC's Region II office of Inspection and Enforcement, locat'ed in Atlanta, GA. (telephone 404-221-4503), will accept collect calls twenty-four hours a day. of ccurco, you may also contact the resident USNRC Inspector on site (tolcphone no. 404-554-9901 or 404-554-9902).

Georgia Power Company is commit'ted to constructing and oporating vogtle in compliance with all safety and quality Irequirements. Since you are involved with Vogtle, it is your recponsibility and obligation to assist Georgia Power in meeting that commitment by informing us of any and all conditions which oight prevent such compliance.

4 J . ler, r.

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O w.

ya a

.g u ENPLOYEE ORENTATIOh I

Welcome to Plant Vogtle. You are now part of a team . a team dedicated to building

~

this plant using the highest possible quality standants. As part of this team, you have two very important responsiktitties. These responsibilities are:

E

2. To do your fcb to the very best of your ability and to make sure that your i work is safe and of the highest possible quality: and E

E 2. To report any event, activity, practice or procedure which you feel adversely

[

n affects the quality of this project or the safety.of cptmction or future.

plant operation.

y

=

Georgia Power Company has.a " Quality Concem Pmgram", which allows you to report any questionable act or pmetice, either orally or in writing, to Lee Glenn, Georvia l Power' Company's Quality Concem Pmgram Coontinator. There are posters explaining b the program, forms for submitting your concems, and collection boxes for concem l forms located throughout the site. You. can also ecntact Lee Glenn directly at i 1-800-225-2055 (toll free). Any concem or complaint will be held in confidence: you j can remain anonymous if you request. Each concern will be investigated and you wt!!

u receive a response if you request it.

L You have recetved a letter from Georgia Power Company President, James H. Miller, Jr.,

N; repanting the Company's concem for safe, quality constmctton. Read the letter, 7: familiartze yourself with the Quality Concem Pmgram, and remember your two primary

, obligations - to do good work and to . eport bad work. . .

................ I' ACKNOWLEDGEMENY m .

The undersigned acknowledges that he/she has recetved a copy of the M!ller quality letter, is aware of the existence of the QUALITY CONCERN PROGRAM, knows what } I his or her obligations are regcrding the reporting of substandant or poor quality work or unsafe practices and knows how to report a quality concem.

I Employee Name (Please Print) Contractor's Name

{

e.

( Social Security No.

,e,,nanen, ,d,,es,. aployee No./saag, No.

Street Date .

r City, State Zip Code Employee's Name (Signature)

I e

Phone No. Witness i

V Revised 9-27-84 E

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I cc: GFT,BWC,DRL,NKJ TROUTMAN, SANDERS 3 LOCKERMg MHMORE 8)

ATTORNEYsAT LAW OM @ 7 /$

CANDLER SUtLDING. suite s.OO 83 7 .EACMTREE STREET. N.E.

ARANTA, MOINHA 30043

.E E. ... .....

_ ... = _ ...

August 8, 1985 ,_

M{ ,

. AUG 131985 urie Fowler, Esq.

18 Flora Avenue, NE tlanta, Georgia 30307 S G=P=

Re: Vogtle Electric Generating Plant, ASLB Docket Nos. 50-424 and 50-425 (Intervenors' Response to Motion for Summary Disposition of Quality Assurance Issues) aar Laurie:

We have received Joint Intervenors' July 31, 1985 Response o Applicants' Motion for Summary Disposition of Intervenors' ntention No. 8. In that pleading, Messrs. Johnson and Teper $

opresent to the Atomic Safety and Licensing Board that Intervenors are in touch with current and former workers of )1 ha plant, some of whom are willing to testify on QA concerns" > l Rooponse at p.5). Joint Intervenors also represent to the "  ; r;

'crd that there may be additional instances involving "QA -

1 rockdowns" (Response at p.6) . While no particulars were .

~ , 0 ,;

rovided, Joint Intervenors referred parenthetically to the -

- O,i sating of a subcommittee of the Advisory Committee on Reactor f.$P. .

ofoguards held in Augusta, Georgia on July 18 and 19, where &e

r. Johnson made a number of allegations based on statements hNy f unidentifed individuals. [.U.j.7.,

a We have carefully reviewed Mr. Johnsdh's statements to 'k. n L-ha ACRS subcountittee. Because they were so sketchy, it is hf.d

% *. Y ..;

ifficult for Georgia Power to follow up on them. Our attempts ro further hampered by not knowing the identity of the individuals f>j o made the allegations. For example, we do not know when @f. M r where the events were supposed to have occurred, and in A.i '::

ny cases we cannot even determine whether the alleged g yL". ::LIL

=ccurances involved safety-related work, or whether they had roviously been documented and corrected in accordance with .' 7. ?. '

tha project's QA procedures. ...

• i

).: s h].$l

~

f:9. , !

f,x ' .: <;.

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n .

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EXHIBIT "9" 4 y J.

((:** .

• nouman, smosas. LoCRE MAN 6 . WORE Laurie Fowler, Esq.

August 8, 1985 .

7 Page Two w

=

To the extent discernable, most of the allegations appear to be outside the scope of Contention 8 as defined by the Licensing Board. Also, the allegations ar_e in the nature of ,

discrete occurances which, if true, could ce/tainly not be -

~

i fairly characterized as QA " breakdowns." Joint Intervenors, J however, have suggested to the Licensing Board the possibility

=

that some unidentified individuals may be presented to testify g on QA concerns. We have' repeatedly asked for the identity F of individuals who have provided information upon which Joint

[ Intervenors rely in support of Contention 8 and we have asked i for,the substance of that information. In written discovery, ..

[ and in Mr. Teper's deposition, we specifically called upon ..

t Intervenors to provide us with all pertinent QA information in their possession and to identify individuals who provided bi

_ information related to Contention 8. Pursuant to 10 C.F.R.

E Section 2.740(e)(1), Joint Intervenors are under a duty to

?i supplement their response to discovery and provide us with ,. . .

g the identity and location of persons having knowledge of

• m discoverable matters. In Mr. Teper's deposition, he agreed =j to provide the name of any person who supplied information . M l' related to Contention 8, although you reserved the right to N h- file a Motion for Protective Order if the informant requested 4 anonymity. (Teper deposition at pp.250-257). r i Beyond the requirements of 10 C.F.R. Section 2.740(e)(1),

y

p.

s however, Georgia Pow-r Company is committed to assuring that N q j/

Plant Vogtle is safely constructed and operated and to thoroughly e'i. H c investigating all safety-related allegations made known to .

'it, no matter how vague or what the source. This commitment v::MA E

exists at all levels of corporate management and is unrelated to the ? resent montested licensing proceeding. Thus , re

~[%.d:

f.: .J of whether allegations of unsafe construction practices'gardless at . .

Plant Vogtle are within or without the scope of Contention e  :. ;

8 as raised by the Intervenors, Georgia Power Company needs o? '.'i #"

to be informed inanediately of any and all allegations relating to safety, so that full and complete investigations can be 'i :?.1.  ??/c conducted and any problems resolved. We ask Joint Intervenors I,6 y

, to assist us in this regard. Because~of the implications of 8Q such matters on.the public health and safety, we consider your Xi; r cooperation to be a responsibility which far outweighs anyone's F desire to withhold or delay information. W.~ S

?

E a;'i s

E . lg;.4 i F

hk ervp W {,r ,

p .,. ; _

7 i.1; f, l yi V '. G .

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wmm, amoces, tocumum, a suon' ,

l Laurio Fowler, Esq.

August 8, 1985 Paga Three" -

For these reasons, we ask that you define and more ,

l* spacifically identify the instances of improper construction practices which Joint Intervenors believe calls into question _' '

tha safety of Plant Vogtle and provide us with the identity of each individual who has provided information which Joint Intervenors believe ca.11s into question the safety of Plant Vogtle. We ask you to do this immediately so that we can begin tha proper investigation and resolution of any such issues.

Sincerely.

f

"& f i '

James E. oiner JEJ/sgp cc: Service List b

e O

e h

4 h

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION a

Before the Atomic Safety and Licensing Board F

~~ ^

In the Matter of ) -

i )

g GEORGIA POWER COMPANY, et al.

) Docket Nos. 50-424

) 50-425 r (Vogtle Electric Generating Plant, )

Units 1 and 2) )

SERVICE LIST k Morton B. Margulies, Chairman Douglas C. Teper -

m Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306

[ Washington, D. C. 20555 E ~

Laurie Fowler -

Mr. t:c.atave A. Linenbergar Legal Environmental Assistance . ;"W )

h Atomic Safety and Licensing Board Foundation y Ji c U. S. Nuclear Regulatory Commission 218 Flora Avenue, N. E. 3 4

E Washington, D. C. 20555 Atlanta, Georgia 30307 -

s E Dr. Oscar H. Paris Tim Johnson /

r Atomic Safety and Licensing Board CampaignforaProsperous. Georgia)Q.A U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W. . MA Washington, D. C. 20555 Atlanta, Georgia 30303

1. . JJ.;3* .

Bernard M. Bordenick, Esquire Docketing and Service Section p[.,l$

$fP

, Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory S.;O$

Washington, D. C. 20555 -- Commission SJ - 4 m Washington, D. C. 20555 M?

Atomic Safety and Licensing Board

_ [: c Panel Bradley Jones, Esquire ...Vc

_ U. S. Nuclear Regulatory Commission Regional Counsel fm

Washington, D. C. 20555 U. S. Nuclear Regulatory i;: 1 ; ..

^

Commission 3.!.,. :. ?

=

Atomic Safety and Licensing Appeal Board Panel Suite 3100 101 Marietta Street N*

J J

U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 J. .# .

Washington, D. C. 20555 J.. H

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August 19, 1985 /

Jcmes E. Joiner AUG 201985 Troutman, Sanders, Lockerman & Ashmore Ccndler Building, Suite 1400 127 Peachtree Street, N.E. J.E.J.

Atlanta, Georgia 30043

^

Re: 'Intervenors' Supplement 6f Rdsponse to Disc'o'v&ry Daar Jim:

We have received your letter of August 8, 1985 referring to Joint Intervenors duty to supplement their response to discovery.

You have raised serious issues and,in order to properly address these issues, it is taking more time than originally thought.

We intend to answer when in position to do so. We are carefully reviewing the allegations of Plant Vogtle workers in order to place in the record that information which proves the systematic breakdown of the QA program at Plant Vogtle. Because of the implications of such matters on the public health and safety, we intend to cooperate fully with any true effort to resolve the dangerous problem at Plant Vogtle.

Sincerely

• W Douglas C. Teper DCT/dct' cc: Service List EXHIBIT "10"

L ATTAC10EhT 1 IlW0mity1W FM mm saa imagm Government Acomuntability project (GAPl*

1941 0 st u.w., unohtagten. D.C. 20409

- (202) M7-7tg4 or locally (404) 724-4900 As a nuclear poner plant upther, yee are protected by the

_ theited States Department of Laher against harassment, intaandation or retaliation for engaging an the ' protected actavity* of cha11engang violations of the Atomic Energy act.

If you are disertainated against in any way for protected activaty, the *Jepartment of 14 tor can latervene to oreer pur

, employer to n to you, to stop harassing you, and to de other things, pas.' :s tactudtag giving you back pay.

• Protected activity

• includes any activity carrying out the t

^

pearposes of the Atomic Stergy Jurts or $he Energy Reorganisation ,"

g Act of Atle, unich created the Ihsclear Regulatory CDeutission.

Se Department of tahor has laterpreted protected activity

^

to include authorship of anternal quainty-assurance gg Errte, such as Corrective action heporte and nonconformance asports.

- F11&ng internal @ reports la considered protected activity even

-- Ji the employee has not retsed his concerns wtth the E y 'proEted ActavstyT~ 6 Etude org advisine a T3 T. ofe viola t irn. -

7 If you believe you have a claio under this standard you aust fAle your cla La w4 thin tilie ty da.ge of the a leged dascriminatory action, wath tee tange and mour Division of the amployment standards Administration of the U.S. Department of tator. For more information, call GAP

• at the numbers listed.

Within thirty days of receiviaq a complaint, the Department of tenor util investagate the complaint and render a decision, as it has recently at other nuclear poemt plants. Me Department of

_ Labor can order the reanstatement of workers fired for engaging y la ' protected activity * (with back pay). The Department of tator can also order the employer to stop haraestag employee's.

mr Whether there mes a retallatory active behind an employer's F actions is a legal conclueton, and can be proven by F etreumstantial evidence. Retallation need only have toen one

~

. hgor m aJa for tae amployee to recover.

Some factors that have suppoeted findtags of rats 11ation include: -.

t Close prostaity in time betwee the protected

, activity and the alleged discrimination. Ttme tags g of oma month.to s&s days have suppcrted claims of .

g retaliattoa.

p V

a t Disregarding seniority. ..

? !aconsistent or shifting management esplanstione Ei of why they dad dat they sid.

t me contents of the Oh report, and its implications of a Oh report, the greater the employer's motivetton to retaliate agaanst the employee.

r S e following are some management-proposed defenses that have been rejected by the Department of Labors t seanagement permission, or even orders, to file a Oh report, af carcumstances show thets d&sapproval - -

of the contents of the report.

g

- t Se fact that other employees who engaged in protected activaty were not subjected to personnel p action.

e?

t he f act that other empbyees who did not eng.ge F in protected activnty were subjected to identacal personnel action. This prevents the employer free

" simultaneously firing other people as a vehicle to E disguise the reprisal.

=_

De Government Accountability Project (CAP)e, a project of the Institute for Policy studies in tisshangtun, D.C., as gt, t a T GAP le a public interest group that

- part of the government.

protects distle-blowere in goverument and industry. Ghr to currently investigating the design and construction quality at Plant westle, unethes the unc is doing its som eiget, and detter coorgia power campany or its contractors are letting the esisters de their joes right.

-paa sees tarompattom on the Department of labor procese, or if you Tev7earormat&on that would and GAP in its on going investigation, call CAP in Washineton at (2021667-7904, or in Auguata, Georgia at (404)?24-4900. aat for tastie Price or Susan negister, r

r-g EXHIBIT "11"  :-

m-

FROM FACS TO LISA NEWMAN m m Don E. DeLono, PR MGR. GEORGIA POWER CO.

-~. WESTERN POWER DIVISION 0 404-526-3771 i x

F NEWS FROM BECHTEL For Release: IVIFDIATE [

Engineers and constructors For Further Inforrnation

Contact:

~

E.U.*$ "c$,'*c'A MOS Al Donner: (415) 882-3871 RECEfVED

-' ^

E- '

SEP0F1985  :

1 5 SAN FRANCISCO, August 30, 1985 -- A $101 million wrongful termination suit E I against Bechtel by former employee Elmo Earl Kent has collapsed in San {

E Francisco Superior Court af ter Kent failed to produce witnesses and wilfully

• )

concealed documents concerning his allegations.  :;

! Presiding Judge William E. Hullins barred Kent's case from trial unless  ;

Kent pays in full the $32,680 in fines levied by the court for violating court i h rules and concealing material evidence.

fl f 'Ihe ruling in favor of Bechtel Power Corporation came in part because two fj f

B top officials of the Governa.ent Accountability Project f GAP), Thomas Devine and Billie Garde, failed to. appear for scheduled deposition testimony on h

Q- i4f,. ip Q -m g Kent's behalf.  %' O m

& Kent is a former welding inspector for Bechtel who made sweeping =;

$ all'egations ,of welding defects on two nuclear power projects. He made the i f charges after his 1982 termination for twice failing to pass a standard -

E welder's examination.

[

Despite denials of Kent's allegations by Bechtel and the plant owners, and  :

[ independent and government investigations that revealed no substance to Kent's --

I claims, GAP promoted Kent and his allegations,in the media, to the Nuclear  ;

Regulatory Conreission (NRC), and to Congress. "

g Previously, Garde told Congress in a letter that "Mr. Kent is by far one of the most credible and honest individuals with whom GAP has had the j

E opportunity to work. Our investigation of his @alifications, professional i_

me:

experience, and contributions to the field of welding impressed us even more -

r than his humility and integrity." She added that Kent had " risen to a '

position of respect and confidence among his professional peers. His -

information is iron-clad." 4 I

w (more) k Principal Operating Companies of Bechtel Group,Inc.

I Bechtel Power Corporation .,

E Bechtel Petroleum, Inc. 4 g-- Bechtel Civil & Minerals, Inc. EXHIBIT "12" E

/ 2 r 2 a  :-c:so as e.n ti es s , ,2 w ,2 2 i.. a a 5___

E, 5 wrn NEWS FROM BECHTEL - 2 2

" GAP is imensely clever at developing publicity for its charges. But for the second time in two years, GAP has demonstrated the substance of its charges were not supported by the facts," according -to Steve Hock, trial ' '

counsel for Bechtel.

1,ast year Bechtel, at its own significant expense, dug up a large tract of Arizona desert to refute another GAP-supported charge that Bechtel had buried large quantities of tools.

"I hope that. Congress, the NRC and the news media in the future will carefully examine GAP-inspired attacks before treating them as factual," Hock added.

Kent filed suit against Bechtel in February,1983 through the law offices of Melvin M. Belli, Sr., which issued a press release announcing the suit.

The halt in the case came when the court barred Kent from proceeding with his suit until he pays the sanctions.

The court said in an order that " plaintiff Elmo Earl Kent willfully, intentionally, and in bad faith concealed material evidence," refused to answer interrogatories during the pre-trial discovery process, and did not cppear for a court ordered psychiatric examination.

Under standard court rules Kent and his counsel are required to identify witnesses who would testify for Kent and allow Bechtel to take sworn depositions from them. Kent named over 30 people he said would substantiate his allegations.

But Kent and his counsel ultimately supplied only one witness--and that person said under oath that Kent was not professional and did not understand welding and engineering codes.

Bechtel is considering further actions it may take in the matter.

I 1582H e

IXHETEr U 3.'.a c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'85 IG 13 m s

~aa.

Before the Atomic Safety and Licens_ing Board

-O';Qi

.c, a, : U, ,

In the Matter of )

) Docket Nos. 50-424 GEORGIA POWER COMPANY, Et al. ) 50-425

) s (Vogtle Electric Generating )

Plant, Units 1 and 2) ) .

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Joint. Intervenors' Motion for Reconsideration of this Bce.rd's Memorandum and Order on Summary Disposition of Contention 8 (Quality Assurance)".were served upon those persons on the .

attached Service List by depositing a copy of same in the United States Mail, postage prepaid, this 12th day of November, 1985.

Respectfully submitted, t

/s f p(t t1G 0 c NtL LLLLL G-

' James E. Joiner, P.C.

Coun'sel for Applicants DATED: November 12, 1985 4

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board E

F i

- In the Matter of ) -- - -

) Dockethos. 50-424 GEORGIA POWER COMPANY, Et al. ) 50-425

)

6 (Vogtle Electric Generating )

Plant, Units 1 and 2) )

SERVICE LIST

\

Morton B. Margulies, Chairman Douglas C. Teper 5 Atomic Safety & Licensing Board 1253 Lenox Circle 7 U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555

- Laurie Fowler Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety & Licensing Board Foundation i U. S. Nuclear Regulatory Commission 218 Flora Avenue, N.E.

I Washington, D. C. 20555 Atlanta, Georgia 30307 1

Bernard M. Bordenick, Esquire Tim Johnson

[ Office of Executive Legal Director Campaign for a Prosperous b U. S. Nuclear Regulatory Commission Georgia L A .~ g E Washington, D. C. 20555 1083 Austin Avenue, N. E. .,,'-"r.,

=

Atlanta, Georgia 30307 V

Atomic Safety & Licensing Board u.a-

.O.* -

Panel Docketing & Service Section D, . ' .

U. S. Nuclear Regulatory Commission Office of the Secretary g Washington, D. C. 20555 U. S. Nuclear Regulatory . d. 'Q:. .')J Commission  % = 9,7 Atomic Safety & Licensing Appeal Washington, D. C. 20555 N ./. c Board Panel o. : .-

U. S. Nuclear Regulatory Commission Bradley Jones, Esquire

,U N -

Washington, D. C. 20555 Regional Counsel 6 6 l,' <

U. S. Nuclear Regulatory f

_- Dr. Oscar H. Paris Commission [ ,(.i y',-

Atomic Safety & Licensing Board Suite 3100 . . . .; 5 .'- l

=-

U. S. Nuclear Regulatory Commission 101 Marietta Street Washington, D. C. 20555 Atlanta, Georgia 30303 le

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