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Insp Rept 50-424/85-36 on 850930-1004.No Violation or Deviation Noted.Major Areas Inspected:Readiness Review of Operations Organization & Administration.Viewgraphs Entitled Readiness Review of Module 5 Encl
	ML20138A338
Person / Time
Site:	Vogtle
Issue date:	11/18/1985
From:	Julian C, Mccoy F; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20138A335	List: IR 05000424/1985036; ML20138A330;
References
	50-424-85-36, NUDOCS 8512110655
	Download: ML20138A338 (18)
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UNITED STATES

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NUCLEAR REGULATORY COMMISSION-f

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101 MARIETTA STREET, t ATLANTA, GEORGI A 30323

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Report'No.: 50 424/85-36 Licensee: . Georgia: Power Company P. O. Box 4545

' Atlanta, GA_ 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1

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Inspection Conducted: September 30 - Oc ber 4, 1985 Inspector: ' *

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F. R. KcCoy . Date Signed Approved by: b~ M-C. A. Julian, Atting Branch Chief

////[97 Wate/ Signed Operations Branch Division of Reactor Safety SUMMARY Scope: This routine, announced inspection entailed 24 inspector-hours on site in the area of readiness review of operations organization and administration (module 5).

Results: No violations or deviations were identifie $$k21kDay 2

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REPORT DETAILS Persons Contacted Applicant Employees

- - H. P. Walker, Manager, Unit Operations

C, E. Belflower, Quality Assurance Site Manager

J. D'Amico, Superintendent of Regulatory Compliance

J. E. Swartzwelder, Acting Superintendent of Training

G. F. Trudeau, Assistant Readiness Review Manager

- - H. Varnadoc, Readiness Review Team Leader

S. A. Bradley, Readiness Review Team Leader

T. Nicklin, Regulatory Compliance Supervisor

- C. W. Hayes, Vogtle Quality Assurance Manager

- G. Bockhold, General Manager, Vogtle Nuclear Operations

- W. C. Ramsey, Readiness Review Program Manager

- P. D. Rice, Vice President and General Manager, Quality Assurance

- G. C. Bell, Readiness Review Quality Assurance

- D. O. Foster, Vice President and Plant General Manager, Vogtle Other applicant employees contacted included engineers, technicians, and office personne NRC Resident Inspector

J. F. Rogge

Attended exit interview

- Attended \'ogtle Management Meeting of October 21, 1985

- - Attended toth the exit interview and Vogtle Management Meeting of October 21, 1985 Exit Interview The inspection scope and findings were summarized on October 4,1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the applican On October 21, 1985, the applicant presented to Region II management their assessment of the scope of the problem associated with the inspection findings based on additional Georgia Power reviews and presented corrective actions being taken to prevent recurrence of this type of proble A summary of this management meeting is delineated in paragraph 10 of this repor The applicant did not identify as proprietary any of the materials provioed to or reviewed by the inspector during this inspectio . - - -- . - . - . . . . . . - .- - . -_- .- - - - . _ .. . . , . -- -

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t Applicant Action on. Previous Enforcement Matters

.This subject was not addressed in the inspection.

' Unresolved. Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One unresolved item was identified which involved improper verification of comitment implementation during the Georgia Power readiness review and improper verification of comitment implementation with the

comitment tracking system. This item is discussed in paragraphs 5 and 6 of the report.

, Improper . Verification of Comitment Implementation by Vogtle Reviewers During Readiness Review b .The inspect!or reviewed Vogtle procedure 00002-C, Plant Review Board - Duties

.and Responsibilities, to verify that selected FSAR and proposed Technical

, . Specification comitments associated with the Plant Review Board (PRB) were i in fact properly implemented into procedure 00002-C pursuant to the >

readiness review module 5 implementation matrix. Six comitments were i determined by the inspector to not be implemented in procedure 00002-C at all. These comitments were:

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FSAR section 12.1.1.2: To verify that the overall radiation protection

. program is functioning properly, the PRB will review the written reports from audits of the ALARA progra '

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FSAR section 14.2.2.4: The members of the PRB will review the startup test results. Test results that are not satisfactory will be resolved under the . direction of the PRB prior to test acceptanc Once acceptance criteria have been met to the board's satisfaction, the members will recommend that the plant manager or designee approve the test as complete. Completed tests will become part of the permanent

. plant recor (This is in actuality two comitments in the readiness *

review module 5 implementation matrix; however, to maintain consistency with Georgia Power readiness review checklists, it is presented as a single comitment.)

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FSAR section 14.2.2.4: The PRB will review startup test results prior to management approva .

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. FSAR section 17.2.3: The PRB shall review all proposed modifications to safety-related systems to determine whether an unreviewed safety question (10CFR50.59)isinvolve Technical Specification 6.7.1: In the event a safety limit is violated the NRC operations center shall be notified by telephone as soon as F

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. possible within one hour. The Vice President and General Manager, the PRB, and the Safety Review Board (SRB) shall be notified within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Technical Specification 6.7.1: The Safety Limit Violation Report;shall be. submitted to' the NRC, SRB and Vice President and General Manager, Nuclear Operations within 14 days of the violatio A r.eview of _Vogtle readiness review checklists for module 5 reflected that c one reviewer had . verified that five of these six. comitments were imple-

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mented in procedure 00002-C,_ and another reviewer had verified that one o the six comitments was implemented in procedure 00002-C. An interview with the reviewer who had verified five of the comitments reflected that an

. improper and inadequate interpretation was involved in conducting that

.particular review and verification. Specifically:

- :With regard -to the FSAR 12.1.1.2 commitment that the PRB will review written reports from audits of the ALARA program, the . reviewer stated that his ' basis for verifying that this commitment was implemented in procedure 00002-C was that procedure 00002-C paragraph 2.1.a.(1)

established the PRB as responsible for review of procedures which _ .

establish plant-wide administrative controls to implement the quality assurance program or Technical Specification surveillance program.: The inspector- does not consider this -procedural requirement to be related to the comitment in questio With _ regard to the FSAR 14.2.2.4 commitment that the PRB will review startup test results, that test results that are not satisfactory will be resolved under the direction of the PRB, that once acceptance criteria- have been met to the board's satisfaction, the members will

- recommend that the- plant manager approve the test as complete, and that completed . tests become part of the permanent plant record, the reviewer's basis for verifying implementation of -this commitment in procedure 00002-C is considered to be unsatisfactory.- The reviewer stated that that since procedure 00002-C, paragraph 2.1.c., established the PRB as responsible for review of all proposed tests and experiments that affect nuclear safety, he considered that_ this-satisfied the comitmen The inspector considers that " proposed tests" are independent of " test results" and that paragraph 2.1.c. of procedure -

00002-C does not implement this commitmen ~

. FSAR 17.2.3 comits that the plant review . board shall review all proposed modifications to safety-related systems to determine whether an unreviewed safety question (10 CFR 50.59) is involved. The reviewer stated that his basis for verifying that this commitment was

. implemented in ' procedure 00002-C was that procedure 00002-C, paragraph 2.1.b(2), established the PRB as responsible for review of. proposed procedures and changes to procedures, equipment, or systems, which involve an unreviewed safety question as per 10 CFR 50.59. The

' inspector considers this basis for verification to be unsatisfactory since Vogtle uses independent safety evaluation reviewers to determine

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if unreviewed safety questions exist and only submit to the PRB those items which are considered by the reviewer to constitute an unreviewed safety question. Consequently, a safety evaluation indicated that an unreviewed safety question did not exis This could result in a proposed modification not being submitted to the PRB and, as such, preclude the PRB from determining the applicability of an unreviewed safety questio Proposed Technical Specification 6.7.1 requires that in the event a safety limit is violated, the NRC operations center shall be notified by telephone as soon as possible within one hour. The Vice President and General Manager and the PRB, SRB shall be notified within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The reviewer stated that his basis for verifying that this requirement was implemented in procedure 00002-C was that paragraph 2.1.f of procedure 00002-C establishes the PRB as responsible for reviewing all reportable events. The inspector considers this basis unacceptable since it is not related to when the NRC or Vogtle management is notified of a safety limit violation. Additionally, the inspector does not consider that procedure 00002-C is the most apprcpriate document for implementation of this requiremen Proposed Technical Specification 6.7.1 requires the Safety Limit Violation Report shall be submitted to the NRC, SRB and Vice President and General Manager, Nuclear Operations, within 14 days of the violation. The reviewer stated that his basis for verifying that this requirement was implemented in procedure 00002-C was again that paragraph 2.1.f of procedure 00002-C established the PRB as responsible for reviewing all reportable event The inspector considers this basis to be unsatisfactory since it is not related to when or to whom a Safety Limit Violation Report is submitte Additionally, the inspector does not consider that procedure 00002-C is the most appropriate document for implementation of this requiremen The inspector informed the applicant's management that this finding casted some doubt on the credibility of the Vogtle readiness review of module 5. The applicant committed to accomplish the following actions in order to try to re-establish credibility in the review of this module:

- Identify that the commitments are properly implemented in other documents and take action to ensure that each of these comitments are properly implemented in a designated documen Perform sample review of the module 5 implementation matrix commitments, and implementing documents in order to determine the extent of the proble Perform a sample review of the review work accomplished by the reviewer involved with this problem to determine if similar problems existed elsewher _

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The inspector noted that sample sizes should be identified and, for action (3), considered that a 100% review was appropriate. This finding was identified as an unresolved item (424/85-36-01).

6. Commitment Tracking Program A review was conducted of the implementation of the Vogtle commitment tracking program as defined in procedure 00405-C, Commitment Identification, Tracking, and Implementation, and as defined in paragraph 4.9.1 of readiness review module 5. The commitment tracking program was found to be imple-mented in accordance with procedures and the programmatic aspects were considered by the inspector to be satisfactor One problem was noted in that a regulatory compliance staff member had verified and inputted as complete into the computer that a commitment, for the PRB to review all proposed modifications to safety-related systems to determine whether an unreviewed safety question was involved, was implemented in procedure 00002-C when in fact it was not. An interview with the staff member who performed the verification reflected that his basis for verification was an improper interpretation of paragraph 2.1.c (the PRB will review proposed tests and experiments that affect nuclear safety), and 2. (the PRB will review changes to Technical Specifications) of procedure 00002-C. The inspector noted that the staff member was a new employee with Leorgia Power and that his prior experiences were with another license The inspector noted that this finding would be identified as a portion of unresolved item 424/85-36-0 . Surveillance Test Tracking The inspector noted that surveillance test tracking was not sufficiently developed to warrant a detailed review. Specifically, a surveillance test tracking program has not been selected for use at Vogtle at this time and substantial revision is required for procedure 00404-C, Surveillance Test Tracking, before a program can be implemented. The applicant indicated that a program should be developed by March 198 Additionally, the applicant indicated that, where plant conditions allowed, it was expected that each surveillance procedure would be performed prior to licensing and that in all cases, after preoperational testing, the surveillance procedure would be walked down jointly by test and operations personnel as part of system turnover to operation . Operations Assessment Program An inspection was conducted of the implementation of the Vogtle operations assessment program as defined in readiness review module 5, paragraph 4.9.3, and as defined in procedures 00414-C, Operations Assessment Program, and 80009-C, Operations Assessment Program - Coordination. This inspection focused on the coordination, tracking and processing of operating experience requiring evaluation and/or action. The inspection did not address the processing of operating experience with regard to training and required

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reading. Within the areas inspected, the program was found to be imple-mented in accordance with procedure. The programatic aspects of the Vogtle operations assessment program were considered to be satisfactory and in compliance with item I.C.S. of NUREG-0737. Staff and supervision associated with this program appeared to be comitted to proper implementation of this progra One area of concern was noted in the evaluation of operational event report An inspection of selected responses to operational event reports indicated a tendency for the applicant to address issues programmatically rather than technicall As an example, IE Information Notice 85-23 identified inadequate surveillance testing at another facility which failed to detect' the inoperability of the over power delta temperature (0PWT)

reactor protection function and also which failed to detect the inoper-ability of a safety system due to improperly connected differential pressure instruments. The applicant's evaluation of this operational event report addressed only the program controls associated with ensuring performance of testing following work on a given component, utilization of maintenance work orders, and review of the work and testing performed. The technical aspects associated with defining what is an adequate . test for ensuring operability of the OPWT function and for ensuring operability of differential pressure instruments were not addressed in the applicant's evaluation. The inspector considers these particular examples significant in that another Region II facility recently experienced the same OPWT problem and a Region III facility recently experienced a similar problem with improperly connected differential pressure instruments. The inspector did not consider that the

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applicant's evaluation and actions with respect to this operational event report would preclude similar occurrences at Vogtl The applicant comitted to reopen and reevaluate IE Information Notice 85-23 in light of this assessment and additionally comitted to evaluate the preoperational testing associated with differential pressure instruments in order to ensure that full operational capability is demonstrated for normal operating conditions during performance of these test Pending completion of these comitments and pending further inspection to determine if future evaluations are technically thorough and adequate, this item is identified as an inspector followup item (424/85-36-02). Performance of Safety Evaluations and Duties and Responsibilities of the Plant Review Board The inspector reviewed - the applicant's program for Plant Review Board functions and performance of safety evaluations as defined in proposed Technical Specifications, paragraph 6.5.1, readiness review module 5, paragraph 4.1.1.4, and procedures 00056-C, Safety Evaluations; 00051-C, Review and Approval of Procedures; and 00002-C, Plant Review Board - Duties and Responsibilities. The inspector noted that, although the approach for utilizing the Plant Review Board is different from that experienced at other-utilities and different from that addressed in Westinghouse Standard Technical Specifications, it is in compliance with section 4.4. of ANSI N18.7-1976 and appears to be satisfactory. The Vogtle Plant Review Board is staffed at a lower level of management than that recognized by Westinghouse

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- Standard Technical Specifications, but this level of staffing is considered

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material. With respect to review of specific material, some procedures

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delineated in Westinghouse Standard Technical Specifications are not r

required to be reviewed by the Vogtle Plant Review Board. For example, j maintenance procedures, surveillance procedures, system operating procedures

and changes to these procedures do not require review by the Plant Review Board unless it has been determined that an unreviewed safety question or Technical Specification change is involved. This determination is made by an independent safety evaluation reviewer and his supervisor in accordance with procedure 00056-C, Safety Evaluations. The applicant stated that they

had, comitted to a safety evaluation reviewer qualification program in

response to NRC questions associated with NRR review of FSAR chapter 1 The inspector reviewed the checklists for regulatory compliance safety evaluation reviewers and confirmed that such a qualification program was

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implemented for reviewers in that department. The inspector considers that

- the applicant's method for performing safety evaluations and utilizing the

Plant Review Board 'is in compliance with regulations and is adequate. The

inspector did note that procedures 00056-C, Safety Evaluation, and 00051-C,

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Review and Approval of Procedures, did not specifically state that if the

safety evaluation reflected that an unreviewed safety question or Technical Specification change existed, the safety evaluation and change would be j

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submitted to the Plant Review Board for review. The inspector considers ;

, that one of these procedures should be revised to specifically delineate

, this requirement. This will ensure full compliance with procedure 00002-C requirements which establishes the Plant Review Board as responsible for-i review of proposed procedures and changes to procedures, equipment, or l' systems which involve an unreviewed safety question as per 10 CFR 50.59.

Resolution of-this concern is identified as an Inspector Followup Item (424/85-36-03).

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As noted in paragraph 5 of this report, several examples were noted where 1- specific comitments and proposed requirements were not delineated within L procedure 00002-C when readiness review indicated that they were.

j Satisfactory implementation of these specific commitments and requirements j' into procedures is recognized as a necessary part of corrective action ,

associated with the resolution of unresolved item 424/85-36-01.

. 1 Summary of Georgia Power Management Meeting of October 21, 1985, Concerning Deficiencies Noted During NRC Inspection of Readiness Review Module 5 I-, On October 21, 1985, the applicant presented to Region II management the results 'of their assessment of deficiencies noted in paragraph 5 of this repor Figures 1 through 8 (attached) represent slides presented by Georgia Power during the course of the presentation. The applicant stated that extensive rereview, subsequent to the NRC inspection, had been performed by Georgia Power in order to define the bounds of the problem and in order to formulate appropriate corrective actions. The applicant stated that . ' a 100% rereview was performed on the commitment matrix and

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implementation matrix of module 5 and a 50% rereview was perfonned on the

. verification process of module. 5. Additionally,10% of each commitment

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matrix and at least 10% of each implementation matrix for modules 1, 2, 3A, 4, 7, 8 and appendices D and I were rereviewe The applicant stated that the results of their review indicated that:

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Although some commitments may not have been specifically delineated within commitment matrixes, in all cases redundant commitments ensured that the subject matter of the comitment was identified and tracke The verification process of module 5 was satisfactor The implementation matrix of module 5 was deficient in that 32 of the 260 comitments (12%) were either not implemented by procedure at all, or were not implemented by the specific procedure identified by the matrix, but were implemented in other documents. Additionally, in 107 of the 260 commitments (41%) the comitments could have been more precisely implemented by the procedure specified or other documents should also have been identified within the matrix. The remaining 121 commitments (47%) were determined to be completely satisfactory within the implementation matri The implementation matrixes for the other modules reviewed had some minor discrepancies which involved " umbrella" procedures not completely delineating some particular comitments. The applicant indicated that they considered these discrepancies to be isolated and concluded that they were not indicative of the problems noted with module The applicant stated that in the case of modules 1, 2, 3A, 4, 7, 8, and appendices D and I, different team leaders with different review techniques from that used in the module 5 review were initially employe Additionally, in some cases, even the discipline managers and *nspection processes a re different. The applicant stated that in the case of module 5, the verification process was initiated prior to full development of the implementation matrix, and commitments for module 5 reviewers were previously categorized to " umbrella" procedures prior to the review taking plac Consequently, the applicant considered that seeing the commitments actually being implemented may have erroneously led the reviewers to conclude that a given umbrella procedure adequately delineated specific comitments when in fact it did no For these reasons, and as a result of the rereview, the applicant concluded that the problem was isolated to module 5 and, specifically, the implementation matrix of module 5, and considered that the root cause of the problem with module 5 was insufficient guidance for reviewers performing implementation verification and insufficient feedback to ensure reviews were being properly performed. The applicant stated that an addendum to module 5 would be submitted which would correct deficiencies within the module. Additionally, the applicant stated that the following corrective actions were being implemented to prevent recurrence of this type of problem:

- Discipline manager and team leader overview would be expanded, team training would be enhanced, readiness review administrative procedures

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would be strengthened, and a policy statement for line organization responsibility would be issued in order to ensure reviewers fully understood what was expected of them during the course of their revie The readiness review teams would review the implementing matrix in detail with the cognizant operational superintendent to ensure complete understandin Management would review more thoroughly the experience and qualifi-cations of personnel assigned specific readiness review function Quality assurance involvement with readiness review would be expanded Following receipt of the module 5 addendum, the NRC will rereview module 5 and the process and results of the applicant's rereview of modules 1, 2, 3A, 4, 7, 8, and appendices D and I in order to determine if the applicant has properly bounded this problem, and if corrective actions taken in response to this problem are adequate. This is identified as an inspector followup item (424/85-36-04).

Attachments:

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NRC INSPECTION REPORT 50-424/85-36 FIGURE 1

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READINESS REVIEW OF MODULE 5 FOR: UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II - SUITE 2900 101 MARIETTA STREET, ATLANTA, GEORGIA 30323

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BY: GEORGIA POWER COMPANY VOGTLE ELECTRIC GkNERATING PLANT P.O. BOX 1600 WAYNESBORO, GEORGIA 30830

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OCTOBER 21,1985

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NRC INSPECTION REPORT 50-424/85-36 FIGURE 2 ,

S, AGENDA ,

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e INTRODUCTION D. O. FOSTER

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e INVESTIGATION RESULTS W. C. RAMSEY H. P. WALKER

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e SUMMARY D. O. EOSTER

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FIGURE 3 READINESS REVIEW .

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VICE PRESIDENT

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A33hRANCE PROGRAM REPRESENTAllVE MANAGER

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NRC INSPECTION REPORT 50-424/85-36 FIGURE 4 l

INVESTIGATIVE PLAN

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NRC INSPECTION REPORT 50-424/85-36 FIGURE 5 INVESTIGATIVE ACTIVITIES S INTERVIEWS e EVALUATION -OF MODULE PROCESS

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e TRAINING OF TEAM MEMBERS e READINESS REVIEW QUALITY ASSURANCE REPRESENTATIVE ACTIVITIES .

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8 EVALUATION OF MODULE AND

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REVERIFICATION PROCESS DESCRIPTIVE MODULE

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NRC INSPECTION REPORT 50-424/85-36 FIGURE 7 M'ODULE 5 REVERIFICATION RESULTS e IDENTIFICATION OF IMPLEMENTING DOCUMENTS I

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