IR 05000424/1987069

Insp Repts 50-424/87-69 on 871130-1204,14-18 & 880105. Violations Noted.Major Areas Inspected:Qa Effectiveness

ML20149G325
Person / Time
Site:	Vogtle
Issue date:	02/02/1988
From:	Belisle A, Mellen L, Moore R, Runyan M, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149G314	List: IR 05000424/1987069 ML20149G311 ML20149G318
References
50-424-87-69, NUDOCS 8802180226
Download: ML20149G325 (27)

Text

-

-

• . .

UNITED STATES

/pm si' Coq'o, NUCLEAR REGULATORY COMMISSION

[\ ' t' '.,

RE GION Il

• '

.. #. j 101 M ARIETTA STF4E ET, ATL ANTA, GEORGI A 30323 rt g, v j

.....

Report Nos.: 50-424/87-69 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 License Nos.: NPF-68 Facility Name: Vogtle 1

Inspection Conducted: November 30 - December 4 and December 14 - December 18, 1987 and January 5, 1987 Inspectors: / K_RC 2/2/89)

D Moore, Date' Signed l

?l llf

'

(7 i f'!::. A :. h, M. Runyan' ' / Dite Signed

/ '

l q , / ?? D i s l,/ :l: /h'

Date Signed L.'Mellen '

/

R. Wright f2L3 4 (J ablee Date Signed Approved by:  ! ' ,f.;Wz// ,

/

r// / ? *

A. Belisle,- Chief Date Signed Quality Assurance Programs Section Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of Quality Assurance Effect.ivenes Results: Three violations were identified: Failure to perform post-modification testing, f ailure to follow procedure 00150-C, Defici2ncy Control, and failure to return EQ equipment to qualified condition following maintenanc h2180226 880211 0 A OCN 05000424 DCD

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

$ o .

!

REPORT DETAILS Persons Contacted Licensee Employees J. Aufdenkampf, Engineering Department, Support Supervisor

• J. Beasley, Manager, Outages and Planning G. Beckhold, General Manager, VEGP

• Burns, Nuclear Licensing Manager W. Burwinkel, HVAC Engineering Supervisor E. Cobb, Nuclear Safety Review Board Manager

• Cross, Senior Regulatory Specialist ,

" Drinkard, QA Engineering Support Manager D. Dutton, Vice President, Generating Plant Projects C. Eckert, Technical Assistant to Plant Manager R. Folker, QA Engineering Support Supervisor

• Fredrick, Operations QA Site Manager R. Garret, Nuclear Steam Supply System Supervisor

• T. Greene, Plant Support Manager M. Griffis, Maintenance Manager

• C, Hayes, Vogtle QA Manager R. Heitz, Unit 1, QC Supervisor H. Jaynes, Plant Engineering Supervisor, Maintenance

'

R. Keys, Plant Design Engineering Group Supervisor

• W. Kitchens, Manager, Operations

• M. Lackey, Work Planning and Control Superintendent R. Lide, Engineering Support Superintendent

• C, Meyer, Operations Superintendent

• T. Moore, General Manager, QA

• A. Mosbaugh, Assistant Plant Support Manager W. Mundy, QA Audit Supervisor R. Odom, Plant Engineering Supervisor, NSAC M. Sheiban, Plant Review Board Support Supervisor

• D. Smith, Manager, Nuclear Performance and Safety

• D. Smith, Superintendent, Nuclear Operations

! *R. Spinnato, ISEG Supervisor

'J. Swartzwelder, Manager, NSAC

'

R. Thomas, Executive Consultant, Southern Company Services H. Varnadoe, Mechanical Engineering Supervisor

• Wagner, QC Superintendent Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personnel, i

NRC Resident Inspectors t

[ "C. Burger, Resident Inspector

• J. Rogge, Senior Resident Inspector l

!

l l

\, . .

• Attended exit interview Exit Interview The inspection scope and findings were summarized on December 18, 1987, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection findings listed belo No dissenting comments were received from the license Item Number Status Description / Reference Paragraph 424/87-69-01 Open Failure to return EQ equipment to a qualified condition following maintenance, paragraph /87-69-02 Open Failure to follow Procedure 00150-C, Deficiency Control, paragraph /87-69-03 Open Failure to perform post modification testing, paragraph Additional findings in the operational area related to the fire brigade manning requirements and minimum shift crew compliment are documented in NRC Inspection Report No. 50-124/87-7 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio Note: A list of abbreviations used in this report is located in the last paragraph of the repor . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items

Unresolved items were not identified during the inspectio . Quality Assurance Effectiveness The objective of this inspection was to assess Quality Assurance Effectiveness. For this report, Quality Assurance Effectiveness is defined as the ability of the licensee to identify, correct, and prevent prcblems and is not limited to the licensee's Quality Assurance organizatio Quality Assurance Ef fectiveness is the aggregate of all efforts to achieve quality result This was a performance-based rather than compliance-based inspection in that the principal effort was to determine whether the results that the

i .

Quality Assurance Program were designed to accomplish were actually achieve The scope of this assessment was Unit 1 activities since issuance of the low power license on January 16, 198 Informatisn for the inspection was derived from licensee personnel interviews, trend and analysis data, licensee audits /surveillances and findings, real time activity observation, and activity historical documentatio The inspection effort was divided into the following areas:

Design Control QA/QC Maintenance Safety Review Board Operations Each area is addressed separately in this report. Due to problems in the early stages of this inspection an overall operations functional area assessment was inconclusive. Apparent problems with respect to Fire Brigade Commitments and minimum shift manning requirements resulted in a concentrated effort in this area as well as the initiation of a fire protection inspection which is documented in NRC Inspection Report No. 50-424/87-7 Noted was the licensee's immediate corrective action to establish a minimum shift crew compliment that did not impact the fire brigade manning requirement exclusive of the shift crew compliment. This action was documented by a memorandum dated December 12, 1987, from the Operations Superintendent to all on shift operations supervisor This area is discussed in paragraph 1 . Design Control An assessment of the design control area was conducted through an in-depth review of DCPs, temporary modifications, RERs, and SORS selected on the basis of their importance to safety. Some questions generated by this review lec to inspection outside the design control are At the Vogtle site, all design change development is either assigned to an onsite consultant group, the PFE-0, or to an of f site consultant. The PFE-0 staff conducts their activities in accordance with the operations phase engineering procedures which were developed by the consultant, Bechtel Western power Corporation. Therefore, an interface exists between the licensee's cesign control procedures and those of PFE-0. Some design changes are handled through the corporate Engineering Liaison staff; others are handled directly between the site licensee staf f and PFE-0, depending on the design complexity and the onsite expertise availabilit All design changes reviewed during this inspection were performed by the onsite consultant grou The site Quality Assurance staff conducted a design control audit dated August 31, 1987, which identified that temporary modifications were not being properly controlled, quality reviews of temporary modifications were not routinely being performed, the shif t supervisor was not identifying active temporary modifications on shift turnover logs, temporary

. .

,

i

modifications were being installed without any review or concurrence by design engineering, and the program was allowing temporary modifications to remain in effect indefinitel Corrective actions for these deficiencies included rewriting the temporary modifications procedure to change the review frequency from four months to three months and to change the review responsibility from operations to engineering. Additionally, temporary modifications can remain in effect greater than 90 days only if approved by the Engineering Support Department Superintenden System engineers were trained on the new procedure on November 2,198 This corrective action was prompt and effectiv Other problems documented by the QA audit included the following:

Some as-built notices were not available in the control roo Two engineering reviews for DCPs were inadequat Some Engineering Support Department procedures did not meet all ANSI N45.2.11-1974 requirement The corrective action scope and implementation for these and other deficiencies identified during the audit appeared adequat .

The following completed DCPs were reviewed in depth to determine compliance with licensee procedures, ANSI N45.2.11-1974, and good engineering practices:

DCP N Description 86-VIE 006 Auxiliary Feedwater Pump Discharge Valve 86-VIE 007 Motor Driven Auxiliary Feedwater Mini Flow Valve 87-VIE 0020 ESF Filtration Units 87-VIE 0057 CVCS Letdown and Letdown Orifice Isolation Valves 87-VIE 0069 ACCW System Design Error on NRC Card 0863

,

The MW0s which implemented the above DCPs were also reviewed as they contained post-modification test results, procurement documents, and QC inspection PFE-0 documents including the design input and design calculations for each DCP were also reviewed. The inspector identified a weakness in that relevant information for each DCP was not maintained together but in three separate physical locations (DCP, MWO, PFE-0 documents).

The safety evaluations for each DCP were reviewed, and although they were considered adequate, some were marginal in quality. An example is the safety evaluation performed for DCP 87-VIE 0069, which involved installing

'

wiring associated with a test channel for the RCP thermal barrier cooling water isolation. In response to the typical 10 CFR 50.59 questions such

_ _ _ _ _ _ _ _ _ - ___ .

< . . .

as, "Does the proposed change increase the probability of an accident or decrease the margin of safety as described in the FSAR or TS", the repetitive justification given was simply that the test channel is not addressed in the FSAR or TS. The fact that a component is not mentioned in the FSAR or TS does not mean that a modification to it could not be important to safety or impact a safety-related component. Modifications have to be reviewed on their own merit and not be construed to be insignificant based on lack of mention in the FSAR or TS. This issue was discussed with licensee personnel who stated that the performance of safety evaluations has been a weak area but that through heightened awareness, the more recent safety evaluations have improved. A quick scan of recent safety evaluations corroborated this positio Another problem area involved the DCP traceability to the original discrepancy which identified the proble In most cases, it was not possible from simply reading the DCP to determine the original discrepant condition details, nor was reference made, in most cases, to a DC or other problem identifying document. The licensee had previously recognized this problem and has instigated a cross-reference system on their master DCP listing.

l In general, cognizant personnel training on design changes appeared adequate, though in the case of DCP 87-VIE 0057, the decision to forgo training appeared questionabl This design change installed need:e valves in the air supply and actuator exhaust tubing to set the open and close stroke times of the CVCS letdown and letdown orifice isolation valves. Though training for this modification may not have been critical l from a safety standpoint, good conservative practice would have included

i Design calculations and the design input record for each DCP reviewed were kept separately in PFE-0 files. The Inspector verified that the design input for each DCP fully met ANSI-N45.2.11-1974 requirement The inspector selected two stress calculations for DCP 87-VIE 0057, 1X50Y00460-B and 1X5DY00459-B, for a detailed technical revie Individuals responsible for calculations were asked to justify all assumptions, specifications, and acceptance criteria upon which the calculations were base Mathematical accuracy was also checked. No discrepancies were identified and the engineers questioned wcre knowledgeable and confident of the calculation result QC involvement during modification in:tallatin appeared comprehensive with many QC signof f s and holdpoints. .%t modification testing results appeared adequate with the exception of DCP 86-VIE 007, where the closing time for the auxiliary feedwater mini-flow valve was tested and accepted at 17.02 seconds despite a specified closing time of 15 seconds, on the DCP drawing modification sheet. However, this was identified as a finding during the most recent QA audi A subsequent engineering analysis determined that the 15 second specification was overly conservative with respect to the TS requirement. Corrective action for this finding is in progress,

_ _ _ _ _ _ _ _ _ _ .

,

. . .

It appeared that all necessary reviews, including the independent design verification, had been performed. The design package closure checklist ensures that all necessary actions had taken place prior to DCP closur The following safety-related temporary modifications vere reviewed:

1-87-353 Seal off Auxiliary Building During Painting 1-87-356 Prevent Low Differential Pressure Signals from Loop APD 12567/12568 1-87-366 Biock Open Watertight Door and Install Air Leck 1-87-398 Dynamic Absorber Installed on Diesel Fire Pump 1-87-403 AFW Pump Speed Indicators 1-87-446 Eliminate Possible RHR Pure Loss Scenario The inspector reviewed documentation and discussed resulting questions with the responsible engineer for the above listed temporary raodi fication The disposition of these items was consistent with the corrective actions committed to in response to the QA audit findings in this are Several temporary modifications had exceeded their original expected duration, but in all cases, action to precipitate closure was in progres As in the case of DCPs, some safety evaluations for temporary modifications were marginal but they appedred to meet 10 CFR 50.59 requiretent Two temporary modifications revealed previous design control deficiencies. Temporary modificnion 1-87-446 involved rewiring cable ta allow continuously running the RHR Pump Train B room cooler because the high temperature fan start switches for both trains were in the same fire zone, threatening a loss of both trains. This resul'ed from an original design error and an oversight during the fire separation walkdown. Temporary modification 1-87-403 involved downsizing a resistor in the turbine driven AFW pump speed indication circuit. The failure of I this circuit resultad from a design error and failure to perform a post-modification functional test during the pre-op phase. Thi: incident is discussed further at the end of this section, i

The inspector reviewed the following RERs for procedural compliance and l

engineering judgments, selected on the basis of their importance to safety:

l 87-1136 Containment Penetration 87-1167 CVCS Stress Calculations ( 87-1198 Cable Separation Criteria l Clarification 87-1209 Tendon Grease Techn1 cal Specification Change

- _ _ - _ - _ - _ _ _ _ _ ._ . _ _ . _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ .. --

- _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

• . .

87-1224 Structural Integrity of Control Building-Each technical position talea cr justifications for continued operation presented for the above RERs was technically well supported and was reviewed by all individuals require _

lhe inspector reviewed -the following SORS involving engineering discrepancies to assess the adequacy and timeliness of the technical response and conclusion Incorrect instrument setpoints 1-87-838 Inaccurate drawings 1-87-841 Parts supplied not 1E qualified 1-87-875 FCRs not worked \

-

1-87-971 Fan failed ANSI criteria 1-87-1018 ESF room coolers inadequate 1-87-1381 Sample pcin+ design inadequa;e 1-87-1383 Door haza'rd due to poor ventilation- ,

1-87-1485 Fire dampers with non-seismic fusible links 1-87-1487 DG cuatrol problem 1-S7-1488 Stress calcelation cased on incorrect valve weight 1-87-1489 Stress calculation based on incorrect valse weight 1-87-1763 Containment penetration breakers inadequate 1-87-1862 Ventilation fan does not function as '

designed 1-87-1985 Auxiliary Waste Gas Valves failed to close 1-87-2056 Inadequate overcurrent protection 1-87-236P OG control panel damroad insulation 1-87-?447 Fire separation die" ancy 1-87-2506 '

Core Exit thermocoupte junction box not R)

1-87-2523 Auxiliary Feedwater Pumphouse flood see.'a inadequate 1-87-2616 Potential for reactor trip breaker weld failures 1-87-2757 Potential for reactor trip switchgear cell switch failures -r A problem observed with the handling of SORS was that there did not exist a positive . tracking mechanism to ensure tirely response The 50Rs reviewed were sent to the Engineering Support D9partment with a nominal 30-day response requirement; however, this 30-day requirement was not monitored. The existing program could allow an individuai SOR to. remain open indefinitely since there is no mechanism which would identify it as overdue; The responses by engineering were timely, however, even in the absence of a tracking syste Licensee personnel stated that a positive tracking mechanism for SORS would be included as part of a j major program enhancement to become effective early next year'(1988),

.

"

- - - - - _ _ _ _ _ - . _ _ _ _ . _ _ _ . _ _ _ _ _ _

. _ _ _ _ _ .

. . .

'

1

Interviews were conducted with responsible engineers for some SOR responses to obtain clarificatio Among the issues raised were 10 CFR Part 21 applicability, 10 CFR 50.73 reportability, root cause evaluation, csiculational methods, use of resulting temporary modifications, and current status (for open SORS). In all cases, responsible engineers provided reasonable justification for all actions taken and were knowledgeable and up to date with the issue Within this area, one violation was identified. During the preoperational phase, a violation of electrical separation criteria in the Terry Turbine AFW Control Panel was documented on ODR T-186-261 '

The Class 1E circuitry was not properly isolated from the non-1E sid under CCP B10301J, and implemented by MWO 18620139 a signal modulator,

.aemndulator, and new converters were installed. A five-thousand ohm (KQ)

resirtor was placed in the circuit to provide the proper running current of 0-1 milliamp for the turbine speed indicato The original FT was lined out on CCP B10301J on November 23, 1986, and revised to state, "N/A, will be completed on CAT 85-632". Work was completed and the MWO was closed out on November 23, 1986. On February 25, 1987, it was discovered during a surveillance test that there was no indication of turbine speed in the control room or on auxiliary shutdown panel MWO 18703326 was issued to troubleshoot and repair the circuit and after several trials and errors, it was discovered that the lack of turbine speed indication was due to the five Kn resistor being oversized. A temporary modification (1-87-167) was issued on May 6, 1987, which replaced the five Kn resistor with a 2.5 KQ resistor per MWO 18705895. The revised circuitry was tested satisfactorily on May 11, 1987. Even though the portion of the circuit involved is non-Class 1E, a violation is still warranted based on a procedural violation of SUM-22, Maintenance Work Orders, Revision 16, Section 6.7 testing, which requires FTs where needed (to demonstrate that components are capable of performing their intended function) and the fact that the failure to perform the required FT resulted in a defective circuit and loss of turbine speed indication in the control room and

. auxiliary shutdown panel C for approximately two months of critical operations. Although this lack of speed indication did not violate the TS or FSAR, it was a condition that had some impact on safety. For example, Procaoure 18038-1, Attachment A, Turbine Driven AFW Pump Operation fr om aux M iary shutdown panel C used in the event of a loss of the control room, Step A.1.9, tells the operator to observe that pump speed is risin The speed indication on the panel would not have worked and required the operator to use an alternate indicator located in the pump room. Failure to perfort post-modification testing is identified as violation 50-424/87-69-0 . Quality Assurance / Quality Control Departments The purpose of the inspection was to assess the effectiveness of the VEGP operations QA0 and QCD to prevent, identify, and correct problems. To accomplish this, the project's audit, surveillance, inspection and work

.

monitoring nrograms, nonconformances trending programs, and arsociated l

.

&$

_ . _ _ _ _ _ - . _ . _ . _ _ _ _ _ . _ . _ - _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

- - --. . .- _- .

.. -

. .

.

reporting systems were reviewea. The evaluation concluded that the site operations' QA/QC programs was accom'plishing their assigned function of identifying, correcting, and preventing problem recurrenc This conclusion is based on the following observations, discussions with responsible management personnel, and documentation r eviews:

The QAD The audit / surveillance unit size and experience level is adequate. The inspector examined the qualitications and training records for the operations QA Site Manager and eight GPC QA audit / surveillance personnel and determined they were qualified in their areas of audit / surveillance expertis Auditors are qualified to QAD Procedure QA-03-05 R6, Qualification of Auditors, which implements ANSI N45.2.23 and RG 1.146 requirements. Their required training is discussed in Procecure QA-03-02 R14, Training and Personnel Qualification Auditors are generally assigned based on their expertis The site QAD utilizes corporate auditors to assist them in coordinated audits (areas common to the corporate office, Vogtle, Hatch, and Sherer) and to perform specific audits whenever their particular skills may be neede The site QAD s

maintains a ca rent QA and technical specialist personnel expertise matrix that identifies qualified audit tr members .from Vogtle, Hatch, Corporate, and Sherer to draw from 'eeded. A recognized strength in the licensee's audit program was the t casional use of outside technical consultants in specialized areas providing an impartial overvie The site has utilized Southern Company Services to perform their annual Fire Protection Audit (87-FP-2) and has already used or anticipates the possible use of consultants to assist them in the following specific audits:

Plant Chemistry Security Plan and Procedures Fire Protection - General Physics Emergency Plan and Procedures - Stu Bland Associates The NRC inspector accompanied a BPC contractor audit team member during his QA surveillance of various TSS test Discussions with this individual concerning test procedures and systems involved indicated that t he was well qualified to menitor the tests and knowledgeable of good audit / surveillance principal The following TSS tests were satisfactorily performed and observed with this contractor:

Surveillance Report Number Procedure N Title 1-TSS-87-061 14545-1, R2 Motor Driven '

AFW pump Monthly Test  ;

1-TSS-87-062 14807-1, R2 Motor Driven AFW pump Inservice Test

._ - _ _ . - _ _ _ . - -

.

--

- - . . .

( *

d g ,

10 1-TSS-87-063 14495-1, R2 AFW System Flow Path Verification 1-TSS-87-064 14825-1, R6 Quarterly Inservice Valve Test

'

A formalized audit / surveillance system was in place and adherence to schedules was adequate. QAD Procedures QA-05-01, R16, Field Audits, and i

QA-05-17, R3, QA Surveillances discuss advance audit / surveillance planning to assure adequate coverage of the Vogtle operations progra The inspector examined the VEGP audit planning and schedule matrices developed for January 1987 through June 1988, the latest tentative audit schedule covering the period January 1988 to June 1989, and the 1987 fourth quarter QA surveillance matrix. GPC surveillances are not intended to replace the formal QA audit program but are utilized to observe current work or an activity as it routinely develops and to fcilowup on previously identified problem area Consequently, surveillance scheduling is usually planned on a quarterly basis. The inspector determined that the 1987 audit and surveillance schedule contained satisfactory coverage of quality related activities and commitments contained in the FSAR and TS, and adherence to these schedules was adequat Audits /sitrveillances appear to be satisfactory in depth and scope and they identify ame relatively significant problems for management corrective action. The inspector reviewed the following audits /surveillances end their respective checklists / procedures that were performed in the VEGP operations area during 198 Audit Number Audit Title OP21-87/07 QA Audit of Corrective Action Programs OP21-87/26 QA Audit of Corrective Action Programs OP21-87/42 QA Audit of Corrective Action Programs OP21-87/43 QA Audit of Corrective Action Programs OP08-87/27 QA Audit of Quality Control Audit checklists for the above audits were prepared by the audit team and approved as required by the QA supervisor prior to audit commencemen Checklists utilized in these audits ranged from typewritten standardized checklists to first time, hand written specific operational ares requirement / attribute checklist Checklist items examined were audited to the depth and scope necessary to ascertain the audited activities compliance or noncompliance with the accepted QA program. The above five audits conducted resulted in ten substantive findings being identifie Discussions with other NRC audit team members who examined audits cor ducted in the maintenance, nuclear operations, and design areas confirmed that the audit program was also identifying significant technical problem issues in these areas for plant management attention and corrective actio The identification of issues with substance versus only documentation findings is ccnsidered another QAD strengt . - - -

, -

, ,

Audit OP26-87/26 is a good broad scope audit that examined the various department methods used for determining root cause of failures and/or operational incidents at Plant Vogtle and the corrective action effectiveness taken in preventing recurrenc Discussions with the QA site manager and cursory examination of some of the most recent audits conducted identified the audit program is working towards increasing the number of audits performed on actual events that are taking plac The fact that audits are becoming more performance based versus primarily programmatic / documentation based was identified as another QAD strengt Surveillances are conducted by the QAD as part of the routine tours of the plant site areas and activities, utilizing either standard checklists or the activity related specific procedures for review. Surveillances are performed by the QAD although there is no licensee requirement or commitment to do so in Section 17.2 of the VEGP FSAR. As of November 4, 1987, the QAD had conducted approximately 200 activity oriented surveillances and 58 QA TS test surveillances. The inspector examined approximately 35 completed surveillances and concluded that the QAD surveillance program was a positive factor (strength) in that it provided more performance based observations of plant activities which is desirable and it greatly augmented and enhanced the audit progra Discrepancies identified by QA audits /surveillances have received timely, appropriate corrective action. Examination of the QA Audit Finding Report Log system identified that it was extremely complex and unwieldy to us Additionally, it was not maintained up-to-date. Since there were other existing methods to determine the status of AFRs and the QAD is in the process of improving this logging system, this item was identified as a weakness. Approximately 137 AFRs were opened during 1987. Currently 37 of these 1987 AFR issues and one 1986 AFR are not resolved. However, 34 of these 38 AFRs are considered to be progressing satisfactorily to closur The four progressing unsatisfactorily were due to inadequate corrective actions taken for various task milestones. Based on the above current statistics, one would have to conclude that the AFR corrective action system has been very responsive and well controlled. However this was not always the cas Responses to AFRs by the audited organization have frequently exceeded the 30-day time frame, milestones in schedules were missed, responses were sometimes inadequate and rejected, and schedules were frequently delayed and change Consequently an undesirable backlog of open AFRs began to accrue during the third quarter of 1987. Recognizing the problem, the QAD implemented the escalated corrective action measures detailed in QA Procedure QA-05-01 and returned the AFR corrective action system to a satisfactorily, well managed, responsive syste Documentation (Interoffice Correspondence Logs NOV-00235, NOR-00762, 00A-87-429, OQA-87-465, and weekly AFR status updates from QAD to managers and supervisors) reviewed identified that the General Manager of Vogtle Nuclear Operations and his management staff were very responsive with the QAD in turning the problem around. Actions of this type give credence to active plant management participation, in that early managment involvement prevented a potential problem from escalatin ... - .- _

-- .

..

'

=

o .

,

.

The inspector examined closed QA surveillance findings87-012, 87-014,87-015, 87-016,87-018, 87-019,87-020, 87-023,87-025, 87-026,87-027, 87-029, and 87-032 and concluded that appropriate corrective action had been implemented for these deficiencie Mechanisms were in place to recognize and prevent recurring or repetitive discrepant conditions and that upper level management was aware, of these trends. QAD Procedure QA-05-20, R2, QA Trend Program, outlines require-ments for implementing a QA trending program. This provides management early indications of possible adverse trends identified in the QA progra The scope of QA's trend review includes NRC violations, operations QA Audit findings, QA surveillance findings and special findings such as those identified by INPO. Routine report distribution is to the GMQ The trend analysis reports analyze data for a three month period prior to each QAC meeting at which time they are presented to the committe The inspector examined the four quarterly QA operational trend analysis reports published for VEGP during 1987. The most significant adverse trend identified during that time frame was a dramatic increase in the total number of findings in the "Personnel Error" area during June, July, and August 1987 (third quarter). The increase in findings was attributed to several large scope assessment type audits (Security, Plant Chemistry, Valve Configura' ion Control, Design Control, and others) which were conducted due to management's concern of previously identified operations /

programmatic weaknesses. The QAD trend program should be recognized as a strength because it was successful in identifying the above adverse trend along with a few other minor trends and management was consequently able to take prompt, proper action to bring these adverse trends back into contro The QAD also keeps upper management aware of trends by their Monthly Summary of NRC and QA Item Reports which include the status of all items that are currently open, a brief description of items being resolved, and a summary of problem area One weakness was identified in the trending area. NSAC and QA are the two departments who trend deficiencies at VEG The trending interface between these two departments appears questionable because neither department was on distribution of the other's trend reports. Although adverse findings are being trended by two separate systems (NSAC and QA)

no one group appears to be monitoring both trending programs to establish overall plant-wide trend The QCD The QCD operates in accordance with VEGP Nuclear Operations Procedure 00201-C, RS, Quality Control, which establishes policies and minimum requirements for QC inspection and work monitoring program The QC Superintendent is responsible to the Assistant Plant Support Manager who reports to the Plant Support Manage Discussions with the QC

-

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

. ._

_ _ _ _ , . . . .

. ,

a

'

Superintendent disclosed that 28 QC inspectors (15 GPC personnel and 13 contract personnel) were assigned to perform the Unit 1 December work schedule. Among the 15 GPC operating inspections personnel there are former VEGP construction personnel which helps maintain an unbroken chain of site knowledge. This is considered a strength in the organizatio Examination of the December computerized printout of Training Completion Status for the subject QCD personnel indicated these individuals were maintaining proficiency in their qualified areas of inspectio One unique aspect (strength) of the QCD is that it maintains its own library of training tapes within the departmen This allows any inspector immediate access to them to upgrade his knowledge in his area of expertise or to crosstrain himself in other inspection areas. The QCD tape library is fairly extensive covering a wide range of electrical, mechanical, equipment repair, and maintenance activitie QC inspections are conducted in the follow areas: maintenance activities, installation of equipment, modifications, requisition of materials and services, receipt inspection, and NDE activities. Inspection results that do not conform with requirements and which require more than immediate rework, minor correction, or adjustment, are identified and corrected on DCs in accordance with Procedure 00150-C, R6, Deficiency Control. NSAC has the responsibility for trending all DCs. Minor corrections are noted on inspection reports which are reviewed by the QC Supervisor. If minor discrepancies become a recurring problem the QC Supervisor may meet with the errant department seeking resolution. If agreeable corrective action cannot be obtained the QC Supervisor has the DC system or stop work order authority to control such situations. The NRC inspector was assured that such actions. would probably never be necessary or very rare since

'

construction work has begun to phase out and the licensee has been very selective and able to retain the best craft and QC personnel available for the operating plan Examination of SW0's revealed a total of three (SWO 85-01, 86-01, 86-02)

had been issued to date by operations QCD and these were prior to commercial operatio These items were satisfactorily resolve A program which supplements the QC inspection effort of ensuring quality and compliance requirements is the work monitoring program. Monitoring is not a substitute for QC inspection of safety-related activities but is used to enhance or supplement the QC inspection program. Unsatisfactory conditions identified during these surveillances are handled in the same manner that was detailed above for QC inspection deficiencie The inspector examined the following QC Inspection / Work Monitoring Reports and related deficiencies described in the following deficiency reports /

cards and maintenance work order . _ - - _ _ . - - - . . - - . - . - - - .-- _ - - -. - .- . . - _ - . . -- .

, . . _ _ _ _

o '

. .

14 i IR/WMR N DR/DC/MTR N MWO No.

i 11216 DR 1-87-573 11318 DR 1-87-575 10342 DR 1-87-503 10285 DR 1-87-503 10344 DR 1-87-511 10323 DR 1-87-277 10364 DR 1-87-668 10324 MTR 1-87-0016 12546 DC 1-87-2177 11252 DC 1-87-1611 11337 DC 1-87-724 15677 DC 1-87-3196 10150 18701131 11317 C8700215 The deficiency reports examined above appeared to prescribe proper corrective actions for the problems identifie The inspector made a cursory review of approximately 1200 to 1500 QCIRs/WMRs and identified three reports with minor documentation errors or omissions (QCIRs 11251, 11317, 10150) which were confirmed to be of no safety significance. Two records were immediately corrected by a records correction notice and DC 1-87-3354 was written to correct the third proble The NRC inspector accompanied a mechanical QC inspector during his inspection of the coupling gap and alignment for jockey pump C-2301-P4-001 located in the south firewater pumphouse. The work was done in accordance with Procedure 25215-C, Revision 3, Coupling Alignment, and MWO C8700643 with acceptable alignment and gap criteria being provided from the vendor's manual CX4AF14-12- The dial indicator gauges used were found to be in current calibration. One additional strength was noted during the inspection in that the crafts and QC exhibited a good professional relationshi The millwrights observed performing the work and the QC inspector verifying the hold points were very conscientious, knowledgeable and proficient in the subject work activity performe NSAC When operational deficiencies are identified, they are initiated on an Operational Deficiency Card which is forwarded to the US Guidance for the program is provided by Procedure 00150-C, Deficiency Control Revision The USS enters the deficiency on the log and reviews it to determine if immediate corrective action is required to maintain safe plant condition This review also determines the need for immediate reporting in accordance with Procedure 00152-C, Revision 5, Federal and State Reporting Requirement. NSAC identifies significant events through their review of

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

.- - a * ,

l

Deficiency Cards on a SOR, which then becomes part of the D NSAC indicates on the SOR whether the significant event is required to be further reported to the NRC. NSAC forwards all SORS to the PRB to ensure concurrence with reportability and proposed corrective action As of November 30, 1987, approximately 62 LERs have been issued during 1987 for VEGP. The inspector reviewed approximately 30 of these LERs concentrating mainly on the handling, timeliness of reporting, and report content of the LERs for agreement with NUREG-1022, Licensee Event Report System One minor documentation omission was identified for LER 87-055-01. Section F of the LER addressed Corrective Actions to be taken and Item 4 of this area stated training which would be conducted in

'

the future but specified no specific date for this trainin This omission was discussed with the license QCP The QCP is an addition to the quality assurance programs already in place at the VEGP. It is a positive feature which allows concerned employees to report suspect practices or defects while remaining anonymous without fear of reprisa The inspector noted that as of December 2, 1987,' there were 75 concerns reported to the Nuclear Operations Quality Concern Coordinator of which 9 are still currently under investigation. Responsiveness and timeliness in handling these concerns appears excellent, because the nine open issues were all identified recentl The inspector selected the following Case Nos. 87V0110, 87V0144, 87V0163,'

and 8703013 from the QCP log for detailed examination of the investigations conducted and conclusions made. One of these concerns came from an anonymous submittal, two from concerned individuals who revealed their identities to the QCP, and one from an employee who submitted his concern as a result of the Quality Concerns QC Questionnaire which is requested yearly of the VEGP QA/QC department The inspector was impressed with the time and ef fort spent, the experience level of the personnel investigating these concerns, and the investigation results supporting the conclusions draw This program appears to be well organized and is beneficial to the licensee.

l 8. Maintenance Assessment of the maintenance functional area included reviewing l applicable audits /surveillances and associated findings, reviewing

[ maintenance programs and imolementation, observing real time maintenance

! activities, reviewing mainte 1ance activity historical documentation and l

reviewing spare parts and material procuremen Additionally, the inspector interviewed various maintenance management and technical personnel regarding maintenance performanc In general, the licensee performance in this functional area was adequate with a problem identified relating to using MWO's for deficiency reporting. A strength was l

l

!

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

_. -

oa ,

,

identified relating to the licensee's identification and correction of programmatic problems and personnel motivatio Maintenance activities were reviewed by the site QA organization via audits and surveillance Audits addressed broad programmatic implementation of activities through historical documentation review while surveillances consisted of real time observation of selected activitie The inspector examined three audits and two surveillances to assay the depth of the reviews and the significance of subsequent finding Audit OP15-87/03, performed January 6-11, 1987, addressed the MWO process i.e.,

the authorization and documentation of maintenance activities. Findings included inadequate functional tests, work document completion, work instructions, and test review result Corrective actions included procedure changes and personnel training. Additionally, an independent review team was established on January 14, 1987, to perform a 100 percent review of generated MW0s for a minimum of 30 days. Audit OP15-87/05, conducted January 14 to February 9, 1987, performed an overview of the review team efforts to verify corrective action in progress. Audit OP15-87/24, conducted June 9-29, 1987, addressed diesel generator maintenance activities and inspections. Findings identified problems with jumper removal / reinstallation and cross reference verification of related MWO completion. Audit findings by the licensee appeared significant and corrective action and followup by the responsible group, maintenance, was timely and adequat The surveillances reviewed by the inspector indicated good technical expertise by the auditing organization. The following are the surveillances reviewed:

1-A05-87-006 Pacific 20X17 type HVF Pump Maintenance 1-TSS-87-034 Main Steam Isolation Valves Partial Stroke Functional Test In each of these surveillances it was evident from QA comments that the auditing organization was familiar with the procedures, equipment, and associated Technical Specification requirements for the activity observe The licensee demonstrated the ability to identify and correct maintenance program and implementation problems via site QA activitie The predictive, preventive, and corrective maintenance programs function primarily to identify, correct, and prevent equipment problems. A basic element of these programs was the maintenance history data system, NPMIS, utilized by the license Input from vibration testing, lube oil analysis, MOVAT, and corrective maintenance provide data for predictive maintenance action, planned maintenance scheduling, and corrective maintenance trending. There were two mechanisms utilized for distributing information to personnel associated with equipment or maintenance problems. A quarterly summary report provided management with information concerning equipment problems and maintenance practices. Input to this report was from the predictive maintenance program, operations and maintenance experience, and corrective maintenance via MWO trending. A maintenance experience assessment report was employed to distribute

. .. .. = . .

,. *

,

information to maintenance personnel regarding activities in the plant and industr For example, concurrent with reactor vessel head maintenance, the MEAR may provide information regarding industry related evolutions and problem These mechanisms distributed information associated with identified or potential problems to maintenance personnel; thereby establishing awareness of problems and directly impacting equipment reliability. The maintenance programs have identified problems with valve leakage due to improper torquing, installation of improper gasket material in CCW pumps, and inadequate equipment installation practice The contractor-developed planned maintenance system was undergoing upgrades to better utilize manpower and plant-specific environmental condition Input from the predictive and corrective maintenance programs has resulted in PM scheduling and task modifications that will potentially improve equipment reliabilit Discussions with maintenance engineers and supervisory personnel indicated that personnel were knowledgeable of their work functions and interfaces with other plant groups. Personnel appeared to be motivated towards identifying problems and improving maintenance programs and equipment reliabilit The inspector observed the performance of a safety-related maintenance i activity to verify procedure adequacy, procedure compliance, procedure l acceptance criteria, and use of required M&TE. The activity observed was I

a TS required battery inspection and maintenance check, TS 4.8.2.la and l 4.8. Procedure 28911-C, Revision 6, Class 1E Seven-Day Battery Inspection and Maintenance Check, was utilized by the craf t personnel to perform the tas The procedure adequately addressed precautions, prerequisites, acceptance criteria, and activity performance via sequential procedural steps. Personnel compliance to the procedure was evident in prerequisite verification, procedural steps, acceptance criteria, and M&TE calibration. Procedure and performance of maintenance j observed was adequate for the tas The inspector reviewed the historical documentation of maintenance activity which was contained in the MWO packages. The following MW0s were reviewed:

18701732 18702036 18702699 2839 2037 3345 1892 2577 3718 2002 2112 3641 l

'

1722 3322 7359 5430 3577 3930 l 5918 3006 4161 6938 3295 4000 6960 3742 6878 6754 3916 7379 3970 1068 4909 3818 1093 5004 2035 1643 5344 3627 1696 5391

.

' ' 9 .

18792583 18701711 18705410 1668 1726 5918 3879 1727 5824 1706 1889 A8701155 3608 1893 0844 1797 2001 2356 1828 2024 1888 2517 Documentation of activity was noticeably improved following the corrective actions previously discussed which originated from licensee identification. However, this review indicated a weakness with respect to utilizing MW0s to report deficiencies. There are two problems associated with deficiency reporting via the MWO process considering the controls presently in place:

Identified deficiencies are not included in the plant trend overview which would permit an incomplete picture of plant performance trends to managemen No operability review is performed for MW0s as is required for the

approved deficiency reporting system. A specific example is further j discussed in paragraph 8.b.

l The inspector reviewed the licensee process for qualification of commercial grade spare parts for safety-related systems. The procurement level system in use at VEGP was outlined in Procedure 00800-C, Requisition of Materials and Services, Revision The system designated that procurement levels 1 through 5 materials are used in nuclear i safety related equipment. Level 1 through 3 suppliers have a GPC audited i

and approved QA program, will accept 10 CFR 21 reportability, and can supply qualifying certifications to document these control level Procurement levels 4 and 5 are commercial grade items used in nuclear safety-related equipment. A checklist is utilized to confirm the commerciai grade status of level 4 and 5 items. All procurement levels are receipt inspected by QC. A specific dedication program for commercial grade items was not in place at the performance of this inspection. The licensee indicated that only two such dedications had occurred since i

issuance of the low power license and these were done via specific i engineering evaluations. The inspector reviewed a Nuclear Qualification Evaluation Report, LAEQ-ES-007, performed by Bechtel Western Power Corporation for VEGP. The report addressed pressure switches which could no longer be procured via the original equipment manufacturer due to its QA program relinquishment. Additionally, the switch manufacturer had made material substitutions for some switch components. The report appeared to adequately address the component critical factors relating to operational i and environmental criteria. Material changes were evaluated with respect

to original specifications and potential performance ef fects resulting from the material substitution Although the licensee did not have an

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

. _ _ _

--

_ _ _ _

• ' i .

established program in place for commercial grade dedication, due to continued use of qualified vendors for the majority of procurement, the sample of dedication activity reviewed by the inspector was adequat Within this area two violations were identifie Failure to Follow Procedure 00150-C, Deficiency Control Progra The licensee's controls for identifying and correcting conditions adverse to quality are delineated in procedure 00150- The inspector's review of MW0s identified that the following five MW0s identified conditions adverse to quality:

18705430 Steam flow transmitters did not meet acceptance criteri Feedwater isolation valve operation failure on reactor tri CVCS charging flow control valve (FV-21) malfunctio PORV power supply open circuite Core exit thermocouple train Junction box in unqualified environmental conditio These conditions adverse to quality were processed via MW0s as opposed to established procedural controls. This failure to process conditions adverse to quality in accordance with established procedural (00150-C) controls is identified as violation 424/87-69-0 ^ Failure to Return EQ Equipment to Qualified Condition Following Maintenanc MWO 18704972 identified that a core exit thermocouple junction box was found in an unqualified condition following maintenance in that there was no documentation which would verify installation of the required environmental seal (gasket). This condition was identified on April 13, 1987, and was corrected on October 10, 1987, following approximately six months of power operation. This junction box is part of the Post-Accident Monitoring system which is required by 10 CFR 50.49 to be environmentally qualified. This failure to return EQ equipment to a qualified condition following maintenance is identified as violation 424/87-69-0 . Safety Review Board The inspector conducted several meetings with SRB member The conferences were also conducted with members in Birmingham, Alabama. The inspector reviewed existing SRB procedures which detail SRB composition and member qualification, conduct of meetings, documenting reviews,

. ' . .

processing SRB materials, record retention, use of subcommittees, and conducting onsite reviews and audits. The inspector also reviewed the following SRB Meeting minutes and SRB Subcommittee Meeting minutes:

SRC Committee SRB Subcommittee 291 87-85 292 87-95 294 87-22 295 87-23 296 87-105 297 87-115 298 87-24 299 87-25 300 87-125 302 87-135 303 87-145 304 87-26 305 87-27 306 87-28 307 87-29 Based on this review and interviews with SRB personnel, the inspector concluded that SRB activities are adequately controlled and documented with one exception which is discussed later in this paragrap SRB members possess the necessary technical expertise for those areas reviewed and the decisions reached are appropriate. The SRB use of subcommittees is appropriate; however, the SRB is not always informed of the total scope of the subcommittee reviews. The SRB is only informed of concerns raised by the subcommittee A weakness was discussed with SRB personnel relative to the subcommittee activitie Since the SRB has the ultimate authority and responsibility for safety issues, as discussed in the TS, they must be informed and document the total scope of all subcommittee activities, not just particular areas of concer . Operations The inspector reviewed the operations area to assess the effectiveness of the licensee's Quality Assurance Program. The inspector reviewed the QA organization's activities in the area of operation The following surveillances were reviewed:

1-AOS-87-006, Plant Operating Orders 1-A05-87-015, Recording Limiting Conditions for Operations

• ' .

1-AOS-87-022, Reactor Coolant System Heatup 1-AOS-87-028, Conduct of Operations 1-AOS-87-029, Unit Heatup 1-A05-87-030, Unit Cooldown 1-AOS-87-036, Unit Heatup 1-AOS-87-040, Power Operations 1-AOS-87-041, Power Operations 1-AOS-87-047, Reactor Startup 1-AOS-87-049, Calculation of Shutdown Margin 1-AOS-87-051, Remote Shutdown Panel Operations 1-AOS-87-052, Reactor Coolant System Leakage Calculations 1-AOS-87-054, Power Operations 1-A05-87-061, Main Turbine Operations 1-AOS-87-069, Estimated Critical Rod Position 1-AOS-87-073, Conduct of Operations 1-A05-87-074, Conduct of Operations 1-AOS-87-075, Conduct of Operations 1-AOS-87-091, Conduct of Operations 1-AOS-87-099, Reactor Startup 1-A05-87-106, Standing Orders 1-A05-87-137, Conduct of Operations 1-AOS-87-15n, Control Room Operations 1-AOS-87-151, Unit Cooldown 1-AOS-87-195, Technical Specification Surveillance Logs 1-AOS-87-202, Conduct of Operations l The surveillances were generally complete and accurate within the l sp ecified scope. The findings were of both the compliance and technical j typ The quantity of surveillances and the subject matter adequately covered the operations are The inspector reviewed the licensee's commitments for alternative shutdown and the ability of the licensee to perform alternate shutdown in conjunction with a design basis fire in the control room or cabie spreading room. The following are excerpts from various alternative shutdown commitments:

Facility Operating License NPF-68 condition G states, "GPC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, and submittals . as approved in the SER (NUREG-1137) through Supplement 5... .".

The Supplement 4 of the SER states in part the approval of the licensee's Alternate Shutdown Capability was based upon: "The staff has reviewed the proposed actions and staff requirements for alternate safe shutdown and concludes they are in accordance with Section C.5.c of BiM CMEB 9.5- measures. ."

Final Safety Analysis Report Section 9.5.1.5.3 states, "These fire team manning requirements will be met without impacting the minimum

- - - _ _ _ _ __ - ____----__-___ - _-

w << , i

1

'

onshift operating staff requirements as described in the VEGP Technical Specifications."

CMEB 9.5-1 Section C.5.c (4), Alternative or Dedicated Shutdown Capability, states, "The number of operating shift personnel, exclusive of the fire brigade members, required to operate such equipment and systems shall be on site at all times."

Technical Specification Section 6.2.2.a states "Each on-duty shif t shall be composed of at least the minimum shift crew composition shown in table 6.2-1". A summary of table 6.2-1 requires the following:

Position Modes 1, 2, 3 or 4 Modes 5 or 6 OS 1 required 1 required SR0 1 required none R0 2 required 1 NLO 2 required 1 STA 1 see note none Note: SR0 or 05 may fill position if qualified

'

Abnormal Operating Procedure 18038-1, Operation from Remote Shutdown Panels, has designated duties for six trained personnel and has never been successfully implemented with less than six trained personne The licensee routinely assigns members of the TS minimum shift compliment to collateral duties as fire brigade members. Examples of this practice from selected three month period are as follows:

The shift supervisor had fire brigade duties during the listed dates:

06/07/87, 06/08/87, 06/10/87, 06/12/87, 06/15/87, 06/16/87, 06/18/87, 06/19/87, 06/21/87, 05/23/87, 06/25/87, 06/29/87, 07/02/87, 07/03/87, 07/04/87, 07/05/87, 07/06/87, 07/07/87, 07/29/87, 08/11/87, 08/13/87, and 08/14/87 The outside area operator had fire brigade duties during the listed dates:

,

06/09/87, 07/02/87, 07/05/87, 07/06/87, 07/07/87, 07/08/87, 07/09/87, 07/10/87, 07/11/87, 07/15/87, 07/16/87, 07/17/87, 07/18/87, 07/20/87, 07/25/87, 07/26/87, 07/27/87, 07/28/87, 07/29/87, 07/30/87, 08/01/87, 08/02/87, 08/03/87, 08/04/87, 08/05/87, 08/06/87, 08/07/87, 08/08/87, 08/13/87, 08/14/87, 08/15/87, 08/16/87, 08/17/87, 08/18/87, 08/20/87, 08/21/87, 08/22/87, 08/23/87, 08/24/87, 08/29/87, 08/30/87, and 08/31/87 Contrary to the above requirements, the licensee routinely failed to provide independent trained fire brigade members and TS required minimum

. - .

shift complimen This item is fully addressed in NRC Inspection Report No. 50-424/87-7 The inspector reviewed the Unit 1 Shift Supervisor's log and the Unit 1 Control log. A number of errant log entries were noted. A partial listing is contained below:

On 11/17/87, minimum compliment for fire brigade not logge On 11/06/87, required criticality data was not logge On 10/15/87, minimum compliment for fire brigade not logge On 10/09/87, the logged unit reactor operator was non-license On 06/01/87, minimum compliment for fire brigade not logge On 09/12/87, minimum compliment for fire brigade not logge On 08/25/87, minimum compliment for fire brigade not logge On 06/14/87, minimum compliment for fire brigade not logge On 06/06/87, minimum compliment for fire brigade not logge On 06/03/87, minimum compliment for fire brigade not logge On 06/03/87, TS required minimum shift compliment not logge On 05/20/87, TS required minimum shift compliment not logge On 05/20/87, no turbine building operator was logge On 05/20/87, minimum compliment for fire brigade not logge On 05/06/87, minimum compliment for fire brigade not logge On 03/30/87, minimum compliment for fire brigade not logge On 03/28/87, minimum compliment for fire brigade not logge On 03/27/87, minimum compliment for fire brigade not logge On 03/26/87, minimum compliment for fire brigade not logge On 03/23/87, minimum compliment for fire brigade not logge The failure to make required log entries involve failure to follow a numerous procedures which include:

12003-1, Reactor Startup, Section 4.2.10 requires, "When Critical Conditions have reached, log Critical conditions in the Unit Control Log."

10001-C, Logkeeping, Section 2.2.1.a requires, "The Shif t Supervisor Log should have an entry prefar.ed by the time of occurrence, for activities on shift including: the name and position of each person on shift."

10003-C, Manning the Shift, Section 3.4 requires, "A Fire Team consisting of at least five members (including a team captain) shall be maintained on site at all times. The 0505 shall designate the Fire Team Captain and members at the beginning of each shif t", and Section 3.5 requires in part, "The shift crew minimum requirements of table 1 (TS Table 6.2-1) and the fire team may be reduced by one person for a period of time not to exceed two hour This is to accommodate the unexpected absence of on-duty shift personnel...

This does not permit any shif t position to be unmanned upon shif t change due to tardiness or absence of on coming shift."

e- * .

l l

On January 5, 1987, the inspector interviewed the non-licensed operator that was logged as the unit reactor operator on October 9, 1987, and reviewed additiorial record The inspector concluded the non-licensed operator was not the unit operator on the date in questio This was identified only as an additional example of errant log entrie These examples of errant log entries are generically addressed in NRC Inspection Report No. 50-424/87-7 An overall assessment of the operations area could not be determine .

~a ,

ABBREVIATIONS ACCW Auxiliary Component Cooling Water AFR Audit Finding Report AFW Auxiliary Feedwater ANSI American National Standards Institute BPC Bechtel Power Corporation CAT Construction Acceptance Test CCP Change Control Package CCW Component Cooling Water CFR Code of Federal Regulations CVCS Chemical and Volume Control System DC Deficiency Card OCP Design Change Package DG Diesel Generator DR Deficiency Report EQ Environmental Qualification ESF Engineered Safety Features FCR Field Change Request FSAR Final Safety Analysis Report FT Functional Test .

GMQA General Manager Quality Assurance GPC Georgia Power Company HVAC Heating, Ventilating and Air Conditioning INPO Institute of Nuclear Power Observations IR Inspection Report ISEG Independent Safety Evaluation Group LER License Event Report MEAR Maintenance Experience Assessment Report MOVAT Motor Opercted Valve Testing MTR Materials Transfer Release M&TE Measuring and Test Equipment MWO Maintenance Work Order N/A Not Applicable NDE Nondestructive Examination NLO Non-licensed Operator NPMIS Nuclear Plant Management Information System NRC Nuclear Regulatory Commission NSAC Nuclear Safety and Compliance ODR Operating Deficiency Raport OS Operating Supervisor OSOS On Shift Operations Supervisor PFE-0 Project Field Engineering - Operations PM Planned Maintenance PORV Power Operated Relief Valve PRB Plant Review Board QA Quality Assurance QAC QA Committee QAD QA Department

s s ,

QC Quality Control QCD QC Department QCP Quality Concern Program QCIR QC Inspection Report RCP Reactor Coolant Pump RER Request for Engineering Review RG Regulatory Guide RHR Residual Heat Removal R0 Reactor Operator SOR Significant Occurrence Report SRB ' Safety Review Board SRO Senior Reactor Operator STA Shift Technical Advisor SWO Stop Work Order SUM Start Up Manual TS Technical Specification TSS TS Surveillance USS Unit Shift Supervisor / Operations WMR Work Monitoring Report VEGP Vogtle Electric Generating Plant 1