ML20042C998
| ML20042C998 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/05/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-87-114, NUDOCS 8706040188 | |
| Download: ML20042C998 (34) | |
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POLICY ISSUE 3
May 5,1987 Onf0rITic3 tion)
SECY-87-ll4 i
For:
The Commissioners From:
Victor Stello, Jr.
Executive Director for Operations 70 'IDY
Subject:
ASSESSMENT OF GEORGIA POWER COMPANY'S READINESS REVIEW PIL0T PROGRAM AT V0GTLE UNIT 1
Purpose:
To inform the Commission of the lessons learned from Georgia Power Company's (GPC) pilot program of readiness reviews at the Vogtle Unit I nuclear pcwer plant and the Nuclear Regulatory _3 Commission's (NRC's) participation in these reviews. The:
7 Commission was informed of the scope of these reviews in 1
SECY-85-122 dated April 8,1985. The Commission directedithe '
staff to report on the program upon its completion.
Summary:
This paper presents an overview of the pilot program objectives, program processes, GPC and NRC experiences and lessons learned, i
and recommendations for future application of the readiness review concept. A detailed assessment of the pilot program is provided as an enclosure.
Backaround:
In recent years, major problems relating to the quality of design and/or construction have arisen at several nuclear pcwer plant construction projects. Several projects which have received widespread attention in this regard include Marble Hill, Midland, and Zimmer. Because of these quality-related problems and others in the U.S. nuclear industry, many in the public and in Congress questioned (1) the nuclear industry's ability to design, construct, and operate reactors in a manner consistent with maintaining public health and saf2ty, and (2) the NRC's ability to provide effective regulatory oversight of these activities.
As a result of these Congressicnal concerns, the NRC was directed by Congress in Section 13(b) of Public Law 4 dc g. < Q 97-415 (the NRC Authorization Act for fiscal years 1982 and n
IF 1983) to conduct a study of existino and alternative programs for improving quality assurance (QA} and quality control in the construction of nuclear power plants.
Contact:
H. J. Miller, 492-8807 l
G. S p 492-4807
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s The Commissioners In the QA Report to Congress, " Improving Quality and the r.ssur-ance of Quality in the Design and Construction of Nuclear Pcwer Plants," NUREG-1055, the staff identified the readiness review concept, as practiced by the Department of Energy (DOE),
the National Aeronautics and Space Administration (NASA), and the U.S. Navy, as a planned, systematic approach for assuring the quality of a major program which may have applicability to the nuclear industry.
Following the issuance of the QA Report to Congress in May 1984, GPC, after discussion with the NRC staff, proposed a pilot readiness review program for Vogtle in October 1984. The GPC-proposed program included a systematic disciplined review, with significant senior management involve-ment, of GPC's implementation of design, construction, and operational readiness commitments for Vogtle Unit 1.
GPC stated that its major objectives were to assure that all quality related programs had been developed and implemented in accord-ance with regulatory commitments and to enhance the stability and predictability of the licensing process.
NRC agreed to participate in the readiness review program in November 1984. The major NRC objective was to test, through implementation of a pilot program, the readiness review concept for inspection and licensing of nuclear power plants under construction.
The overall Vogtle pilot program objectives were to improve the effectiveness and efficiency of the reviews conducted by the licensee and the NRC, thereby providing added assurance that NRC regulations and licensing commitments had been adequately implemented.
These objectives were to be achieved by:
1.
Providing a more systematic and structured method and inspectable documentation by which, first, the licensee, and, subsequently, the SnC could, on a modular basis, conduct reviews and inspections to establish that regulatory commitments are being met.
2.
Formally involving senior licensee management at critical incremental stages in the prcject's licensing process.
3.
Providing predictability of the operating license review process, enabling early identification an resolution of NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria.
4.
Enabling early identification of regulatory problems and concerns with sufficient time to take appropriate correc-tive actions without undue delay or disruption of the licensing process.
This involved prudent commitment of l
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l The Comm'ssioners i resources early in the licensing process to minimize the risk of needing a larger commitment of resources later.
i 5.
Providing a planning system with milestones acceptable to Loth the licensee and the NRC, enabling incremental accep-tance of the licensee's work.
At initiation of the pilot program, construction of Vogtle Unit I was approximately 75 percent complete; therefore, a major portion of the pilot program was a post-implementation review rather than an incremental readiness review from the start of the design and construction process.
GPC did perform an intensive review of Vogtle Unit I regulatory commitments and implementing documentation covering most aspects of plant design and construc-tion.
Items such as emergency preparedness and security were not covered. GPC indicated this review was significantly more intensive than that performed in the course of the FSAR/SER process during the licensing of Hatch Units 1 and 2.
Discussion:
1.
Overview of Readiness Review Program Overall, GPC and the NRC staff believe that the pilot readiness review program at Vogtle Unit 1 was a success and that the program provided significant adaed assurance that Vogt'.e Unit I licensing commitments and NRC regula-tions have been met.
The following sections describe the program and address benefits realized from the program, areas for improvement in future readiness reviews, and staff recommendations and planned actions.
GPC divided Vogtle Unit I work activities into 22 modules for purposes of the readiness review.
(See Table 1, p. 5 of the enclosure.)
The module reviews were scheduled in sequence to allow incremental submittals to the NRC. The NRC Region II Administrator was assigned as readiness review project manager to coordinate participation of all NRC licensing and inspection offices and act as principal point of contact with the licensee.
GPC module reviews were performed by an independent task force selected and led by a member of senior licensee management.
The task force was composed of technically competent staff who were not directly involved in perform-ing the work being reviewed.
Upon its completion, each module was evaluated by a senior licensee management readi-ness review board.
The readiness review board consisted of technically experienced senior managers and one or more independent technical experts.
These technical experts were selecteo based on their broad bhckground in a
The Commissioners,
F particular oiscipline and were rotated on the board to review modules according to their areas of expertise.
The first step in the module review process was to identify and document in one place all licensing commitments appli-cable to each module.
Then records of completed work were reviewed and, to a limited degree, visual inspections and testing were conducted by the task force to further assure all commitments had been met.
When the GPC Review Board approved a module, the approval denoted licensee acceptance that all regulatory requirements and licensing commitments had been met, with the exception of identified cases for which GPC would identify planned corrective actions. The module was then submitted to the NRC for review.
Region II coordinated the NRC review and inspections of the completed modules as discussed in Enclosure 1.
When completed, Region II transmitted a report of the NRC review results to GPC. The report provided the licensee and the public a discussion of significant findings, a statement of required followup or corrective actions, and the basis for module acceptability.
2.
Pilot Proaram Benefits Realized a.
The modular structure of the licensee program, the procedures developed for its implementation, and the tracking system established for monitoring the resolu-tion of outstanding issues provided a sound mechanism for reaching a common NRC and GPC understanding of regulatory issues and commitments.
The GPC implemen-tation of the program provided a systematic, detailed set of documents showing how each licensee commitment and NRC requirement were met, which greatly facili-tated NRC's inspection and review of Vogtle Unit 1.
This approach to documentation provided for a thorough review of its implementation of FSAR commitments, b.
Licensee personnel, especially the senior management involved, indicated that they gained a better under-standing of regulatory requirements (including standards) by participating in this structured, systematic review process. As an example, GPC indicated it gained substantial additional understanding of the regulatory requirements for the heating and ventilating system during the commitment review it performed in this area.
c.
Many NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria were resolved in the readiness review program, helping to
i The Commissioners stabilize the licensing process. An example involved a GPC commitment in design control of high energy pipe breaks. The commitment involved a design criterion that no pipe whip restraint is needed if postulated intermediate pipe break locations in high energy piping are more than five pipe diameters from any welded pipe attachments.
The readiness review uncovered a licensee misunderstanding in the implemen-tation requirements for this comitment. The matter has been resolved by re-analysis that has been reviewed and approved by the NRC.
d.
The predictability of the licensing process was improved by early identification of regulatory prob-1 ems and concerns. This early identification of problems provided sufficient time to take corrective action without undue delay or disruption in the licensing or plant construction process. An example was the early identification of erroneous cavitation criteria being used in the design of auxiliary feedwater system flow orifices. The orifices have been replaced with hardware acceptable to the NRC.
Additional examples of the safety problems identified and satisfactorily resolved.by GPC during the pilot program are discussed in Section 3 of the enclosed report.
e.
One of the most important benefits derived from this self-assessment program was early and ongoing involve-ment of senior licensee management. The. process developed by GPC for reviewing the Vogtle Unit I readiness review modules assured that GPC senior management was involved and knowledgeable in licensing and implementation activities. Each readiness review module was sponsored by a member of GPC's senior management who was not only required to select the technical review team members from the readiness review task force, but was also responsible for submitting the module to the readiness review board.
This senior.nanagement involvement was one of the key success factors of the readiness review program.
f.
There is a consensus among key GPC and NRC partici-pants that the program provided added assurance that Vogtle Unit I licensing commitments were adequately implemented and that the plant was ready for start of j
operations.
l
The Commissioners 3 The concept appears to be a viable approach or adjunct practice for licensing and inspection of nuclear power plants.
3.
Areas for Improvement a.
Even though a considerable amount of planning went into the NRC participation in the program, the HRC should have been more actively involved in certain aspects of the early program planning. GPC had already' i
done much of its pilot program planning prior to NRC i
involvement.
GPC had not defined the structure of the program in relation to the FSAR format or the NRC-inspection programs. The NRC staff (NRR and the Regional Office) should provide early input to the utility's program planning, including the program's scope, structure and milestones. This should enhance success of a readiness review program for both the licensee and the NRC and allow more efficient use of NRC resources.
b.
Except for Comanche Peak, which has experienced design and construction quality and licensing difficulties, i
significantly greater resources were expended by NRC in licensing and inspection of Vogtle 1 than in the other recent NT0L cases.
(The comparison is shown in Table 2, p. 13 of the enclosure.) This is largely attributed to the trial nature of the Vogtle 1 readi-ness review program and the timing of the review weil l
after operating licensing reviews began. Both the specific enhancements made to the Vogtle 1 licensing review process and the long-term benefits of lessons i
learned in the trial program made the additional resources well worthwhile.
c.
The readiness reviews for the Unit 1 operational readiness modules, such as operations training and qualifications, were started at the beginning of the development of these programs. This provided an opportunity to test the full potential of the concept.
However, GPC reviewed these programs only on a "one-time" basis and before an adequate degree of commitment implementation for those areas hao occurred.
In the opinion of the NRC Region II staff, GPC did not include sufficient in-depth followup reviews in the pilot program to verify that these operational readiness activities were adequately implemented. As a i
consequence, the operational readiness area was l
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,'4 The Comm'issioners !
addressed, for the most part, outside the readiness review program by GPC and Region 11 and determined to be adequate.
d.
In some instances, NRC reviews and the internal concurrence and approval process were delayed due to competing demands for resources from other priority activities such as TVA issues. However, these delays were successfully kept from affecting the licensing decision schedule.
e.
Because of delays in receiving the modules from GPC, the NRC's review of modules was less incremental than originally anticipated. However, the GPC delays in the program were principally the result of GPC taking more time to ensure its reviews were thorough'and to 1
correct identified deficiencies. The early identifi-cation and correction of deficiencies was a signifi-cant strength of the pilot program.
4.
Other Readiness Review Concept Observations a.
The full potential of the readiness review concept would be better realized if started early in the construction phase.
Section C.4.g(6) of the enclosure describes in general terms how NRC could fully incor-porate an integrated, incremental licensing and inspection approach into its licensing process. To a large extent, the inspection pro:ess is already an incremental one. However, an incremental approach to licensing would be a significant departure from the regulatory process currently required by regulations.
Numerous, important questions about the mechanics of a revised licensing process would have to be addressed before it could be successfully implemented.
Some questions are: Would the licensee still submit a single FSAR, or would a series of modular reports be required? What would change, if anything, in the sequence and schedules for conducting licensing hearings? What woulo be the nature and scope of reports documenting incremental acceptance of licensee work? How would the standardized plant concept affect the mechanics of an incremental licensing review process? The Vogtle pilot program, given that it occurred after much of the licensing review was completed, did not provide experience upon which to settle these questions or to estimate what resource impact there would be.
The Commissioners t While in the future the Commission may choose to alter the licensing review process to incorporate an incre-mental review and acceptance methodology, it would be impracticable and unnecessary to radically alter the process for plants currently undergoing licensing review.
Relatively few in number, these plants are either in advanced stages of completion or are second units, identical to plants already licensed. While-altering the NRC licensing review process for the few plants still in the construction pipeline may not be appropriate, licensees may benefit significantly by performing readiness reviews on their own initiative as GPC did for Vogtle.
For this reason, the NRC should encourage any utility expressing interest in the concept. This report will be made available to the utilities constructing plants so the benefits of such a program are known.
b.
A readiness review by itself will not address all of the construction and licensing problems identified in the NRC's QA Report to Congress (NUREG-1055). The readiness review concept involves only a process or framework for conducting reviews.
It does not, for example, deal with the issue of NRC inspection resources or with qualifications of applicant utilities to manage and construct a complex nuclear facility.
However, the readiness review concept could afford the licensee the opportunity to go beyond the regulatory requirements and ccmmitments and assure that all plant systems, procedures, and personnel are ready to operate.
With respect to resources, the readiness review process, as is the case for the more conventional inspection and licensing review alternatives, will not eliminate the need for significant NRC inspection effort to perform in-depth hardware inspections.
In many past construction cases, NRC inspection-efforts and resources, particularly onsite resources, were very limited.
The issue of resource adequacy applies to licensees as well, because NRC resources, even when expanded beyond what was allocated in past cases where problems occurred, will always be limited, permitting only audits of licensee activities. Therefore, the applica-tion of highly cerrpetent rescurces and technical expertise by licensees to their cuality programs will be crucial. While the. readiness review concept may
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The Commissioners i t
force a certain rigor to the licensee's quality certification process, without technically competent personnel performing both work and quality verifica-tions, quality breakdowns can again occur.
I The Commission should note that:
1.
In response to a request by GPC, the staff is considering plans to participate in a readiness review program being-initiated by GPC for Vogtle Unit 2.
GPC intends to take credit for work performed during the Unit I readiness review, where appropriate, in performance of the Unit 2 i
program. The staff is considering plans to participate with GPC in the planning of the program, including providing inputs to the GPC readiness review team composition, goals, milestones and schedules. A meeting with GPC on its plans for Vogtle Unit 2 was held on March 24, 1987 at Region II.
2.
The staff intends to publish the enclosed assessment of the Vogtle Readiness Review Pilot Program as a NUREG report.to share with industry and other interested government agencies the experiences and lessons learned during the program.
The enclosed report will be placed in the Public Document i
Room and subsequently sent to GPC for comment before issuance as a NUREG document.
3.
Based on the staff's evaluation of the Vogtle pilot pro-gram, including interviews of the NRC and GPC management staff and key reviewers, the staff developed a number of recommendations on how the readiness review concept could be incorporated into licensing of future plants.
(See Section C.4.g(6) of the enclosure.) Should a new appli-cation for a construction permit be filed, the staff will
'i take the next step in determining what specific changes, including revisions to regulations, might be necessary to fully incorporate an incremental review and acceptance approach into the licensing and inspection process.
However, because of the priority which must be given to the safety of operating plants and the remaining plants now under construction, and because the legislative framework for licensing could change before a future generation of
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The Cominissioners -
j plants is licensed, staff resources have not been allocated
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at this time to further activity.
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Enclosure:
Assessment of the Georgia Power Company Vogtle
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Unit 1 Readiness Review Pilot Program DISTRIBUTION:
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ASSESSMENT OF GEORGIA POWER COMPANY V0GTLE UNIT 1 READINESS REVIEW PILOT PROGRAM l
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t CONTENTS Page j
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INTRODUCTION l'
1 B.
BACKGROUND 1
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I C.
DISCUSSION 2
1.
Vogtle Unit 1 Pilot Program Objectives 3
a.
GPC Program Objectives b.
NRC Program Objectives 2.
Vogtle Unit 1 Readiness Review Process 4
a.
GPC Readiness Review Process I
b.
NRC Readiness Review Process 3.
Vogtle Uni,t 1 Pilot Program Experience 9
a.
GPC Experiences b.
NRC Experiences j
4.
Vogtle Unit 1 Pilot Program Assessment 14 D.
PLANNED STAFF ACTIONS 20 f
I i
d I
ASSESSMENT OF GEORGIA POWER COMPANY V0GTLE UNIT 1 READINESS REVIEW PILOT PROGRAM A.
INTRODUCTION This paper assesses the effectiveness of the Georgia Power Company's (GPC's) readiness review pilot program (RRPP) at Vogtle Unit 1.
It includes (1) an overview of what was experienced during the program's implementation, (2) an assessment of how well program objectives were met, and (3) recommendations on the future use of the readiness review concept.
Among the assessments of program results is an evaluation of the added assurance the program provided that Vogtle Unit I was ready for low power licensing.
B.
BACKGROUND In recent years, major problems relating to the quality of design and/or construction have arisen at several nuclear power plant construction projects. Projects which have received widespread attention in this regard include Marble Hill, Midland, and Zimmer.
Because of these quality-related problems and others in the U.S. nuclear industry, many in the public and in Congress questioned (1) the nuclear industry's ability to design, construct and operate reactors in a manner consistent with main-taining public health and safety, and (2) the Nuclear Regulatory Commission's (NRC's) ability to provide effective regulatory oversight of these activities. As a result of these Congressional concerns, the NRC was directed by Congress in Section 13(b) of Public Law 97-415 (the NRC Authorization Act for fiscal years 1982 and 1983) to conduct a study of existing and alternative programs for improving quality assurance and quality control in the construction of nuclear power plants.
The Quclity Assurance (QA) Report to Congress (NUREG-1055, May 1984), in t
response to Public Law 97-415, identified the concept of readiness reviews as a practice that should be considered for adoption by the commercial nuclear industry. A readiness review is a formal assessment of the implenientation of a program or project to determine the preparedness of the responsible personnel, the plant, and management systems to proceed to the next major phase of the project. The readiness review concept repre-sents a structured management approach for assuring that all the elements required to perform an activity have been identified and are ready to support that activity.
For nuclear power plant application, the following phases in a facility's life could be chosen:
1.
Initial design and site preparation i
2.
Beginning of construction
/
3.
Major construction milestones 4.
Plant licensing for operation 5.
Major outages
. 6.
Plant decommmissioning 7.
Plant Life Extension (PLEX)
GPC proposed the RRPP for Vogtle Unit 1 in a letter to the NRC dated October 3, 1984, as "a pilot program for a new and innovative approach for the systematic and disciplined review with senior management involvement in GPC's implementation cf design, construction, and operational readiness processes to increase the level of assurance that Plant Vogtle's quality programs have been accomplished in accordance with regulatory requirements."
GPC modified the readiness review concept to include a very detailed re-examination of performance to date.
This emphasis on past performance was mandated by the status of Vogtle when the pilot program was initiated.
Most construction activities had already begun and were in varying stages of completion. GPC estimated that Unit I was approximately 75% complete at pilot program initiation.
l On November 9, 1984, the NRC informed GPC that the NRC would participate in the Vogtle Unit 1 RRPP.
SECY-85-122, dated April 8, 1985, provides an overview of the pilot program plan, the roles and responsibilities of the GPC and the NRC [ Region II, Office of Nuclear Reactor Regulation (NRR),
Office of Inspection and Enforcement (IE) and Office of the General Counsel (OGC)], and the public's involvement in the program. The program was completed in January 1987 and did provide added assurance that Vogtle Unit I licensing commitments had been adequately implemented with the exception of specifically identified corrective actions still in progress.
Those corrective actions that were still outstanding were not of a safety significance to require any conditions to the Vogtle Unit I full power operating license.
IE had program oversight throughout the pilot program and had responsi-bility for providing programmatic direction to Region II and NRR in the conduct of the program. A preliminary program assessment was made in the Spring of 1986 which included review of program documentation completed at that time and interviews of key participants in the program from GPC, Region II, NRR, and IE. This was followed by a more complete program assessment by a team of IE staff and consultants in October and November 1986. This review examined the completed GPC Pilot Program except for final resolution of some corrective actions. The assessment included detailed interviews of senior management participants at Region II and GPC, members of the licensee readiness review board, selected members of the GPC task force who performed parts of the readiness review, selected GPC project personnel for Vogtle Unit I responsible for some of the corrective actions resulting from the review, selected Region II inspectors and NRR reviewers who performed parts of the NRC review of the Vogtle Pilot Program. These assessments provide the bases for this report.
C.
DISCUSSION Overall, GPC and the NRC staff believe that the pilot readiness review program at Vogtle Unit I was a success and that the program provided
4
-! i significant added assurance that Vogtle Unit 1 licensing commitments and NRC regulations have been adequately implemented. The following sections describe the program and address benefits realized from the program, areas for improvement in future readiness reviews, and staff recommendation and suggested actions.
1.
Vogtle Unic 1 Pilot Program Objectives i
a.
GPC Program Objectives l
The GPC Vogtle RRPP proposal indicates that the pilot program i
would be a management process developed to accomplish the following objectives (reference: GPC letter to NRC dated October 3,1984):
(1) Clearly define the individual work processes involved in the quality program at Vogtle Unit I and describe how these processes comply with regulatory commitments.
(2)
Provide a phased in-depth self-assessment of all work processes and a separate senior management overview of the self-assessment process, including an expert evaluation of both the readiness review assessment and its conclusions.
(3)
Enhance the identification of problems and concerns and ensure their correction in a timely manner.
(4)
Provide a mechanism for the early resolution of any differ-ences in the NRC and GPC interpretation of regulatory requirements and the resulting acceptance criteria, provid-ing stability and predictability in the licensing process.
(5)
Provide a planning system, including GPC-prepared and NRC-accepted milestones for the orderly conduct of the separate actions of GPC and the NRC.
b.
NRC Program Objectives Through establishment of the following objectives, the NRC 7
sought to determine to what extent participation in the Vogtle RRPP could improve the effectiveness and efficiency of the licensee's and the NRC's review processes to provide added assurance that licensing commitments had been adequately imple-mented:
(1)
Providing a more systematic and structured method and inspectable documentation by which, first, the licensee and, subsequently, the NRC can plan and conduct reviews and inspections to establish that regulatory commitments are adequately fulfilled.
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I (2)
Formally involving significant early senior licensee management at critical incremental stages of a project's licensing process.
j (3)
Providing predictability of the operating licensing process through early resolution of NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria.
(4)
Enabling early identification of regulatory problems and concerns with sufficient time to take appropriate correc-tive actions without undue delay or disruption of the licensing process.
j (5)
Providing a planning system with milestones acceptable to both the licensee and the NRC, enabling NRC review and incremental acceptance of the licensee's work.
2.
Voctle Unit 1 Readiness Review Process a.
GPC Readiness Review Process The GPC readiness review process divided plant design, construc-tion and operational readiness activities into four functional areas:
civil, mechanical, electrical (including instrumentation and control), and plant operations. All plant activities fit into one of these four functional areas.
For purposes of the readiness review, GPC divided the work activities into the 22 modules shown in Table 1.
As can be seen in Table 1, module 21 consists of seven appendices which encompass activities. comon to several of the other modules. Module 22 provides the results of an independent design review, by Stone and Webster Engineering Co., of the design process and design adequacy of the plant across all four functional areas.
I In performing the RRPP, GPC assured that most plant design, con-struction, and operational readiness activities necessary to ensure safe operations were included in the readiness review modules.
Items such as emergency preparedness and security were not covered. GPC also assured that the implementation of the
'1 readiness review program did not result in deviations from its comitments and design criteria in the Final Safety Analysis Report.
GPC was comitted to processing any changes to the Final Safety Analysis Report (FSAR) by amendments through the normal licensing process.
Each module provides a trail of documentation and implementation to meet pertinent comitments.
The GPC organization for implementing the readiness review program consisted of a readiness review task force and an independent readiness review board which were dedicated to the program for the two-year Unit I readiness review. The readiness 4
, review task force consisted of engineering and support personnel independent of the Vogtle Unit 1 Project, selected from applicable design, construction, operations, and quality assurance disciplines. They reported to the readiness review program manager, who was a member of GPC's senior management.
The readiness review board consisted of technically experienced, senior GPC managers and independent technical experts from organizations outside GPC.
The technical experts were selected on the basis of their broad technical backgrounds in particular disciplines and served on the board for module reviews within their area of expertise. Both the readiness review task force manager and the readiness review board chairman reported to the GPC Senior Vice President-Nuclear.
Each readiness review module was sponsored by a member of GPC's senior management who was not only required to organize the technical review team from the readiness review task force but was also responsible for submitting the module to the readiness review board. Technical specialists preparing the modules, and ultimately the module sponsors, hac to prove the correctness of their methods, procedures, implementation, and results to the readiness review task force.
Typically, the task force conducted a multistage review of the activities within the scope of a module.
It began by describing the activities for engineering, procurement, construction, and i
operational readiness that translate the FSAR commitments into implementing documents, such as design criteria, drawings, calculations, specifications, and design, construction, and operational readiness procedures.
These results were incorpor-ated into a commitments matrix for each module.
Readiness review task force groups then reviewed the project records and conducted inspections and walkdowns to ascertain whether docu-ments that demonstrate compliance with procedures and implemen-tation of commitments existed (documents which demonstrate that compliance was incorporated into an implementation matrix) and whether constructed systems compliec with the desian requirements.
3 Five types of reviews were conducted:
(1) programmatic review L
of the design engineering process, (2) programmatic review of construction planning, (3) inspections and walkdowns of selected systems to observe whether hardware correctly complied with 1
cesign documents, (4) review of completed ccnstruction records, and (5) technical review of design documents.
In addition, the findings of past audits and special investigations were evalu-ated for their indivicual and collective significance in regard to the quality of the systems. These investigations included GPC audit findings, NRC inspections, Institute of Nuclear Power i
Operations (INPO) evaluations, and self-initiated evaluations.
l
. TABLE 1.
V0GTLE P.EADINESS REVIEW MODULES Module No.*
Title 1.
Reinforced Concrete Structures 2.
Operations Training and Qualification 3.A Initial Test Program, Preoperational Test Phase 4.
Mechanical Equipment, Piping and Components 5.
Operations Organization and Administration 6.
Electrical Equipment
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7.A Plant Operations and Support 8.
Structural Steel 9.A Radiological Protection 9.B Chemistry 11.
Pipe Stress and Supports 12.
Electrical Cables and Terminations 13.A Foundations and Backfill 13.B Coatings 13.C Post Tensioned Containment 16.
Nuclear Steam Supply System 17.
Raceways 18.A Heating, Ventilating, and Air Conditioning System 19.
Electrical Supports 20.
Instrumentation and Control 21.
Appendices C.
Pr'ocurement D.
Document Control E.
Material Control F.
Inspector Qualification / Certification G.
Measuring and Test Equipment I.
Project Quality Assurance Organization Supplement; Quality Concerns J.
Equipment Qualification 22.
Independent Design Review
- Gaps in module numbering sequence such as 14 and 21A etc. developed due to reorganization of the module structure including deletion of some modules as the pilot program developed.
[.'
Each module report contains a list of findings, a description of corrective actions, and a discussion of the safety significance of each finding.
Following evaluation, the findings were classified by GPC into 3 levels as follows:
Level I -
Violation of licensing commitments, project pro-cedures, or engineering requirements with indication of safety concerns.
i Level II -
Violation of licensing commitments or engineering requirements with no safety concerns.
Level III -
Violation of project procedures with no safety concerns.
Details of the individual and collective evaluations of findings and resulting corrective actions and corrective actions in progress were included in the module.
Each module was completed by the readiness review task force. It I
was then sent to the readiness review board for review and acceptance. GPC indicated that their readiness review board performed an extensive review to prepare for each module review.
From potential and actual problems discovered by NRC and GPC internal audits, allegations from intervenors, and problems encountered at other near-term operating license (NTOL or former NT0L) plants such as Diablo Canyon, Waterford, South Texas, i
Comanche Peak, Zimmer and Mialand, the GPC board gathered a data base of potential and known problems that could impact each module area. The GPC module preparers were required to cemonstrate fully to senior management that these problems did not exist and would not arise at Vogtle. The document, when accepted by the GPC Board, was sent to the Vice President and Vogtle Project General Manager, who reviewed the module and the Board's recommendations. After GPC management was satisfied that the module was complete, accurate, and acceptable, the module was submitted to the NRC.
b.
NRC Readiness Review Process The key NRC office roles and responsibilities were as stated in SECY 85-122. These remained the same throughout the program and are described as folicws:
e (1) Recion II:
The Regional Administrator was the NRC Vogtle RRPP manager and, as such, was responsible for managing the NRC participation in the program, identifying problems and deficiencies in the readiness review pilot-program, notifying GPC, and transmitting NRC evaluations of the l
readiness review modules to the licensee. Regicn II I
^
. j was responsible for planning, conducting and coordinating ~
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NRC reviews and inspections for each module. Module evaluation letters were prepared by Region II based on the comments, inputs and findings of NRR, IE, and OGC. -0GC, NRR, and IE each concurred on these letters and on NRC's-acceptance of the module.
Finally, Region II was-responsible for tracking and resolving the status of-corrective action and open issues, both before and'after the NRC evaluation and acceptance of modules, except those involving either FSAR or Safety Evaluation Report (SER) ~
issues, which was the responsibility of NRR.
(2) NRR: NRR's role in the RRPP was to review GPC FSAR comit-ments and interpretation of commitments contained in each readiness review module.
I positions and conclusions with infonnation in the modules and was responsible for tracking and resolving any FSAR.
t actions or open issues.
5 (3)
IE: The IE role in the RRPP was to develop and provide Frogrammatic direction to Region II, NRR, and OGC in -
conducting the program, including developing procedures ~for NRC review of the pilot program. ~IE was also tasked with reviewing and analyzing the results of the pilot program to 1
assess how well the objectives were met and the applicability-of the readiness review concept to future nuclear power i
plants.
In addition, IE supported the program by providing guidance in the development of the-scope and depth of the Independent Design Review Module and conducting module reviews, including independent hardware-oriented inspections -
and design inspections at the site and at the offices of i
the architect / engineer in support of Region ~II.
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1 (4) OGC: OGC provided legal advice to support-the pilot program. The NRC review began with the receipt of a j
readiness review module from GPC. Approximately two weeks after NRC receipt of each module, GPC presented the module in a formal and public meeting attended by representatives i
from each NRC reviewing organization. The licensee made a formal presentation of the module, and the NRC staff and.
I 1
GPC representatives discussed issues and questions arising from the NRC staff preliminary review.
Upon receipt of each module, NRC performed a detailed review of the module by (1) verifying that the commitments identified in the module were in accordance with FSAR.
commitments and regulatory requirements, (2) checking a representative sample of the documents reviewed by the GPC.
readiness review staff and an independent sample of documents selected by the NRC inspectors, (3) checking preoperational
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i plans and procedures, including testing procedures within the scope of a particular module, inspecting a representative independent sample of installed components f
and equipment, (5) walking down systems and areas, and (6) reviewing past NRC inspections and INP0 audits of the plant pertaining to the module. The reviews were performed by Region II inspectors, and reviewers from NRR and IE. Region II was the NRC focal point for contacts between NRC and GPC.
The NRC reviewers of each module used a standardized report format which was more in the form of an SER than an inspection report in that the module reports emphasized a review and conclusion as to the acceptability of the work activities covered by the module under review. The report provides the licensee and the public with a determination of module acceptability, discussion of significant findings, statement of any required followup or evaluation, and the summary of results for the Vogtle Unit I work activities covered by that module. Copies of RRPP correspondence between the NRC and GPC were placed in the NRC Public Document Room.
j 3.
Vogtle Unit 1 Pilot Program Experience a.
GPC Experiences The pilot program was initiated in Nuvember 1984 and was completed in January 1987.
Significant GPC experiences during the program's execution were as follows:
(1) GPC indicated that the systematic and structured method, including inspectable documentation, in which -they identified their regulatory commitments and then tied those commitments to their implementing documents, led to early resolution of FSAR commitment misunderstandings. This, in turn, led to identification of problems and initiation of corrective actions much earlier than would have occurred without the readiness review.
Indicative of the early problem identification and corrective action implementation were the 47 Level I findings identified by the licensee (Level I findings are violations of licensing comnitments, project procedures, or engineering requirements with indication of safety concerns). Most Level I findings have impacted Vogtle Unit I hardware.
Examples of Level I findings by the GPC readiness review program that were found early enough to permit timely resolution were as follows:
(a) There was incorrect implementation of a high energy line break criterion. Longitudinal breaks were not
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. postulated at high stress points. This required hardware modifications to maintain a safe shutdown capability.
(b) A pipe support calculation used smaller loads as an input than design requirements. This. required hardware modifications.
(c) The Auxiliary Feedwater System (AFW) flow orifice design was unacceptable because erroneous vendor cavitation criteria were used. The~ orifices have been replaced with hardware acceptable to the NRC.
(d) No overpressure protection was provided for low design pressure of AFW and Safety Injection System pump suction to protect against discharge check valve backleaks on the non-operating pump. A relief valve has been installed to provide the necessary protectiJn.
(e) Safety Injection / Residual Heat Removal systems had manual valves installed which could have inadvertently isolated relief valves. This required hardware modifications.
(f)
Inadequate seismic separation (spatial) was found between pieces of Class 1E equipment.
Six such violations were found. The necessary hardware changes have been made.
(g)
Inadequate shielding of Technical Support Center (TSC) filters was identified.
Plant modifications are being made to stay within Post-LOCA acceptable radiation limits in the TSC.
(h) Sixty-four instruments, including NSSS differential pressure transmitters and pressure transmitters, were found secured by bolts not in accordance with specifica-tions. The instruments were reinstalled in accordance with specifications.
(2) The readiness reviews for the Unit 1 operational readiness modules, such as operations training and qualification, were started at the beginning of the development of those programs. This provided an opportunity to test the full potential of the concept. However, GPC reviewed those programs only on a "one-time" basis and before an adequate degree of commitment implementation for those areas had occurred. In the opinion of the NRC Region II staff, GPC did not include sufficient in-depth followup reviews in the pilot program to verify that those operational readiness
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. i activities were adequately implemented. As a consequence, the operational readiness area was addressed, for the most part, outside the readiness review program by GPC and Region-II and determined to be adequate. The routine program formed the basis for licensing in this area.
In future readiness reviews, both the licensee and NRC should have planned incremental acceptance points rather than "one time" reviews.
(3) The number and content of the modules originally planned were changed substantially as the pilot program progressed.
Also, most of the appendices, which address those areas like document control which relate to several module areas, were submitted relatively late in the program. This reduced their value in supporting related module reviews.
The most significant change was to incorporate the independent design reviews into one separate module.
This enabled a more thorough check of the adequacy of design interfaces between technical disciplines. The effectiveness of this approach is shown by the resulting findings, discussed in paragraph 3.a.(1), above. They were originally planned to be separate reviews in each module.
(4) Associated with the independent design review were design program verifications of the prcgrammatic aspects of design. This evaluation was a systematic review of design documents that identified the implementation of licensing commitments and included an assessment of design processes.
These design program verifications also identified and corrected safety problems. An example was the identification of inadequate pipe stress and pipe support design procedures.
GPC subsequently developed adequate procedures which NRC has approved.
(5) The preparation and submittal of modules to the NRC did not follow the originally planned schedule of approximately two a month from May 1985 to June 1986.
Five modules and appendices had been delivered to the NRC by February 1986.
The remaining 23 modules and appendices were submitted between February 1986 and July 1986. GPC indicated a major cause of the original schedule's slippage was the necessity for revisions and corrective actic.is by GPC after scrutiny by the readiness review board. GPC required that correc-tive actions be either completed or in progress before submitting the modules to the NRC.
(6) GPC indicated their initial cost estimate to perform the readiness review of $10M was exceeded; cost was approxi-mately 513.5M. GPC indicated this was primarily due to GPC underestimating the amount of work required to ensure i
commitment tracking and the rework required of many of the readiness review modules.
GPC initially estimated the cost of performing the necessary corrective actions as a result of the readiness review program to be approximately $15M.
The actual cost of corrective actions was approximately
$30M.
(7) GPC and NRC readiness review meetings were given public notice, and public interest groups were notified of the submittal and subsequent NRC evaluation of modules.
Copies of NRC/GPC correspondence on the Vogtle Readiness Review Pilot Program were sent to the NRC Public Document Room.
Public interest groups, such as Georgians Against Nuclear Energy (GANE) and Georgians For a Safe Environment (GFSE),
attended only three meetings with GPC and NRC on the readiness review. Hence, only little public involvement was realized.
b.
NRC Experiences The NRC completed its review of the GPC pilot program in January 1987.
Significant observations by NRC during its participation in the Vogtle readiness review pilot program include the following:
(1)
In general, the NRC found the GPC pilot program to be thorough and accurate.
NRC findings were generally dis-covered during an examination of an independently selected sample of records and an on-site inspection of an indepen-dently selected sample of hardware critical elements.
Fifteen violations of regulatory commitments were discovered during the NRC review. These tended to be isolated cases l
rather than weaknesses in GPC's overall program.
(2) Region II inspectors found that the relatively large data =
base established by the GPC program aided them in the performance of the routine Manual Chapters 2512, 2513, and 2514 inspections of Vogtle Unit 1.
(3)
Initially, NRC had an inadequate understanding of the medule and appendices interfaces. This was particularly difficult for NRR's tracking of FSAR commitments for the various modules. This was primarily due to differences in module and FSAR structures as well as unclear criteria regarding which regulatory comrnitments pertained to a given module.
(4) The delay in GPC submittal of the majority of the modules I
caused NRC to perform 75 percent of its review in the last six months of the program. This caused a strain on resources and had some impact on Region II's routine inspection program during that period.
y (5) Despite the delay in module submittals by GPC, the NRC inspectors indicated the GPC reviews hrd identified licensing problems and instituted corrective actions that would have potentially been discovered much later without the readiness review. This reduced the risk of needing a large commitment of resources by both GPC and NRC later in the licensing process and loss of flexibility later in corrective action solutions.
(6) The NRC reviewers noted that some areas of the Vogtle pilot program, such as civil / structural areas, were reviewed very late in the project activity. Since construction of Vogtle Unit I was approximately 75 percent complete at the initia-tion of the pilot program, the program was essentially an after-the-fact review.
In other areas, such as operational i
readiness, GPC completed their readiness reviews where there was an inadequate base of actual implementation for NRC review and inspection.
In addition, most of the FSAR commitment review performed by NRR had already been completed as part of NRR's normal SER for an operating license.
(7)
In many instances, tra NRC reviews and the internal con-currence and approval process were delayed within the NRC staff due to competing demands for resources from other priority activities, such as TVA issues.
However, these delays were successfully kept from impairing program effectiveness.
(8) The Regional Administrator, Region II, was the NRC responsible manager in coordination of NRC staff efforts in support of the Vogtle pilot program. This tended to facilitate NRC/
utility communications due to the major role of Region II in the program and the proximity of the Regional Office to the GPC corporate office and the Vogtle site. However, the hRC staff concurrence and approval process experienced some delays, primarily due to the pilot nature of the program.
(') A comparison was made of the NRC resources expended on the Vogtle Unit 1 pilot program with those NRC resources expended on four other NT0L plants (Perry Unit 1, Nine Mile Point Unit 2, Shearon Harris Unit 1, and Comanche Peak Unit 1). The comparison is shown in Table 2, below.
For comparison purposes, the data are for the same period prior to low power licensing for each plant, except for Comanche Peak, which is not yet licensed.
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, l TABLE 2 COMPARATIVE NRC RESOURCES USED FOR SEVERAL NT0L PLANTS y
Plants Staff Hours * (K)
K$'s Contractors IE, RII NRr.
Vogtle Unit 1**
47.1 30.2 77.3 362 713 1075 Perry Unit 1**
25.7 14.9 40.6 462 672 1134 Nine Mile Point Unit 2**
22.5 20.9 43.4 253 339 592 Shearon Harris Unit 1**
34.8 15.9 50.7 546 629 1175 Comanche Peak Unit 1***
29.1 32.9 62.0 1691 5023 6714 To establish a valid comparison, the same basis was used in the compilation of staff hours for each plant. The staff hours shown above include all NRC expenditures associated with each plant for the time period involved.
Data for the Z-year period preceding icw power licensing of that plant.
- Data for FYS4 through mid-FY86.
f Except for Comanche Peak, which has experienced design and continuous quality and licensing difficulties, significantly greater resources were expended by NRC in licensing and inspection of Vogtle 1 than in the other recent NT0L cases.
l This is attributed to the trial nature of the Vogtle 1 readiness review program and the timing of the review well after operating licensing reviews began. Both the specific enhancements made to the Vogtle -1 licensing review process and the long-term benefits of lessons learned in the trial program made the additional resources well worthwhile.
(10) Pilot program procedures were established by Region II for the NRC review process. Using the pilot program experience, the Quality Assurance Branch of NRR, as part of its program development role, is developing generic readiness review procedures for future applications. A preliminary version of these generic procedures was used successfully in the NRC review of one Vogtle Unit 1 pilot program module.
4.
Vogtle Unit 1 Pilot Program Assessment As part of its participation in the Vogtle readiness review pilot program, benefits from the use of the readiness review concept as an NRC regulat the NRC staff had six major objectives. These objectives relate to potential The following is an assessment of how well the Vogtle pilot program met these 4
objectives and some of the lessons learned from the experience.
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. a.
Objective:
Provide a more systematic and structured method by which, first, the licensee and, subsequently, the NRC can establish that regulatory commitments are adequately fulfilled.
Degree of Success The modular structure of the program, the procedures developed for its implementation, and the established schedule led to a more r
precise focus on specific technical issues and commitments. The utility, including their senior management, recognized early in the process that they did not have a full understanding of their FSAR commitments. The process provided a mechanism for achieving a common understanding of the commitments with the NRC and led GPC to develop a tracking system for monitoring resolution of outstanding issues for-use by both GPC and NRC. This structuring of the licensee's commitments and tracking of issues was the keystone for a more systematic review of completed and in process work by both licensee management and NRC staff.
In turn, this led to an enhanced assurance of compliance with regulatory commitments.
Hence, there is greater assurance for both the licensee and the NRC that the regulatory requirements were properly implemented and translated into hardware, 4
programs, trained personnel, and activities. The licensee also indiccted that its personnel, especially senior management, gained a better understanding of regulatory requirements by participating in this structured, systematic review process. This resulted in GPC l
being much more effective in identifying and correcting problems. An example, which was discussed in paragraph C.3.a(1)(c), was the early identification and acceptable correction of a hardware problem with AFW flow orifices.
b.
Objective:
Formally involve senior management in a self-assessment at critical incremental stages of a project's licensing process.
Degree of Success This objective was achieved, particularly in the licensee's organization. Each of the licensee's completed modules was reviewed by the readiness review board.
The board was composed of senior managers in GPC, with the chairman of the board reporting to the Senior Vice President-Nuclear.
The formal process for reviewing modules assured that these senior managers were significantly involved throughout the program.
In part, because of how the licensee's review process was attually conducted, the involvement of senior NRC managers at critical, incremental stages was somewhat diminished since all the GPC modules were submitted to NRC in approximately a six month time i
period. The NRC's review of the modules was less incremental with-respect to time than had been anticipated due to. delays in receiving the modules from the licensee.
These delays appeared to rcsult, in i
part, from the licensee's approach of establishing and incorporating l
. corrective actions for all findings in each module before submitting it to the NRC. However, this thoroughness of the GPC reviews has been one of the major strengths of the Vogtle pilot program.
c.
Objective:
Provide predictability and stability.in the operating licensing process, enabling early resolution of NRC and GPC differ-ences in interpretation of regulatory requirements and acceptance criteria.
Degree of Success Many NRC and GPC differences in interpretation of regulatory requirements and acceptance criteria were resolved relatively early in the readiness review process.
Early resolution of the differences was achieved by establishing effective channels of communication (verbal and written) between NRC and GPC technical staff. An example involved a GPC commitment in design control of high energy pipe breaks. The commitment involved a design criterion that no pipe whip restraint is needed if postulated intermediate pipe break locations in high energy piping are more than five pipe diameters from any welded pipe supports. The readiness review revealed a misunderstanding on the implementation requirements of a safety-related commitment. The matter has been resolved.
d.
Objective:
To enable early identification of regulatory problems and concerns with sufficient time to take appropriate corrective actions without undue delay or disruption of the licensing process.
j Degree of Success As discussed earlier, the licensee identified several problems during_the readiness review that had potential for disrupting the licensing process.
They were detected earlier than they would have been through the normal-licensing process. This early identification and correction of problems was of significant benefit to the licensee, as well as to the NRC, in reducing licensing delays and last minute expenditures of resources.
e.
Objective:
Provide a plcnning system with milestones and schedule acceptable to both the licensee and the NRC. The schedule should enable incremental acceptance of the licensee's work by the NRC.
Degree of Success The incremental acceptance of the licensee's work was only marginally successful in part because of the relatively late phase of construction at Vogtle Unit I when the pilot program was initiated.
Also, a large number of completed modules were submitted to the NRC simultaneously rather than sequentially. This detracted from the goal of incremental acceptance because so many modules were submitted 1
=.
for review at one time and ;he modules were submitted toward the eno of the program.
f.
Objective:
Improve the effectiveness and efficiency of NRC's review process to provide added assurance that licensing commitments have been adequately implement-d Dearee of Success There is a consensus among most key participants that the Vogtle Readiness Review Pilot Program provided significant added assurance that Vogtle Unit I licensing commitments have been adequately implemented. While the resources required for both GPC and NRr, exceeded original estimates, the benefits accrued are, in the opinion of the staff, well worth the costs.
In addition, the licensee benefitted from the readiness review since the program went beyond the regulatory requirements and commitments and addressed the overall adequacy of its design and construction programs. The concept appears to be a viable approach or adjunct to currert nuclear power licensing and inspecti< a practices.
g.
Lessons Learned i
(1) The effectiveness and efficiency of NRC's participation could have been enhanced by a greater degree of planning with the licentee prior to beginning the program. Early program planning was hcid on a compressed schedule between senior NRC management and senior GPC management.
However, it appeared that the NRC was not adequately involved in certain aspects of the early program planning.
For excple, GPC had not defined the structure of the program in relation to the FSAR format or the NRC inspectic ;rograms. This made it difficult for NRC reviewers and inspectors, particularly with regard to interfaces f
betwe9 modules and appendices. There was a lack of criteria on how commitments would be chosen for inclusion in each module, and, in some cases, relevant commitments were not included without explanation. In addition, the approach used for the design reviews was changed well after the program had been initiated. Greater emphasis should 'e placed on planning future readiness reviews. The NRC staff (NRR and the Region) should provide input to this planning through audit of the program's scope, structure, and milestones. This should enhance efficiency and program payoff for both the licensee and NRC.
I (2) During the early stages of the program, the independent design reviews (IDRs) were being performed on a module-by-module approach.
IE recommended this approach be changed to a systems oriented integrated design review to enable a review of disciplinary interfaces in addition to design aspects within a particular discipline. This change was made and enhanced the pilot program's effec',iveness.
I
(3) The full readi.iess review concept as described above will not work without significant commitment of both inspection and licensing resources. Therefore, the readiness review program should be meshed with existing NRC licensing and inspection programs in the future. The resultant program should incorporate a structured system of incremental work acceptance by the NRC inspection and licensing programs. A master inspection schedule should be established which is adaptable to the progress of work activities. More emphasis should be placed on timely planning and the conducting of on-site independent inspections of critical elements by NRC for each module.. NRC readiness review procedures should be issued as program l
guidance.
(4)
It appeared that communications between the GPC Readiness Review Board and the GPC licensing staff could have been improved in the processing of FSAR changes resulting from the readiness review. Also, a system to track closure of FSAR issues should be included in future programs.
(5)
It is essential that NRC and the licensce agree early to a realistic, flexible schedule permitting an in-depth review by i
the licensee, yet permitting NRC's incremental acceptance of work.
The experience gained in the GPC pilot program will be beneficial in planning schedules for future readiness review programs. More emphasis on on-site hardware and product-oriented inspection of critical elements of the licensee's i
modules is required.
(6)
In summary, building on the Vogtle ait 1 pilot and lessons learned from it, the readiness raview cor. cept could be incorporated into the operating lice m.
eview process in the following manner.
In order to identify and resolve isso " _, a. a rly time, i
following licensee self-assessments, the staff would incrementally review and document acceptance of licensee work.
NRC acceptance of work at early stages will
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necessarily be conditional with open items identified for followup. The acceptance would be conditional, because issues of substance could arise in public hearings or from subsequent licensee or NRC audits.
Instead of a major SER, with supplements, prepared by the staff relatively late in the construction / pre-operating license period, the staff would produce a series of acceptance reports issued throughout this period. A final SER integrating program elements would still be necessary, but its scope would be substantially reduced from part SERs. Appropriate incremental acceptance points in the program might be:
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, (a) At the program plan / procedure development stage before work begins. GPC management felt that many problems could be avoided if an early detailea review of regulatory commitments and requirements was accomplished. The review should entail agreement on the cemitments and requirements, resolution of NRC and licensee differences in interpretation of regulatory requirements, and acceptance criteria.
(b) After approximately 10% completion of the work activity where there has been significant experience in implementing comitments.
In addition to continuing to identify and resolve questions of interpretation of regulatory requirements, this step focuses on implementation of the commitments in each of the numerous work areas and activities involved in plant design, construction and operational readiness.
This step is important in that, only after some work is completed and experience is acquired in using work procedures, can confidence be gained that potential problems in work procedures have been discovered. A hard, in-depth look by both the utility and NRC at work products and procedures at about the 10% stage of work completion was suggested by GPC as a point far enough into work to get needed expcrience in the activity yet early enough to avoid excessive rework or job disruption if problems are identified.
(c) A final review when work is complete.
In this regard, it should be noted that the various work areas or modules, as shown in Table 1, will be completed sequentially in accordance with the work progress for the plant. Many of the civil / structural work areas, such as reinforced concrete, will be completed relatively early in the program, while other areas, such as pre-operational testing, will be completed late in the program. This allows for a natural incremental review and acceptance of work by both the licensee and the NRC.
While NRC acceptance reports might be issued at several discrete points, it should also be noted that the NRC inspection process will need to be continuous throughout the con-struction period to assure commitments are being met.
Similar to staff reviews, ACRS reviews could be performed early and incrementally upon completion by the staff of its acceptance reports.
This would be an important step in assuring that, to the extent practicable, issues are being identified and resolved early.
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It must be noted that incremental acceptance of work by the staff would in no way bind the licensing board, should the operating license be contested, nor prevent NRC staff reexamining issues which might, for example, be raised through allegations.
(7) The full potential of the readiness review concept would be better realized if started early in the construction phase.
Section C.4.g(6) describes in general terms how NRC could fully incorporate an integrated, incremental licensing and inspection approach into its licensing process. To a large extent, the inspection process is already an incremental one. P never, an incremental approach to licensing would be a s!yificant departure from past practice.
- Numeroes, important questions about the mechanics of a revised licensing process would have to be addressed before it could be successfully implemented.
Some questions are:
would the licensee still submit a single FSAR, or would a series of modular reports be required? What would change, if anything, in the sequence and schedules for conducting licensing hearings? What would be the nature and scope of reports documenting incremental acceptance of licensee work? How would the standardized plant concept affect the
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mechanics of an incremental licensing review process? The Yogtle pilot program, given that it occurred after much of the licensing review was completed, did not provide experience i
upon which to settle these questions or to estimate what resource impact there would be.
While in the future the Commission may choose to alter the licensing review process to incorporate an incremental review and acceptance methodology, it would be impracticable and unnecessary to ridically alter the process for plants currently undergoing licensing review.
Relatively few in number, these plants are either in advanced stages of completion or are second i
units, identical to plants already licensed. While altering the i
NRC licensing review process for the few plants still in the l
construction pipeline may not be appropriate, licensees may
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benefit significantly by performing readiness reviews on their l
own initiative as GPC did for Vogtle. For this reason, the NRC should encourage any utility expressing interest in the concept.
This report will be made available to the utilities constructing i
plants so the benefits of such a program are known.
t D.
PLANNED STAFF ACTIONS 1.
In response to a request by GPC, the staff is considering plans to participate in a readiness review program being initiated by GPC for Vogtle Unit 2.
GPC intends to take credit for work performed during the Unit I readiness review, where appropriate, in performance of the l
Unit 2 program. The staff is considering plans to participate with
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' GPC in the planning of the program, including providing inputs to the GPC readiness review team composition, goals, milestones and schedules. A meeting with GPC on its plans for Vogtle Unit 2 was held on March 24, 1987 at Region II.
2.
Based on the staff's evaluation of the Vogtle pilot program, including interviews of the NRC and GPC management staff and key reviewers, the staff developed a number of recommendations on how the readiness review concept could be incorporated into licensing of future plants.
(See Section C.4.g(6).) Should a new application for a construction permit be filed, the staff will'take the next step in determining what specific changes, including revisions to regulations, might be necessary to fully incorporate an incremental review and acceptance approach into the licensing and inspection process. However, because of the priority which must be given to the safety of operating plants and the remaining plants now under construction, and because the legislative framework for licensing could change before a future generation of plants is licensed, staff resources have not been allocated at this time to further activity.
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UNITED STATES O 'i -
' t, NUCLEAR REGULATORY COMMISSION 5,3 " # -i W ASHINGTON,0.C. 20555 5.k ' /,/
v s,
.p
- y. 3 +, jq 9' C(;
orrtCE OF THE May 15',
1987 ~
SECRETARY MEMORANDUM FOR THE PUBLIC DOCUMENT ROOM FROM:
Sandy Showman,lct' g Branch Chief Correspondence and Re rds Branch
@ch
SUBJECT:
RELEASE OF SECY-87-104 RELEASE OF SECY-87-114 The following two documents have been cleared for release to the public by the Commissioners' Offices.
1.
SECY-87-104 -- Proposed Agreement Between the State of Illinois and U.S.
Nuclear Regulatory Commission Pursuant to Section 274 of the Atomic Energy Act of 1954, as Amended 2.
SECY-87-ll4 -- Assessment of Georgia Power Company's Readiness Review Pilot Program at Vogtle Unit 1 I
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