ML18277A199

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NRC Program Inspection for Corrective Action Program Implementation Inspection
ML18277A199
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/03/2018
From: Victor Hall
NRC/RGN-II
To: Yox M
Southern Nuclear Company
Geanette D
References
IR 2018010
Download: ML18277A199 (19)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 3, 2018 Mr. Michael Yox VEGP 3 & 4 Regulatory Affairs Director Southern Company 7825 River Road Waynesboro, GA 30830

Subject:

NRC PROGRAM INSPECTION FOR CORRECTIVE ACTION PROGRAM IMPLEMENTATION INSPECTION

Dear Mr. Yox:

On August 23, 2018, the U.S. Nuclear Regulatory Commission completed the annual Corrective Action Program (CAP) inspection at your Vogtle Electric Generating Plant, Units 3 and 4. The inspection team discussed the results of the inspection with Mr. Joseph Klecha, Vice President Vogtle 3 and 4 Site Operation, and other members of your staff and documented the results in the enclosed inspection report.

The inspection examined a sample of construction activities conducted under your Combined License (COL) as it relates to safety and compliance with the Commissions rules and regulations and with the conditions of these documents. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection team sample selection concluded that the implementation of the CAP and overall performance related to identifying, evaluating, and resolving problems at Vogtle Electric Generating Plant Units 3 and 4 was adequate. Licensee and contractor identified problems were put into the CAP at an appropriate threshold. Problems were prioritized and evaluated proportional to the safety significance of the problems. Corrective actions were reviewed effectively and in a timely manner proportionate with their importance to safety and dealt with the identified causes of problems. Lessons learned from industry construction experience were effectively reviewed and applied when appropriate. Audits and self-assessments were generally used to find problems and appropriate actions. Based on the assessment of safety culture results, interviews done during the inspection, and a review of the employee concerns program, employees appeared to show freedom to raise nuclear safety concerns without fear of reprisal.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any), will be made publically available electronically in the NRC Public Document Room or from the Publically Available Records component of the NRCs document system, Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room).

M. Yox 2 Should you have any questions concerning this letter, please contact us.

Sincerely,

/RA/

Victor Hall, Deputy Director (Acting)

Division of Construction Oversight Docket Nos.: 5200025, 5200026 License Nos: NPF-91, NPF-92

Enclosure:

NRC Inspection Report (IR) 05200025/2018010, 05200026/2018010 w/attachment: Supplemental Information

M. Yox 3 cc:

Office of the Attorney General Resident Inspector 40 Capitol Square, SW Vogtle Plant Units 3 & 4 Atlanta, GA 30334 8805 River Road Waynesboro, GA 30830 Resident Manager Oglethorpe Power Corporation Mr. Barty Simonton Alvin W. Vogtle Nuclear Plant Team Leader 7821 River Road Environmental Radiation Program Waynesboro, GA 30830 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company, Inc. 4244 International Parkway, Suite 120 Document Control Coordinator Bin N-226-EC Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 George B. Taylor, Jr.

2100 East Exchange Pl Anne F. Appleby Atlanta, GA 30084-5336 Olgethorpe Power Corporation 2100 East Exchange Place Brian H. Whitley Tucker, GA 30084 3535 Colonnade Parkway, Bin N-226-EC 42 Inverness Center Parkway, BIN B237 County Commissioner Birmingham, AL 35243 Office of the County Commissioner Burke County Commission Mr. Michael Yox Waynesboro, GA 30830 Site Regulatory Affairs Director Vogtle Units 3 & 4 Mr. Wayne Guilfoyle 7825 River Road, Bin 63031 Commissioner District 8 Waynesboro, GA 30830 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334

M. Yox 4 Email acchambe@southernco.com (Amy Chamberlian) agaughtm@southernco.com (Amy Aughtman)

ALPUGH@southernco.com (Amanda Pugh) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) bjadams@southernco.com (Brad Adams) bwwaites@southernco.com (Brandon Waites) castelca@westinghouse.com (Curtis Castell) comerj@westinghouse.com (James Comer) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dgbost@southernco.com (Danny Bost) dlfulton@southernco.com (Dale Fulton) drculver@southernco.com (Randy Culver) durhamdc@westinghouse.com (David Durham) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David) erg-xl@cox.net (Eddie R. Grant) fdhundle@southernco.com (Forrest Hundley) fhwillis@southernco.com (Fred Willis)

G2NDRMDC@southernco.com (SNC Document Control) graysw@westinghouse.com (Scott W. Gray) jadwilli@southernco.com (J.D. Williams) james1.beard@ge.com (James Beard) jannina.blanco@pillsburylaw.com (Jannina Blanco) jantol1dj@westinghouse.com (David Jantosik) jenmorri@southernco.com (Jennifer Buettner)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) jpredd@southernco.com (Jason R. Redd) jranalli@meagpower.org (Jerry Ranalli) karen.patterson@ttnus.com (Karen Patterson) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) lchandler@morganlewis.com (Lawrence J. Chandler) markus.popa@hq.doe.gov (Markus Popa)

M. Yox 5 Matthew.Williams@hq.doe.gov (Matthew Williams) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith)

Michael.Kuca@hq.doe.gov (Michael Kuca) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mlgraves@southernco.com (Michelle Graves)

MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple) patriciaL.campbell@ge.com (Patricia L. Campbell)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) r.joshi15@comcast.net (Ravi Joshi)

RJB@NEI.org (Russell Bell)

Ronald.Jones@scana.com (Ronald Jones) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak) sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) skauffman@mpr.com (Storm Kauffman) sroetger@psc.state.ga.us (Steve Roetger) stephan.moen@ge.com (Stephan Moen) stephen.burdick@morganlewis.com (Stephen Burdick) tom.miller@hq.doe.gov (Tom Miller)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) vcsummer2n3@gmail.com (Brian McIntyre) wasparkm@southernco.com (Wesley A. Sparkman) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver) x2gabeck@southernco.com (Gary Becker) x2kmseib@southernco.com (Kristin Seibert)

Publicly Available Non-Publicly Available Sensitive Non-Sensitive SUNSI Review Complete Form 665 Attached OFFICE DCO DCO DCO DCO DCO DCO DCO SIGNATURE D. Harmon J. Lizardi G. Khouri T. Nazario S. Smith N. Coovert V. Hall DATE 09/28/2018 09/27/2018 10/02/2018 10/02/2018 09/28/2018 10/03/2018 09/28/2018 U.S. NUCLEAR REGULATORY COMMISSION Region II Docket Numbers: 5200025 5200026 License Numbers: NPF-91 NPF-92 Report Numbers: 05200025/2018010 05200026/2018010 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Unit 3 Combined License Vogtle Unit 4 Combined License Location: Waynesboro, Georgia.

Inspection Dates: August 13, 2018 through August 23, 2018 Inspectors: D. Harmon, Construction Inspector, DCO G. Khouri, Senior Construction Inspector, DCO J. Lizardi-Barreto, Construction Inspector, DCO T. Nazario, Senior Test Inspector, DCO S. Smith, Senior Construction Inspector, DCO Approved by: Victor Hall, Deputy Director (Acting)

Division of Construction Oversight Enclosure

SUMMARY

OF FINDINGS Inspection Report (IR) 05200025/2018010, 05200026/2018010; 08/13/2018 through 08/23/2018; Vogtle Unit 3 Combined License, Vogtle Unit 4 Combined License, Annual Corrective Action Program (CAP) inspection report.

This report covers a two week period of inspection by five Region II Construction Inspectors.

The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using IMC 2519, Construction Significance Determination Process, dated July 15, 2013.

Construction Cross Cutting Aspects are determined using IMC 0613, Power Reactor Construction Inspection Reports, dated February 9, 2017. The NRC's program for overseeing the construction of commercial nuclear power reactors is described in IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document, dated February 20, 2017 and IMC 2504, Construction Inspection Program: Inspection of Construction and Operational Programs, dated October 24, 2012. The CAP inspection was performed in accordance with inspection procedure (IP) 35007, Quality Assurance Program Implementation during Construction and Pre-Construction Activities, dated December 8, 2016.

Problem Identification and Resolution The inspection team sample selection concluded that the implementation of the CAP and overall performance related to identifying, evaluating, and resolving problems at Vogtle Electric Generating Plant Units 3 and 4 was adequate. Licensee and contractor identified problems were put into the CAP at an appropriate threshold. Problems were prioritized and evaluated proportional to the safety significance of the problems. Corrective actions were reviewed effectively and in a timely manner proportionate with their importance to safety and dealt with the identified causes of problems. Lessons learned from industry construction experience were effectively reviewed and applied when appropriate. Audits and self-assessments were generally used to find problems and appropriate actions. Based on the assessment of safety culture results, interviews done during the inspection, and a review of the employee concerns program, employees appeared to show freedom to raise nuclear safety concerns without fear of reprisal.

A. NRC-Identified and Self Revealed Findings No findings were identified.

B. Licensee-Identified Violations None

REPORT DETAILS

1. CONSTRUCTION REACTOR SAFETY Cornerstones: Design/Engineering, Procurement/Fabrication, Construction/Installation, Inspection/Testing IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs 1P01 Construction QA Criterion 15 - Nonconforming Materials, Parts, and Components
  • 35007-A15.04 - Inspection Requirements and Guidance
  • 35007-A15.04.01 - Inspection of QA Implementing Documents
  • 35007-A15.04.02 - Inspection of QA Program Implementation
a. Inspection Scope The inspectors reviewed recent revisions of quality assurance (QA) implementing documents for the control of nonconforming materials, parts, and components to verify they met the requirements in the Quality Assurance Program Document (QAPD) and commitments in Section 17.5 of the Updated Final Safety Analysis Report (UFSAR).

This review included documents and procedures related to the licensee's implementation of its processes to control nonconforming items in storage and nonconformance evaluations for items that were previously rejected, repaired, reworked, or accepted for use as is. The inspectors reviewed a sample of Nonconformance and Disposition Reports (N&Ds) and Nonconformance Reports (NCRs) to determine if:

  • the reports correctly and clearly identified the nonconformances;
  • the N&Ds and NCRs were adequately initiated, processed, reviewed, dispositioned, and closed in accordance with the quality assurance program implementing procedures for the control of nonconforming material, parts, and components;
  • applicability to project documents, records, and inspections, tests, analysis, and acceptance criteria (ITAAC) was properly identified and documented;
  • affected organizations were notified of the status of nonconforming items;
  • the dispositions were properly identified and documented;
  • there was adequate written technical justification for the acceptance of a nonconforming item, dispositioned repair, or use-as-is;
  • nonconformances dispositioned use-as-is or repair were subjected to design control measures commensurate with those applied to the original design; and
  • repaired or reworked items were re-examined in accordance with applicable procedures and with the original acceptance criteria unless the disposition had established alternate acceptance criteria.

2 The inspectors reviewed procedures and interviewed licensee staff regarding trend analysis and reporting programs for NCRs and N&Ds. This information was used to determine if the licensee periodically trended and assessed information from these programs; identified programmatic and common cause problems; and then communicated the results of the trending to the applicable personnel.

The inspectors toured the offsite warehouse to determine if the licensee was segregating and controlling nonconforming items in accordance with its approved procedure for controlling nonconforming items. The inspectors reviewed a sample of nonconforming items, from the offsite warehouse, to determine if clear and traceable identification of nonconforming items was maintained to prevent inadvertent use, installation, or testing as required by the licenses procedures.

b. Findings No findings were identified.

1P02 Construction QA Criterion 16 - Corrective Action

  • 35007-A16.04.01 - Inspection of QA Implementing Documents
  • 35007-A16.04.02 - Inspection of QA Program Implementation

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope The inspectors reviewed the licensee's Corrective Action Program (CAP) to determine if the licensee effectively implemented its approved quality assurance program as required by 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. The licensee clearly defined the interface requirements for implementing the CAP to its contractors, Westinghouse and Bechtel. The delegation was allowed by the licensees QAPD, Section 16, and details outlined in the services agreement and interface documents. The inspection scope therefore included a review of the CAP interface between the licensee and its contractors.

The inspectors reviewed implementing procedures and documents from the licensee and its contractors for the identification, evaluation, and resolution of conditions adverse to quality to determine if they met Section 16 of the licensee's QAPD, Basic Requirement 16 of NQA-1, and Section 17.5 of the UFSAR.

The inspectors reviewed revisions to the CAP procedures (ND-AD-002 & W2-5.1-101) to verify that the changes made did not reduce commitments, license requirements, etc.

and to verify that the procedure changes did not negatively impact CAQs, condition reports, and reportable items.

The inspectors reviewed the CAP implementing procedures to determine if they established: thresholds for problem identification, requirements for the effectiveness of immediate and preventative corrective actions and the accuracy and thoroughness of problem documentation, and the adequacy of corrective actions for previously identified compliance issues. The program review scope included an evaluation of the following CAP performance attributes to verify if they were addressed in the CAP programs:

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  • classification, prioritization, and evaluation for reportability of CAQs;
  • complete and accurate identification of problems in a timely manner fitting with their significance and ease of discovery;
  • screening of items entered into the CAP to determine the proper level of evaluation;
  • finding and fixing procurement program problems;
  • finding and fixing design errors;
  • considerations for extent of conditions, generic implications, common causes, and previous occurrences as appropriate;
  • classification and prioritization of the resolution of problems fitting the safety significance;
  • identification of corrective actions focused to fix the problem;
  • completing corrective actions in a timely manner proportional to the safety significance of the issue (including the use of interim corrective actions to minimize the problem and/or mitigate its effects until permanent actions can be done);
  • provisions for escalating corrective actions that are not adequate or timely to higher management;
  • overview of trends in CAQs;
  • coverage to include important non-safety related structures, systems, and components; and
  • evaluation of operating experience information.

The inspectors reviewed a sample of CAP issues closed since the last CAP inspection (August 2017) to determine if the program procedures were properly implemented. The issues chosen included a diverse sample across the licensee and contractors' programs.

The inspectors sampled issues related to CAQs and issues that had been determined to not be CAQs to determine if:

  • classification and prioritization of the resolution of each problem was proportionate with its safety significance and at the appropriate threshold;
  • conditions were screened upon entry into the CAP to determine the proper level of evaluation;
  • proper consideration was given to extent of conditions, generic implications, common causes, and previous occurrences;
  • the corrective actions were focused to ensure the problems were fixed;
  • the identification and correction of design deficiencies were being adequately addressed;
  • extent of conditions were adequately addressed and appropriate corrective actions were developed and done; and
  • the evaluations properly considered the escalation of issues to higher management if the corrective actions were not adequate or timely.

4 The inspectors reviewed the procedures and a sample of issues from the licensee and contractors observation, trending, and metrics programs to determine if the licensee was identifying CAQs and transferring those issues to the respective CAP program.

The inspectors reviewed a sample of recent trend reports and metrics to determine if:

  • the trend reports were issued within the time frames given in procedures;
  • the trend reports and metrics had information and analyses of licensee and contractor performance improvement activities; and
  • CAP inputs were generated for adverse trends or recommendations as required by program procedures.

The inspection scope included an evaluation of the handling of issues introduced into the CAPs from sources such as: self-assessments and audits, NRC generic communications, and operating and construction experience.

The inspectors evaluated the processing of CAP entries to determine if the following qualities were considered: risk, safety significance, consequence of malfunctions, complexity of design and fabrication, needs for special controls or surveillance over activities, the degree to which functional compliance could be shown by inspection or test, the quality history and degree of standardization of items, and the difficulty of repair or replacement.

The inspection of alternative processes to handle issues that do not constitute conditions adverse to quality is documented under Criterion 15 (Section 1P01 of this report).

The inspectors reviewed a sample of Condition Reports (CRs) and Corrective Action, Prevention, and Learnings (CAPALs) for non-safety related structures, systems, and components that have safety significant functions. Specifically, the inspectors reviewed CRs and CAPALs for regulatory treatment of non-safety systems (RTNSS) components to verify that the coverage of the CAP was extended to these components as required by the QAPD, Section 16, and the Updated Final Safety Analysis Report (UFSAR), Section 17.3 and 17.4.

b. Assessment Assessment - Effectiveness of Problem Identification The inspectors determined, based on the sample of issues reviewed, that issues were being effectively identified. The samples reviewed indicated that issues were identified in a timely manner; they were described clearly; and a systematic screening processes ensured that issues were appropriately entered into the CAP.

Assessment - Effectiveness of Prioritization and Evaluation of Issues Based on the sample of issues reviewed, the inspectors determined that the licensee was adequately evaluating and prioritizing issues. The reviewed sample of issues were screened by appropriate levels of management and they were assigned levels corresponding to their significance. There were no significant conditions adverse to quality identified in the last 12 months for review.

5 Assessment - Effectiveness of Corrective Actions The inspectors determined that in the selected sample, corrective actions for identified deficiencies were timely, adequate, and proportional to their safety significance.

Problems found by apparent cause investigations were handled per the licensees CAP procedures.

c. Findings No findings were identified.

.2 Assessment Use of Construction Experience

a. Inspection Scope The inspectors interviewed the licensee's principal managers of construction and operating experience to understand how they handled relevant internal and external experiences. The inspectors reviewed the licensee's experience database and CAP to determine if items that were classified as applicable to the site were entered into the CAP as specified by their construction experience program procedure ND-AD-VNP-004.

The inspectors reviewed the licensee's experience database to determine if it added NRC related information, such as NRC Regulatory Issues Summaries and Information Notices. The inspectors reviewed a sample of CAP documents to determine if disposition and handling of applicable industry experience items met the construction experience program procedure.

b. Assessment Based on the inspection activities described, the inspectors determined that the licensee adequately identified construction and operating experience; adequately screened and evaluated these experiences for applicability to the project; and entered issues into their CAP program for tracking and handling.
c. Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope The inspectors reviewed a sample of documented audits, and a CAP self-assessment.

The review was performed to determine whether the oversight of the CAP by the licensee was sufficient to verify the health of the program and to identify areas for improvement as needed. The inspectors also compared the results of the audits and self-assessment to the results of the inspection to determine if there were any discrepancies between the results of the inspection and the licensees conclusions.

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b. Assessment The inspectors determined that the conduct of audits and self-assessments by the licensee were accomplished in accordance with the established plans. Corrective actions to address the identified issues were generally prioritized, evaluated, and completed within applicable procedural requirements.
c. Findings No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope The inspectors conducted a review to provide insight into whether a safety conscious work environment (SCWE) was being maintained at the site. The inspectors assessed the sites Employee Concern Program (ECP) effectiveness and evaluated management oversight of the corrective action process including anonymous CAP entries. These reviews were used to determine if construction personnel were willing to report safety issues via the different avenues available (CAP, ECP, management, etc.).

The team performed the following activities:

  • conducted interviews;
  • reviewed the ECP work instructions;
  • reviewed various ECP case files and Work Environment Assessments (WEA);

and

  • performed a walk-down of the ECP and CAP drop boxes and office locations.

The inspectors interviewed construction staff to identify areas and issues that may represent challenges to the free flow of information, such as areas where employees may be reluctant to raise concerns or report issues in the CAP.

The inspectors reviewed the ECP work instructions and interviewed ECP personnel to understand the interrelationship between the licensee and construction personnel; and the current health and challenges of the sites SCWE as assessed by the ECP office.

The licensees ECP procedures and files were reviewed to determine if:

  • procedures were adequate to implement a site ECP;
  • files contained adequate documentation;
  • issues were entered and reviewed in a timely manner;
  • concerns were adequately addressed;
  • corrective actions were tracked; and
  • individuals were provided feedback.

ECP WEAs were reviewed to determine if identified issues were addressed and actions to prevent recurrence were put in place.

7 The inspectors evaluated a sample of anonymous concerns entered into the CAP.

These CAP entries were reviewed to determine if issues raised anonymously were promptly entered, into the CAP, and addressed.

b. Assessment Based on this review, the NRC found no evidence to indicate that there are challenges to the construction organizations SCWE. Overall, individuals were willing to raise safety concerns without fear of retaliation. The interviews also indicated that, in general, the craft were aware of the various avenues to report safety concerns and were willing to use them. The ECP was effective in evaluating concerns that were reviewed during this inspection. Anonymous CAP entries reviewed by the inspectors were determined to be properly investigated and dispositioned. From the inspection results, the inspectors determined that employees felt free to raise issues.
c. Findings No findings were identified.

4OA6 Meetings, Including Exit

1. Exit Meeting.

On August 23, 2018, the inspectors presented the inspection results to Joseph Klecha, VP Site Operations, along with other licensee and contractor staff members.

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensees and Contractor Personnel D. Mickinac, SNC Licensing C. Perego, WEC Licensing C. Calia, SNC PI-CAP Manager J. Ealick, SNC CAP supervisor K. Stacy, SNC Licensing Supervisor M. Yox, SNC Licensing Director T. Cheek, Bechtel PI & CAP Supervisor C. Castell, SNC Licensing J. March, SNC ECP T. Edwards, SNC ECP LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description None LIST OF DOCUMENTS REVIEWED Section 1P01 Procedures:

Vogtle 3&4 Updated Final Safety Analysis Report, Rev. 6.2 NDQAM, SNC Nuclear Development Quality Assurance Manual, Version Number 18 (per SNC UFSAR, the QAPD is the SNC Nuclear Development Quality Assurance Manual) 26139-000-4MP-T81C-N7104, "Control of Non-Conforming Items," Rev. 2 26139-000-GQN-GAQG-N0001, "Bechtel Nuclear Quality Control Manual," Rev. 0 APP-GW-GAP-428, "Nonconformance and Disposition Report (N&D)," Rev. 15 26139-000-GPP-GAQ-00004, "General Project Procedure Metrics and Trending," Rev. 0 26139-000-4MP-T81C-N7104, "Control of Nonconforming Items," Rev. 3 Nonconformance Reports (NCRs):

26139-000-G61-GCQ-00005, 26139-000-G61-GCQ-00009, 26139-000-G61-GCQ-00012, 26139-000-G61-GCQ-00016, 26139-000-G61-GCQ-00021, 26139-000-G61-GCQ-00028, 26139-000-G61-GCQ-00031, 26139-000-G61-GCQ-00034, 26139-000-G61-GCQ-00039, 26139-000-G61-GCQ-00045, 26139-000-G61-GCQ-00061, 26139-000-G61-GCQ-00066, 26139-000-G61-GCQ-00071, 26139-000-G61-GCQ-00075, 26139-000-G61-GCQ-00080, 26139-000-G61-GCQ-00084, 26139-000-G61-GCQ-00089, 26139-000-G61-GCQ-00095, 26139-000-G61-GCQ-00101, 26139-000-G61-GCQ-00107, 26139-000-G61-GCQ-00112, 26139-000-G61-GCQ-00116, 26139-000-G61-GCQ-00398, 26139-000-G61-GCQ-00420, Nonconformance & Disposition Reports (N&Ds):

APP-1208-GNR-850862, Rev. 0, APP-CH71-GNR-850001, SV4 CH71_02B Rev. 0, APP-PV40-GNR-850076, Rev. 0, APP-PXS-GNR-850032, Rev. 0, SV3-CC01-GNR-000480, Rev. 0, SV3-

2 CC01-GNR-000495, Rev. 0 , SV4-CA20-GNR-000186, Rev. 0 , SV4-CC01-GNR-000292, Rev.

0, SV4-CR01-GNR-000413, Rev. 0 , SV3-CP01-GNR-000037, Rev. 0 SV4-SS01-GNR-000141, Rev. 0 SV3-CR01-GNR-000978, Rev. 0 SV4-CR01-GNR-000405, Rev. 0 SV4-CA05-GNR-000043, Rev. 0 SV4-CA05-GNR-000018, Rev. 0 SV4-CR01-GNR-000404, Rev. 0 SV3-SS01-GNR-000743, Rev. 0 APP-SS01-GNR-850244, Rev. 0 SV3-WWS-GNR-000155, Rev. 0 SV3-CR01-GNR-000975, Rev. 0 Condition Reports (CRs):

10471644, 10467942, 10466828 Miscellaneous Documents (Misc.):

IR # 26139-SV3-IR-C0-00032, WP SV3-1230-C0W-850005 Concrete Pre-Placement Inspection Record, dated 3/12/2018 Section 1P02 Procedures:

26139-000-4MP-T81C-N6201, Field Material Storage Control, Rev. 2 26139-000-4MP-T81C-N7104, Control of Nonconforming Items, Rev. 3 ND-AD-002-004, Management Review Committee (MRC) Charter, Version 1.0 W2-5.1-101, Westinghouse Corrective Action Program procedure, Rev. 3.0 W2-5.1-101, Westinghouse Corrective Action Program procedure, Rev. 4.0 W2-5.1-104, Apparent Cause Analysis, Rev. 1.2 W2-5.1-102, Issue Review Committee, Rev. 3.0 ND-RA-001-005, Screening, Evaluating, and Reporting Conditions Related to ITAAC, Version 7.0 NCSP 03-16, Preventative Maintenance (PM) Program, Rev. 07.00 SVPP 08-01, Preservation and Preventative Maintenance (PPM), Rev. 01 26139-000-GQN-GAQG-N0001, Bechtel Nuclear Quality Control Manual, Rev. 0 W2-5.1-102, Issue Review Committee, Rev. 4 W2-5.1-102, Issue Review Committee, Rev. 4.1 W2-5.1-102, Issue Review Committee, Rev. 5 ND-AD-002-025, Issue Identification, Screening, and Dispatching, Version 1.0 ND-AD-002, Nuclear Development Corrective Action Program, Version 27.0 Vogtle 3&4 Updated Final Safety Analysis Report, Rev. 6.2 NDQAM, SNC Nuclear Development Quality Assurance Manual, Version Number 18 (per SNC UFSAR, the QAPD is the SNC Nuclear Development Quality Assurance Manual)

Project ECP Work Instruction, rev. 0 ND-AD-VNP-004, Construction Experience Program, Version 12 NMP-GM-008, Operating Experience Program, Version 19

3 CRs:

10394581, 10396913, 10396918, 10402069, 10421289, 10416584, 10402072, 10402069, 10445807, 10485332, 10491047, 10400471, 10405955, 10418241, 10484251, 10434660, 10449023, 10453322, 10501642, 10506754, 10488549, 10492910, 10481819, 10439965, 10403028, 10411396, 10421408, 10457245, 10499009, 10510440, 10423894, 10507461, 10449056, 10060139, 10391946, 50003622, 10386272, 10389687, 10274783 Corrective Action Report (CARs):

270890, 270970, 270975, 271136, 272003, 272469, 273788, 274008, 271119, 271161, 271868, 274096, 273905, 273632, 272431, 272627, 271931, 272671, 271868, 270562, 271977 CAPALs:

100488631, 100488579, 100488622, 100489811, 100489810, 100496573, 100509386, 100492464, 100491074, 100224197, 100224197, 100482542 Technical Evaluation (TEs):

991448, 1005354, 1010420, 1011692, 1011693, 997104, 997106, 997107, 1014573, 1002801, 974103 Misc.:

ND-17-2023, Vogtle 3&4 Construction Project Quality Assurance Interface Document - Bechtel, Rev. 0 SVP_SV0_005074, Approved Vogtle 3 & 4 Construction Project Quality Assurance Interface Document, Rev. 1 Services Agreement between Georgia Power Company, and WEC & WECTEC, Rev. 0 Work Environment Assessments:

WEA 2017005995 WEA 2018005780 WEA 2018005631 WEA 2018005202 WEA 2018003369 WEA 2018000227 WEA 2017005713 Audits/Assessment:

SNC Audit Report ND-CS-CAP-2018, PI&CAP Audit March 9, 2018 Bechtel Audit report 26139-000-2QA-GAQ-18001, QA Audit Vogtle Units 3 & 4 Construction Completion Project, Revision 0 Bechtel Audit Checklist: 26139-000-2QC-GAQ-00001, Vogtle 3&4 Construction Completion Project, Rev. 0 SNC Document NDD-18-0624, NDQA Audit Report for the WEC QA and ASME Programs, SNC-ND-2018.01-WEC-SIE/CORP-QA/ASME, Dated May 1, 2018 Focused Area Self-Assessment (FASA) Plan and Report, CAP FASA, Dates of Assessment, 6/4/2018 6/8/2018 LIST OF ACRONYMS CAPAL Corrective Action, Prevention, and Learning CAP Corrective Action Program CAQ Condition Adverse to Quality CR Condition Reports

4 ECP Employee Concern Program ITAAC Inspections, Tests, Analysis, And Acceptance Criteria NCR Nonconformance Report N&D Nonconformance and Disposition Report QA Quality Assurance QAPD Quality Assurance Program Document SCAQ Significant Conditions Adverse to Quality SCWE Safety Conscious Work Environment UFSAR Updated Final Safety Analysis Report WEA Work Environment Assessment