ELV-03939, Submits Clarification to Re Rev to Biennial Review of Plant Procedures,Per NRC 920721 Request.Revised, Proposed FSAR Markups,Including Description of How EOPs & Abnormal Procedures Will Be Maintained,Encl

Submits Clarification to Re Rev to Biennial Review of Plant Procedures,Per NRC 920721 Request.Revised, Proposed FSAR Markups,Including Description of How EOPs & Abnormal Procedures Will Be Maintained,Encl

ML20113J189
Person / Time
Site:	Vogtle
Issue date:	08/03/1992
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ELV-03939, ELV-3939, NUDOCS 9208070140
Download: ML20113J189 (7)

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7t p H C.K.McCoy Georgia Power r .-* w August 3, 1992 Docket Nos. 50-424 ELV-03939 50-425 4

U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 4

V0GTLE ELECTRIC GENERATING PLANT BIENNIAL REVIEWS OF NUCLEAR PLANT PROCEDURES CLARIFICATION Gentlemen:

In response to the letter from Caudie A. Julian, NRC to W. G. Hairston, III dated July 21, 1992, Georgia Power Company hereby submits a clarification to its letter dated April 3,1992 regarding the revision of the biennial review of procedures. The Quality Assurance Program, as described in the Vogtle Electric Generating Plant Units 1 and 2 Final Safety Analysis Report (FSAR),

Sections 1.9.33, 13.5.1.1 and 17.2.1.3.3, will be revised, using guidance provided in the above referenced NRC letter, to include a description of how emergency operating procedures (EOPs) and abnormal procedures (A0Ps) will be maintained accurate. E0Ps and A0Ps will continue to be reviewed at least every two years by a knowledgeable individual to determine whether changes are necessary or desirable.

Attachment I to this letter provides the revised proposed FSAR markups.

Pursuant to the requirements of 10 CFR 50.54 (a), Georgia Power Company continues to conclude that there would be no significant reduction-in commitments in the Quality Assurance Program as a result of this change.

The Plant Review Board has reviewed and recommended approval of this proposed change and_the Safety Review Board will review this proposed change at a future meeting.

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/1 1 9 08070140 920803 I

PDR ADOCK 05000424 ,i P PDR l

U.S. Nuclear Regulatory Commission Page 2 l I

In accordance with 10 CFR 50.91, the designated state official will be sent a copy of this letter and all enclosures.

Respectfully submitted, GEORGIA POWER COMPANY C. K. McCoy

) CKM/JMG Attachment

! Sworn to and subscribed before me this 8 day of M t(4 , 1992.

'tWe w 'fl. did1

> Nota'ry Public. 7 My Commission Expires: **83"* Wl],

cc: Georaia Power Comoany Mr. W. B. Shipman, General Manager - Plant Vogtle NORMS U. S. Nuclear Reaulatory Commission. Washinaton. DC Mr. D. S. Hood, Licensing Project Manager - Vogtle U. S. i clear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. B. ;s. Bonser, Senior Resident Inspector - Vogtle Mr. C. A. Julian, Chief - Engineering Branch Mr. F. Jape State of Georaia Mr. J. D. Tanner, Commissioner, Department of Natural Resources l

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1 ATTACHMENT I REVISED PROPOSED FSAR MARKUPS

VEGP-FSAR-1

3. Paragraph C.S g of Regulatory Guide 1.33 will be implemented with the addition of the modifier "normally" after each of the verbs (should) which the Regulatory Guide converts to "shall. " It is GPC intent to_ fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by_ management personnel. In these cases, the reason for the exception shall be retained for the same period of time

%gQ fected preoperational tests.

4. Inwt I 1.9.34 REGULATORY GUIDE 1.34, DECEMBER 1972, CONTROL OF ELECTROSLAG WELD PROPERTIES 1.9.34.1 Regulatory Guide 1.34 Position This guide describes an acceptable method of implementing requirements with kegard to the control of weld properties when fabricating electroslag welds for nuclear components made of ferritic or austenitic materials.

1.9.34.2 VEGP Position Conform. Refer to paragraph 5.2.3,4,6.

1.9.35 REGULATORY GUIDE 1 35, REVISION 2, JANUARY 1976, INSERVICE INSPECTION OF UNGROUTED TENDONS IN PRESTRESSED CONCRETE CONTAINMENT STRUCTURES 1.9.35.1 Requiatory Guide 1.35 Position This guide describes an acceptable basis for developing an appropriate inservice inspection and surveillance program for ungrouted tendons in prestressed concrete containment structures.

1.9.35.2 VEGP Position Conform au discussed in subsection 3.8.1.

1.9-32

VEGP-FSAR-13 Operations department heads-shall further ensure that procedures described in subsection 13.4.1 are forwarded to the Plant Review Board (PRB) for additional review.

For procedures not forwarded to the PRB, reviewers will meet requirements of section 4.4 of ANSI N18.1-1971 for applicable disciplines. For those' disciplines not described in section 4.4 of ANSI 18.1-1971, the reviewer will have a minimum of 5 years experience. A maximum of 4 years of this 5 years may be fulfilled by related technical or academic training. Reviewers of quality control inspection procedures shall meet the requirements of Regulatory Guide 1.58. Also, those procedures not forwarded to the pRB and impacting another department's area of responsibility, shall be forwarded to the impacted departments for their review.

The general manager-nuclear plant (Vogtle) (GMMP) has ultimate responsibility for all plant procedutes, provisions of these procedures establish the GMNP as the approving authority for procedures which establish plant-wide administrative controls (which implement the quality assurance program and the Technical Specifications surveillance program); unit operating procedures (UOPs); emergency operating procedures (EOPs); abnormal operating procedures (A0ps);

procedures for implementing the security plan, the emergency plan, and the fire protection program; and fuel handling procedures. Nuclear Operations department heads are established as the approving authority for other procedures covering activities l

within their area of responsibility.

1 Additional provisions of these procedures exist to ensure that changes or revisions to procedures are reviewed and approved in accordance with the same administrative controls used for review and approval of new procedu res .% A-trev&nen- is madc t o ensu r c t4 tat p 1 a n t p ^cedu-r-es-exce p t f4+ef-ight-ing--prephns a r c l revicued--at-least every 2 yea rs by a %celedgeable-l i-ndividu al t o det+emi-nc w he t h c r cheng e s a r s n e c c s s s er e+-des i r a b l-a . Also, provisions exist to ensure that procedures, once approved, are-distributed appropriately so that only the most current procedures are used by plant personnel.

Enserf Z.

13.5.1-2 REV 1 3/91

VEGP-FSAR-17 17.2.1.3.3 SNC Safety Audit and Engineering Review (Onsite) l The SNC SAER staff will selectively audit those quality-related l activities that are within the scope of the OQAP, as described in subsection 17.2.2, to verify compliance with the requirements of the OQAP. These consist of activities performed onsite and those performed offsite in support of VEGP when directed. T'9 results of all such audits will be reported to the organization audited and the vice president-nuclear (Vogtle).

SAER personnel have written authority to stop work on a system, structure, or component that affects nuclear safety if the work is not in accordance with provisions of the OQAP. Disputes arisinJ from differences of opinion between SAER personnel and other department personnel will be resolved by the lowest level of management possible. If necessary, the vice president-nuclear (Vogtle) will make the final disposition. The MSAER shall regularly assess the SAER workload to ensure a sufficient number of personnel are available for complete and efficient implementation of their quality assurance responsibilities.

Specific duties and responsibilities of the SAER onsite group (headed by the supervisor-safety audit and engineering review) are as follows:

A. Prepares annual schedule and performs planned audits of organizations and activities (GPC and contractors).

B. Provides the MSAER with information on site activities on a routine basis.

C. Maintains open-items list of SAER onsite group eudit results; follows up until resolved and closed out.

D. SAER participates in the development process for plant

'~'~~~ % procedures by evaluating procedure adequacy and E . Insed-/3 ) implementation in the SAER audit program and through its non-voting membership in the Plant Review Board.

SAER personnel have access to meetings where quality matters are discussed. The MSAER shall designate the types of meetings his staff or representative (s) from his staff will routinely attend, including day-to-day work planning meetings and staff meetings.

17.2.1.4 Engineering The SNC Nuclear Support (Vogtle) has overall responsibility for l assuring the availability of and providing or securing adequate engineering and technical support for the VEGP. The SNC manager- l

( nuclear engineering and licensing (Vogtle) serves as the 17.2.1-7 REV 1 3/91

4 INSERT 1 During original plant licensing, a 2 year review process for plant procedures was developed to meet the requirement of Regulatory Guide 1.33 and ANSI 18.7-1976. Since the procedural process has now matured and

adequate programs to assure procedural revisions consistent with plant design, operational, and regulatory requirements are in place, this original commitment has been modified to require biennial Quality Assurance audits of procedures and the procedural development and maintenance program utilizing a representative sampling process. Non-routine procedures, which are emergency operating procedures (EOPs) and abnormal procedures (A0Ps), will continue to be reviewed at least every two years and revised as appropriate.

Therefore, the 2 year review process for procedures, except E0Ps and A0Ps and other programs where a review requirement is specifically stated, is no longer required.

INSERT 2 A provision is made to ensure that E0Ps and A0Ps are reviewed at least every two years by a knowledgeable individual to determine whether changes are necessary or desirable.

As a part of the overall quality assurance program, the SAER group performs various audits (described in 17.2) to assure that the procedural process is working and that procedures are being properly maintained.

INSERT 3 To assure that controls are in place to effectively maintain plant procedures, the SAER staff will perform a biennial audit of plant procedures and the procedural development and maintenance program utilizing a representative sampling process. The audit will ensure the acceptability of the procedures and verify that the procedure review and revision program is

. being implemented effectively. The root cause of significant deficiencies will be determined and corrected.

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