IR 05000424/1986034

Insp Rept 50-424/86-34 on 860325-0729 of Readiness Review Module 9A, Radiological Protection. Resolution of Most Findings Adequate.Some Corrective Actions Remain to Be Completed

ML20215F113
Person / Time
Site:	Vogtle
Issue date:	12/05/1986
From:	Hosey C, Novak T, Sinkule M, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F086	List: IR 05000424/1986034 ML20215F082
References
50-424-86-34, NUDOCS 8612230267
Download: ML20215F113 (17)

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UNITE) STATES

• AEZug'o,^ NUCLEAR REGULATORY COMMISSION O REGION 88 h ,

101 MARIETTA STREET, * ^t ATI.ANTA, GEORGI A 30323 s,*****/

DEC 111986 Report No.: 50-424/86-34 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 g

Docket No.: 50-424 License No.: CPPR-108

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Facility Name: Vogtle 1 Review Topic: Vogtle Readiness Review Module 9A, Radiological Protection Review Conducted: March 25 - July 29, 1986 On-Site Inspections Conducted: April 21-25,1986 May 5-9, 1986 June 2-6, 1986 NRC Offices Participating in Inspections / Reviews:

Office of Inspection and Enforcement, Bethesda, MD Office of Nuclear Reactor Regulation, Bethesda, MD Region II, Atlanta, Georgia Lead Technical Reviewer: / /0 f!8%

G. L. Troup y . D' ate Signed Senior Radiation Specialist, Region II Reviewers: R. J. Serbu, Health Physicist, NRR W. L. Belke, Quality Assurance Engineer, IE F. R. Orr, Reactor Systems Engineer, NRR Approved by: jk & & /#Mf'[84 C. M. Hosey, Section CJief Date Signed Facilities Radiation Protection Section Division of Radiation Safety and Safeguards Region II # /

f _l 7 M. V.' Sinkule', Chief

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Date Signed Projects Section 2D Division of Reactor Projects Regio II k LL nW 5 ,

T. bcyak, Depu~ty Director / Dath Signed Division of PWR Licensing-A /

Office of Nuclear Reactor Regulation e612230267 861211 4 DR ADOCK 0500

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TABLE OF CONTENTS

TOPIC PAGE

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~ Summary- 1

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Scope of' Review 2

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Meti.edology 3 Evaluations 4 Findings 13 Conclusions 14 References 15

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V0GTLE' ELECTRIC GENERATING PLANT, UNIT 1

, READINESS REVIEW PROGRAM MODULE 9A~

RADIOLOGICAL PROTECTION SUMMARY The - Readiness -Review Program is being _ conducted at the initiative of Georgia o Power Company -(GPC) management to assure that all design, construction, and J . operational commitments. have been properly identified and implemented at the Vogtle Electric Generating Plant Unit Module .9A, which was presented on March 25, 1986, presents an assessment to

!. ascertain whether the Radiological _ Protection Program complies with Final Safety Analysis. Report (FSAR) commitments and regulatory requirements. This evaluation- i

was conducted to determine if the results of the program review of the

Radiological Protection. Program presented in this module are an effective and accurate assessment of the requirements, that the requirements are being properly i implemented, and that the resolutions of the findings identified in Module 9A were corrected or being correcte ,

This evaluation was performed by NRC reviewers and inspectors from the Office of

Inspection and Enforcement (I&E), the Office of Nuclear Reactor Regulation (NRR),

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and Region II .(henceforth referred to as the staff). .The evaluation was i . accomplished through a detailed review of all sections of the module by:

! Verifying that commitments identified in the module properly reflected FSAR '.

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commitments- and regulatory requirements.

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i Verifying, by review of a comprehensive and representative sample of approved procedures, that commitments are being implemented into procedure . Verifying, by review of a sample of programs delineated within the module, ,

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that program implementation is in accordance with procedures and

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k Reviewing the module findings identified by GPC and evaluating the correctness of their resolutio During this evaluation, it was apparent to the staff that GPC management

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i-supported the program by active participation in the development and *

l implementation of the program. This evaluation also indicated that when apparent deficiencies or discrepancies which indicated potential problems with the review process itself, were identified by the staff, management responsiveness was positive and prompt resolution of concerns was achieve .

As discussed in the conclusions section of this report, the staff finds that some aspects of the radiological protection program are adequate, and some aspects i

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require further actions between GPC and the staff to achieve full resolution.

With regard to those aspects considered to be adequate:

Identification of comitments in FSAR, SER and related documents Implementation of comitments in plant procedures and documents

Coordination of commitments with the elements of the programs which make up the radiological protection program.

With regard to those aspects which require further action to achieve full resolution:

The requirement for a qualified health physics technician to be onsite at all times when there is fuel in the reactor (versus an individual qualified in health physics procedures).

Requirements for high radiation area controls which differ from the Standard Technical Specifications (and may omit some critical control elements).

These two items relate to the Technical Specifications which will be implemented when the operating license is issued. They do not degrade or reflect on the implementation of the radiological protection program.

The finding identified during this evaluation is discussed in Sections 3 and 4 of this report and is summarized belo IFI 424/86-34-01 Installation and testing of a shielded prefilter in the Technical Support Center ventilation system. Scope of Review This review, which consisted of an examination of each section of the module, was performed by reviewers from NRR, IE, and inspectors from Region II. The scope of the NRC review and the subsequent NRC findings were limited due to the operational nature of radiological protection progra Although the commitments have been included in approved procedures, the programs have not been implemented. The NRC inspection program will be performed by Region II to complete review activities in the implementation of the programs prior to licensin GPC performed a program verification to ascertain that the radiological protection program was properly implemente The program was conducted in three parts: verification of commitments, verification of commitment implementation, and a field vecification to identify potential problem The process utilized ten team members to examine the implementation of approximately 300 commitment Module Sections 1.0, 2.0, 5.0, and 7.0, which contain information concerning the module introduction, organization, division of responsibility,

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interfaces, audits, special investigations, and conclusions regarding the assessment of the module, did not require as detailed a review or evaluation as the remaining sections. The more significant aspects of the module appear in Sections 3.0, 4.0, and 6.0. These sections discuss applicant commitments, method of implementing comitments, program implementation and prograa verification. Review of these sections included a detailed review of the content, examination of items identified as findings, an examination of a sample of documents reviewed by the GPC Readiness Review Staff, and an examination of independently selected sample of document The staff review was based on commitments contained in the Vogtle Final Safety Analysis Report (FSAR) and in the Vogtle Technical Specification sections (draft documentr,). The primary areas considered in this review covered the radiation protection and ALARA programs proposed for Vogtle by GPC. A portion of the review encompassed those commitments contained in the Vogtle Module 9B (Chemistry) related to radioactive waste systems and environmental and radiological surveillance of Vogtle. Radiation protection commitments related to quality assurancc were reviewed by the Quality Assurance Branch of the Office of Inspection and Enforcement (IE).

Radiation protection comitments related to conduct of operations were reviewed by the Facilities Operations Branch, Division of PWR Licensing-A, NRR and the Facilities Radiation Protection Section, Region I . Methodology The review of Section 3.4 of Module 9A was performed by comparing the information presented in the commitment matrix to the FSAR, SER, and related plant documents filed for Vogtle. All applicable sections of the FSAR and SER were reviewed for consistency and comprehensiveness whether or not there were commitments to cover these areas. Discussions with the staff and Georgia Power representatives were held to resolve questions and clarify procedures.

! Formal responses to staff quest:ons were provided by Georgia Power Co. The applicant satisfactorily responded to these questions and either modified the commitment matrix or revised the FSAR to reflect the correct Standard Review Plan positio The review and evaluation by Region II was accomplished by reviewing the i module in its entirety in the Region II office beginning on March 25, 1986, and by inspections at the Vogtle site on April 21-25, May 5-9, and June 2-6, 198 The Region II review of Section 3.0, Commitments, was accomplished in two part The commitment matrix was briefly reviewed by Region II personnel since NRR performed this review as previously discussed. Review of the implementation matrix concentrated on verification of the radiological protection program commitments and their corresponding implementing l procedures. The commitment sources by Region II were primarily portions of I the FSAR. Selection of commitments for verification was based in part on those which comprised a program, such as dosimetry or respiratory l

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protection, rather than a random selectio The review of Section 4.0, Program Description, was accomplished by examining four programs and comparing the description with the commitment section and regulatory requirement . Evaluations The evaluation of each section reviewed is provided below. For each module section, a description of the section, a description of the review conducted on that section, and a description of the results of each review is provided, Section 1.0 - Introduction This section of the module presents an introduction to the intent and content of the module organization, areas of evaluation, and status of the projec This section was reviewed primarily for content and background information. No additional followup or evaluation of the section was require Section 2.0 - Organization and Division of Responsibilities This section discusses the organization and division of responsibility associated with the health physics program and the radiological shielding design program between the Plant Vogtle staff, Georgia Power Company corporate staff, and Bechtel Power Corporation. This section includes a discussion of the various parts of the health physics department organizatio As part of the review of Module 2, Operations Training and Qualification, it was noted that the organization as shown in FSAR Figure 13.1.2-1 and discussed in FSAR Section 12.5 was different than the organization discussed in Module Organizational differences concerned the separation of the Health Physics and Chemistry departments into two departments, each under a superintenden Inspector Followup Item (IFI) 85-45-01 addressed the applicant's commitment to revise the FSAR to recognize the two separate departments and the qualifications of the superintendents. This item was closed in Inspection Report 50-424/85-54, based on the submittal of FSAR Amendment forwarded to the NRC on April 4, 1986. The evolution of the organization change is also discussed in Section 2.4.1 of Module 9 Section 2.2 discusses the division of responsibilities within the health physics department based on the new organization. Plant Procedures 00001-C, Plant Organization and Managerial Staff Responsibilities and Authority, and 40000-C, Conduct of Health Physics Operations, were reviewed and determined to be consistent with Section No additional followup or evaluation of this section was require _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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5 Section 3.0 - Commitments

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This section of the module defines comitments as project obligations-to regulatory guides, industry standards, _ branch technical positions, and other -licensing requirements, to the extent defined in the FSA This section also identifies the source of commitments to be restricted

~ to the FSAR, . responses to _ NRC questions associated with the FSAR and draft Technical Specifications. . As defined, comitments which were considered by the applicant to be most appropriately categorized in this module were tabulated in a comitment matrix identified in Section 3.4 of the module. The applicant identified 260 comitments as being most appropriately categorized in this modul This section of the module also defines an implementing document as a working level document, such as a health physics-department procedure or a plant administrative procedure, that- fulfills a comitment applicable to _ a specific activity. Implementing documents .were identified .for each of the 260 comitments. This information was tabulated in an implementation matrix identified in Section 3.5 of the

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-modul The evaluation of this section consisted of reviewing the comitment matrix , delineated in Section 3.4 and reviewing the implementation matrix delineated in Section 3.5 as discussed belo In addition,17 comitments contained in Module 2 which relate to radiation protection training and health physics staff _ qualifications and five comitments contained in Module 7 which relate to specific operations of. the radioactive waste solidification process, were reviewed. The inclusion of comitments from other modules was done because these comitments are part of programs which are under the overall radiological protection progra (1) Evaluation of the Section 3.4 Comitment Matrix:

As a result of the Module 9A review, the staff had comments generated by the Facilities Operations Branch and by the Plant Systems Branch. Reference (e) documents the response of Georgia Power Company to these comment (a) Questions developed by Facilities Operations Branch 1) FSAR Section 13.5.1.1.A (No. 1731)

Staff Question: FSAR Section 13.5.1.1.A states that the General Manager -- Vogtle Nuclear Operations (GMVNO) has the ultimate responsibility for all plant procedure The GMVN0 is also the approving authority for procedures which establish plant wide administrative controls and other listed procedures. The FSAR section also states that nuclear operation department heads are the

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approving autho' r ity for 'other procedures - in their respective areas of -authorit Comitment 1731, as stated,~ would give nuclear operation department head approving authority (under direction'of GMVNO) .for all procedures in their respective areas. including those listed by the FSAR as . reserved for the GMVNO. The commitment and/or FSAR should be clarified to resolve this inconsistency for the procedures listed in FSAR'

Section'13.5.1. GPC response: -The paraphrased content of Comitment Number 1731 is_ not intended to dictate the authority of the GMVN0 beyond that specified in the FSAR. For clarity, the comitment and implementation matrices will

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be amended to state that certain procedures are reserved for GMVN0 approval. The applicant also attached copies of amended matrices to the respons . Staff Position: Question resolve ) FSAR Sections 13.5.1.1.C and 13.5.1. Staff Question: FSAR Sections 13.5.1.1.C and 13.5.1. have been omitted from the Module 9A comitments. These commitments should be included in Module 9 GPC Response: Details of comitment in FSAR Section 13.5.1.1.C are included in Comitment Number 76 FSAR Section 1.9.33 and 13.5.1.1~.C both address the ANSI 18.7 and Regulatory Guide 1.33 concern on the feedback of operating experience and were verified as being implemented in plant Administrative Procedure 00414-C, " Operations Assessment Program."

FSAR Section 13.5.1.1.D on control room access is reflected in Module 7 as Commitment Numbers 1743, 1744, 1745, 1746, 1747, and 276 Staff Position: Question resolve ) FSARSection13.5.1.1.H(No.1769)

Staff Question: FSAR Section 13.5.1.1.H describes procedures for shift relief turnover for plant personne Included is the requirment for " appropriate" supervisory personnel to develop shift log This requirement is omitted from the Module 9A commitments and should be include GPC Response: Comitment Numbers 1767, 1768, and 1769 address the requirements of FSAR Section 13.5.1.1.H. In l

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verifying the implementation of these requirements, procedures for the establishment and review of logs were reviewed. These procedures satisfactorily resolved the commitmen Staff Position: Question resolve ) FSAR Section 17. Staff Question: FSAR Section 17.2.5 describes .the provision of instructions, procedures, and drawing This section also identifies that the GMVN0 is responsible for ensuring preparation, execution, and proper training for procedures. This responsibility is not covered in the Module 9A commitment GPC Response: This is a general statement of the GMVN0's overall responsibility as described in Module Staff Position: Question resolve ) Technical Specification Section 6.2.2.F (No. 2631)

Staff Question: Section 6.2.2.F does not exis This specification is given in Techncial Specification Section 6. GPC Response: Commitment Number 2631, reference to Technical Specification Section 6.2.2.F, was a typographical erro The correct Section is 6.2. Staff Position: Question resolve (b) Questions developed by Plant Systems Branch Plant System Branch identified two areas for which commit-ments were made in a telecon discussion with the licensee, but which may not be in full compliance with NRC staff positions. These two areas are as follows:

1) The requirement for a qualified Health Physics Technician to be on site at all times when there is fuel in the reactor (versus an individual qualified in health physics procedures).

2) Requirement for high radiation area controls which differ from the Standard Technical Specifications (and may omit some critical control specification).

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GPC Response: As stated in the NRC letter, the NRC will handle comments from the Plant Systems Branch through

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the normal licensing. process. No Readiness Review response is necessar Stiaff Position: Questions resolve (2) Evaluation of the Section 3.5 Implementation Matrix:

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In assessing the Module 9A, Implementation Matrix,107 of 260 commitments were selected for review. Although the matrix indicated that the implementing procedures for 37 commitments were in draft, an initial review of procedure indices revealed that approved procedures had been issued for 34 of the commitment It was determined that this evolved over the time between the preparation of the matrix and the start of the review, and was not

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Additionally, five commitments in Module 7 relating to radioactive

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solid waste were reviewed but all were in draft procedu.res; no

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further review was accomplishe Sixteen commitments in Module 2

relating to qualifications and training of the health physics and

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chemistry staff, and radiation protection training of employees

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were reviewed for the Implementation Matrix and the Program

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Implementatio Additional reviews of specific training

requirements and general employee training were conducted during

the Emergency Preparedness Appraisal,'which was separate from the Readiness Review activitie During the evaluation of the Implementation Matrix, questions arose concerning four commitment The questions and the responses or resolutions are delineated below

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(a) Staff Question (No.1481): Commitment l'481 regarding the purging of iodine sampling cartridges prior to analysis to

. remove entrapped noble gases lists a draft Procedure 43801-C, as the implementing procedure. The approved revision of 43801-C does not include this requirement.

l GPC Response: Amendment 19 to the FSAR clarified this commitment as referring to post-accident sampling rather than i all iodine samplin This requirement is specified in Procedure 91303-C, which covers emergency samplin The inclusion of the purging of iodine cartridges on a routine

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basis will be reviewe Staff Position: Question resolved.

i (b) Staff Question (No. 1507): Commitment 1507 regarding the use i of step-off pads in the contamination control program lists

approved Procedure 00903-C as the implementing procedur '

The procedure index or file do not include such a procedure.

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GPC Response: This is a typographical error in the matri Procedure 00930-C is the correct procedure number. This procedure includes the requirement for step-off pads, and was verified by the reviewe Staff Position: Question resolve (c) Staff Question (Nos. 1545 and 1546).

Commitments 1545 and 1546 refer. to a draft Procedure 00911-C regarding violations of radiation work permit requirements or radiation work rules. The procedure index or file do not include such a procedur GPC Response: Procedure 00911-C is still a draft procedur It will be issued prior to fuel loa Staff Position: Question resolve (d) Staff Question (No. 1433): Commitment 1413 states that each high radiation area is equipped with an automatic controlled access terminal. Commitment 2737 states that the entrance is equipped with audible and/or visible alarm Procedures 43005-C and 43101-C specify the requirements for designating, posting, and controlling high radiation areas but do not include any requirements for automatic controlled access terminal GPC Response: Procedures 43005-C and 43101-C address the requirements for high radiation areas and locked high radiation areas. The automatic controlled access terminals discussed in Commitment 1433 are part of a permanently installed system located at preselected locations and connected to a central computer terminal. This system is not used when a high radiation area is created in the plant; the requirements of Procedures 43005-C and 43101-C appl Staff Position: Question resolve The staff considered the resolution of these questions to be acceptabl During the review of procedures to verify that the commit-ments had been included as shown in the Implementation Matrix, there were instances where typographical errors, or apparent inconsistencies between procedures were identifie These were discussed and resolution obtained, which generally required a procedure revisio These instances did not reflect on the adequacy of the Implementation Matrix.

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10-Based on the evaluation of selected commitments, the staff-concluded that the . commitments are being - satisfactorily

. implemented into plant procedures and programs. Where later revisions of the procedure or different procedure numbers

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Matrix, part of the review was- directed to determining that the commitments remained adequately addresse For example, Procedure 40001-C. replaced Procedure 00730-C for the selection, training and qualification of health physics department personnel but= was determined to meet the commitments' originally identified as to be implemented in Procedure 00730- Section 4 - Program Description This section of the module addresses the programs which will. comprise-the~ health physics program. The module states that the section "is written to describe the health physics program which will result from current developmental efforts." While the commitments listed in Section 3.5 may have been included in approved procedures, the implementation of the programs and procedures has not begun due to the status of plant completion. The health physics program is required for plant operations rather than construction and preoperational testin The Radioactive Materials Control program has been implemented for sources and materials on site for training, testing, and calibration as well as materials to be installed in plant equipment (such as check sources). Possession and use of this material is authorized by NRC Material. License 10-24805-01. Inspection of the conditions of the license was performed by Region II but is considered to be separate from the Readiness Review activitie 'The evaluation of this section consisted of a review of four of the programs (subparts of the plant health physics program). The review consisted primarily of comparison of the program elements contained in Section 4 with the contents of approved procedures to establish that there was a means of accomplishing that element. The programs reviewed were:

(1) Exposure Controls (monitoring only)

(2) Radiation Control Areas (3) Radiation Protection Support (4) Facilities and Equipment In conducting the review, a number of apparent discrepancies were note Additionally, questions concerning the implementation were raised. In part, both the apparent discrepancies and the questions resulted from the evolution of the programs since Section 4 had been prepared and were not the result of inadequate preparation or revie , ,

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s Staff Question: - Section 4.4.1.3 describes 1the method for monitoring groups of visitors who. remained together continuousl Procedures 00950-C and'45004-C specify that dosimetry will be issued to each visitor. Which is correct?

GPC Response: -Visitors who are authorized access into the Radiation Control Area (RCA) will be provided oosimetry on an individual basi Groups 'will remain outside of the RCA. This is in accordance with plant procedure Staff Position: Question resolve b '. . Staff Question: Sections 4.4.3 and 4.6.1 address " company objectives" or " policy." Where are these stated and how are they approved?

GPC Response: ' At present, these are corporate management policies approved by the Chairma However, new, more explicit policy

- statements are being drafted as part of the Nuclear Operations Policies Manual, which will be approved by the Senior Vice President Nuclear

.. 0peration These new policy statements will. be issued prior to fuel

- loadin Staff Position: Question resolve Staff Question: Section 4.6.3 states that calibrat! ion of TLDs will be checked as specified in approved-plant procedures. This could not be identified in the procedures. _ Where is this requirement specified?

GPC Response: At present, this requirement is not in plant procedure TL9s in use'are processed by a vendor and the calibration check program is handled by Plant Hatch. A check program will be in place with the

. TLD processor for Plant Vogtle before fuel load, when the TLD program is implemente Staff Position: Question resolved, Staff Question: Section 4.7.3 discusses various types of reports, including radiation exposure incidents, theft or loss of licensed

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! may be required by 10 CFR 20?

GPC Response: Procedure 00152-C will specify the requirements for ,

L making these notifications. This procedure is presently in draft, j- Staff Position : Question resolve The staff considered the resolution of these questions to be acceptable at this tim Final completion of these items will be reviewed when the operational programs are complet .

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Sections 4.4.4 and 4.4.5 discuss radioactive waste disposal and

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shipment of radioactive materials. Module 9A contains some commitments regarding - solid wast Additionally, Module 7 contains some commitments regarding waste solidification systems -for which the

- implementing procedures are listed in draft. Since the time that Modules 7 and 9A were submitted to the NRC, major policy changes have occurred regarding the waste solidification syste On April 8.1986, GPC notified the NRC that the radioactive waste solidification facility (described in FSAR Section 11) would not be completed on schedule with the . plan This was due to concerns about the ability of the process to provide a product which will meet the

burial site criteri This decision made - further review of the

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commitments regarding waste solidification moo Once a decision is made concerning an alternate system or method to process waste, a change to the FSAR will be necessary. Review of the program and the associated procedures will be accomplished by Region II separate from Readiness Review. This will also apply to changes in organizational responsibilities within the plant organization which may result from the changes in the waste solidification progra Section 5.0 - Audits and Special Investigations This section of the module describes the quality assurance audit program conducted of the health physics program, the audit findings and the responses to the audit findings and observations. The results of the audit included the reorganization of the Health Physics and Chemistry Department into two separate departments and the definition of actions to be taken to implement various programs within the health physics program.

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Review of this section involved the selection of three of the identified program areas and comparing the stated plans or requirements

with the program description in Section 4 of the Module. This ( comparison was done to verify that the programs cover the areas of

! concern identified by the audits and subsequent reviews. The review concluded that the program elements were being adequately addressed, i: Section 6.0 - Program Verification This section discusses the methods used to verify conformance to the radiological protection program requirements. The section is comprised of two subsections. Subsection 6.1 covers the identification of commitments, development of the verification plan, findings, responses and corrective actions for the health physics program. Subsection covers the same topics for radiological desig A Region II inspector reviewed the established verification proces Personnel directly involved in the process were interviewe Additionally, four verification checklists used by GPC for confirming

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1 the - stated commitments and listed procedures were reviewed for completeness. The inspector reviewed.each verification process finding and the proposed corrective action for these findings. The proposed corrective actions were judged to be adequate. Corrective action completion was not verified as this had 'not been completed for all identified items at the time of the inspection The review of Section 6.0 indicated that the review conducted by the GPC Readiness Review Team -for the radiological protection program was comprehensive and adequat One item identified during the radiological design review concern potentially high radiation levels in the Technical Support Center (TSC)

under post-accident conditions. The corrective action to resolve this finding was to install a new pre-filter (absorber) unit upstream of the existing TSC ventilation filtration unit to reduce the radiation levels in the TSC from radioactive materials collected in the filtration uni The installation, testing, and shielding of the new pre-filter will be reviewed during future - routine inspections and identified as an Inspector Followup Item (424/86-34-01). Section 7.0 - Assessment The section contains a summary of open corrective actions associated with the readiness review findings. Additionally, statements assessing the acceptability of the readiness review from the readiness review quality assurance representative, the technical consultants and the readiness review board are included. Resumes of the personnel instrumental in the development of Module 9A were also included. This section was reviewed for content only with no comment by the staf , Findings Some areas of concern were noted during the course of this review and these matters were discussed with GPC representatives during an April 29, 1986, teleconference. Those issues which involved ALARA program commitments and contamination control were satisfactorily resolved through the following: confirmation by the applicant that radiation protection performance will be analyzed and trended; 4 confirmation by the applicant that an integrated effort to incorporate training, purchasing, space allocation, and field use procedures for ,

practical application of ALARA measures and respiratory protection

, eng1ceering controls was in effect at Vogtle;

! confir aation by the applicant that preoperational ALARA walkdowns of

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the facility are being performed; and , confirmation by the applicant that the use of frisking and portal t

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i mcr.itors is being evaluated on a practical and technical basis.

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Two areas for which commitments have been made on a telecon on April 29,

1986 but for which the GPC position may not be in full compliance with NRC staff positions-are: the requirement for a qualified health physics technician to be on site at all times when there is fuel in the. reactor (versus an individual-qualified in health physics procedures) (PSB Question 1), and requirements for high radiation area controls which differ from the Standard Technical Specifications (and may omit some critical control elements)--(PSBQuestion2)..

These latter -issues were based on a review of initial draft Technical Specifications. and will be handled through the normal licensing process during Technical Specification -review. While GPC commitments may be adequate.in this area, radiological safety considerations and implementation are dependent upon the details of the final Technical Specification The applicant had provided adequate responses to all staff questions and will incorporate the applicable responses into the module by ' amendment addenda One finding, which was identified by the GPC Readiness Review Team, has been identified as an Inspector Followup Item (IFI). Resolution of the item will be addressed during the pre-operational inspection progra Finding a. (IFI 424/86-34-01) Installation of a shielded, prefilter system in the Technical Support Center (TSC) ventilation system. This prefilter system was identified during the Readiness Review as necessary to reduce radiation levels in the TSC under post-accident condition . Conclusions Based upon the review of the radiological protection program within the scope of Module 9A, Radiological Protection, which is in an early stage, the staff has reached the following conclusions: The Vogtle licensing commitments and other sections in the module scope have demonstrated compliance with the FSAR and applicable sections of staff documents such as the SRP and Regulatory Guides. The technical findings and the associated corrective actions taken to confirm the technical adequacy of the Radiological Protection Program are acceptable to the staf Therefore, the staff concludes that the reviewed scope of Module 9A of the Vogtle Electric Gennating Plant Readiness Review Program is acceptabl . The review conducted by the GPC Readiness Review Staff for the verification program was comprehensive and adequat Findings were of minor significance and the resolution of the findings adequate; however, some of the corrective actions for the findings remain to be complete *

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15 During the review, it was apparent to the NRC reviewers and inspectors that GPC management supported the program by their active participation in the development and implementation of the program. Review and evaluation of Module 9A by the staff indicates- that the review performed by the GPC Readiness Review Staff was sufficiently comprehensive in scope and depth to identify problem areas, and that the dispositions of findings were proper and satisfactory, except as noted above. The NRC findings identified appear to be minor and do not represent a breakdown or inadequacy in the progra The procedures and documents for the radiological protection program were consistent with commitments and therefore, acceptable. Pending resolution of the findings identified in the Readiness Review Verification, the staff finds that the program complies with the Final Safety Analysis Report and that compliance is verifiable with existing documentatio Implementation of the operations radiological protection program will be inspected in future Region II inspections, Two issues regarding the GPC position and the draft Technical Specifications remain to be resolved. These issues will be handled through the licensing proces The commitments described in Section 3, and the programs described in Section 4, describe an adequate radiological protection program if they are fully and adequately implemente These conclusions are based on information currently available to the inspectors and reviewers. Should information subsequently become available which was not considered during this review or previous inspections and which conflicts with earlier information, it will be evaluated to determine what effect it may have on the above conclusio . References . Letter to NRC, Region II from O. Foster, Georgia Power Co. ,

Subject: Vogtle Electric Generating Plant Unit 1, Readiness Review Module 9A - Submittal, February 28, 1986 NRC Inspection Report 50-424/85-45 issued November 6, 1985 NRC Inspection Report 50-424/85-54 issued August 5, 1986 Letter to Georgia Power Company from NRC, Region II, Subject: Vogtle Readiness Review Program - Interim Review Questions Module 9A -

Radiological Protection, June 11, 1986 Letter to NRC Region II from D. 0. Foster, Georgia Power Company, Subject: Response to Interim Review Questions - Module 9A -

Radiological Protection, June 24, 1986.