ML20064B492

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Submits Application for Amend 39 to License NPF-68 for Util FSAR
ML20064B492
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/23/1988
From: Rice P
GEORGIA POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20064A263 List:
References
NUDOCS 9010170122
Download: ML20064B492 (8)
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s- Georgis Power Comeaay  ;

Post Office Box 883 . q Waynesboro Geor&a 30830 '

  • "' l0 E d ATTACHMENT.8 Soutnern Company Services. Inc.

4 Post Ottice Box 2625 1 Birmingham. Alabama 35202 wooeone 2:s m.On .Vogtle Project -

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November 23. 1988 ,1

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i' U.S. Nuclear Regulatory Commission File:- 'X7N00.0-39 Log:- GM-1502 Attn.: Docutent Control Desk -1 Washington, D.C. 20555.

NRC DOCKET NUMBERS 50-424 AND 50-425 OPERATING LICENSE NPF-68 '

CONSTRUCTION PERMIT NUMBER CPPR-109 V0GTLE ELECTRIC GENERATING PLANT -UNITS l'AND 2 FSAR AMENDMENT NUMBER 39 l Gentlemen:  ;

Georgia Power Company, acting on its own behalf and as agent- for'0g'lethorpe Power Corporation, Municipal Electric Authority'of Georgia,Eand the City of Dalton, Georgia, hereby submits Amendment-39 to the Vogtle Electric Generating' l Plant (VEGP) Final Safety-Analysis Report (FSAR).

3 The changes resulting from this amendment are identified in.the ' Attachment.

These changes are applicable >to both Units l'and 2.- All substantive changen,

~e for Unit 1, were evaluated as required by Title 10 CFR 50.59. This amendment i l contains all the known processed changes for Unit 2 as of.0ctober 31, 1983.-

( Due to the time lag associated with the as-built: notification process, not all ,

of the FSAR figures have been updated in this amendment. '.Our submittals to  !

the stati, as noted in the Attachment, do contain the information on drawing .

modification sheets and provide the appropriate cross references to the; affected FSAR figures. Your staff 'till be notified should the final drawings .;

materially differ from what was previously provided. 3 l

In accordance with the requirements of Title 10 CFR 50.30(f) and .

Title 10 CFR 50.4(b), one (1) signed original and thirty-seven (37)' copies of Amendment 39 are submitted for your use. Also in accordance with the-  ;

requirements of Title 10 CFR 50.4(b), copies of Amendment 39 are being sent to j the NRC Regional Office and the NRC Resident Inspector.  ;

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9010170122 900928 PDR ADOCK 05000424 ,

P PDC ]

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E Files::X7N00.0-39 I U.S. Nuclear Regulatory Commission-November 23,-1988 Log: GN-1502 ,

Page 2 Should you have any questions on the enclosed. submittal,Ldo not hesitate to-contact me. .

Yours truly,. .

f, h. Y--1  ;

I P. D. Rice November , - 19 8 8 . ---

SWORN AND SUBSCRIBED-BEFORE ME, THIS M DAY 0Fl l

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'Noga(/Public Alabama State at Large My commission expires %CommissientrairesNovember24.1991 PDR/sm j ' Attachment xc: NRC Regional Administrator-NRC Resident Inspector FSAR Distribution List l

1548V

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VEGP-FSAR-13 t

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13.1.1.2.2 Nuclear Operations Organization  ;

The nuclear operations organization,.under the supervision of the executive vice president-nuclear. operations, has direct j responsibility for the operation and maintenanceLof:GPC's nuclear plants. .The n'ac. ear operations : organization consists 1of the

l plant operatin; staffs, the. safety. audit and engineering-reviewL organization, tnd the nuclear support (Vogtle) organization which? ,

provides support in the areas of. engineering, licensing, '!

i maintenance, and administration.

Engineering support during plant operation'will-be provided '!

primarily by the SCS Nuclear Plant Support, Department. ThetSCS [

Technical Services-Nuclear Department will provide-nuclear 3 fuel' contract administrative services, reload licensing,,and operating ,

licensing support. The structure of the General Office- 1' organization is shown in figures 113.1.1-2 and 13.1'l-3 and is I

described in the following paragraphs. .

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13.1.1.2.2.1 Executive-Vice President-Nuclear Operations. The executive vice president-nuclear operations, an officer: of both; i Georgia Power Company 1(GPC) and Alabama' Power-Company (APC),.is . .;

responsible to the chairman and-CEOs of each company for all l

aspects of operation of the nuclear genezeting plants in the~GPC and APC systems, as well as technical and . adnd nistrative - support ~

activities provided by SCS. The executive vice president-nuclear operations directs the senior vice .

president-nuclear operations in. fulfillment of his responsibility.

Amend. 16 4/85 Amend. 24 6/86

' Amend. 25 9/86 Amend. 26 10/86 Amend. 29 11/86 Amend. 35: 3/88 13.1.1-7 Amend. 39 11/88; .l

. N VEGP-FSAR-13  ;

13.1.1.2.2.2 Senior Vice President-Nuclear Operations. The.

senior vice president-nuclear operations, an officer of both Georgia Power Company (GPC) and Alabama Power, Company (APC),

reports to the executive vice president-nuclear. operations. This -

individual is responsible for the safe, reli~able, and efficient- ,

operation of Plants Vogtle, Hatch, and Farley. The-senior vice i president-nuclear operations directs the' efforts of the-vice president-nuclear (Vogtle), the vice president-nuclear-(Hatch), .

and the vice president-nuclear-(Farley).  !

13.1.1.2.2.3 Vice President-Nucl' ear-(Vogtle). The vice ,

president-nuclear (Vogtle) reports to the senior vice '

president-nuclear operations and is responsible for operation.and }'

maintenance of Plant Vogtle as well as licensing,-engineering,-

maintenance, and administrative support activities. The vice ,

president-nuclear (Vogtle) directs the general manager-nuclear plant (Vogtle), the general manager-nuclear support (Vogtle), and the manager-safety audit-and engineering-review-(Vogtle).

q 13.1.1.2.2.4 General Manager - Nuclear Support-(Vogtle). The general manager-nuclear support (Vogtle) reports to the vice; j president-nuclear (Vogtle) and11s responsible for corporate ~ l support in the areas of engineering,. licensing, maintenance,=and administration. The general manager-nuclear support (Vogtle)E  ;

directs the manager-nuclear engineering and-licensing-(Vogtle), '

the manager-nuclear maintenance and' support (Vogtle), and the manager-nuclear administration (Vogtle).

13.1.1.2.2.5 Manager-Safety Audit and Engineering Review (Vogtle). The responsibilities of the manager-safety audit and engineering review (Vogtle) are described'in.section 17.2.

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Amend. 16 4/85. .

Amend. 24 6/86 Amend. 25 9/86 4 Amend. 26 10/86 Amend. 29 11/86-i Amend. 35 3/88' l 13.1.1-8 Amend. 39 11/88  ;

ATTACHMENT 9 Interoffice Correspondence GeogiaPowerk DATE: August 21, 1990; * .;

RE: Operational, Assessment Inspection FROM: G. Bockhold Jr. 1 T0: Plant Employees  :

As many' of you know. the. NRC recently concluded -an Operatienal '

Assessment Inspection. The inspection. among .other things, includedi investigation of a number of allegations - of -"wron doing " such as-intentional -violations of NRC requirements. . Somes VE P employees were interviewed femally in "on the recotti" interviews.

The NRC appropriately : investigates allegations: of wrongdoing which 'l bear on matters of safety or public health in a thorough and deliberate.

manner. While a fomal interview. may be disconcerting :or stressful, these reviews are sometimes necessary. Georgia! -Power. encourages couperation in these investigations .and . views it as essential that the -

NRC obtain the relevant and material' facts.  :

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We have been inforined that all allegations of wrongdoing by -VESP l

employees were found to be unsubstantiated. At the same time. .the-Operational' Assessment team identified several technical: items where potential violations of NRC requirements may have occurred. For example. i the NRC observed at least one instance in. Which a : Deficiency Card -was not issued for equipment mpair, contrary' to .our practices. We must remember to use our Deficiency Card systemi only by identifying potential-deficiencies can we achieve our high standards of . excellence inca 11 of the areas which support this plant. All of us need; to be reminded to pay strict attention to detail -- to dot all the 1's;and cross all the t s -- in each of our daily tasks.

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I want - to thenk all of you who- worked diligently to support the Operational Assessment team. Your cooperation during,this , difficult, time is greatly appreciated. I. personally, am very proud of the.

professionalism shown by each of you and. encourage you to maintain those high standards as we move forward to fulfill our goal of efficient and, foremost, safe operation of the Vogtle Electric Generating Plant.

M AD/TV6/69/tdm i

t y ew ,ww ,--em-- -

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L . ATTACHMENT 10 D!tstL STARTE AND FA!WRt REPORTING: 8/12/90

. Time: 13:00~ # .

Page1of2 .

MRC_ Concern

1. The NeC is concerned about the incorrect number._ of diesel- starts reported in LER 1-90-06 and the number of starts: presented to: the NRC.on April 9,.

1990 and in the confirmation response letter' of April 9,1990. The. major- 'l issue remaining is to try and determine ~ through personal interviews, how- '

the number of 19 for diesel 18 was arrived at in the April 9 letter to the l

NRC. The NRC believes the intent of- the April 9 letter .and the- '

presentation discussed- consecutive . successful starts.. The: revised-response to LER 90-06 did not clarify the number of starts reported J.

NRC April 9, and did not clarify that the Ig starts were not consecutive. ,

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2. The inspector noted that documentation provided by Operations to support.

diesel trending -(14940-C and 13145-C data; sheets)- does not contain- an adequate description of what happens during the start attemptc The plant ,

is not interpreting Reg Guide.1.108. properly with regard to ' reporting '

valid and non-valid failures. There may be valid and non-valid failures that were not reported. The NRC does not consider the current ~ status of:

reporting diesel failures.to be in compliance with cosaiteents made to the NRC in V olation 50-424/87-57. ,

l NRC_Doegmentation The NRC has reviewed the' diesel start log and supporting documentation (149eo-C and 13145-C data sheets). The NRC currently believes some probless-i identified on 14980's and 13145's should be classified as non-valid fattures '

and reported to the NRC. The NRC has requested' and received written analysis to explain the disposition of the following -Il_ diesel' starts: O s ' 123, 124, ,

132. 133, 134, 136. 160, 161, 161, .164, - 168, . and 190. LER 1-90-06, reviston 1; QA Audit Report opt 6-90/33; QA Audit Report OP09-90/311 and Special Report-1-90-05, dated August 7,1990; GPC confirmatory action letter dated April 9, >

1990.

VMP Petitlen

1. The error made in the number of diesel starts reported to the NRC on April-9,1990, and in LER 190-06 is attributed to two factors:-
a. The testing as described in LER 90-06, revision: 0, . was- in the- '

" context of' and "in reference to" the- diese)- eentral evetene. The first-two sentences of the 5th paragraph' explain actions taken with regard to sensor calibrations and control system. testing. In this.

context, the test arenra'a correlates to testin9 discussed with the NRC on April 9,1990, and reported in the April 9,1990, confirm l 1etter. The LER 90-06 comment of " subsequent to the test program was not intended to exclude successful diesel starts before declaring the diesel :,perable. As a.nsult, diesel starts after testing of the contro) systems, but before a declaration of operability were !

counte(. The transmittal letter for LER 90-06, revision 1, describes .

the confusion and attempts to. clarify the concern by redefining the types af starts and the point of counting. ,

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O!ESELSTARTSANDFAILUREREPORTINGL L ,

Pagt2of-2 ,

i .b. LER 90-06, revision 1 was ' intended to clarify any inadvertent-l

! *sisleadint" of the NRC,on successful operation of the diesel control- '

L systems. een Vo9tle Management- was : aware of the probles in ;Ltt  ;

l 96-06, revision 0. management notified the NRC Residents. - Also at i

the corporate office on 6/11/90, .4.s Shipman contacted Ken Brockman

l. and on about 8/11/90. H. G. Wairston !!! contacted Mr. 5. Ibneter ' 1
of NRC Region !!. The revised LER was submitted on 4/19/90. i The 19 starts discussed on April 9 were based on operator assessments.

of the starts as- successful using VEGP edures. - Additional review of these starts by both the NRC and Vo tio personnel indicates start. ,

L #134. performed on March 23. 1990, cou d be counted: ss unnueceanful.

If 'startc #134 isc not counted. .on1 14. successful- starts occurred before April 9.1990. This start 11? be reviewed in- detail- and an appropriate report to clarify ,the: number of starts reported Apri1 ~ 9.

-1990 will be made.  ;

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2. After a thorou9h review of Reg ' Guide 1.108. Engineering- Support (Mike Horton) agreed that all distel start erehtaan have not been reported as failures. GpC's response to .NRC Violation 424/87-57 committed. to report such equ ent problems as failures;: ;however, due to internal administre ve problems, the commitment was not implemented. Engineering ,

Support intends to review diesel start records for any unreported failures. '

l-VEP Documentation l o LER 1-90-06, revision 1; QA Audit Report opt 6-90/33; LQA Audit- Report l

OP09-90/31; and Special Report 1-90-05, dated -August 7. 1990; GpC :

confirmatory action letter dated. April 9.;1990.

j o 13 diesel start analysis available 8/15/90 'and' Re9 Guide .1.108. position l

from Engineering Support.

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1/W90 Response to RC Question Concerningc Time: 11:00 >

Dittel $t&Ptl Reported 6R April 9 1990-

&nd in LER 90 06, Revisions 0 and 1 L ouantian at 1 Who pre Answer: pared the slide for the ~4/9/90 presentation?

G. Bockhold. Jr., J. P. Cash, and K.- Burr working as a group..

2. Who approved use of the slidet Answer: G. 80ckhold, Jr.

Quantien at

1. Who prepared the confirmatory letter of April 9,:19901 Answer: C. K. McCoy, J. A. Bailey,-W. G. Nairston. !!!'as a group.
2. Who approved the letter?

Answer: W. G. Hairston. III ouantien as (with rosard to LER 90 06, revision 0,' dated 4/19/90)-

1. Who prepared the LER? _

Answer: Several draft revisions of the LER were prepared by Tom Webb and others of the NSAC group of the Vogtle Site Technical: Support.

These drafts were reviewed and commented on by the Plant Review Board. . The final < revision of LER 90-04. revision 0 was prepared by a phonacon between site management and corporate mana Those participating are believed to be G. Bockhold, Jr.,gement. A. L.

Mosbaugh, J. G. Aufdenkampe, W. Shipman.

2. Who reviewed the LERt Answer: All revisions of the LER Were reviewed by the PRB and the General Manager-Plant Vogtle.
3. Who approved the LER?

Answer: The LER was approved by W. G. _Hairston.. !!!

Quantien se

. 1. Who prepared the cover letter for LER 90-06, revision 17 Answer: The cover-letter was prepared by H. W. Majors of the corporate staff. This letter was prepared > under the guidance of W. G.

Hairston.

2. What was the purpose (intent) in the wording of- the cover 1stter with '

regard to the number of diesel starts?

Answer: The cover letter was intended to document discussions with NRC Region !! to clarify the ' starts documented in LER 90-06, revision 0. By picking- a well defined wint to specify

" subsequent to the test program" it was poss9ble to identify a substantial number of successful diesel starts. This was-intended to remove any additional ambiguity.

Quantion #5 *

1. Who in' corporate added the words " subsequent to the test program" in LER -

90-06, revision of Answer: Corporate Licensing personnel in conjunction with the phone conversation described above made editorial changes as directed. Those present durini.the on are thought to be W. Shipsan. G. lockhold, phone Jr. , A.conversatd L. Mosbaugh, J. G. Aufdenkampe, and J. Stringfellow.

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