ML20154L587

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Submits Questions & Comments Generated from Initial Review of Module 16, NSSS, Submitted on 860109.Written Response Requested by 860330
ML20154L587
Person / Time
Site: Vogtle  
Issue date: 03/05/1986
From: Walker R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Kelly R
GEORGIA POWER CO.
References
NUDOCS 8603110519
Download: ML20154L587 (6)


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MAR 0 51986 Georgia Power Company ATTN: ' Mr. R. J. Kelly Executive Vice Presideat P. O. Box 4545 Atlanta, GA 30302 Gentlemen:

SUBJECT:

V0GTLE READINESS REVIEW - INTERIM REVIEW QUESTIONS - MODULE NO. 16

" NUCLEAR STEAM SUPPLY SYSTEM" We have completed an initial review of the subject module which you submitted to us on January 9,1986, for evaluation.

As a result of this initial review, the following questions and comments have been generated which need clarification and a written response.

ACCEPTABLE COMMITMENTS REQUIRING CORRECTIONS The following commitments have. been determined to be consistent with the Review Plan (SRP)ysis Report (FSAR), Safety Evaluation Report (SER) and Standard Final Safety Anal They are acceptable if the indicated corrections are made.

(1)~FSAR Section 3.2.2-1, Classification of Structures, Components and Systems, Comitment No. 847.

In the " Remarks" entry for this commitment in the Comitment Matrix in Section 3.4 of Module 16, it should show Table 3.2.2-1 instead of Table 2.2.2-1.

(2) FSAR Section 5.2.1.1, Compliance with Codes and Code Cases, Comitment No. 188.

" Code Cases" should be removed from the description of this comitment.

Code cases are discussed in FSAR Section 5.2.1.2.

-(3) FSAR Section 5.2.3.2.2, Compatibility with External Insulation and Environmental Atmosphere, Comitment No. 211.

The referenced FSAR Section should be 5.2.3.2.3 instead of 5.2.3.2.2.

'(4) FSAR Section 6.1.1.1, Engineered Safety Features Materials Specification Requirements, Comitment No. 326.

The referenced FSAR Section should be 6.1.1.1.1 instead of 6.1.1.1.

i (5) FSAR Section 6.1.1.1, Engineered Safety Features Materials--Containment Penetration Materials, Commitment No. 327.

The referenced FSAR Section should be 6.1.1.1.1 instead of 6.1.1.1.

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MAR 0 51986 Georgia Power Company 2

(6) FSAR Section 6.1.1.1.3.A, Engineered Safety Materials Integrity of Safety Related Components, Commitment No. 256.

The referenced FSAR Section should be 6.1.1.1.3 instead of 6.1.1.1.3.A.

The entire FSAR Section 6.1.1.1.3 appears to be specific to Vogtle and all the appropriate Regulatory Guides, i.e., 1.31, 1.36, 1.37, and 1.44, should be incorporated.

OMITTED REGULATORY GUIDE COMMITMENTS As part of our review, the corresponding SRP sections and the referenced Regulatory Guides were determined for the commitments submitted.

The following Regulatory Guide comitments were apparently omitted from. the Commitment Matrix in Section 3.4 of Module 16.

These omissions should either be justified or provided in a revision to the Comitment Matrix.

(1) FSAR Section 1.9.26 (Regulatory Guide 1.26), Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants.

Regulatory Guide 1.26 is referenced in FSAR Section 3.2.2.

The VEGP classification system (FSAR Section 3.2.2) is included as a commitment (No.

1754).

Furthermore, the seismic design classification (FSAR Section 1.9.29) is included as a commitment (No.1532).

Thus, the quality group classifi-cations should be included as a commitment for consistency.

(2) FSAR Section 1.9.71 (Regulatory Guide 1.71), Welder Qualification for Areas of Limited Accessibility.

Regulatory Guide 1.71 is referenced in FSAR Section 5.2.3.3.2.

Field welds are plant specific. Thus, it' appears that FSAR Section 1.9.71 is applicable to plant specific. aspects of Vogtle and should be included as a commitment.

Furthermore, since FSAR Section 5.2.3.3.2 is included as a commitment, the referenced Regulatory Guide should also be included as a commitment for consistency.

(3) FSAR Section 1.9.147, (Regulatory Guide 1.147) Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1.

Regulatory Guide 1.147 is referenced in SRP Section 5.2.1.2 and should have been included in FSAR Section 5.2.1.2.

(In Commitment No. 188, Code cases are incorrectly stated to be included in FSAR Section 5.2.1.1.)

Acceptable Code cases evolve with time and are plant specific.

Thus, FSAR Section 1.9.147 should be included as a commitment.

Furthermore, since we believe that the FSAR Section 5.2.1.2 should be included as a commitment, the referenced Regulatory Guide should also be included as a commitment for consistency.

~ 1 MAR 0 51986 Georgia Power Company 3

OMITTED FSAR COMMITMENTS The comitments in Section 3.4 of Module.16 were evaluated for consis'tency and correctness.

The following FSAR comitments were apparently omitted from the Comitment Matrix in Section 3.4 of Module 16:

(1). FSAR Section 3.2.1, Seismic Classification.

The seismic design classification (FSAR Section 1.9.29) is included as a comitment (No.1532).

Furthermore, the VEGP classification system (FSAR Section 3.2.2) is included as a commitment (No.1754).

Thus, the seismic classification should be included as a comitment for consistency.

(2) FSAR Section 5.2.1.2, Compliance with Code Cases.

Comitment No.188 (FSAR Section 5.2.1.1) as stated in the Commitment Matrix in Section 3.4 of Module 16 incorrectly includes Code cases. Code cases are discussed in FSAR Section 5.2.1.2.

Because the applicable Code cases are specific to Vogtle, FSAR Section 5.2.1.2 should be included as a commitment.

COMMITMENT CLARIFICATIONS-There are no commitments identified in certain FSAR sections that appear to he

. ithin the scope of the nuclear steam supply system.

Conversely, there are w

comitments identified in certain FSAR sections that appear to be outside the scope of the nuclear steam supply system..Also, there is a slight inconsistency in the referenced Code edition in one of the comitments.

Thus, the following clarifications.are requested:

(1) FSAR Section 3.1.4, Nuclear Steam Supply System Components Design Classification, Comitment No.1727.

FSAR Section 3.1.4 indicates that Westinghouse classifies nuclear steam supply system components according to ANSI N18.2-1973.

However, FSAR Section 1.9.26.2 indicates that Westinghouse classifies components within its scope of supply using ANSI N18.2a-1975.

Clarification is required for the specific referenced ANSI Code. edition.

(2) FSAR Section 5.2.4, Inservice Inspection and Testing of Reactor Coolant Pressure Boundary, and FSAR Section 6.6, Inservice Inspection of Class 2, 3 Components.

Preservice and inservice inspections (PSI and ISI) are plant specific and relief can be requested on a plant specific basis. Thus, PSI and ISI should be included as comitments.

However, FSAR Sections 5.2.4 and 6.6 indicate the need for license conditions and FSAR Sections 5.2.4.3 and 6.6 (PSI program) contain open items.

Clarification of the assumptions regarding commitments in the area of PSI and ISI is needed.

MAR 0 51986 Georgia Power Company 4

(3) FSAR Section 5.3.2, Pressure-Temperature Limits.

. Because the ' properties of reactor vessel materials vary from plant to plant, operating limitations are based on the specific properties of the reactor vessel materials at Vogtle. Thus, FSAR Section 5.3.2 appears to be specific-to Vogtle and should be included as a comitment.

Furthermore, because Regulatory Guide 1.99 is referenced, FSAR Section 1.9.99 (Effects of.

Residual Elements on Predicted Radiation Damage to Reactor Vessel Materials) should also be included as a commitment.

(4) FSAR Section 5.3.3, Reactor Vessal Integrity.

The applicable Code edition, the materials surveillance program, and the fracture toughness of the reactor vessel materials are specific to Vogtle.

Thus, it appears that FSAR Section 5.3.3 should be included as a commitment.

Furthermore, because Regulatory Guide 1.99 is referenced, FSAR Section 1.9.99 (Effects of Residual Elements on Predicted Radiation Damage to Reactor Vessel Materials) should also be included as a commitment.

(5) FSAR Section 5.4.2.5, Steam'. Generator Inservice Inspection.

The steam generator (SG) preservice and inservice inspections may be plant specific items. Accordingly, SG inspection would be included as commitments and the referenced Regulatory Guide would also be included.

Clarification of the assumptions regarding commitments in the area of SG inspections is needed.

(6) FSAR Section 6.1, Engineered Safety Features Materials', and FSAR Section 6.2.2, Containment Heat Removal Systems.

Some commitments in FSAR Sections 6.1 and 6.2.2 have been included in Module 16.

However, Module 16 is for the nuclear steam supply system.

Thus, it does not seem appropriate to include these commitments in Module 16.

Furthermore, comitments in the engineered safety features and containment heat removal systems are scattered in~ various Modules. Thus, it is difficult for the ' reviewers to establish consistency and determine program completeness in evaluating the systems.

Clarification of the assumptions used in regard to the inclusion of these systems in Module 16 and in regard to the plant specific versus generic aspects of these systems is needed.

Please review these comments and questions and provide a written response. Your input is requested to be received on or before March 30, 1986. Please coordinate your written response and any telecons you may require with W. H. Rankin (404-331-4197) of my staff.

a MAR 0 51988 Georgia Power Company 5

Your assistance in responding to this request for additional information is appreciated.

Sincerely, Original Signed by Roger D. Walker.

Roger D. Walker, Director Division of Reactor Projects cc:

R. E. Conway, Senior Vice President

& Project Director D. O. Foster, Vice President, Project Support P. D. Rice, Vice President, Project Engineering R. H. Pinson, Vice President, Project Construction J. T. Beckham, Vice President &

General Manager - Operations R. A. Thomas, Vice President, Licensing C. W. Hayes, Vogtle Quality Assurance Manager W. C. Ramsey, Manager -

Readiness Review G. B. Bockhold, General Manager,-

Nuclear Operations L. Gucwa, Manager, Nuclear Safety and Licensing-M. H. Googe, Project Construction Manager E. D. Groover, Quality

. Assurance Site Manager -

Construction J. A. Bailey, Project Licensing Manager G. F. Trowbridge, Esq., Shaw, Pittman, Potts and Trowbridge B. W. Churchill, Esq., Shaw, Pittman, Potts and Trowbridge E. L. Blake, Jr., Esq., Shaw, Pittman, Potts and Trowbridge J. E. Joiner, Troutman, Sanders, Lockerman and Ashmore cc:

(Continued on page 6) o

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MAR 0 51986 Georgia Power Company 6

(CC Cont'd)

J. G. Ledbetter, Commissioner, Department.of Human Resources C. H. Badger, Office of Planning and Budget D. Kirkland, III,. Counsel, Office of the Consumer's litility Council D. C. Teper, Georgians Against Nuclear Energy.

T. Johnson, Executive Director, Educational Campaign for a Prosperous Georgia M. B. Margulies, Esq... Chairman, Atomic. Safety and Licensing Board Panel Dr. O. H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel G. A. Linenberger, Jr., Administrative Judge, Atomic. Safety and Licensing Board Panel B. P. Garde, Citizens Clinic, Director Governnent. Accountability Project bec: E. Reis,-ELD W. M. Hill, IE M. Miller, NRR W. Brach, EDO M. Sinkule, RII W. Rankin, RII NRC Resident Inspector Document Control Desk State of Georgia A. R. Herdt, RII.

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