ML20207K369
| ML20207K369 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/02/1987 |
| From: | Mark Miller Office of Nuclear Reactor Regulation |
| To: | James O'Reilly GEORGIA POWER CO. |
| References | |
| RTR-REGGD-01.068, RTR-REGGD-1.068 NUDOCS 8701090402 | |
| Download: ML20207K369 (4) | |
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l Docket No.: 50-424 Mr. James P. O'Reilly
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Senior Vice President - Nuclear Operations 4
Georgia Power Company g
3 P. O. Box 4545 g1 Atlanta, Georgia 30302 l
Dear Mr. O'Reilly:
Subject:
Request for Additional Infonration Regarding Vogtle Unit 1 Pre-l operaticnal and Startup Testing Programs Enclosed is a request for additional information on several issues relating to the preoperational and startup testing programs for Vogtle Unit 1.
These issues i
pertain to tests which Georgia Power Company (GPC) has proposed to defer or not perform and which therefore represent exceptions to the guidance of Regulatory Guide 1.68.
In most cases GPC provides minimal explanation of reasons for f
deferral or deletion of the tests as well as insufficient justification for the j
proposed test exceptions and deletions.
j We have discussed these issues previously with GPC representatives in several i
telephone conference calls, and we have received oral commitments that infor-
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mation to resolve these issues will be documented.
Because these issues must be resolved prior to fuel load, we request immediate response in order not to impact licensing.
Sincerely, I
Melanie A. Miller, Project Manager PPR Project Directorate #4 Division of PWR Licensing-A
Enclosure:
As stated i
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Mr. J. P. O'Reilly Georgia Power Company Vogtle Electric Generating Plant cc:
ir. L. T. Cocva Resident Inspector Chief Necicar Cngineer Nuclear Regulatory Cormission Georgia Power Corpany P. C. Box 572 P.O. Box 45aF Paynesboro, Georgia 30830 Atlanta, Georgio 30302 Fr. Fiuble A. Thomas Depoish Kirkland, III, Counsel Vice Prcsident - Licensing Office of the Consumers' Utility Vogtle Project Council Georgia Power Company /
Suite 225 Scutherr Coreany Services, Inc.
32 Peachtree Street, N.W.
P.O. Box 26?5 Atlanta, Georgia 30303 Birmingham, Alaban;a 35202 James E. Joiner Fr. Donald O. Foster Troutman, Sanders, Lcckerr.ian, Vice President & Project Gencrel Penacer
& Ashmore Georgia Power Corrpany Candler Building Post 0 Fire Fox 799A, Route 2 127 Peachtree Street, N.E.
llaynesboro, Georgia 30830 Atlanta, Georgia 30303 Danny Feig Fr. J. A. Eailey 1130 Alta Avenue Freject Licensing Manager Atlanta, Georgia 30307 Southern Ccrpany Services, Inc.
P.O. Box 2625 Carol Stengler Birmingham, Alabama 35702 Fecrgians Against Nuclear Energy 425 Euclio lerrace Ernest L. Blake, Jr.
Atlanta, Georgia 30307 Bruce W. Churchill, Esq.
Shaw. Pittran, Potts and Trowbridge 2300 N Street, N.W.
Washington, D. C.
20037 Mr. G. Bockhold, Jr.
Vogtle Plant Manager Georgio Power Company Route 2, Box 299-A llaynesboro, Georgia 30830 Regional Administretor, Region II U.S. huclear Regulatory Comission 101 Marietta Street, fi.W., Suite 2900 Atlontc, Ct.crcie 30323 Mr. R. E. Conway' Senior V1te President and Project Director Georgia Power Compary Rt. 2, P. O. Box 299A Waynesboro, Georgia 30830
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Enclosure Request for Additional Inform ti Vootle Unit J Precoerational a d a on By FSAR Amendment 25 Startup Tes_t Proorg n
1 Buildin GPC prcposed to indefinitely action.g PV8C Preoper,ational Test, but prcvioe We understand that the Alterrat utilized pending cortpletion of of planned tests for structuresof the SRP state e Radwaste Building (ARB) w the radwaste building.
tha t.
release.. will be used to process,, systems, com a test abstract forof radioactive materials." tore, control, measure s
s eatures a preoperational test of the ARB HVACTh meets the guidelines of SRP Secti follows:
provide on 14.2.11.8.
system which "The abstracts should incl d These guidelines are as monitored, and acceptance criterisignificant that the functional edcquacy a in sufficient detail toerfonnan design features will be demo nstrated by tests."of structures, system establish perfortred prior to the tine thAlso, provide written
,and e ARB HVAC system is required 2
Py FSAR Arendraent 25 GPC prop Solidification System Frecper ti e
e operable.
osed to indefinitely postpone the R d will not be completed until a
in the interim GPC plans to relthe radwaste building i onal icJ.
a waste system to te used in conjunction wi h Section y on a mobile radwaste solidificatiructed a of SRP Section14.2.11.8, we re t
the ARB.
14.2.11.8) quire a test abstract (whi hIn accordance with SRP on used for for radwaste sol scor, as practicable. idification and a corrmitment ta preoperat c
3 er system is By FSAR Amendment 29, GPC prop c perform this test as which wculd delay the Loss of Off i As discussed with GPC represe(ntosed power plateau.
s te Power unacceptable to LCOP) Test until e 1.C8 u
this exception. the staff.
Provide a proposed FSAR am, this delcy is atives the 75%
4 for Rod Misalignment Test 6 dBy FSAR Amendme endment deleting
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posed to delete the Nuclear I position indication system bei r
This justification is unacceptablng rod ratsalignments.
nstrumentation deletion of this test provided GPC furni h include, as a n inimum ual rod e.
ning control
, the following inforretion:s es adequate justification to strate the system capabilitydata from this tes o.
at other facilities which cerron
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b.
a comparison of the pertinent design features of Vogt,le with the design features of the facilities whose data is referenced te verify that perfonnance at Vogtle will be con'oarable to that of the referenced plants c.
a description of the experience and training of the Vogtle operating staff to verify that qualified personnel are aveilchle at all tir:es to interpret the data and draw the correct conclusions.
5.
By letter dated Decen,ber 23, 1986, GPC proposed to defer 27 rrecperational tests or rcrtions thereof until power ascension testing. The justi-fications for each of these deferrals does not, in many cases, provide assurance that the eauipment will be operable when required 6y Technical Specifications. This is true of the f1SIVs, the AFW systerr. the HEPA and carbon filter packages, the pressurizer PORVs, RCS leak rate test, RTD cross calibration, response tire tests, RCP seal injection ficyrate, and the pressurizer spray.
It may also be true of the digital radiation monitoring system. GFC appears to have confused Technical Specification surveillence tests with preoperationel tests.
10 CFR 50.36 states, in part, that " Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systers ard ccmponents is maintained." However, RG 1.68, Appendix A, Secticn 1, states, in part, that "Preoperational tests should demonstrate that structures, systems, and components will operate in accordance with desier in all operating modes and thrcughout the full design operating rance."
Therefcrc, surveillance tests do not necessarily establish initial operability of structures, systems, and components as do precperational tests, particularly when problems have orevented completion of the pre-operational test. For those cases where GPC claims operability based upon surveillance tests, trovide justification that these tests are comparable to the precperational test or provide justification for a Technical Specification waiver. Also, 27 test deferrals is excessive and will divert attention and resources from the fuel load, iritial criticality, and power ascension efforts. Provide a revised request which certeins a more reasonable number of tests to be deferred.
f.
.Tte f.PC Region II staff has been discussing with GPC site representativos deficiencies in the test program for the forced-draf t cooling toucrs.
CFC shculd certinue to resolve this issue with Region II on a schedule consistent with fuel load, and we will provice input to the Region as nccc"ary. GPC should cerfirm that the capabilities of the bitimate Heat Sink 11 be verified at power.
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