ML20207K763

Forwards Request for Addl Info & Comments Re Module 9B, Chemistry. Response Requested by 860715

ML20207K763
Person / Time
Site:	Vogtle
Issue date:	07/01/1986
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Foster D GEORGIA POWER CO.
References
NUDOCS 8607300022
Download: ML20207K763 (6)

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Georgi Power Company ATTN: Mr. D. O. Foster Vice President and General Manager Route 2 Box 299A Waynesboro, GA 30830

SUBJECT:

V0GTLE READINESS' REVIEW - INTERIM REVIEW QUESTIONS - MODULE NO. 9B,

" CHEMISTRY" We have completed an initial review of Module 98, which you submitted to us on March 25, 1986, for evaluation. As a result of the review, the enclosure lists comments and questions which need clarification and a written response.

Please review the comments and provide a written response.

Your input is requested to be received on or before July 15, 1986.

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

Sincerely, GNhd wm &

Xi A. fm Luis A. Reyes, Acting Director Division of Reactor Projects

Enclosure:

Vogtle Readiness Review Program -

Module No. 98, Questions and Clarifications and Remarks JM w/ encl:

VJ. H. iiiller, Jr.

/ President

\\/R. E. Conway, Senior Vice President &

/ Project Director VP. D. Rice, Vice President, Project

/ Engineering vR. H. Pinson, Vice President, Project Construction (cc w/ encl:

Con't see page 2)

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• 1986 Georgia Power Company 2

cc w/ encl: Cont'd)

J. T. Beckham, Vice President &

General Manager - Operations

/R. A. Thomas, Vice President, Licensing D. S. Read, General Manager Quality Assurance

/C.W. Hayes,VogtleQuality Assurance Manager

/W.C.Ramsey, Manager-Readiness Review

/G. B. Bockhold, General Manager,

/ Nuclear Operations V L. Gucwa, Manager, Nuclear Safety and Licensing

/M.H.Googe, Project Construction Manager d D. Groover, Quality Assurance Site Manager -

onstruction

. 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

. G. Ledbetter, Commissioner, Department of Human Resources

/C. H. Badger, Office of Planning f and Budget

/ D. Kirkland, III, Counsel, Office of the Consumer's Utility

/. Council D

C. Teper, Georgians Against

/ Nuclear Energy VM. B. Margulies, Esq., Chairman, Atomic h fety and Licensing Board Panel

/ Dr. O. H. Paris, Administrative Judge

/AtomicSafetyandLicensingBoard Panel G. A. Linenberger, Jr., Administrative Judge Atomic Safety and Licensing Board

/B. P. Garde, Citizens Clinic, Director Panel Government Accountability Project

Georgia Power Company 3

cc w/ encl:

/E.Reis, ELD

/. M. Hill, IE

.: Miller, NRR

. Brach, E00

. Sinkule, RII E. Christnot, RII RC Resident Inspector ocument Control Desk tate of Georgia 1

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o ENCLOSURE V0GTLE READINESS REVIEW PROGRAM - MODULE NO. 9B QUESTIONS, CLARIFICATIONS, AND REMARKS NRR has completed an initial review of Module No. 9B, Chemistry, which was presented to the NRC on March 25, 1986. As a result of the review, one branch within NRR (Facility Operations Branch) has generated questions and clarifications which need a written response. These comments are based on interactions between NRC staff and Georgia Power Company and are stating NRR staff views and observations as a result of the Module 9B review. Questions and comments which need a response are as follows:

Facility Operations Branch 1.

Commitment Nos. 1582, 1583, 1584.

FSAR Section 13.1.2.2.3 (to which these comments apply) also describes other requirements which are not addressed by these or other commitments in Module 98.

2.

Commitment No. 1731, FSAR Section 13.5.1.1.A states that the General Manager -

Vogtle Nuclear Operations (GMVNO) has the ultimate responsibility for all plant procedures. The GMVNO is also the approving authority for procedures which establish plant wide administrative controls and other listed procedures.

It also states that nuclear operations department heads are the approving authority for other procedures in their respective areas of authority.

Commitment No. 1731 as stated would give nuclear operations heads approving authority (under direction of GMVNO) for all procedures in their respective areas, implicitly including those listed by the FSAR as reserved for the GMVNO.

The commitment and/or FSAR should be clarified to resolve this inconsistency for procedures listed in FSAR Section 13.5.1.1.A.

3.

FSAR Sections 13.5.1.1.C and 13.5.1.1.D have been omitted from the Module 98 commitments. This should be resolved.

4.

FSAR Section 13.5.1.1.H describes procedures for shift relief and turnover for plant personnel.

Included is the requirement for " appropriate" supervisory personnel to develop shift logs.

This requirement has been omitted from the Module 9", commitments.

o

. 5.

Commitment Numbers 1849 and 1852 address commitments in FSAR Section 14.2.5; however, connitments in the last paragraph (pertaining to NUREG-0737, Item I.G.1) of FSAR Section 14.2.5 have not been included in Module 98. This should be resolved.

6.

Commitment Number 1856 addresses the FSAR Section 14.2.6.2 commitment to sample and analyze RCS coolant for boron during post fuel loading tests.

FSAR commitments to predict critical boron concentration and to modulate boron concentration with approach to criticality are not addressed by Module 98 commitments. This should be resolved.

7.

Commitment Number 1886 addresses the FSAR Section 14.2.6.3 commitment for periodic sampling of RCS coolant during low power testing.

FSAR Section 14.2.6.3 has commitments identifying measurement verifications to be made and actions to be taken if anomalies develop. These are not addressed in Module 98 commitments and should be included.

8.

Commitment Number 1891 provides periodic sampling during power ascension, referencing FSAR Section 14.2.6.4.

Neither Commitment Number 1891 nor the referenced statement in FSAR Section 14.2.6.4 is specific about which tests, frequencies, criteria, etc. However, FSAR Section 14.2.8.2 does contain descriptions of various tests (including chemical to be performed, but does not associate which section (14.2.6.4) discussions might relate to which tests (chemical). The discussions in FSAR Section 14.2.6.4 (other than the one referenced in Commitment 1891) should be reconsidered in light of FSAR Section 14.2.8.2 for possible inclusion as commitments in Module 9B.

9.

Commitment Numbers 2200, and 2202 address criteria and assurances for identification and control of material, parts, and components as discussed in FSAR Section 17.2.8.

However, FSAR Section 17.2.8, specifications for implementation procedures, responsibilities, and audits is not reflected in Module 9B commitments.

This should be resolved.

10. Commitment Numbers 2230, 2232, and 2858 discuss test Control criteria and Procedures as identified in FSAR Section 17.2.11.

However, FSAR Section 17.2.11, specifications.for changes to test procedures, test records, review of test results, approval designations, tests performed at the supplier's facility, and audits are not reflected in Module 98 commitments. This should be resolved.

11. Commitment Number 2861 specifies that the Superintendent of Maintenance is responsible for developing, approving and implementing procedures and instructions to establish a control / calibration program and that he approves calibration procedures. This commitment does not compare well with the corresponding designations in FSAR Section 17.2.12, and omits the role of the GMVNO, the Plant Review Board, the Quality Control Department, and periodic audits.

a.

.- 12. Commitment Number 2254 addresses the FSAR Section 17.2.14.8 provision requiring measures to bypass various operations and establish procedures to control altering sequences. However, Commitment. Number 2254 omits the FSAR requirement that the control be such that alterations are subject to the same control as the original.

13. Commitment Number 2256 omits the FSAR Section 17.2.14.C descriptive clause at the end of the sentence.

It is not clear that inclusion of this clause clarifies the FSAR intent.

This item should be clarified so that the importance of the clause can be determined.

14. Commitment Numbers 2272, 2273, and 2869 address the commitments to R.G. 1.33, Rev. 2, and initiation of corrective action corresponding to those in the first two paragraphs of FSAR Section 17.2.16 (Corrective Action).

However, the remainder of FSAR Section 17.2.16 dealing with identifying problems requiring corrective action, responsibilities related to corrective actions, evaluations of actions, reccommendations, and documentation are not reflected in Module 9B commitments.

This should be resolved.

15. Commitment Numbers 2276, 2872, and 2873 address FSAR Section 17.2.17 (Quality Assurance Records), provisions referencing R.G. 1.33 and requiring submittal of adequate documentation to permit systematic storage and retrieval.

j Other requirements of FSAR Section 17.2.16 dealing with other responsibilities, review designations, storage facilities, and audits are not reflected in Module 9B commitments.

This should be resolved.

16. Commitment Numbers 2650 and 2651 reference Technical Specifications 6.8.2.B and 6.8.1.C.

However, material from these commitments do not appear in Technical Specification Section 6.8.1.

This should be corrected.

If your have any further questions we will be please to discuss them.