Text

Insp Rept 50-424/86-33 on 860217-1003.Major Areas Inspected: Readiness Review Program Module 9B, Chemistry
	ML20214F481
Person / Time
Site:	Vogtle
Issue date:	11/13/1986
From:	Dan Collins, Novak T, Sinkule M; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation
To:	;
Shared Package
ML20214F448	List: ML20214F447; ML20214F481;
References
	50-424-86-33, NUDOCS 8611250321
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># C Eftq UNITED STATES

o NUCLEAR REGULATORY COMMisslON

[ n REGION ll

g j 101 MARIETTA STREET, N.W.

* ATLANTA, GEORGl A 30323

%,*****/

NOV 131995

Report No.: 50-424/86-33

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, Georgia 30302

Docket No.: 50-424 Construction Permit No.: CPPR-108

Facility Name: Vogtle Nuclear Power Plant

Reviews Conducted: February 10 - August 29, 1986

On-Site Inspections Conducted: . February 17-21, 1986, April 21-25, 1986,

July 14-18, 1986, and September 29-

October 3, 1986'

NRC Offices Participating in Inspections / Reviews:

Office of Inspection and Enforcement, Bethesda, MD

Office of Nuclear Reactor Regulation, Bethesda, MD

Region II, Atlanta, GA

Reviewers: W. L. Belke, QA Engineer,. Quality Assurance Branch, Office of

Inspection and Enforcement

W. T. LeFave, Mechanical Engineer, Plant Systems Branch, Office of

Nuclear Reactor Regulation

F. Orr, Reactor Systems Engineer, Facilities Operation Branch,

Office of Nuclear Reactor Regulation

R. J. Serbu, Health Physicist, Plant Systems Branch, Office of

Nuclear Reactor Regulation

J. Wing, Chemical Engineer, Plant Systems Branch, Office of

Nuclear Reactor Regulation

W. B. Gloersen, Reactor Inspector, Region II

W. J. Ross, Reactor Inspector, Region II

Review / Approved by: M7- dwt /o-22-86

D. M. Collins, Chief Date Signed

Emergency Preparedness and Radiological

Protection Branch

Division of Radiation Safety and Safeguards

Region II

k , f .c c.__. lifeohC,

M. t. Sinkuld, Chief Ddte Signed

Projects Section 20

Division of Reactor Projects

Region II

8611250321 861113

PDR ADOCK 05000424

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Nik 4Ad m / /

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T. M. Novak, Deputy Direct 6 DatqSighed

Division of PWR Licensing-A

Office of Nuclear Reactor Regulation

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i TABLE OF CONTENTS

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TOPIC PAGE

I Summary 1

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Scope of Review 2

Methodology 2

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Evaluations 3

, Findings 14

Conclusions 14

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References 15

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V0GTLE ELECTRIC GENERATING PLANT UNIT 1

READINESS REVIEW PROGRAM

MODULE 9B

CHEMISTRY

SUMMARY

The Readiness Review Program is being conducted at the initiative of Georgia

Power Company (GPC) management to assure that all design, construction, and

operational commitments have been properly identified and implemented at the

Vogtle Electric Generating Plant Unit 1 (henceforth referred as Vogtle or the

plant). Module 98, Chemistry, was completed on February 17, 1986, and

represented the applicant's " review program to ascertain whether the Vogtle

Chemistry Department activities were being developed to comply with licensing

commitments and whether compliance was verifiable in existing project

documentation." Module 9B addressed the following elements of the Vogtle

Chemistry program: chemical and radiochemical analyses; chemistry for primary,

secondary, radwaste, and auxiliary systems; the post-accident sampling system

(PASS); the process and effluent radiation monitoring (PERMS) program; and

program administration.

The NRC conducted an evaluation of the applicant's assessment to determine if the

review of the chemistry program was effective and accurate and if the

requirements were being properly identified and implemented. This evaluation was

performed by NRC reviewers from the Office of Nuclear Reactor Regulation (NRR)

and the Office of Inspection and Enforcement (I&E) and by inspectors from

Region II (inclusively identified as the staff). This evaluation was

accomplished through a detailed review of all sections of the Module by:

1. verifying that the commitments identified in the Module are correct and in

accordance with FSAR commitments and regulatory requirements.

2. reviewing the Module findings identified by the licensee and evaluating the

correctness of their resolution.

3. reviewing a comprehensive and representative sample of the documents

reviewed by the Readiness Review Staff and an independent sample of

documents selected by the inspectors.

4. interviews by staff personnel.

5. an initial inspection of the elements of the Vogtle water chemistry program

in September-October 1986.

The staff's review showed that Module 98 represents a comprehensive and accurate

compilation of the applicant's commitments and provides an adequate listing and

description of the elements of a plant chemistry program. However, a significant

number of commitments were still being converted into implementing procedures.

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i Consequently, the staff will continue to assess the extent to which the

commitments have been implemented during future pre-licensing inspections.

No regulatory violations or deviations were identified during this review. The

staff was concerned, however, that the phased approach taken by the applicant in

the development of the Vogtle Chemistry program has not provided adequate time

for full development of the support (procedures, staff, training, and chemistry

facilities) needed for pre-operational tests and operational chemistry

control-based on a proposed fuel loading date in December 1986. The applicant's

progress toward this goal will be monitored during future inspections before

licensing.

1. Scope of Review

This review consisted of an examination of each section of Module 98.

Section 1 (Introduction), Section 2 (Organization and Division of

Responsibility), Section 5.0 (Audits and Special Investigations),

Section 6.0 (Chemistry Program Verification), and Section 7.0 (Program

Assessment / Conclusions) were given only cursory attention so that an

in-depth assessment could be made of the proposed chemistry program

(Section 4.0) and, especially, the commitments and implementing procedures

(Section 3). Special attention was given to those portions of the Chemistry

Department's organization and program development that were keyed to plant

milestones that were upcoming during pre-operational tests. Likewise an

effort was made to evaluate this module relative to startup and operational

needs; however, this phase of the review was necessarily limited because the

cutoff dates for the implementation matrix (Section 3.5) had been

December 20, 1985, and a significant member of procedures had still not been

completed by July 1986. The implementation of these remaining

pre-operational and post-operational commitments will be evaluated by

Region II inspectors during future inspections.

2. Methodology

The review of Section 3.4 (Comitment Matrix) was performed by NRC personnel

in the Office of Nuclear Reactor Regulation while Section 3.5

(Implementation) was reviewed by Region II inspectors.

The NRR review of the Vogtle Readiness Review Module 9B, Chemistry, was

initiated by a review of the Commitment Matrix (Section 3.4). The review

I consisted of a comparison of the commitments listed in Section 3.4 with the

guidance contained in the Standard Review Plan (SRP) and other regulatory

documents. The staff also reviewed the matrix to ensure that all

commitments necessitated by the Standard Review Plan had been included in

the Readiness Review Program (all modules). Additional information was

provided to the staff by the applicant in tele-conferences on April 29,

May 29, and July 15, 1986.

Evaluation of the Implementation Matrix (Section 3.5) was initiated after

the Region II inspectors reviewed the Module in its entirety in the

Region II offices. The Region II inspectors review of the commitments in

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Section 3.4 and the key portions of the FSAR that related to plant chemistry

and effluents was directed towards comprehending the scope of the

commitments that were subsequently referenced in the Implementation Matrix.

During site visits on February 17-21, 1986, April 21-25, 1986, and

July 14-18, 1986, the inspectors performed audits to ascertain if the

commitments had been, or were to be, incorporated into procedures. Through

these audits, the inspectors also established if implementation actions were

being tracked, to ensure that an acceptable chemistry program would be

available at all pre- and post-operational milestones.

Review of Section 4 (Program Description) was ir.itiated by the Region II

inspectors in parallel with their review of Section 3.5. An evaluation of

the adequacy of the implemented program was begun during an inspection held

during September 29-October 3,1986 and was discussed in the inspection

report.

Some conclusions related to the scope and effectiveness of the Vogtle

Chemistry program were able to be reached on the basis of activities that

had been carried out during pre-operational tests (hydrostatic and hot

functional). However, the Region II inspectors will pursue a more in-depth

appraisal during subsequent pre-licensing inspections.

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3. Evaluation

The evaluation of each section reviewed is provided below. For each

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section, a description of the section, what was reviewed, and the basis of

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acceptance is provided.

a. 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

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the project. This section was reviewed primarily for content and

background information. No additional followup or evaluation of the

section was required.

b. Section 2.0 - Organization and Division of Responsibility

This section presents a one-page tabular description of the

organization of the Vogtle Chemistry Department. The adequacy of this '

chain of authority will be assessed during future inspections when

staffing has been completed.

c. Section 3.0 - Commitments

< (1) This section of the Module contains a listing of commitments and

implementing documents which are presented in two matrices. The

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first matrix is the Connitment Matrix which contains a listing of

the sources and subject of the applicant's commi tments .

Commitments listed in this matrix were identified by the Georgia

Power Company Readiness Review Staff through a review of the FSAR,

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responses to NRC questions, responses to generic letters, and

responses to IE letters. The second matrix is the Implementation

Matrix which contains a listing of documents and features

discussed in the FSAR and implementing documents. The Readiness

Review Staff had reviewed these documents to verify compliance

with the commitment requirements.

(2) The NRR evaluation of Section 3.4 (Commitment Matrix) was

performed by comparing licensing commitments with the following

source documents: the Vogtle Final Safety Analysis Report ( SAR);

the NRC Standard Review Plan (NUREG-0800); NRC Regulatory Gu[ des;

industry code: and standards; the NRC question and answer records;

the NRC staff's Safety Evaluation Report (SER) for Vogtle; and the

draft Vogtle Technical Specifications.

The commitment matrix in Module 9B, Chemistry, consists of the

chemistry program details that will (1) minimize plant degradation

and optimize p(lant

environments. performance

2) control by controlling

radioactivity levels bothsystem

insidechemistry

the

plant and in plant effluents, and (3) ensure compliance with

regulatory requirements and guidelines. These chemistry program

activities include chemical and radiochemical sampling and

analysis, chemical controls and treatments, radwaste management,

and radiation monitoring in various plant systems and streams.

The plant systems and streams involved in the chemistry program

activities are the radwaste management systems, post-accident

sampling system, reactor coolant system, spent fuel pool cleanup

system, nuclear service cooling water, ultimate heat sink,

condensate storage facility, reactor makeup water, turbine plant

cooling water system, process sampling and effluent streams,

chemical and volume control system, chlorine supply system, fire

protection system, emergency diesel engine fuel oil storage and

transfer system, emergency diesel engine cooling water system,

secondary side water, condensate cleanup system, condensate and

feedwater system, potable and sanitary water system, and process

and effluents radiological monitoring systems.

Other chemistry-related commitments not included in Module 9B are

addressed in other modules of the Readiness Review Program.

Protective coatings are addressed in Module 13B, Coatings. The

containment hydrogen control system is addressed in Module 18A,

Heating, Ventilation and Air Conditioning. The chemical additive

subsystem of the containment spray system, however, is not

included in any module of the Readiness Review Program since it is

addressed in the draf t Technical Specifications. As a general

rule, an item in the Technical Specifications may not necessarily

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be included in a commitment matrix, since it would be redundant.

unless a commitment is more restrictive than the corresponding

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Technical Specification.

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The Facilities Operations Branch identified 16 areas of concern

dealing with operation procedures. These questions were submitted

to the applicant by letter dated July 1,1986 (Reference 1). The

applicant responded to these questions by letter dated July 16,

1986 (Referenca 2). The following is a discussion of these items.

Staff Question #1: Comitment 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.

GPC Res)onse: FSAR Section 13.1.2.2.3 commitments directly

applica)le to the Chemistry organization through FSAR Amendment 18

. (as stated in Module 98, Section 3.4) are reflected in commitments

! 1580, 1583, and 1584. Responsibilities and job descriptions for

engineering, health physics, and maintenance personnel are beyond

the scope of Module 98, " Chemistry." A subsequent amendment to

the FSAR (Amendment 24) clarified chemistry responsibilities in ,

! lightofdepartmentorganizationchanges(discussedinSection2.2

of Module 9B).

Staff Position: Question resolved.

Staff Question #2: Commitment No. 1731, FSAR Section 13.5.1.1.A

states that the General Manager - Vogtle Nuclear Operations

(GMVN0) has the ultimate responsibility for all plant 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

operation heads approving authority (under direction of GMVN0) for

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all procedures in their respective areas, implicitly including

those listed by the FSAR as reserved for the GMVN0. The

commitment anu/or FSAR should be clarified to resolve this

inconsistency for procedures listed in FSAR Section 13.5.1.1.A.

GPC Response: The paraphrased content of Commitment 1731 is not

intended to dictate the authority of the GMVNO beyond that

specified in the FSAR. For clarity, the commitment has been

amended in the master database to state that certain procedures

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are reserved for GMVNO approval.

Staff Position: Question resolved.

Staff Question #3: FSAR Sections 13.5.1.1.C and 13.5.1.1.0 have

been omitted from the Module 98 commitments. This should be

i resolved.

GPC Response: FSAR Section 13.5.1.1.C is addressed in Module 7,

' Commitments 1737,1738,1739,1740,1741, and 1742. Procedures

implementing these commitments are plant administrative which

encompass all plant staff departments. FSAR Section 13.5.1.1.D is

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addressed in Module 7, Commitments 1743, and 1744,1745,1746,

2764, and 1747. Procedures implementing these commitments are

plant administrative which encompass all plant staff departments.

Staff Position: Question resolved.

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Staff Question #4: FSAR Section 13.5.1.1.H describes procedures

for shif t relief and turnover for plant personnel. Included is

the requirement for " appropriate" supervisory personnel to develop

shif t logs. This requirements has been omitted from the Module 98

commitments.

GPC Response: Chemistry Procedure 31045-C establishing a

chemistry shift turnover log and its format was reviewed and

approved by chemistry supervisory personnel. Paraphrased

Commitment 1768 encompasses this requirement and was

satisfactorily verified.

Staff Position: Question resolved.

Staff Question #5: Commitment Numbers 1849 and 1852 address

commitments in FSAR Section 14.2.5; however, commitments in the

last paragraph (pertaining to NUREG-0737, Item I.G.1) of FSAR

Section 14.2.5 have not been included in Module 9B. This should

be resolved.

GPC Response: Commitment to NUREG 0737, Item I.G.1 pertains to

training during the Initial Test Program, (FSAR Section 14.2.5),

and was addressed in Module 2 Commitment 1850.

Staff Position: Question resolved.

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Staff Question #6: Commitment Number 1856 addresses the FSAR

Section 14.2.6.3 connitment to sample and analyze RCS coolant for

l boron during post fuel loading tests. FSAR commitments to predict

critical boron concentration and to modulate baron concentration

with approach to criticality are not addressed by Module 9B

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commitments. This should be resolved.

GPC Response: Prediction of critical boron concentration and

modulation of boron concentration with approach to criticality

(FSAR Section 14.2.6.2) were addressed in Module 7, commitments

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1875,1871, and 1872. Initial Test Program activities are the

! responsibility of Nuclear Operations department, and the Chemistry

department provides support as directed. Commitments pertaining

! to FSAR Section 14.2.6.2 and the Initial Test Program were fully

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addressed in Module 7, as such, Commitments 1856 and 1878 of

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Module 9B were redundant and will be deleted from Module 98 in the

i master database.

l Staff Position: Question resolved.

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Staff Question #7: Commitment Number 1886 addresses the FSAR

Section 14.2.6.3 comitment 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 9B

commitments and should be included.

GPC Response: Low power testing measurement verifications and

actions to be taken if anomalies develop (FSAR Section 14.2.6.3),

were addressed in Module 7, Commitments 1881, 1882, 1883, 1884,

1885, and 2783. Initial Test Program activities are the

responsibility of Nuclear Operations department, and the Chemistry

department provides support as directed. Commitments pertaining

to FSAR Section 14.2.6.3 and the Initial Test Program were fully

addressed in Module 7, as such, commitment 1886 of Module 9B was

redundant and will be deleted from Module 98 in the master

database.

Staff Position: Question resolved.

Staff Question #8: Commitment Number 1891 provides periodic

sampling during power ascension, referencing FSAR 3ection

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 98.

GPC Response: Power ascension testing (FSAR Section 14.2.6.4 and

14.2.8.2) comitments were addressed in Module 7, commitments 1890

through 2073. Initial Test Program activities are the

responsibility of the Nuclear Operations department, and the

Chemistry department provides support as directed. Comitments

pertaining to FSAR Sections 14.2.6.4, 14.2.8.2, and the Initial

Test Program were fully addressed in Module 7. As such,

commitments 1891, 2032, 2044, and 2063 of Module 9B were redundant

and will be deleted from Module 9B in the master database.

Staff Position: Question resolved.

Staff Question #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 98 comitments. This should be resolved.

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GPC Response: Commitments of FSAR Section 17.2.8 directly

impacting the specification, qualification, and certification of

certain chemicals and lab standards were included in Module 9B.

Commitments for specifications for implementation procedures,

responsibilities, and audits which were outside the immediate

scope of the Chemistry department were addressed in Module 5,

Table 3.0-2, pages 28 and 29 and in Module 7, commitments 2197,

2199, 2200, 2201, 2202, 2203, 2204, and 2205. Procedures

implementing commitments addressed in Module 5 and Module 7 are

Plant Administrative which encompass all plant staff departments.

Staff Position: Question resolved.

Staff Question #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, test performed at the supplier's

facility, and audits are not reflected in Module 9B commitments.

This should be resolved.

GPC Response: Changes to test procedures are done to criteria

specified in FSAR Section 13.5.1.1.A and reflected in Module 98

commitment 1732. Departures from approved procedure are by

temporary procedure changes which conform with FSAR Section

13.5.1.1.B and Module 9B commitment 1735. Test records and review

and approval of test results were addressed in Module 5,

Implementation Matrix, pages 31 and 32. Procedures implementing

these commitments are Plant Administrative which enccxpass all

plant staff departments. Prior to an outside supplier perfonning

quality testing, they are audited and qualified by the Quality

Assurance organization who verifies they have procedures in place

to control the testing. QA organization activities for approval

and codits of suppliers are described in Readiness Revied Appendix

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, Staff Position: Question resolved.

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I Staff Question #11: Commitment Number 2861 specifies that the

i Superintendent of Maintenance is responsible for developing,

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approving and implementing procedures and instructions to

establish a control / calibration program and that he approves

calibration procedures. This commitment does not compare well

i with the corresponding designations in FSAR Section 17.2.12, and

omits the roles of the GMVN0, the Plant Review Board, the Quality

Control Department, and periodic audits.

GPC Response: Module 9B commitments were identified and verified

to FSAR Amendment 18. Amendment 19 to the FSAR has clarified this

area of concern by outlining GMVNO role in M&TE (maintenance and

test equipment), specifying PRB review and GMVNO approval for M&TE

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administrative procedures and assigning QC department

responsibilities. The Amendment 19 version was verified in Module

7, commitment 2861.

Staff Position: Question resolved.

Staff Question #12: Commitment Number 2254 addresses the FSAR

Section 17.2.14.B provision requiring measures to bypass various

operations and establish procedurcs 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.

GPC Response: Procedure revision process requires the same

controls as approval of the original procedure. See Module 98,

commitment 1732 which specifies that procedure alterations are

subject to the same controls as approval of the original

procedure.

Staff Position: Question resolved.

Staff Ouestion #13: Commitment Number 2256 omits the FSAR Section

17.2.1L.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 c Luse

can be determined.

GPC Response: As a result of your question, we have reviewed

Section 17.2.14.C with Nuclear Operations Regulatory Compliance

who will submit an FSAR revision to clarify the intent of the

paragraph. The revision to the FSAR will be similar to

NUREG-0800, Revision 2, Section 17.1.14, page 17.1-20.

Staff Position: Question resolved.

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Staff Question #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, recommendations, and

documentation are not reflected in Module 9B connitments. This

should be resolved.

GPC Response: Commitments of FSAR Section 17.2.16 give criteria

for corrective actions which were addressed in Module 5 and Module

7. Specific commitments more directly impacting chemistry were

included in Hodule 98. These commitments procedurally addressed

within Chemistry department procedures include determining

chemistry conditions adverse to quality, initiating chemistry

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corrective actions to correct these conditions and documentation

of the adverse chemistry conditions and corrective actions as

stated in commitment 2272. Commitments pertaining to plant wide

responsibilities related to corrective actions, evaluation of

actions, recommendations, and documentation which were outside the

immediate scope of the Chemistry department were addressed in

Module 5, Table 3.0-2, pages 39 and 40 and Module 7, commitments

2272, 2273, 2274, and 2869. These commitments are implemented

through Plant Administrative procedures which encompass all plant

staff departments.

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Staff Position: Question resolved.

Staff Question #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.

Other requirements of FSAR Section 17.2.16 dealing with other

responsibilities, review designations, storage facilities, and

audits are not reflected in Module 98 commitments. This should be

resolved.

GPC Response: Commitments of FSAR Section 17.2.17 give criteria

for Quality Assurance records which were addressed in Module 5 and

Module 7. Specific commitments more directly applicable to the

chemistry effort were included in Module 98. These commitments

procedurally addressed within Chemistry department procedures

include the Chemistry department generation and submittal of

quality records. Commitments of FSAR Chapter 17.2.17 concerning

plant wide responsibilities, review designators, storage

facilities, and audits which were outside the immediate scope of

the Chemistry department were addressed in Module 5, Table 3.0-2,

page 40 and Module 7, conmitments 2276, 2872, and 2873.

Staff Position: Question resolved.

Staff Question #16: Commitment Numbers 2650 and 2651 reference

Technical Specifications 6.8.1.8 and 6.8.1.C. However, material

from these commitments do not appear in Technical Specification Section 6.8.1. This should be corrected.

GPC Response: Module 98 is current through October 15, 1985 (as

stated in Module 98, section 3.4). Draft Technical Specifications

current at that time and utilized in commitment identifications

activities were dated June 14, 1985 and contained commitments 2650

and 2651 as stated in Module 98. Subsequent draf ts of the

Technical Specifications have incorporated these two conmitments

into 6.8.1.A, " applicable procedures recommended in Appendix A of

Regulatory Guide 1.33, Revision 2, February 1978."

Staff Position: Question resolved.

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The staff has not identified any omissions in the Commitment

Matrix and has concluded that the applicant's response to our

questions were adequate.

(3) Region II inspectors reviewed Section 3.5 (Implementation Matrix).

This matrix was developed by the applicant by correlating each of

the 444 commitments in Section 3.4 with either an approved

procedure, a draft procedure, or by locating the commitment in a

commitment tracking system. Module 98 was published in February

1986, with a cutoff date of December 20, 1985, relative to the

status of implementing procedures. The status of all commitments

subsequently were followed through the Readiness Review Commitment

Tracking System. The data base for this system (CTDB) assigned a

OPEN

number for each

(comitment commitment

identified), OPEN-1and a code

(draft for its status;

procedure i.e., C

prepared), G5ED

(Cheinistry Department had closed / completed review , COMPLETED

(Regulatory Compliance had closed / completed review)).

The inspectors' review covered two principal areas:

(1) commitments related to radiochemistry, quality assurance for

radiochemical analyses, process and effluent radiation monitoring,

radiological effluent management, and post-accident sampling; and

(2) commitments related to non-radiochemical plant chemistry

control and pre-operational chemistry concerns. Within these two

areas, all of the 20 in the

planning

applicant's program development (networks identifiedSection 4) were review

status and acceptability.

During this phase of the review, a selected number (approximately

300) of commitments were checked against the CTDB to determine if

the commitment was being tracked and to establish if the

implementing document (procedure) was available in an approved

version. Considerably fewer implementing procedures had been

completed and approved in the areas of radiological effluent

monitoring and management, and in radiochemical analysis, than

those that related to the other elements of the plant's chemistry

program.

1

Forty procedures that related to the radiochemical and

radiological effluent areas were identified as being complete and

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were verified to implement the associated commitment in an

acceptable manner. Likewise, 140 completed procedures relating to

other program elements were verified to be acceptable. There were

no major findings. Minor errors and perceived deficiencies were

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! discussed with the applicant's personnel during the site visits so

! that resolution could be achieved quickly. The implementing

documents had not been developed to an approved stage for the

following principal subjects and commitments:

Regulatory Guide 1.21 (Measuring, Evaluating, and Reporting

Radioactivity in Solid Wastes and Releases of Radioactive

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Materials in Liquid and Gaseous Effluents from Light

Water-Cooled Nuclear Power Plants)

FSARSection11(LiquidandSolidWasteManagementSystems)

Regulatory Guide 4.15 (Quality Assurance for Radiological

Monitoring Programs (Normal Operations), Effluent Streams and

the Environment)

Sampling schedules.

In all cases, the CTOB indicated that a commitment had been

identified and the implementing procedure had a due date. The

applicant had developed an effective control program for tracking

the implementstion of each commitment. As of August 1986, a

significant rumber of implementing documents had not been

completed,

d. Section 4.0 - Program Description i

This section described the elements (responsibilities) of a

comprehensive chemistry program for minimizing corrosion, for

minimizing radiation exposure, and for controlling radioactive

effluents to the environment, as well as the elements needed to

administer such a program. Inasmuch as this Section was written in

1985, it actually described a proposed program that would be developed

in phased stages to support pre-operational tests, initial criticality,

and commercial operation of the plant. The framework for the program

development consisted of 20 planning networks that addressed licensing

commitments, chemistry support of construction and operations

milestones, and personnel training.

In reviewing this Section, the Region II inspectors correlated the

applicant's goals with the requirements, co:nmitments, and procedures

that had been reviewed in Section 3.5. In addition, a preliminary

evaluation of the scope and adequacy of the proposed program was n.ade

using the criteria included in the following NRC Inspection Modules

that form the basis of the Region II pre-operation inspection program:

Module 84523 - Liquids and Liquid Waste !

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Module 84524 - Gaseous Waste System

Module 84525 - Quality Assurance and Confirmatory Measurements

for In-Plant Radiochemical Analysis

Module 79701 - LWR Water Chemistry Control and Chemical Analysis

Module 79502 - Plant Systems Affecting Plant Water Chemistry

On the basis of their preliminary evaluation. the Region II inspectors

considered the components of the chemistry program, that were evolving

through the applicant's phased approach, provided a satisfactory

framework for the surveillances and controls that will be needed to

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ensure the integrity of the plant and to fulfill the ALARA concept.

This area will be further reviewed during future inspections.

e. Section 5.0 - Audits and Special Investigations

This section described the applicant's audits and assessments related

to the development of health physics / chemistry programs at Plant

Vogtle. At the earliest stage of these activities (December 1984), and

af ter the FSAR was written, it was the applicant's intent that

chemistry activities and responsibilities would be managed by a

Superintendent of Health Physics and Chemistry. Later, these two

disciplines were placed under separate Superintendents, and, then, the

planning of the chemistry program was initiated. As discussed earlier,

this planning led to the development of the Commitment and

Implementation Matrices.

The NRC staff found this phase of the applicant's activities to have

been performed in an acceptable manner, although there is concern that

the planning was started late. It was the inspector's opinion that the

" phased approach" may not provide sufficient time for all elements of a

fully effective chemistry program to be in place before December 1986,

f. Section 6.0 - Chemistry Program Verification

This section described the verification plan developed by the Readiness

Review Team and also the findings and resolution of these findings.

This section was developed in 1985; i.e., before the pre-operational

tests began. Therefore, this section was only cursorily reviewed by

the staff because the applicant had little to base such an assessment

on at this early stage of development of the Chemistry Department and

Chemistry program,

g. Section 7.0 - Program Assessment / Conclusions

This section included assessments by the Readiness Review Team Quality

Assurance Representatives, by the applicant's Technical Consultant, and

by plant management verifying the completeness and accuracy of

Module 9B relative to licensing commitments and being representative of

the chemistry program. Two of these statements were not dated while

the third was dated February 13, 1986. Since the applicant's

assessments were based on an incompletely developed program they were

actually only confirmations of the planning process.

The NRC staff agrees with the applicant's assessment that the module

represents a comprehensive and accurate compilation of the applicant's

commitments and all regulatory requirements related to the development

of a plant chemistry program and to the control of chemistry variables

during all modes of plant operation. The module was considered an

excellent compilation of elements that must be addressed during the

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14

development of such a program. Correct emphasis was placed on the need

for specific guidance and instructions to be available as written

procedures.

On the basis of this review of implementing documentation and a

preliminary observation of the applicant's physical facilities and

analytical instrumentation it was evident that the Vogtle Chemistry

Program will benefit from state-of-the-art technology. However, much

construction remains incomplete and, in the opinion of the Region 11

inspectors, the training and expertise required to implement a modern

chemistry program has only begun to be absorbed by the personnel in the

Chemistry Department.

4. Findings

a. The applicant had not completed procedures for a number of commitments.

This item will be followed as Inspector Followup Item

No. 50-424/86-33-01, Completion of Procedures.

b. The chemistry staff had not been completely developed. This item will

be considered as Inspector Followup Item No. 50-424/86-33-03,

Completion of Staffing.

c. The physical facilities, laboratories and sampling stations, to be used

by the Chemistry Department had not been completed. This issue will be

reviewed in future inspections as Inspector Followup Item

No. 50-424/86-33-03, Completion of Chemistry Facilities.

5. Conclusion

a. Specific Conclusions

(1) The staff has not identified any omissions in the Commitment

Matrix and, consequently, believes that Section 3a accurately and

fully reflects regulatory requirements.

(2) The staff established that the applicant had developed a program

to translate all commitments into implementing documents. As of

August 1986 a significant number of implementation procedures had

not been completed; however all incomplete actions were being

tracked.

(3) The staff considered the elements suninarized in Section 4 would

constitute the framework for an effective chemistry program.

(4) The staff considers that the applicant's planning and

verifications process failed to recognize that the phased approach

to implementing a chemistry program did not provide sufficient

time for the development of some elements (staffing, training,

laboratorics) to support pre-operational and operational

schedules.

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(5) The staff considered the applicant's review, audit, and assessment

program to be well designed and sufficiently thorough. In the

development of some program elements, however, the actual

development lagged significantly behind the audit schedule.

4 b. General Conclusions

. The staff believes that the Readiness Review staff's extensive efforts

have insured that all requirements for establishing an effective

chemistry program have been identified. The major deficiency in the

development of the chemistry control program is considered to be its

timeliness. However, during a pre-operational inspection in October

1986 the Region II inspector observed that significant progress had

been made toward completion of a water chemistry program. Increased

,

attention to this effort will be required, however, since the

'

applicant's scheduled fuel loading date is in December 1986.

REFERENCES

1. Letter to D. O. Foster, GPC, Subject: Vogtle Readiness Review -

j Interim Review Questions - Module No. 9B " Chemistry," dated July 1,

1986,

4 2. Letter to J. N. Grace, RII, Subject: Vogtle Readiness Review, Interim

! Review Questions, Module 98, " Chemistry," dated July 16, 1986.

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ML20214F481

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