ML20214F481
| 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: |
| References | |
| 50-424-86-33, NUDOCS 8611250321 | |
| Download: ML20214F481 (18) | |
See also: IR 05000424/1986033
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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101 MARIETTA STREET, N.W.
ATLANTA, GEORGl A 30323
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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:
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dwt
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D. M. Collins, Chief
Date Signed
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
Region II
k , f .c
lifeohC,
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M. t. Sinkuld, Chief
Ddte Signed
Projects Section 20
Division of Reactor Projects
Region II
8611250321 861113
ADOCK 05000424
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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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TABLE OF CONTENTS
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TOPIC
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Summary
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Scope of Review
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Methodology
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Evaluations
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Findings
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Conclusions
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References
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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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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
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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.
3.
Evaluation
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The evaluation of each section reviewed is provided below.
For each
section, a description of the section, what was reviewed, and the basis of
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acceptance is provided.
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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
the project.
This section was reviewed primarily for content and
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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
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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
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implementing documents which are presented in two matrices.
The
first matrix is the Connitment Matrix which contains a listing of
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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 performance by controlling system chemistry
environments.
2) control radioactivity levels both inside 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
be included in a commitment matrix, since it would be redundant.
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unless a commitment is more restrictive than the corresponding
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.
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
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(as stated in Module 98, Section 3.4) are reflected in commitments
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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
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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
are reserved for GMVNO approval.
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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
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resolved.
GPC Response:
FSAR Section 13.5.1.1.C is addressed in Module 7,
Commitments 1737,1738,1739,1740,1741, and 1742.
Procedures
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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.
Staff Question #6:
Commitment Number 1856 addresses the FSAR
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Section 14.2.6.3 connitment to sample and analyze RCS coolant for
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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
commitments. This should be resolved.
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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
1875,1871, and 1872.
Initial Test Program activities are the
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responsibility of Nuclear Operations department, and the Chemistry
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department provides support as directed.
Commitments pertaining
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to FSAR Section 14.2.6.2 and the Initial Test Program were fully
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
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master database.
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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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Staff Question #11:
Commitment Number 2861 specifies that the
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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
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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
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
number for each commitment and a code for its status; i.e., G5ED
OPEN
(comitment identified), OPEN-1 (draft procedure prepared), C
(Regulatory Compliance had closed / completed review)).
(Cheinistry Department had closed / completed review , COMPLETED
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
in the
planning (networks identifiedSection 4) were review
areas, all of the 20
applicant's program development
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
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
i
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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13
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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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.
b.
General Conclusions
4
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,
2.
Letter to J. N. Grace, RII, Subject:
Vogtle Readiness Review, Interim
4
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Review Questions, Module 98, " Chemistry," dated July 16, 1986.
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