IR 05000424/1985030

Readiness Review Module 3A,Initial Test Program, Preoperational Test Phase Insp Rept 50-424/85-30 on 850514- 0906.Corrective Actions Not Complete & Commitment to Reg Guide 1.95 Not Included in Module 3A

ML20198A671
Person / Time
Site:	Vogtle
Issue date:	10/17/1985
From:	Clayton H, Jape F, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20198A604	List: IR 05000424/1985030 ML20198A601
References
RTR-REGGD-01.095, RTR-REGGD-1.095 50-424-85-30, NUDOCS 8511060125
Download: ML20198A671 (19)

Text

I g>R cec o UNITED STATES g 'o,' NUCLEAR REGULATORY COMMisslON

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REGION ll N 0 101 MARIETTA STREET. ATI.ANTA, GEORGI A 30323 ('.s, v /E

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Report No.: 50-424/85-30 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 Construction Permit No.: CPPR-108 Facility Name: Vogtle Unit 1 Reviews Conducted: May 14 - September 6, 1985

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On-Site Inspections Conducted: June 10 - 13, 1985; and August 12 - 15, 1985 NRC Offices Participating In Inspections / Reviews:

Office of Inspection and Enforcement, Bethesda, MD Office of Nuclear Reactor Regulation, Bethesda, MD Region 11, Atlanta, GA Reviewers: W. L. Belke, QA Engineer, IE R. A. Becker, Nuclear Engineer, NRR W. T. LeFave, Mechanical Engineer, NRR M. R. Hum, Materials Engineer, NRR K. C. Leu, Structural Engineer, NRR H. Balukjian, Nuclear Engineer, NRR C. Y. Li, Nuclear Engineer, NRR J. J. Lazevnick, Electrical Engineer, NRR 1' F. R. Allenspach, Nuclear Engineer, NRR

, J. R. W. Rajan, Mechanical Engineer, NRR R. Pichumani, Mechanical Engineer, NRR J. Wing, Chemical Engineer, NRR A. Serkiz, Task Manager, NRR R. L. Gruel, Pacific Northwest Laboratory, NRR Consultant Inspectors: G. A. Belisle, Reactor Inspector, Region II R. Latta, Reactor Inspector, Region 11 J. F. Rogge, Senior Resident Inspector, Region 11 G. A. Schnebli, Reactor Inspector, Region II

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Approved by: / A hFt J -CL/ N_ ! E4 Mape, Section Chief (/ / Date Signed Engineering Branch Division of Reactor Safety

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Region II I bm 1. bradk(L HTB.Clfyton,ActingChief '

/O/h7/Pf Da'te Signed Procedures and Systems Review Branch Division of Human Factors Safety Office of Nuclear Reactor Regulation B e- Io ! tBC P. V. Sinkule, Chief Date Signed Projects Section 20 Division of Reactor Frojects Region 11

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TABLE OF CONTENTS TOPIC PAGE Summary 4 Scope of Review 5 Methodology 6 Evaluations 8 Findings 16 Conclusions 18 References 19 l

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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM M0 PULE 3A INITIAL TEST PROGRAM PREOPERATIONAL TEST PHASE 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. Module 3A, which is the second Module, submitted on May 14, 1985, and the change submittal on July 29, 1985, presents an assessment to ascertain whether the Initial Test Program, Preoperational Test Phase, complies with Final Safety Analysis Report (FSAR) commitments and regula-tory requirements. This evaluation was conducted to determine if the results of the program review of the Preoperational Test Program presented in this Module are an effective and accurate assessment of the requirements, that the require-nents are being properly implemented, and that the resolutions of the findings identified in Module 3A were corrected or being correcte This evaluation was performed by NRC reviewers from the Of fice of Nuclear Reactor Regulation (NRR) and the Of fice of Inspection and Enforcement (IE), and inspec-tors from Region II. The evaluation was accomplished through a detailed review of all sections of the Module by: Verifying that the Preoperational Test Program commitments identified in the Module are correct and in accordance with FSAR commitments and regulatory requirement . Reviewing the Module findings identified by the licensee and evaluating the correctness of their resolutio . Reviewing a comprehensive and representative sample of the documents re-viewed by the Readiness Review Staff and an independent sample of documents selected by the inspector During this review, it was apparent to the NRC reviewers and inspectors that GPC management supported the program by active participation in the development and implementation of the program. This evaluation also indicates that the licensee's program review for the preoperational test phase was comprehensive and provides adequate assurance that plant components and systems will be tested in accordance with NRC requirements and FSAR commitments except for several deficiencies which were identified by the NRC reviewers and inspectors. A deficiency is considered to be an item having minimal safety significance, but one which should be evaluated by the applicant to determine what action could be taken to I

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correct the item and thus preclude the possibility of the development of safety problems. The findings identified during this evaluation are summarized below:

Deficiency - Verify Completion of Georgia Power Company QA Audit of the 35 Findings Associated with Module 3 Deficiency - List Regulatory Guide 1.95 as a Commitment in Module 3 Deficiency - Limit Reference to Regulatory Guide 1.68 to Module Appropriate for Applicable Test Phas Deficiency - Amend FSAR Concerning Leak Rate and Vibration Testing (five

items).

Deficiency - Add General Statement to Future Modules Applying Appropriate QA Control Deficiency - Include Commitment to the Code and Standards Rule 10 CFR 50.55a in Module 16 and Response to Q210.47 in Module 7.

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It does not appear that these deficiencies represent significant programmatic weaknesse Details on these items are discussed in Section 4 of this repor Resolution of these items will be handled during future Region II inspection Implementation of the preoperational test program will be inspected during future Region II inspection This program is expected to require approximately 18 months to complet . Scope of Review This review, which consisted of an examination of each section of the Module, was performed by reviewers f rom NRR, IE, and inspectors from Region II. The scope of the NRC review and the subsequent NRC findings were limited due to the extensive amount of unapproved implementing procedures referenced in this Module. Tne NRC inspection program will be performed by Region II to complete review activities in the implementation of the preoperational test phase prior to licensin GPC performed a program verification to ascertain that the preoperational test phase was properly implemente The program was conducted in three parts: verification of commitments, verification of commitment implementa-tion, and a field verification to identify potential problems. The process utilized eight team members and expended approximately 2000 staff hours to examine the implementation of approximately 700 commitment Module Sections 1.0, 2.0, 5.0, and 7.0, which contain information concerning the Module introduction, company organization, division of responsibility, interfaces, audits, special investigations, and conclusions regarding the assessment of the Module, did not require as detailed a review or evaluation as the remaining sections. The more significant aspects of the Module appear in Sections 3.0, 4.0, and These sections discuss applicant commitments, method of implementing commitments, administrative controls during the test program, scheduling, program implementation and program

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verificatio Review of these sections included a detailed review of the content, examination of items identified as findings, an examination of a sample of documents reviewed by the GPC Readiness Review Staff, and an examination of independently selected sample of document The scope of the review by NRR predominantly covered the commitment matrix and any impacts the other sections of the Module might have with respect to these commitments. Although NRR - Procedures and Systems Review Branch (PSRB) - had the major portion (287 of 391 commitments) of the test program review, there were some areas associated with the initial test program where other Branches had primary review responsibil1Ly as delineated by the Standard Review Plan (SRP). These areas are noted below and were reviewed by the responsible Branches indicate . Vibration, thermal expansion, and dynamic movement testing covered undei SRP Section 3.9.2 were evaluated by the Mechanical Engineering Branc h (MEB). Testir.g of American Society of Mechanical Engineers ( ASME) Code Class 1, 2, cnd 3 components and supports, covered by SRP 3.9.3 were reviewed by ME . Contairment Leakage testing covered by SRP Section 6.2.6 was reviewed by Contlinment Systems Branch (CSB). Electrica' system testing covered by SRP sections 8.3.1 and 8.3.2 were evalt.ated by the Power Systems Branch (PSB). Administrative procedures used to develop, review, and approve test procedures covered Ly SRP Section 13.5 were reviewed by Licensee Quali-fications Branch (LQ3). Administrative procedures governing the review, evaluation, and approv-al of initial tesc program testing, covered by SRP Sections 13.5 and 17.2 were reviewed by LQB and the Quality Assurance Branch (QAB),

respectivel . Methodolcgy The NRR review of Mcdule 3A was conducted in two phases.

I Phase I of the review consisted of a comparison of the commitments listed in

! Section 3.4 of the Module, Commitment Matrix, with the guidance contained in SRP Section 14.2, Initial Plant Test Program. This phase of the review consisted of two parts: conformance with approved FSAR Chapter 14 preopera-tional test abstracts, and conformance with PSRB requests for additional information pertinent to the preoperational test program. This ensured that all commitments necessitated by the SRP were included in the Readiness Revie Phase II of the review consisted of a comparison of the commitments listed in Section 3.4 of the Module with the source FSAR Section listed for each commitment. This phase of the review included the same areas identified in Phase I plus those FSAR sections identified by the matrix as containing

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preoperational testing commitments. Each identified commitment was reviewed for appropriateness and applicability to the preoperational test phas l As a product of this review process, several apparent errors or omissions were identified. These items were either discussed with or forwarded to the applicant in the form of questions to be answered (Reference 2). The applicant satisfactorily responded to these questions (References 1 and 3)

and modified the commitment matrix or committed to revising the FSAR to provide an acceptable NRR/IE scope of the commitment matri The review and evaluation by Region II inspectors was accomplished by reviewing the Module in its entirety in the Region II Office beginning on May 14, 1985, and by inspections at the Vogtle site on June 10 - 13, 1985 (Inspection Report No. 50-424/85-24) and August 12-15, 1985 (Inspection Report No. 50-424/85-41). Section 1.0, Introduction, which presents an introduction to the intent and content of the Module and Section 2.0, Initial Test Program Organization and Division of Responsibility were only reviewed for general content and needed background dat Review of Section 3.0, Commitments, was acccmplished in two parts. The l commitment matrix was briefly reviewed by Region II personnel since NRR l

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performed this review as previously discussed. Review of the implementation matrix concentrated on verification of the preoperational test phase commit-ments and their corresponding implementing documents. The commitment sources reviewed included the FSAR, the Safety Evaluation Report (SER),

Regulatory Guides, American National Standard Institute ( ANSI) standards, and the A5ME codes.

i Review of Section 4.0, Program Description, was accomplished by examining the three subsections and comparing the program description with regulatory requirements. Section 5.0, Audits and Special Investigations, was reviewed for general content as this section contains a description of the audit program and the INP0 evaluation of the preoperational test program. The inspectors reviewed the seven audits conducted by the Quality Assurance Department of test program activities as well as the audit schedules for 1985 and 1936. Audit findings identified in subsection 5.2 were not exam-ined in detail because similar type findings were examined and evaluated in the review of Section Review of Section 6.0, Initial Test Program Preoperational Test Phase Verification, centered around Subsection 6.2, Findings, Responses, and Corrective Actions. In Subsection 6.1, Verification Scope and Plan, the inspectors reviewed the established verification process as well as inter-viewing licensee personnel that were directly involved in the findings, responses, and corrective actions of the readiness review. Additionally,

the inspectors reviewed the five verification checklists used by GPC during the readiness review of procedures. Review of Subsection 6.2 was accom-plished by reviewing and examining the corrective actions associated with the resolution of the 35 Readiness Review Team findings which included examination of records, implementing procedures, industry standards, and FSAR commitments associated with the items identified in the finding . _ . -

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Review of Section 7.0, Assessment, was reviewed primarily for content and background information. Subsection 7.1, Summary of Open Corrective Actions, was reviewed in conjunction with Subsection . Evaluations The evaluation of each section reviewed is provided belo For each sec-tion, a description of the section, what was reviewed, and the basis of acceptance is provided, 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 projec This sectior. was reviewed primarily for content and background information. No additional followup or evaluation of the section was require Section 2.0 - Organization and Division of Responsibility This section presents a description of the organization and division of responsibility of Georgia Power Company, Bechtel, and Southern Company Services for their role in the Initial Test Program. This section of the Module was reviewed for content onl No additional followup or evaluation of this section was require 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

, first matrix is the commitment matrix which contains a listing of the sources and subject of the applicants commitment Commit-ments listed in this matrix were identified by the Readiness Review Staff through a review of the FSAR, 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 reviewed these documents to veri fy compliance with the commitment requirement (2) NRR reviewers' and Region II inspectors' review and evaluation of this section was performed by comparing licensing commitments and corresponding source documents with the SRP, Regulatory Guides, a

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the provisions of the industry codes and standards, the NRC question and answer records, the staff's SER and the FSAR docu-ments. The review also included a review of commitment sources and implementing procedures to verify that the FSAR commitments were being correctly implemented in project documents. Region II l'

review of the implementing procedures mainly centered around review of the Startup Manual (SUM) in regards to the program, as

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the majority of the preoperational test procedures were not completed at the time of the inspection. Review of the program is discussed in paragraph 3.d belo Inspection of program implemen-tation will be accomplished throughout the test program during routine and special Region II inspections (see inspection Report No. 50-424/85-24).

(3) When applying the review methodology described above, the staff concluded that the commitment matrix included most of the regula-tory guidance and staff positions for the scope of revie However, in the course of the review, the staff found two catego-

-ies of deficiencies: (a) omitted commitments and (b) incorrectly or inappropriately identified commitments resulting from a variety of causes or commitments where further clarification was require Following is a discussion of these items:

(a) Evaluation by pSRB Questions The apparent omissions were formulated as questions and forwarded to the applicant for respons The apparent i

omitted commitments were:

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FSAR Subsection 1.9.95 (Regulatory Guide 1.95, Protec-tion of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release).

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FSAR Subsection 14.2.8.1.20 (Boron Thermal Regeneration

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FSAR Subsection 14.2.8.1.112 (Main Turbine System).

FSAR Subsection 14.2.8.1.113 (125-Vdc Class 1E Minimum

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Load Voltage Verification).

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FSAR Question 640.3 (Loss o'f Air Tests on Safety-Related Pneumatically Operated Valves).

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FSAR Question 640.6 (Completion and Approval of Test Results of All Preoperational Tests Prior to Initial Fuel Loading).

These apparent errors in structure or annotation were formu-lated as questions and forwarded to the applicant for re-spons The apparent errors were:

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FSAR Subsection 1.9.68 commitmer.t (3206, p. 5) remarks

should be deleted as they are in reference to startup

(not preoperational) test exceptions.

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FSAR Subsection 3.1.4, Criterion 37 commitment (3219, p. 7), states that ECCS functional tests are performed with the pressurizer water level below the safety injection (SI) signal setpoint. This test is no longer applicable as the pressurizer water level SI setpoint has been removed (FSAR Table 7.3.1-1).

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FSAR Subsection 6.3.4.1 commitment (2675, p. 16) refer-ences emergency diesel generator testin The test items in this section are not all related to the emer-gency diesel generators and do not address specific test This commitmer.t is misstated and should there-fore be reworded or delete FSAR Subsection 8.3.1.1.3.H.3.k'mmitment (3263, p. 20)

should be deleted as switching from one diesel fuel oil supply system to another is not part of the normal operating procedure to satisfy the 7-day storage re-quirement (FSAR Subsection 9.5.4.2) as contained in Regulatory Guide 1.108, Periodic Testing of Diesel Generators Used as Onsite Electric Power Systems at Nuclear Power Plant FSAR Subsection 9.4.9.2.4 commitment (2714, p. 25)

incorrectly addresses testing of the Auxiliary Steam Syste This commitment should be deleted as this FSAR section addresses the Electrical Tunnel Ventilation System (commitment 2727, p. 25). Testing of the Auxil-iary Steam System is described in FSAR Subsection 9.5.9.4 (commitment 2720, p. 25).

Resolution

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The applicant responded with corrections in an addenda to the Commitment Matrix, Section 3.4, and other sec-tions (Reference 1). These corrections provided suffi-cient information to resolve the above questions with the exception of the following minor clarifications:

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The applicant stated that a commitment to Regulatory l Guide 1.95 is included in Module 7A, Plant Operation It should also be listed as a commitment in Module 3A, Initial Test Program. (IFI 85-30-01)

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The applicant stated Regulatory Guide 1.68 is applicable to both Module 3A, Preoperational Test Phase, and 3B Startup Test Phase, and that the same entry will appear in both Modules. The remarks in each Module should be limited to those appropriate for each test phas (IFI 85-30-02)

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(b) Evaluation by CSB Questions The following clarifications were requested by CSB in Reference It is not clear why fan operation during the Integrated Leak Rate Test (ILRT) is necessary for their protectio This is counter to current ILRT practic It is also not clear whether cooling water flow will be terminated during the ILRT. The impact of fan-cooler operation on stabilization of test conditions should also be evaluat-ed (page 13, commitment 3276).

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The leakage rate that should be compared to 0.75 La is the upper confidence limit based on the statistical methodology of either BN-TOP-1 or ANSI /ANS 56.8 198 The commitment should be more precisely stated to reflect this (page 14, Source Item 4340).

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This is a commitment to test all Containment Isolation Valves (CIVs) in the Type C test program individuall Allowance should be made for the fact that with appro-priate justification, series isolation valves may be leak tested simultaneously. The test fluid is a gas (usually air), unless the objective is to demonstrate the presence of a water seal that will preclude contain-ment atmosphere leakage under accident conditions, in i

which case the test fluid is water. Those CIVs to be excluded from the Type C test program would be identi-fied and appropriately justified (i.e., approved by the staff) (page 15, commitment 3285 and 3286).

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A commitment to pressurize the Steam Generators (SGs)

above containment pressure for the ILRT is not accept-able. The secondary side CIVs are not Type C tested because it is judged by the staff that they are not potential containment atmosphere leak path This

implies that the SG shell/ piping (the first isolation barrier under GDC 57 criteria) has exceptional leakage integrity. For the ILRT, then, the SG air space should be atmospheric pressure to include the closed system (viewed as an inward protrusion of the containment boundary) in the ILRT (page 15, commitment 3287).

Resolution

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The applicant responded with proposed corrections to the FSAR in Reference 3. The corrections in Reference 3 are

acceptable responses to the questions raised above by the

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4 staf The corrections are listed in Section 4.0 of this report under Finding The licensee will make these corrections to the FSAR and the commitments will be verified in the NRC plant revie The commitment matrix in Readiness Review Module 3A will not have to be revised to incorporate these FSAR change (IFI 85-30-03, 85-30-04, 85-30-05, and 65-30-06)

(c) Evaluation by MEB Question

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The following omission was cited by MEB in Reference "The applicant's response to Q210.47 relative to the

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preservice examination of snubbers is not included in the Module 3A commitment Matrix."

Resolution

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The applicant's response in Reference 3 states that the commitment for preservice examination (inspection) is assigned to Module 7, Plant Operations and Support. The readiness review verification program for Module 7 is complete and the implementation of the commitment for preservica examination was addresse The verification review found that the commitment for preservice examina-tion was being addressed in draft copies of nuclear operations engineering support procedures. These draft procedures included all of the requirements contained in the response of FSAR Q210.47 relating to preservice examination of snubber The applicant's response is satisfactory and this commitment will be verified in the review of Module (IFI 85-30-09)

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A discrepancy was identified in commitment 3231 (Piping Vibration, Thermal Expansion and Dynamics Effects). The commitment as stated in the Module is as follows. "If steady-state vibrations are observed during initial operations maximum amplitudes are measure Acceptance criteria-maximum amplitude shall not induce stress in piping greater than 1/2 limit ( ASME III) (3.9.B.2.1)."

Resolution

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As a result of a telephone conversation with the appli-cant on June 18, 1985, the applicant agreed to revise the FSAR to provide criteria that are consistent with

! the ANSI /ASME OM-3 standard " Requirements for k

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Preoperational and Initial Startup of Vibration Testing of Nuclear Power Plant Piping Systems." The applicant agreed to document the changes and incorporate them in FSAR Amendment 17. The commitment will be verified in the NRC plant revie The commitment matrix in Readiness Review Module 3A will not have to be revised to incorporate these FSAR changes. (IFI 85-30-07)

Question

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Omission of the commitment to the Code and Standards Rule 10 CFR 50.55a was brought to the attention of the applicant in a telephone conversation of September 10, 198 Resolution

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The applicant responded that this commitment more appropriately belongs in Module 16 - Nuclear Steam Supply System and agreed to include it in that Modul The staff agreed to this action. (IFI 85-30-09)

(d) Evalaution by QAB Question

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A general question, raised by QAB in Reference 2, was why certain quality assurance guides were not cited in the commitments to this matri Response

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The applicant's response in Reference 3 states that the guides listed in the Module 3A commitment matrix are those determined to be most applicable to the Initial Test Program, Preoperational Test Phase; other QA guides will be included in other readiness review Modules as appropriat The applicant has committed, in Reference 3, to include a general statement in each Module that would apply the appropriate quality assur-ance controls, includirg the FSAR referenced quality related Regulatory Guides, exceptions and alternatives thereto to those activities ~ expressed in each Modul This statement would apply to the program in general and to each Module submitted including all previously submitted Module Modules that have been issued (or are in printing) do not have to be revised to include this statemen The staff finds this acceptabl (IFI 85-30-08)

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Review of this section by the reviewers and inspectors showed, except as noted above, that the Vogtle licensing commitments and implementing documents comply with the FSAR, the SRP, Regulatory Guides, and indus-try codes and standards, d. Section 4.0 - Program Description (1) This section of the Module describes the initial test program in detail, including administrative controls, scheduling, and the activities associated with the preoperational test phas (2) Review of this section by Region II inspectors included a detailed examination of the three subsections and a comparison of the program description with FSAR requirement In addition, an in-depth review of the Startup Manual and applicable sections of the Plant Administrative Procedures Manual was performed as these documents implement the program requirement The areas covered in the overall preoperational test program review included the following:

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Verification that the applicant has prepared a detailed description of the preoperational test progra Verificatica that the test organization is clearly defined including qualifications, responsibility, lines of authority, and definition of interfaces between organization Verification that formal methods have been established to administer the test progra Verification that formal measures have been established to control the test procedure process including preparation, review, approval, issuance, and revisio Verification that a formal program has been established to control design changes and modifications during the test program, including temporary modifications, jumpers and bypasse Verification that a program has been established to control maintenance during preoperational testin Verification that a program exists for general housekeeping activities, including equipment protection, cleanliness and water chemistry control Verification that controls have been established for test and measurement equipment to be used throughout the test' progra . - . . _

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Verification that training requirements have been established for personnel involved in the test progra (3) Review of this section indicated that the program described in the subsections is correct and ascertains that the overall administra-t tive controls for the preoperational test phase have been devel-

oped in accordance with FSAR commitments and regulatory require-ment No findings were identified during the review of this

. sectio Section 5.0 - Audits and Special Investigations (1) This section contains a discussion of the QA audit program,

completed audits, and special inspections performed by INP ;

' (2) Review of this section included a review of the two subsections and of seven audits conducted between September 17, 1984 and June 27, 198 The corrective actions required by INP0 evalua-tions were reviewed to ensure adequacy. During the audit review, it was verified that an approved audit checklist was used, that audits were issued as procedurally required, and that corrective action was planned or had been completed for audit finding (3) Review of this section indicated that it is an accurate presenta-tion of the audit proces Section 6.0 - Program Verification (1) This section discusses the methods used to verify conformance to the preoperational test program requirements. The section is comprised of two subsections. Subsection 6.1 covers the identifi-cation of commitments, and development of the verification plan i and scope. Subsection 6.2 discusses the findings, responses, and j corrective action (2) Region II inspectors reviewed the established verification pro-

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cess. Personnel directly involved in the process were inter-

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viewed. Additionally, the five verification checklists used by GPC for confirming the stated commitments and listed procedures i were reviewed for completeness. The inspectors reviewed each verification process finding and the proposed corrective action

for these findings. The proposed corrective actions were judged j to be adequate. Corrective action completion was not verified as

this had not been completed at the time of the inspection. An audit is scheduled by the GPC operations QA group to verify

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corrective action completion. Cne Inspector Followup Item (IFI 85-41-01) was identified pending QA completion of this audit and this is discussed in paragraph (3) below.

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(3) NRC review of Section 6.0 indicated that the review conducted by i the GPC Readiness Review Team for the preoperational test program was comprehensive and adequate. Examination of the findings indicated that they were of minor significance and that the l

proposed corrective action for the findings was sufficient. One area of concern was identified in the review of this sectio Subsection 6.2, contains a list of findings, responses, and corrective actions identified by the readiness review team during the preoperational test phase verification. Corrective action for j these findings was in process or had been completed and the findings are being tracked by GPC operational QA personnel. An i audit has been scheduled to verify corrective action adequacy and completion but, as of this review, the audit had not been starte Until operations QA have conducted this audit and verified cor-i rective action completion for the readiness review team findings, j this item will remain open and is identified as Inspector Followup Item 424/85-41-0 Section 7.0 - Assessment

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This section contains the statements addressing the independent assess-i ment of the Module by Georgia Power Company Quality Assurance, Stone j and Webster Engineering Corporation, the General Manager for Nuclear i Operations, the Initial Test Manager, and the Readiness Review Boar This section was reviewed for content only. No additional followup or

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evaluation is required.

j Findings

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The following findings were identified from the reviews by NRR and IE reviewers and Region II inspector The findings are identified as a deficiency which is considered as an item having minimal safety significance but one that should be evaluated further to preclude safety problem Deficiencies will be pursued as an Inspector Followup Item (IFI) in future routine inspection l Deficiency - Review of Section 6.2 showed that the corrective actions j

(IFI 85-41-01) for the Readiness Review Teams findings were not yet

complet A QA audit was scheduled to verify the l adequacy and completion of the corrective action; j

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however, at the time of this review, the audit had not commence Deficiency - The applicant stated that a commitment to Regulatory (IFI 85-30-01) Guide 1.95 is included in Module 7A, Plant Operation It should also be listed as a commitment in Module 3A,

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Initial Test Program.

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I Deficiency - The applicant stated Regulatory Guide 1.68 is (IFI 85-30-02) applicable to both Module 3A, Preoperational Test Phase, and 3B, Startup Test Paase, and that the same entry will appear in both Modules. The remarks in each Module should be limited to those appropriate for each test phas Deficiency - The FSAR will be revised to delete the statement that (IFI 85-30-03) "the containment fan coolers are protected by operating them throughout the duration of the ILRT." (commitment 3276)

Deficiency - The FSAR statement will be revised to say, "The measured (IFI 85-30-04) leakage rate shall be less than 0.75 of the maximum allowable le8 age rate value La. " In addition, the FSAR will be revi>qd in 6.2.6.1 to say, "The actual leakage rate will be uetermined by using the methods and re-quirements of Appendix J to 10 CFR 50 and ANSI /ANS 56.8, 1981." (commitment 4340)

Deficiency - The FSAR will be revised to read as follows: "Contain (IFI 85-30-05) ment isolation valve leakage is determined in accordance with the requirements of 10 CFR 50, Appendix J and ANSI /ANS 56.8, 1981 for Type C testing. The leakage will be measured in the same direction as would occur in an accident, unless it can be determined that leakage measured in a different direction will provide an equivalent or more conservative re s u l *. s . The test medium used for pressurization is determined by the valve's post-accident condition. All valves which could be exposed to the containment atmosphere subsequent to an accident will be tested with air or nitrogen. Valves which are in lines designated to be filled with a liquid for at least 30 days subsequent to an accident may be leakage rate tested with water." (commitment 3285 and 3286).

Deficiency - The FSAR statement will be changed as follows: "The (IFI 85-30-06) secondary side of the SGs is subjected to Type A tests as shown in Table 6.2.4-1". (commitment 3287).

Deficiency - The FSAR will be revised to provide criteria that are (IFI 85-30-07) consistent with the ANSI /ASME OM-3 standard " Require-ments for Preoperational and Initial Startup of Vibra-tion Testing of Nuclear Power Plant Piping Systems."

This FSAR change has resulted from the review of commit-ment 3231.

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Deficiency - The applicant agreed in Reference 3, to include a (IFI S5-30-08) general statement in each Module that would apply the appropriate quality assurance controls including the FSAR referenced quality related regulatory guides, exceptions and alternatives thereto to those activities

expressed in each Module. This statement would apply to the program in general and to each Module submitte Modules that have been issued (or which are in printing)'

do not have to be revised to include this statemen ,

Deficiency - The applicant agreed to include the commitment to (IFI 85-30-09) the Code and Standards Rule 10 CFR 50.55a in Module 16 and has stated that the response to Q210.47 with regard i to preservice examination of snubbers has been included in Module 7. These commitments will be pursued in the l review of Modules 7 and 1 The commitments for the five FSAR changes do not have to be revised in Module 3A. They will be verified in the normal plant review after the FSAR changes are submitte Resolution of the above listed findings will be followed and addressed in Region II site inspections and documented in inspection reports, i Conclusions

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Based upon the review within the scope of Module 3A, Initial Test Program, Preoperational Test Phase, which is in an early stage, the NRC has reached i the following conclusions for preoperational test phase for Vogtle Unit (1) The Vogtle licensing commitments and other sections in the Module scope have demonstrated compliance with the FSAR and applicable sections of staff documents such as the SRP and Regulatory Gaide '

The technical findings and the associated corrective actions taken to confirm the technical adequacy of the Preoperational Phase of

the Initial Test Program are acceptable to the staff. Therefore, the staff concludes that the reviewed scope of Module 3A of the Vogtle Electric Generating Plant Readiness Review Program is acceptabl (2) The review conducted by the GPC Readiness Review Staff for the preoperational test phase verification program was comprehensive and adequate. Findings were of minor significance and the resolu-tion of the findings adequate, however, some of the corrective j actions for the findings remains to be complete (3) During the review, it was apparent to the NRC reviewers and

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inspectors that GPC management supported the program by their

! active participation in the development and implementation of the I

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program. Review and evaluation of Module 3A by the NRC indicates that the review performed by the GPC Readiness Review Staff was sufficiently comprehensive in scope and depth to identify problem i

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areas, and that the dispositions of findings were proper and satisfactory, except as noted above. The NRC findings identified appear to be minor and do not represent a breakdown in the progra (4) The procedures and documents for the preoperational test phase were consistent with commitments and, therefore, acceptabl Pending resolution of the findings identified above, the NRC finds that the Vogtle program for the preoperational test phase complies with the Final Safety Analysis Report and that compliance is verifiable with existing documentatio Implementation of the preoperational test phase will be inspected in future Region II inspection These conclusions are based on information currently available to the inspectors and reviewer Should information subsequently become available which was not considered during this review or previous inspections and which conflicts with earlier information, it will be evaluated to determine what effect it may have on the above conclusio . REFERENCES: Letter to NRC, Region II, J. Nelson Grace, from D. O. Foster, Georgia Power Co., Subject: Vogtle Electric Generating Plant Unit 1, Readiness Review Program Module 3A - Change Submittal, July 29, 198 . Letter to Georgia Power Co., R. J . Kelly, from Roger D. Walker, NRC-Region II, Subject: Vogtle Readiness Review - Interim Review Questions - Module No. 3A " Initial Test Program - Preoperational Test Phase" dated September 3, 198 . Letter to NRC, Region II, J. Nelson Grace, from D. O. Foster, Georgia Power, Co., Subject: Response to Vogtle Readiness Review Interim Review Questions - Module 3A. File: X780102, dated October 3, 198 i