ND-18-0123, Notice of Uncompleted ITAAC 225-Days Prior to Initial Fuel Load Item 2.3.10.02a (Index Number 431)
| ML18032A586 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/30/2018 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| ND-18-0123 | |
| Download: ML18032A586 (13) | |
Text
hk. Southern Nuclear JAN 3 0 2018 Docket Nos.:
52-025 52-026 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4 7825 River Road Waynestx)ro, GA 30830 706-848-6459 tel 410-474-8587 cell myox@southernco.coni ND-18-0123 10CFR 52.99(c)(3)
Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.3.10.02a findex Number 4311 Ladies and Gentlemen:
Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of January 29, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item2.3.10.02a
[Index Number431] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing this ITAAC. Southern Nuclear Operating Company will, at a later date, provide additional notifications for ITAAC that have not been completed 225-days prior to initial fuel load.
This notification is informed by the guidance described in NEI 08-01, Industry Guidelinefor the ITAAC Closure Process Under 10 CFR Part 52, which was endorsed by the NRC in Regulatory Guide 1.215. In accordance with NEI 08-01, this notification includes ITAACfor which required inspections, tests, or analyses have not been performed or have been only partially completed. All ITAAC will be fully completed and all Section 52.99(c)(1) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding that all acceptance criteriaare met priorto plant operation, as required by 10 CFR 52.103(g).
This letter contains no new NRC regulatory commitments.
If there are any questions, please contact Tom Petrak at 706-848-1575.
Respectfully submitted.
Michael J. Yox Regulatory Affairs Director Vogtle 3 &4
U.S. Nuclear Regulatory Commission ND-18-0123 Page 2 of 4
Enclosure:
Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.10.02a [Index Number431]
MJY/pgl/amw
U.S. Nuclear Regulatory Commission ND-18-0123 Page 3 of 4 To:
Southern Nuclear Operating Company / Georgia Power Company Mr. D. A. Bost (w/o enclosures)
Mr. M. D. Rauckhorst (w/o enclosures)
Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)
Mr. D. L. McKlnney Mr. M. J. Vox Mr. D. L. Fulton Mr. J. D. Williams Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. 0. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. R. L. Beiike Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:
Nuclear Reoulatorv Commission Mr. W. Jones (w/o enclosures)
Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. T. C. Brimfield Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Oolethorpe Power Corporation Mr. K. T. Haynes Mr. R. B. Brinkman Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson
U.S. Nuclear Regulatory Commission ND-18-0123 Page 4 of 4 Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)
Mr. D. 0. Durham (w/o enclosures)
Mr. M. M. Corletti Ms. L. G. Iller Mr. D. Hawkins Ms. 8. DiTommaso Mr. J. L. Coward Ms. N. E. Deangelis Other Mr. J. E. Hosier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, inc.
Mr. 8. Roetger, Georgia Pubiic Sen/ice Commission Ms. 8. W. Kernizan, Georgia Pubiic Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-18-0123 Enclosure Vogtle Electric Generating Plant (VEGP) Unit3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.10.02a [Index Number 431]
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 2 of 9 ITAAC Statement Design Commitment:
2.a)Thecomponents identified in Table 2.3.10-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.
2.b)The piping identified in Table 2.3.10-2 as ASME CodeSection III isdesignedand constructed in accordance with ASME Code Section III requirements.
3.a) Pressureboundary welds in components identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements.
3.b) Pressureboundary welds in piping identified in Table 2.3.10-2 as ASME CodeSection III meet ASME Code Section III requirements.
4.a) Thecomponents identified in Table2.3.10-1 as ASME CodeSection III retain their pressure boundary integrity at their design pressure.
4.b)The piping identified inTable2.3.10-2 as ASME Code Section III retains itspressure boundary integrity at its design pressure.
5.b) Each of the lines identified in Table 2.3.10-2 for which functional capability is required is designed to withstand combined normal andseismic design basis loads without a lossof its functional capability.
Insoections. Tests. Analyses:
Inspection will be conducted of the as-built components and piping as documented in the ASME design reports.
Inspection of theas-built pressure boundary welds will be performed in accordance with the ASME Code Section III.
Ahydrostatic test will be performed onthecomponents andpiping required by theASME Code Section III to be hydrostatically tested.
Inspection will be performed for the existence ofa report verifying thattheas-built piping meets the requirements for functional capability.
Acceptance Criteria:
The ASME Code Section III design reports existforthe as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III.
Areport exists and concludes thatthe ASME Code Section III requirements are met for non destructive examination of pressure boundary welds.
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 3 of 9 A report exists and concludes that the results ofthe hydrostatictest of the components and piping Identified In Tables 2.3.10-1 and 2.3.10-2as ASME Code Section III conform with the requirements of the ASME Code Section III.
A report exists and concludes that each ofthe as-bullt lines Identified In Table 2.3.10-2 for which functional capability Is required meets the requirements for functional capability.
ITAAC ComDietlon Description This ITAAC requires Inspections, tests, and analyses be performed and documented to ensure the Liquid Radwaste System (WLS) components and piping listed Inthe Combined License (COL) Appendix C, Table 2.3.10-1 (Attachment A) and Table 2.3.10-2 (Attachment B) that are Identified as American Society of Mechanical Engineers (ASME) Code Section III or Functional CapabilityRequired are designed and constructed In accordance with applicable requirements.
2.a and 2.b) The ASME Code Section III deslon reoorts exist for the as-bullt components and ololno Identified In Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III.
Each component listed In Table 2.3.10-1 as ASMECode Section III Is fabricated In accordance withthe VEGP Updated Final Safety Analysis Report (UFSAR) and the ASMECode Section III requirements. The ASME Code Section III certified Design Reports for these components exist and document that the as-bullt components conform to the approved design details. The ASME Section III Design Report for each component Is documented In the component's completed ASME Section III Code Data Report. The Individual component ASME Section III Code Data Reports are documented on the ASME Section III N-5Code Data Report(s) for the applicable piping system (Reference 1).
The as-bullt piping listed In Table 2.3.10-2 Including the components listed InTable 2.3.10-1 as ASMECode Section III, Is subjected to a reconciliation process (Reference 2), which verifies that the as-bullt piping Is analyzed for applicable loads (e.g., stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-bullt systems.
Including Installed components, validates that constructioncompletion. Including field changes and any nonconforming condition dispositions. Isconsistent with and bounded by the approved design. All applicablefabrication. Installation and testing records, as well as, those forthe related QualityAssurance (OA) verification/Inspection activities,whichconfirm adequate construction In compliance with the ASMECode Section III and design provisions, are referenced Inthe N-5 data report and/or Its sub-tier references.
The applicable ASME Section III N-5 Code Data Report(s), which Include the location of the certified Design Reports for allthe components listed In Table 2.3-10-1 (Attachment A) and piping listed In Table 2.3.10-2 (Attachment B) as ASME Code Section III, exist and conclude that these Installed components are designed and constructed (Including their Installationwithin the applicable as-bullt pipingsystem) In accordance with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements as applicable, as described In UFSARSubsection 5.2.1 (Reference 3). The N-5 Code Data Reports for the piping system(s) containing the components listed In the Table 2.3.10-1 and Table 2.3.10-2 are Identified In Attachments A and B, respectively.
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 4 of 9 3.a and 3.bf A report exists and concludes that the ASME Code Section III reouirements are met for non-destructive examination of oressure boundary welds.
Inspections are performed in accordance with ASME Code Section III (1998 Edition, 2000 Addenda) to demonstrate that as-built pressure boundary welds in components identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications).
The applicable non-destructive examinations (including liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the components' pressure boundary welds are documented inthe Non-destructive Examination Report(s), which support completion of the respective ASME Section III N-5 Code Data Report(s) certified by the Authorized Nuclear Inspector, as listed in Attachment A.
Per ASME Code Section III, Subarticle NCA-8300, "Code Symbol Stamps," the N-5 Code Data Report(s) (Reference 1) documents satisfactory completion of the required examination and testing of the item, which includes non-destructive examinations of pressure boundary welds. Satisfactory completion of the non-destructive examination of pressure boundary welds ensures that the pressure boundary welds incomponents identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements.
An inspectionis performedinaccordance with Reference 3 to demonstrate that the as-built pressure boundarywelds in piping identified inTable 2.3.10-2 (Attachment B) as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications). This portion of the ITAAC is complete when the piping identified in Table 2.^10-2, which is encompassed within the respective pipingsystem Code Symbol N-Stamp and the corresponding piping system Code N-5 Data Report Form(s) (Reference 1), is complete. The non-destructive examinations (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing,as required byASME Code Section III) ofthe piping pressure boundary weldsare documented inthe Non-destructive Examination Report(s) within the piping system'ssupporting data package, which support completion ofthe respective Code Stampingand Code N-5 Data Report(s). The completion of stamping the respectivepiping systemalong with the corresponding ASME Code N-5 DataReport Form(s) (certified by the Authorized Nuclear Inspector) ensure that the piping is constructed inaccordance with the design specification(s) andthe ASME CodeSection III andthatthesatisfactoiy completion of the non-destructive examinationsof piping pressure boundaryweldsforthe pipe lines identified in Table 2.3.10-2 meet ASME Code Section III requirements and are documented in the Non destructive Examination Report(s) within the supporting data packages.
4.a and 4.b1 A report exists and concludes that the results of the hvdrostatic test of the comoonents and pipino identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III conform with the reouirements of the ASME Code Section III.
Ahydrostatic test is performed bythe vendor to demonstrate thatthe components identified in Table 2.3.10-1 (Attachment A) as ASME Code Section III retaintheir pressure boundary integrity at theirdesign pressure. The completion ofthe N-5 Data Reports isgovernedby Reference 2.
This portion ofthe ITAAC is completeonce each componentidentified in Table2.3.10-1 has their individual Code Symbol N-Stamp and corresponding Code Data Report (Reference1)
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 5 of 9 completed, and the components are installed intothe respective Code Symbol N-Stamped piping system and documented on the corresponding N-5 Code Data Report(s) (Reference1).
The hydrostatic testing resultsofthe component's pressure boundaryare documented in the Hydrostatic Testing Report(s) within the supportingcomponent's data package, which support completionof the respective Code Stamping and Code Data Report(s).
The completion ofstamping the individual components and the respective piping system along with the corresponding ASME Code Data Reports (certified by the Authorized Nuclear Inspector)ensures that the components are constructed inaccordance with the Design Specifications and the ASME Code Section III and that the satisfactory completion ofthe hydrostatic pressuretesting ofeach component identified in Table 2.3.10-1 as ASME Code Section III are documented inthe HydrostaticTesting Report(s) within the supporting data packages and meets ASME Code Section III requirements.
This ITAAC also verifies that the piping identified in Table 2.3.10-2 (Attachment B)fully meets all applicable ASME Code,Section III requirements and retains its pressure boundaryintegrity at its design pressure.
Ahydrostatic test is performed in accordance with procedure XYZ (as applicable) that complies with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements to demonstrate that the ASME Code Section III piping identified inTable 2.3.10-2 retains its pressure boundary integrity at its design pressure.
Ahydrostatic test verifies there are no leaks at welds or piping, and that the pressure boundaryintegrity is retained at its design pressure. The hydrostatic testing results ofthe pipe lines are documented in the Hydrostatic Testing Report(s). The Hydrostatic Testing Report(s) supports completion ofthe ASME Section III N-5 Code Data Report(s) forthe applicable piping system (i.e.,WLS) (Reference 1).
The applicable ASME Section III N-5 Code Data Report(s) (Reference1) identified in Attachments A and B documents that the results of the hydrostatic testing of the components and piping identified in Table2.3.10-1 and Table2.3.10-2 respectively conform with the requirements of the Code (1998 Edition, 2000 Addenda),Section III.
5.b1 A reoort exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional caoabilitv is reauired meets the reouirements for functional capability.
An inspection is performed ofthe ASME Section III as-built piping design report XXX toverify that the report demonstrates that each ofthe WLS piping linesidentified in ITAAC Table 2.3.10-2 that requires functional capability is designed to withstand combined normal and seismicdesign basis loadswithout a loss of itsfunctional capability. "Functional capability," in this context, refers to the capability ofthe piping to withstand the effects ofearthquakes, without a loss ofsafetyfunction (toconvey fluids from one location to another). Specific functional capability requirements are defined in the VEGP UFSAR Table 3.9-11 (Reference 3).
Piping functional capability is not a specific ASME Code requirement but it isa requirement in the VEGP UFSAR (Reference 3).Assuch, information demonstrating that UFSAR functional capability requirements are met isincluded in theASME Section III As-Built Design Reports for safety class piping prepared in accordance with ASME Section III NCA-3550 under theASME
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 6 of 9 Boiler&Pressure Vessel Code (1998 Edition, 2000 Addenda)Section III requirements. The as-built piping systems are subjected to a reconciliation process (Reference 2), which verifies that the as-builtpiping systems are analyzed forfunctional capability and for compliance with the design specification and ASME Code provisions. Design reconciliation ofthe as-built systems validates that construction completion, includingfield changes and any nonconforming condition dispositions, is consistent with and bounded by the approved design. As required by ASME Code, the As-Built Design Report includes the results of physical inspection of the piping and reconciliation to the design pipe stress report.
Inspections ofthe ASME Code Section III As-Built Piping Design Reports (Reference 4) forthe WLS piping lines identified inTable 2.3.10-2 are complete and conclude that each ofthe as-built WLS piping linesfor which functional capability is required meets the requirements for functional capability. The ASME Section III As-Built Piping Design Reports for each ofthe as-builtWLS piping lines in Table 2.3.10-2 are identified in Attachment B.
References 1 and 4 provide the evidence that the ITAAC Acceptance Criteria requirements are met:.
The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III; A reportexists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds; A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2as ASME Code Section III conform with the requirements of the ASME Code Section III; and A report exists and concludes that each of the as-built lines identified inTable 2.3.10-2 for whichfunctional capabilityis required meets the requirements forfunctional capability.
References 1 and 4 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.3.10.02a Completion Packages (References 5 and 6, respectively).
List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern NuclearOperating Company (SNC) performeda review of all ITAAC findings and associated correctiveactions.
This review, which included now consolidated ITAAC Indexes 432, 433, 434, 435, 436 and 440, found no relevant ITAAC findings associated with this ITAAC.
References favailable for NRC inspection) 1.
WLS ASME N-5 Code Data Report(s)
- 2. APP-GW-GAP-139, 'Westinghouse/WECTEC ASME N-5 Interface Procedure"
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 7 of 9 3.
VEGP 3&4 Updated Final Safety Analysis Report a.
Subsection 5.2.1 Compliance with Codes and Code Cases
- b. Table 3.9 Piping Functional Capability - ASME Class 1, 2, and 3 4.
WLS ASME III As Built Design Repoil(s)
- 5. Completion Package for Unit 3 ITAAC 2.3.10.02a [COL Index Number431]
- 6. Completion Package for Unit 4 ITAAC 2.3.10.02a [COL Index Number 431]
- 7. NEI 08-01, "Industry Guideline forthe ITAAC ClosureProcess Under 10CFR Part 52"
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 8 of 9 Attachment A SYSTEM: Liquid Radwaste System (WLS)
Equipment Name
- Tag No.
- ASME Code Section III*
ASME III as-bullt Design Report N-5 Report WLS Drain from Passive Core Cooling System (PXS) Compartment A (Room 11206) Check Valve WLS-PL-V071B Yes XXX N-5 Code Data Report WLS Drain from PXS Compartment A (Room 11206) Check Valve WLS-PL-V072B Yes XXX N-5 Code Data Report WLS Drain from PXS Compartment B (Room 11207) Check Valve WLS-PL-V071C Yes XXX N-5 Code Data Report WLS Drain from PXS Compartment B (Room 11207) Check Valve WLS-PL-V072C Yes XXX N-5 Code Data Report WLS Drain from Chemical and Volume Control System (CVS)
Compartment (Room 11209) Check Valve WLS-PL-V071A Yes XXX N-5 Code Data Report WLS Drain from CVS Compartment (Room 11209) Check Valve WLS-PL-V072A Yes XXX N-5 Code Data Report "Excerptsfrom COLAppendix C Table 2.3.10-1
U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 9 of 9 Attachment B SYSTEM: Liquid Radwaste System (WLS)
Line Name*
Line Number*
ASME Code Section ill*
Functional Capability Required*
ASME III As-Built Design Report N-5 Report WLS Drain from PXS Compartment A WLS-PL-L062 Yes Yes XXX N-5 Code Data Report WLS Drain from PXS Compartment B WLS-PL-L063 Yes Yes XXX N-5 Code Data Report WLS Drain from CVS Compartment WLS-PL-L061 Yes Yes XXX N-5 Code Data Report
'Excerpts from COL Appendix C, Table 2.3.10-2