ML18089A349
| ML18089A349 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/29/2018 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| ITAAC 2.7.01.02a, ND-18-348 | |
| Download: ML18089A349 (11) | |
Text
Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 706-848-6459 tei Vogtie 3 & 4 410-474-8587 ceii myox@southernco.com MAR 2 9 2018 Docket Nos.: 52-025 52-026 ND-18-0348 10CFR 52.99(c)(3)
U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtie Electric Generating Plant Unit 3 and Unit 4 Notice of Uncomoleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.7.01.02a [Index Number 6781 Ladies and Gentlemen:
Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of March 19, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.7.01.02a [Index Number 678]
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 Guideline for 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 ITAAC for which required inspections, tests, oranalyses 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 criteria are met prior to 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.
7^1 Michael J. Yox.
Regulatory Affairs t)irector Vogtie 3 &4
Enclosure:
Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Planfor Uncompleted ITAAC 2.7.01.02a [Index Number 678]
MJY/LBP/amw
U.S. Nuclear Regulatory Commission ND-18-0348 Page 2 of 3 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. McKinney Mr. M. J. Yox Mr. D. L. Fulton Mr. J. B. Klecha Mr. G. Chick Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:
Nuclear Reouiatorv 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. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Ms. L. A. Kent Mr. P. B. Donnelly Ooiethorpe Power Corporation Mr. R. B. Brinkman Municioai Eiectric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson
U.S. Nuclear Regulatory Commission ND-18-0348 Page 3 of 3 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. J. Monahan Mr. J. L. Coward Ms. N. E. Deangelis Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., CDS Associates, inc.
Mr. 8. Roetger, Georgia PublicService Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-18-0348 Enclosure Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.7.01.02a [Index Number 678]
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 2 of 8 ITAAC Statement Design Commitment:
2.a) The components identified in Table 2.7.1-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.
2.b) The piping identified in Table 2.7.1-2 as ASME Code Section Hi is designed and constructed in accordance with ASME Code Section ill requirements.
3.a) Pressure boundary welds in components identified in Tabie 2.7.1-1 as ASME Code Section III meet ASME Code Section III requirements.
3.b) Pressure boundary welds in piping identified in Table 2.7.1-2 as ASME Code Section III meet ASME Code Section III requirements.
4.a)The components identified in Table 2.7.1-1 as ASME Code Section Hi retain their pressure boundary integrity at their design pressure.
4.b) The piping identified in Tabie 2.7.1-2 as ASME Code Section HI retains its pressure boundary integrity at its design pressure.
Inspections. Tests. Analyses:
Inspection will be conducted of the as-built components and piping as documented in the ASME design reports.
Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section HI.
Apressure test will be performed on the components and piping required by the ASME Code Section HI to be pressure tested.
Acceptance Criteria:
The ASME Code Section HI design reports exist for the as-built components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Hi.
Areport exists and concludes that the ASME Code Section HI requirements are met for nondestructive examination of pressure boundary welds.
Areport exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section HI conform with the requirements of the ASME Code Section HI.
ITAAC Completion Description This iTAAC requires inspections, tests, and analyses be performed anddocumented to ensure the Nuclear Island Nonradioactive Ventilation System (VBS) components and piping listed in the Combined License (COL) Appendix C, Tabie 2.7.1-1 (Attachment A) and Table 2.7.1-2
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 3 of 8 (Attachment B) that are identified as American Society of Mechanical Engineers (ASME) Code Section III, are designed and constructed in accordance with applicable requirements.
2.a and 2.bf The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section III.
Each component listed in Table 2.7.1-1 as ASME Code Section III is fabricated in accordance with the VEGP Updated Final Safety Analysis Report (UFSAR) and the ASME Code Section III requirements. The ASME Code Section III certified Design Reports for these components exist and document that the as-built components conform to the approved design details. The ASME Section III Design Report for each component is documented inthe 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-5 Code Data Report(s) for the applicable piping system (Reference 1).
The as-built piping listed in Table 2.7.1-2 including the components listed in Table 2.7.1-1 as ASME Code Section III, are subjected to a reconciliation process (Reference 2), which verifies that the as-built piping are analyzed for applicable loads (e.g. stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-built systems, including installed components, validates that construction completion, including field changes and any nonconforming condition dispositions, isconsistent with and bounded by the approved design. Ail applicable fabrication, installation and testing records, as well as, those for the related Quality Assurance (OA) verification/inspection activities, which confirrn adequate construction in compliance witfi the ASME Code Section III and design provisions, are referenced in the 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 all the components listed in Table 2.7.1-1 (Attachment A) and piping listed in Table 2.7.1-2 (Attachment B) as ASME Code Section III, exist andconclude thatthese installed components are designed and constructed (including their installation within the applicable as-built piping system) in accordance with the ASME Code (1998 Edition, 2000 Addenda and 1989 Edition, 1989 Addenda),Section III requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference 3). The N-5 Code Data Reports for the piping system(s) containing the components listed in the Table 2.7.1-1 and Table 2.7.1-2 are identified in Attachments A and B, respectively.
3.a and 3.b1 A report exists and concludes that the ASME Code Section III reouirements are met for nondestructive examination of pressure boundarv 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 2.7.1-1 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 componerits' pressure boundary welds are documented in the 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 AttachmentA.
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 4 of 8 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 in components identified in Table 2.7.1-1 as ASME Code Section III meet ASME Code Section III requirements.
An inspection is performed in accordance with Reference2 to demonstrate that the as-built pressure boundary welds in piping identified in Table 2.7.1-2 (Attachment B) as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications). This portion ofthe ITAAC is complete when the piping identified in Table2.7.1-2, which is encompassed within the respective piping system 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 by ASME Code Section III) of the piping pressure boundary welds are documented in the Non-destructive Examination Report(s) within the piping system's supporting data package, which support completion of the respective Code Stamping and Code N-5 Data Report(s). The completion of stamping the respective piping system along with the corresponding ASME Code N-5 Data Report Form(s) (certified by the Authorized Nuclear Inspector) ensure thatthe piping is constructed in accordance with the design specification(s) and the ASME Code Section III and that the satisfactory completion of the non-destructive examinations of piping pressure boundary welds for the pipe lines identified in Table 2.7.1-2 meet ASME Code Section III requirements and are documented inthe Non-destructive Examination Report(s) within the supporting data packages.
4.a and 4.b) A reoort exists and concludes that the results of the pressure test of the components and pioino identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.
Apressure test is performed by the vendor to demonstrate that the components identified in Table 2.7.1-1 (Attachment A) as ASME Code Section III retain their pressure boundary integrity at their design pressure. The completion of the N-5 Data Reports is governed by Reference 2.
This portion of the ITAAC is complete once each component identified in Table 2.7.1-1 has their individual Code Symbol N-Stamp and corresponding Code Data Report (Reference 1) completed, and the components are installed into the respective Code Symbol N-Stamped piping system and documented on the corresponding N-5 Code Data Report(s) (Reference 1).
The pressure testing results of the component's pressure boundary are documented in the Pressure (i.e. hydrostatic) Testing Report(s) within the supporting component's data package, which support completion of the respective Code Stamping and Code Data Reporl(s).
The completion of stamping 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 in accordance with the Design Specifications and the ASME Code Section III and that the satisfactory completion of the pressure testing of each component identified in Table 2.7.1-1 as ASME Code Section III are documented in the Pressure(i.e. hydrostatic) Testing Report(s) within the supporting data packagesand meets ASME CodeSection III requirements.
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 5 of 8 This ITAAC also verifies that the piping identified in Table 2.7.1-2 (Attachment B) fully meets all applicable ASME Code,Section III requirements and retains its pressure boundary integrity at its design pressure.
A pressure 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 in Table 2.7.1-2 retains its pressure boundary integrity at its design pressure.
A pressure test verifies that there are no leaks at welds or piping, and that the pressure boundary integrity is retained at its design pressure. The pressure testing results of the pipe lines are documented in the Pressure Testing Report(s). The Pressure Testing Report(s) supports completion of the ASME Section III N-5 Code Data Report(s) for the applicable piping system (i.e., VBS) (Reference 1).
The applicable ASME Section III N-5 Code Data Report(s) (Reference 1) identified in Attachments A and B documents that the results of the pressure testing of the components and piping identified in Table 2.7.1-1 and Table 2.7.1-2 respectively conform with the requirements of the Code (1998 Edition, 2000 Addenda),Section III.
Reference 1 provides 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 2.7.1-1 and 2.7.1-2 as ASME Code Section III;
- A report exists and concludes that the ASME Code Section III requirements are metfor nondestructive examination of pressure boundary welds; and
- A report exists and concludes that the results ofthe pressuretest of the components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME CodeSection III conform with the requirements of the ASME Code Section III.
Reference 1 is available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.7.01.02a Completion Packages (References 4 and 5, respectively).
List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern Nuclear Operating Company (SNC) performed a review of all ITAAC findings and associatedcorrective actions.
This review, which included now consolidated ITAAC Indexes 679, 680, 681, 682 and 683, found no relevant ITAAC findings associated with this ITAAC:
References favailabie for NRC inspection)
- 2. APP-GW-GAP-139, "Westinghouse/WECTEC ASME N-5 Interface Procedure"
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 6 of 8
- 3. VEGP 3&4 Updated Final Safety Analysis Report, Subsection 5.2.1, Compliance with Codes and Code Cases
- 4. Completion Package for Unit 3 ITAAC 2.7.01.02a [COL Index Number678]
- 5. Completion Package for Unit 4 ITAAC 2.7.01.02a [COL Index Number 678]
- 6. NEI 08-01, "Industry Guideline forthe ITAAC Closure Process Under 10 CFR Part 52"
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 7 of 8 Attachment A SYSTEM: Nuclear Island Nonradioactive Ventilation System (VBS)
ASME Code Equipment Name
- Tag No.
- N-5 Report Section Hi*
VBS-PL-V186 Yes VBS N-5 Code Data Report MCR Supply Air Isolation Valve VBS-PL-V187 Yes VBS N-5 Code Data Report MCR Supply Air Isolation Valve VBS-PL-V188 Yes VBS N-5 Code Data Report MCR Return Air Isolation Valve VBS-PL-V189 Yes VBS N-5 Code Data Report MCR Return Air Isolation Valve VBS-PL-V190 Yes VBS N-5 Code Data Report MCR Exhaust Air Isolation Valve VBS-PL-V191 Yes VBS N-5 Code Data Report MCR Exhaust Air Isolation Valve PWS MCR Isolation Valve PWS-PL-V418 Yes VBS N-5 Code Data Report PWS MCR Isolation Valve PWS-PL-V420 Yes VBS N-5 Code Data Report PWS MCR Vacuum Relief PWS-PL-V498 Yes VBS N-5 Code Data Report SDS-PL-V001 Yes VBS N-5 Code Data Report MCR SDS (Vent)
Isolation Valve SDS-PL-V002 Yes VBS N-5 Code Data Report MCR SDS (Vent)
Isolation Valve MCR WWS Isolation WWS-PL-V506 Yes VBS N-5 Code Data Report Valve "Excerpts from COL Appendix C Table 2.7.1-1
U.S. Nuclear Regulatory Commission ND-18-0348 Enclosure Page 8 of 8 Attachment B SYSTEM: Nuclear Island Nonradioactive Ventilation System (VBS)
ASME Code Line Name* Line Number*
Section III* N-5 Report Main Control Room VBS N-5 Code Data VBS-L311 Yes Supply Report Main Control Room VBS N-5 Code Data VBS-L312 Yes Exhaust Report Main Control Room VBS N-5 Code Data VBS-L313 Yes Toilet Exhaust Report Main Control Room VBS N-5 Code Data SDS-PL-L016 Yes Sanitary Vent Line Report Main Control Room VBS N-5 Code Data SDS-PL-L179 Yes Sanitary Drain Line Report VBS N-5 Code Data Main Control Room SDS-PL-L182 Yes Report Sanitary Drain Line Main Control Room VBS N-5 Code Data PWS-PL-L319'^ Yes Water Line Report Main Control Room VBS N-5 Code Data Water Line PWS-PL-L320'^ Yes Report VBS N-5 Code Data Main Control Room WWS-PL-L808 Yes Report Waste Water Line Main Control Room VBS N-5 Code Data WWS-PL-L851 Yes Water Line Report
- Excerpts from COL Appendix C, Table 2.7.1-2
+ For girth fillet welds between piping and socket welded fittings, valves and flanges, refer to VEGP UFSAR Section 5.2.1.1 (Reference 3).