ND-18-0669, Voggle Electric Generating Plant Unit 3 and Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.03.07 (Index Number 616)

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Voggle Electric Generating Plant Unit 3 and Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.03.07 (Index Number 616)
ML18152B686
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 05/31/2018
From: Yox M
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
References
ITAAC 2.6.03.07, ND-18-0669
Download: ML18152B686 (9)


Text

Michael J. Yox 7825 River Road

^ Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel 410-474-8587 cell myox@southernco.com MAY 3 12018 Docket Nos.: 52-025 52-026 ND-18-0669 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 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 2.6.03.07 [Index Number 6161 Ladles and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of May 17, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.6.03.07 [Index Number 616]

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, 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 criteria are 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

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.6.03.07 [Index Number 616]

MJY/PGL/amw

U.S. Nuclear Regulatory Commission ND-18-0669 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 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. 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 Ms. N. C. Coovert Ooiethoroe Power Corporation Mr. R. B. Brinkman

U.S. Nuclear Regulatory Commission ND-18-0669 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Daiton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. OrlanI (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 Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-18-0669 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.6.03.07 [Index Number 616]

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 2 of 6 ITAAC Statement Design Commitment

7. The IDS do battery fuses and battery charger circuit breakers, and dc distribution panels, MCCs, and their circuit breakers and fuses, are sized to supply their load requirements.
8. Circuit breakers and fuses in IDS battery, battery charger, dc distribution panel, and MCC circuits are rated to interrupt fault currents.
9. The IDS batteries, battery chargers, dc distribution panels, and MCCs are rated to withstand fault currents for the time required to clear the fault from its power source. .
10. The IDS electrical distribution system cables are rated to withstand fault currents for the time required to clear the fault from its power source.

Insoections/Tests/Analvses Analyses for the as-built IDS dc electrical distribution system to determine the capacities ofthe batteryfuses and battery charger circuit breakers, and dc distribution panels, MCCs, and their circuit breakers and fuses, will be performed.

Analyses for the as-built IDS dc electrical distribution system to determine fault currents will be performed.

Analyses for the as-built IDS dc electrical distribution system to determine fault currents will be performed.

Analyses for the as-built IDS dc electrical distribution system to determine fault currents will be performed.

Acceptance Criteria Analyses for the as-built IDS dc electrical distribution system exist and conclude that the capacitiesof as-built IDS battery fuses and battery charger circuit breakers, and dc distribution panels, MCCs, and their circuit breakers and fuses, as determined bytheirnameplate ratings, exceed their analyzed load requirements.

Analyses for the as-built IDS dc electrical distribution system exist and conclude that the analyzed fault currents do not exceed the interrupt capacity of circuit breakers and fuses in the battery, batterycharger, dc distribution panel, and MCC circuits, as determined by their nameplate ratings.

Analyses for the as-built IDS dc electrical distribution system exist and conclude that the fault current capacities ofas-built IDS batteries, battery chargers, dc distribution panels, and MCCs, as determined by manufacturer's ratings, exceed their analyzed fault currents for the time required to clear the fault from its power source as determined bythe circuit interrupting device coordination analyses.

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 3 of 6 Analyses for the as-built IDS do electrical distribution system exist and conclude that the IDS dc electrical distribution system cables will withstand the analyzed fault currents, as determined by manufacturer's ratings, for the time required to clear the fault from its power source as determined by the circuit interrupting device coordination analyses.

ITAAC Completion Description Analyses for the as-built Class 1E dc and Uninterruptible Power Supply System (IDS) dc electrical distribution system are performed to verify the system is sized to supply the load requirements, the analyzed fault currents do not exceed the interrupting capacity of the protective devices, and the system equipment and cables are rated to withstand fault currents.

Analvses for the as-built IDS dc electrical distribution svstem exist and conclude that the capacities of as-built IDS batterv fuses and batterv charger circuit breakers, and dc distribution panels. MCCs. and their circuit breakers and fuses, as determined bv their nameplate ratings, exceed their analvzed load requirements.

Analyses for the as-built IDS dc electrical distribution system are performed to verify that the capacities of as-built IDS battery fuses and battery charger circuit breakers, and switchboards, dc distribution panels, motor control centers (MCCs), and their circuit breakers and fuses ("the IDS equipment"), as determined by their nameplate ratings, exceed their analyzed load requirements. Fault current and circuit interrupting device coordination analysis requirements for the IDS dc electrical distribution system are performed in accordance with the criteria stated in Institute of Electrical and Electronics Engineers (IEEE) Standard 946, (Reference 1), IEEE Standard 741 (Reference 2), and IEEE Standard 242 (Reference 3).

The load requirements of the IDS equipment are determined by reviewing the as-built IDS dc electrical distribution system configuration and the associated IDS dc electrical distribution system component load rating information, to determine the analyzed load requirements for the IDS dc electrical distribution system.

The nameplate current capacity ratings of the IDS equipment are inspected in accordance with the Construction Quality Verification Program (Reference 4). The nameplate ratings of the IDS equipment, as documented in inspection records, are compared to the load requirements to verify that the capacities of the IDS equipment exceed the analyzed load requirements.

The results of these analyses and comparisons are documented in the Unit 3 and Unit 4 Principal Closure Documents (References 5 and 6, respectively) supporting the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages (References 7 and 8, respectively) and conclude that the capacities of as-built IDS battery fuses and battery charger circuit breakers, and switchboards, dc distribution panels, MCCs, and their circuit breakers and fuses, as determined by their nameplate ratings, exceed their analyzed load requirements.

Principal Closure Documents XXX and YYY exist and are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages.

Analvses for the as-built IDS dc electrical distribution svstem exist and conclude that the analvzed fault currents do not exceed the interrupt caoacitv of circuit breakers and fuses in the batterv. batterv charger, dc distribution panel, and MCC circuits, as determined bv their nameolate ratings.

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 4 of 6 Analyses for the as-built IDS do electrical distribution system are performed to verify that the analyzed fault currents do not exceed the interrupting capacity of circuit breakers and fuses in the battery, battery charger, switchboards, do distribution panel, and MOO ("the IDS equipment")

circuits, as determined by their nameplate ratings.

The minimum required interrupting capacity rating of circuit breakers and fuses in the IDS equipment circuits are determined by calculation and summarized in the IDS Short Circuit Analysis (Reference 9) and the IDS Protection Coordination Study (Reference 10). These calculations utilize the worst case short circuit contribution from each battery, battery charger, and motor load of the IDS, which determines the minimum required protective device interrupting capacity in accordance with the criteria stated in the IEEE Standard 946, Sections 7.1 and 7.9 (Reference 1), IEEE Standard 741 (Reference 2), and IEEE Standard 242 (Reference 3).

The nameplate capacity ratings of the as-built IDS circuit breakers and fuses in the IDS equipment circuits are inspected in accordance with the Construction Quality Verification Program (Reference 4). The nameplate rating for each of these circuit breakers and fuses is evaluated to assure the device interrupting capacity exceeds the minimum required interrupting capacity rating.

The combination of the as-built IDS inspection results and the analyses documented in the IDS Short Circuit Analysis and the IDS Protection Coordination Study conclude that the analyzed fault currents do not exceed the interrupting capacity of circuit breakers and fuses in,the battery, battery charger, switchboards, do distribution panel, and MCC circuits, as determined by their nameplate ratings. The as-built IDS inspection results, the IDS Short Circuit Analysis and the IDS Protection Coordination Study analysis results are documented in the Unit 3 and Unit 4 Principal Closure Documents XXX and YYY (References 5 and 6, respectively) supporting the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages (References 7 and 8, respectively)

Principal Closure Documents XXX and YYY exist and are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages.

Analvses for the as-built IDS dc electrical distribution svstem exist and conclude that the fault current capacities of as-built IDS batteries, batterv charoers. dc distribution panels, and MCCs.

as determined bv manufacturer's ratings, exceed their analvzed fault currents for the time required to clear the fault from its power source as determined bv the circuit interrupting device coordination analvses.

Analyses for the as-built IDS dc electrical distribution system are performed to verify that the fault current capacities of as-built IDS batteries, battery chargers, switchboards, dc distribution panels, and MCCs ("the IDS equipment"), as determined by manufacturer's ratings, exceed their analyzed fault currents for the time required to clear the fault from its power source as determined by the circuit interrupting device coordination analyses. Fault current and circuit interrupting device coordination analysis requirements for the IDS dc electrical distribution system are performed in accordance with the criteria stated in IEEE Standard 946, (Reference 1), IEEE Standard 741 (Reference 2), and IEEE Standard 242 (Reference 3).

The worst case short circuit (fault) currents of the IDS equipment are determined by the IDS Short CircuitAnalysis (Reference 9). The results of this analysis are used in combination with

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 5 of 6 the circuit interrupting device IDS Protection Coordination Study (Reference 10) to determine the worst case analyzed fault currents.

The manufacturer's nameplate fault current ratings of the IDS equipment are inspected in accordance with the Construction Quality Verification Program (Reference 4). The as-built fault current rating for each piece of the IDS equipment, as documented in inspection records, are then compared to the fault current information determined in References 9 and 10 to verify that the fault current capacities of the IDS equipment exceed the analyzed fault currents.

The results of these analyses and comparisons are documented in the Unit 3 and Unit 4 Principal Closure DocumentsXXX and YYY (References 5 and 6, respectively) supporting the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages (References 7 and 8, respectively) and conclude that the fault current capacities of as-built IDS batteries, battery chargers, switchboards, do distribution panels, and MCCs, as determined by manufacturer's ratings, exceed their analyzed fault currents for the time required to clear the fault from its power source as determined by the circuit interrupting device coordination analyses.

Principal Closure Documents XXX and YYY exist and are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages.

Analvses for the as-built IDS dc electrical distribution svstem exist and conclude that the IDS dc electrical distribution svstem cables will withstand the analvzed fault currents, as determined bv manufacturer's ratines, for the time required to clear the fault from its power source as determined bv the circuit interrupting device coordination analvses.

Analyses for the as-built IDS dc electrical distribution system are performed to verify that the IDS dc electrical distribution system cables will withstand the analyzed fault currents, as determined by manufacturer's ratings, for the time required to clear the fault from its power source as determined by the circuit interrupting device coordination analyses. Fault currentand circuit interrupting device coordination analysis requirements for the IDS dc electrical distribution system are performed in accordance with the criteria stated in IEEE Standard 946, (Reference 1), IEEE Standard741 (Reference 2), and IEEE Standard 242 (Reference 3).

The worst case short circuit (fault) currents of the as-built IDS dc electrical distribution system cables are determined by calculation and are summarized inthe IDS Short Circuit Analysis (Reference 9). The results of this analysis are used in combination with the circuit interrupting device IDS Protection Coordination Study (Reference 10) to determine the worst case analyzed fault currents.

The as-built IDS dc electrical distribution system cables are inspected in accordance with the Construction Quality Verification Program (Reference 4). Each cable is inspected byQuality Control when it is removed from the specified cable reel. The manufacturer's unique cable reel number is recorded during the inspection. The cable reel number provides traceability to the manufacturer's rating of the cable. Each cable termination is inspected by Quality Control following installation. The inspection records provide traceability to the manufacturer's rating for each cable terminal.

The manufacturer's rating of the cable and cable terminals, as traceable through inspection records, are compared to the fault current information determined in References 7 and 8 to

U.S. Nuclear Regulatory Commission ND-18-0669 Enclosure Page 6 of 6 verify that the fault current capacities of as-built IDS dc electricaldistribution system cables, as determined by manufacturer's ratings, exceed their analyzed fault currents.

The results of these analyses and comparisons are documented in the Unit 3 and Unit 4 Principal Closure DocumentsXXX and YYY (References 5 and 6) supporting the Unit 3 and Unit 4 ITAAC 2.6.03.07 Completion Packages (References 7 and 8), and conclude that the fault current capacities of as-built IDS dc electrical distribution system cables, as determined by manufacturer's ratings, exceed their analyzed fault currents for the time required to clear the fault from its power source as determined by the circuit interrupting device coordination analyses.

Principal Closure Document XXX exists and is available for NRC inspection as part of the ITAAC 2.6.03.07 Completion Package.

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern Nuclear Operating Company (SNC) performed a review ofall findings pertaining to the subject ITAAC and associated corrective actions. This finding review, which included the now-consolidated ITAAC Indexes617, 618, and 619, found fhe following Notice of Nonconformance (NGN) associated with this ITAAC.

1) 99901467/2016-201-01 (open)

References favaiiabie for NRC inspection)

1. IEEE Standard 946, "IEEE Recommended Practicefor the Design of DC Auxiliary Power Systems for Generating Stations," 1992
2. IEEE Standard 741, "IEEE Standard Criteria for the Protection of Class 1E Power Systems and Equipment in Nuclear Power Generating Stations," 1997
3. IEEE Standard 242, "IEEE Recommended Practice for Protection and Coordination of Industrial and Commercial Power Systems," 1986
4. 26139-000-4MP-T81C-N7101, "Construction Quality Verification Program"
5. Unit 3 Principal Closure Document XXX
6. Unit 4 Principal Closure Document YYY
7. 2.6.03.07-U3-CP-Rev 0, IT/VAC Completion Package
8. 2.6.03.07-U4-CP-Rev 0, ITAAC Completion Package
9. IDS Short Circuit Analysis, Rev. X
10. IDS Protection Coordination Study, Rev. X