ND-18-0979, Unit 4, Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.1.01.04 (Index Number 41)

Unit 4, Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.1.01.04 (Index Number 41)

ML18205A453
Person / Time
Site:	Vogtle
Issue date:	07/24/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.1.01.04, ND-18-0979
Download: ML18205A453 (8)

Text

Michael J. Yox 7825 River Road A Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel 410-474-8587 cell myox @southernco.com JUL 2 4 2018 Docket Nos.: 52-025 52-026 ND-18-0979 10 CFR 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 2.1.01.04 [Index Number 41 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as ofJuly 20, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.1.01.04 [Index Number 4]

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 Companywill, 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 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.

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 2.1.01.04 [Index Number 4]

MJY/PGL/amw

U.S. Nuclear Regulatory Commission ND-18-0979 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (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 Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Ms. A. C. Chamberlain 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 Mr. P. B. Donnelly Ms. N. C. Coovert Oalethorpe Power Corporation Mr. R. B. Brinkman Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-18-0979 Page 3 of 3 Westinqhouse 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 Public Service 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-18-0979 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-18-0979 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.1.01.04 [Index Number 4]

U.S. Nuclear Regulatory Commission ND-18-0979 Enclosure Page 2 of 5 ITAAC Statement Design Commitment

2. The FHS has the refueling machine (RM), the fuel handling machine (FHM), and the new and spent fuel storage racks.

4. The RM and FHM/spent fuel handling tool (SFHT) gripper assemblies are designed to prevent opening while the weight of the fuel assembly is suspended from the grippers.

5. The lift height of the RM mast and FHM hoist(s) is limited such that the minimum required depth of water shielding is maintained.

6. The RM and FHM are designed to maintain their load carrying and structural integrity functions during a safe shutdown earthquake.

7. The new and spent fuel storage racks maintain the effective neutron multiplication factor required by 10 CFR 50.68 limits during normal operation, design basis seismic events, and design basis dropped spent fuel assembly accidents over the spent fuel storage racks.

Insoections/Tests/Analvses Inspection of the system will be performed.

The RM and FHM/SFHT gripper assemblies will be tested by operating the open controls of the gripper while suspending a dummy fuel assembly.

The RM and FHM will be tested by attempting to raise a dummy fuel assembly.

i) Inspection will be performed to verify that the RM and FHM are located on the nuclear island.

ii) Inspection will be performed to verify that the new and spent fuel storage racks are located on the nuclear island.

Acceptance Criteria The FHS has the RM, the FHM, and the new and spent fuel storage racks.

The RM and FHM/SFHT gripper assemblies will not open while suspending a dummy test assembly.

The bottom of the dummy fuel assembly cannot be raised to within 24 ft, 6 in. of the operating deck floor.

i) The RM and FHM are located on the nuclear island.

ii) The new and spent fuel storage racks are located on the nuclear island.

U.S. Nuclear Regulatory Commission ND-18-0979 Enclosure Page 3 of 5 ITAAC Completion Description This ITAAC requires inspections and testing to demonstrate that the Fuel Handling and Refueling System (FHS) has the refueling machine (RM), the fuel handling machine (FHM), and the new and spent fuel storage racks; that the RM and FHM/spent fuel handling tool (SFHT) gripper assemblies are designed to prevent opening while the weight of the fuel assembly is suspended from the grippers; that the lift height of the RM mast and FHM hoist(s) is limited such that the minimum required depth of water shielding is maintained; that the RM and FHM are designed to maintain their load carrying and structural integrity functions during a safe shutdown earthquake; and that the new and spent fuel storage racks maintain the effective neutron multiplication factor required by 10 CFR 50.68 limits during normal operation, design basis seismic events, and design basis dropped spent fuel assembly accidents over the spent fuel storage racks.

2. The FHS has the RM. the FHM. and the new and soent fuel storaoe racks.

A walkdown inspection of the as-built FHS is conducted to confirm that the FHS has the RM, the FHM, and the new and spent fuel storage racks. In accordance with procedure XYZ (Reference 1), a walkdown inspection is performed, which involves visual observations of the RM, the FHM, and the new and spent fuel storage racks. The inspection results are documented inthe Unit 3 and Unit 4 Principal Closure Documents (Reference 2 and 3, respectively) and verify the FHS has the RM, the FHM, and the new and spent fuel storage racks.

References 1 through 3 document the inspection and are available for NRG inspection.

4. The RM and FHM/SFHT aripoer assemblies will not open while susoendino a dummv test assemblv Testing is performed in accordance with preoperational tests for Unit 3 and Unit 4 (References 4 and 5, respectively). A dummy test assembly is lifted by the Fuel Handling Machine using the preoperational test procedure to a sufficient height to be fully suspended. At this height the open controls for the FHM/SFHT grippers are exercised for releasing the test assembly. The grippers do notopen. Thus, the FHM grippers meetthe acceptancecriteria in that theydo not open while suspending a dummy test assembly.

Adummy test assembly is lifted bythe Refueling Machine using the preoperational test procedure to a sufficient height to be fully suspended. At this height the open controls for the RM grippers are exercised for releasing the test assembly. The grippers do not open. Thus, the RM grippers meet the acceptance criteria in that they do not open while suspending a dummy test assembly.

References 4 and 5 document the test results and are available for NRG inspection.

5. The bottom of the dummv fuel assemblv cannot be raised to within 24 ft. 6 in. of the operating deck floor.

Testing is performed in accordance with preoperational tests for Unit 3 and Unit 4 (References 4 and 5, respectively). A dummy fuel assembly is lifted bythe FHM to the upper hard stop using the preoperational test procedure. The distance between the bottom ofthe dummy fuel assembly and the operating deckfloor is measured. The measured value is XX feet and YY

U.S. Nuclear Regulatory Commission ND-18-0979 Enclosure Page 4 of 5 inches for Unit 3 and XX feet and YY inches for Unit 4 which is > 24 ft, 6 inches. This demonstrates the FHM meets the acceptance criteria that the bottom of the dummy fuel assembly cannot be raised to within 24 ft, 6 inches of the operating deck floor.

A dummyfuel assembly is lifted by the Refueling Machineto its highest location intothe mast using the preoperational test procedure. The distance between the bottom of the dummy fuel assembly and the operating deck floor is measured. The measured value is XX feet and YY inches for Unit 3 and XX feet and YY inches for Unit 4 which is > 24 ft, 6 inches. This demonstrates the RM meets the acceptance criteria that the bottom of the dummy fuel assembly cannot be raised to within 24 ft, 6 inches ofthe operating deck floor.

References 4 and 5 document the test results and are available for NRC inspection.

6.h The RM and FHM are located on the nuclear island.

To assure that the RM and the FHM maintain their load carrying and structural integrity functions during a safe shutdown earthquake, these components are designed to be located on the seismic Category I Nuclear Island. In accordance with procedure XYZ (Reference 1), an inspection is conducted of the RM and FHM to confirm the satisfactory installation of these components to ensure they maintain their load carrying andstructural integrity functions during a safe shutdown earthquake. The inspection includes verification ofthe RM and FHM installed locations (Building and Room).

The inspection results are documented in the Unit 3 and Unit 4 Principal Closure Documents (Reference 2 and 3, respectively) which concludes that the RM and FHM are located on the nuclear island and meet the ITAAC acceptance criteria.

References 1 through 3 document the inspection and are available for NRC inspection.

7.ii1 The new and soent fuel storage racks are located on the nuclear island.

To assure that the new and spent fuel storage racks maintain the effective neutron multiplication factor required by 10CFR 50.68 limits during normal operation, design basisseismic events, and design basis dropped spent fuel assembly accidents over the spent fuel storage racks, the new and spent fuel storage racks are designed to be located on the seismic Category I Nuclear Island. In accordance with procedure XYZ (Reference 1), an inspection is conducted of the new and spent fuel storage racks to confirm the satisfactory installation of these components to maintain the effective neutron multiplication factor required by 10 CFR 50.68 limits during normal operation, design basis seismic events, and design basis dropped spent fuel assembly accidents over the spentfuel storage racks. The inspection includes verification of the new and spent fuel storage racks installed locations (Building and Room).

The inspection results are documented in the Unit 3 and Unit 4 Principal Closure Documents (Reference 2 and 3, respectively) which concludes that the new and spent fuel storage racks are located on the Nuclear Island and meet the ITAAC acceptance criteria.

References 1 through 3 document the inspection and are available for NRC inspection.

Together, these inspections, tests, and reports (References 1through 5) provide evidence that the ITAAC Acceptance Criteria requirements are met:

U.S. Nuclear Regulatory Commission ND-18-0979 Enclosure Page 5 of 5

• The FHS has the RM, the FHM, and the new and spent fuel storage racks;

• The RM and FHM/SFHT gripper assemblies will not open while suspending a dummy test assembly;

• The bottom of the dummy fuel assembly cannot be raised to within 24 ft, 6 in. of the operating deck floor;

• The RM and FHM are located on the nuclear island; and

• The new and spent fuel storage racks are located on the nuclear island.

References 1 through 5 are available for NRG inspection as part of the Unit 3 and Unit 4 ITAAC 2.1.01.04 Completion Packages (References 6 and 7, respectively).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of aii findings pertaining to the subject iTAAC and associated corrective actions. This review, which inciudes now-consolidated ITAAC Indexes 2, 5, 6, and 9, found there are no relevant ITAAC findings associated with this ITAAC.

References favailable for NRG inspection)

1. FHS Inspection Procedure XYZ

2. FHS Inspection Report XYZ, Unit 3

3. FHS Inspection Report XYZ, Unit 4

4. 3-FHS-ITPP-522, "Fuel Handling Equipment Mapping, Bundle Lift Height and Gripper Test Procedure"

5. 4-FHS-ITPP-522, "Fuel Handling Equipment Mapping, Bundle Lift Height and Gripper Test Procedure"

6. 2.1.01.04-U3-CP-Rev0, "ITAAC Completion Package"

7. 2.1.01.04-U4-CP-Rev0, "ITAAC Completion Package"

8. NEI 08-01, "Industry Guideline forthe iTAAC Closure Process Under 10 CFR Part 52"