ND-18-1103, Vogtie, Units 3 and 4, Resubmittal Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.3.02.11a.i (Index Number 309)

Vogtie, Units 3 and 4, Resubmittal Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.3.02.11a.i (Index Number 309)

ML18235A273
Person / Time
Site:	Vogtle
Issue date:	08/20/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-18-1103
Download: ML18235A273 (8)

Text

Michael J. Yox 7825 River Road hk. Southern Nuclear Regulatory Affairs Director Vogtie 3 & 4 Waynesboro, GA 30830 706-848-8459 tei 410-474-8587 ceil myox @southernco.com AUG 2 0 2018 Docket Nos.: 52-025 52-026 ND-18-1103 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 Resubmittal Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.3.02.11a.i [Index Number 3091 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of August 14, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.02.1 la.i [Index Number 309] 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.

Southern Nuclear Operating Company (SNC) previously submitted Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load for Item 2.3.02.11 a.i [Index Number 309] ND-18-0818

[ML18171A124] dated June 18, 2018. This resubmittal supersedes ND-18-0818 in its entirety.

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 Vogtie 3 &4

Enclosure:

Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.02.1 la.i [Index Number 309]

MJY/SBB/amw

U.S. Nuclear Regulatory Commission ND-18-1103 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. D. L. McKinney (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. J. B. Klecha Mr. G. Chick Mr. M. J. Vox Mr. A. 8. Parton Ms. A. L. Pugh Mr. T. G. Petrak Mr. W. A. Sparkman Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. C. T. Defnall Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reauiatorv Commission Mr. W. Jones (w/o enclosures)

Mr. F. D. Brown Ms. J. M. Heisserer Ms. A. E. Rivera-Varona Mr. M. E. Ernstes Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Oalethorpe Power Corporation Mr. R. B. Brinkman Municipal Electric Authorltv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-18-1103 Page 3 of 3 Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. C. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward 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 Pubiic Service 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-18-1103 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-18-1103 Enclosure Vogtle Electric Generating Riant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.02.1 la.i [Index Number 309]

U.S. Nuclear Regulatory Commission ND-18-1103 Enclosure Page 2 of 5 ITAAC Statement Design Commitment 11 .a) The motor-operated and check valves identified in Table 2.3.2-1 perform an active safety-related function to change position as indicated in the table.

Insoections. Tests. Analvses i) Tests or type tests of motor-operated valves will be performed that demonstrate the capability of the valve to operate under its design conditions.

ii) Inspection will be performed for the existence of a report verifying that the as-built motor-operated valves are bounded by the tested conditions.

Acceotance Criteria i) Atest report exists and concludes that each motor-operated valve changes position as indicated in Table 2.3.2-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded bythe tests or type tests.

ITAAC Completion Description Multiple Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) are performed to demonstrate that the Chemical and Volume Control System (CVS) motor-operated valves identified in the Combined License (COL) Appendix C, Table 2.3.2-1 perform an active safety-relatedfunction to change position as indicated in the table.

\) A test reoort exists and concludes that each motor-operated valve chances position as indicated in Table 2.3.2-1 under design conditions.

This portion of the subject ITAAC requires tests or type tests of motor-operated valves to be performed to demonstrate the capability of the valve to operate under its design conditions.

The motor-operated valves identified in COL Appendix C, Table 2.3.2-1 are qualified in accordance with the provisions of American Societyof Mechanical Engineers (ASME)

QME-1-2007, "Qualification of Active Mechanical Equipment Used in Nuclear Power Plants" (Reference 1).

Functional qualification is performed under the design conditions identified inthe design specification for the valves (Reference 2) to demonstrate that each motor-operated valve is qualified to perform its designated function when used in its intended service. In accordance with ASME QME-1-2007, qualification is substantiated by demonstrating the relationship between the service requirements and the type testing and analysisthat was conducted as part of this qualification program.

Type testing is performed, including natural frequency determination, side load static deflection testing, final static seat and stem leakage testing, steam testing, and water testing, for the

U.S. Nuclear Regulatory Commission ND-18-1103 Enclosure Page 3 of 5 ranges ofthe pressure, temperature and flow for each valve and the maximum seat-sealing differential pressure. In accordance with ASME QME-1-2007, the functional qualification process for these motor-operated valve assemblies also included valve and actuator internal inspections and measurement, orientation requirements, seat and stem leakage limitations, diagnostic data collection and analysis methods, static and dynamic flow diagnostic testing, and pressure locking and thermal binding evaluations. The qualification also followed the provisions of ASME QME-1 -2007 for the extrapolation of functional qualification to another valve assembly, and demonstration of functional capability of production valve assemblies.

The results of the qualification are documented inthe Equipment Qualification (EG) Reports (Reference 3) which are identified in Attachment Afor each applicable valve. These reports summarize the test methodologyand ASME QME-1-2007 functional qualification that demonstrate that each motor-operated valve changes position as indicated in VEGP Unit 3 and Unit 4 CQL Appendix C Table 2.3.2-1 under design conditions.

W) A report exists and concludes that the as-built motor-operated valves are bounded bv the tests or tvoe tests.

This portion of thesubject ITAAC requires that an inspection is performed for the existence of a report verifying that the as-built motor-operated valves are bounded bytests or type tests.

The motor-operated valves in VEGP Unit 3 and Unit 4 CQL Appendix 0 Table 2.3.2-1 are verified by tests in accordance with section i) above, to demonstrate the capability of the valves to operate under their design conditions. The EQ Reports in Attachment Aidentify the equipment mounting employed for the testing and the specific conditions tested.

In accordance with the EQ Walkdown ITAAC Guideline (Reference 4), an inspection is conducted of the CVS to confirm the satisfactory installation of the motor-operated valves. The inspection includes verification of equipment make/model/serial number, verification of equipment mounting and location, and verification thatthe mechanical and electrical connections are bounded by the tested conditions.

The documentation of installed configuration ofthe motor-operated valves includes photographs and/orsketches of equipment mounting and connections. The verification of installed component configuration isdocumented in the As-Built EQ Reconciliation Report(s) (EQRR)

(Reference 5).

Attachment A identifies the EQRR which verify that the installed configuration of the motor-operated valves identified in VEGP Unit 3 and Unit 4 COL Appendix 0 Table 2.3.2-1 are bounded by the tests or type tests.

Together, these EQ Reports and EQRR (References 3 and 5), provide evidence that the ITAAC Acceptance Criteria requirements are met:

• Atest report exists and concludes that each motor-operated valve changes position as indicated in Table 2.3.2-1 under design conditions; and

• Areport exists and concludes thatthe as-built motor-operated valves are bounded by the tests or type tests.

U.S. Nuclear Regulatory Commission ND-18-1103 Enclosure Page 4 of 5 References 3 and 5 are available for NRG inspection as part of tfie Unit 3 and Unit 4 ITAAC 2.3.02.11a.i 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 all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This finding review, which includes now-consolidated ITAAC Index310, found the following relevant ITAAC findings associated with this ITAAC:

• Notice of Nonconformance 99900905/2012-201-01 (closed)

• Notice of Nonconformance 99900905/2012-201-04 (closed)

References favailable for NRG inspection)

1. American Society of Mechanical Engineers (ASME) QME-1 -2007, "Qualification ofActive Mechanical Equipment Used in Nuclear Power Plants"

2. APP-PV01 -ZO-001 Revision X, "3" and Larger Motor Operated Gate and Globe Valves, ASME Boiler and Pressure Vessel Code Section III, Class 1, 2, and 3"

3. Equipment Qualification (EQ) Reports as identified in Attachment A

4. ND-XX-XX-001, EQ Walkdown ITAAC Guideline

5. As-Built Equipment Qualification Reconciliation Reports (EQRR) as identified in Attachment A for Units 3 and 4

6. 2.3.02.11a.i-U3-CP- RevO, IT/\AC Completion Package

7. 2.3.02.11a.i-U4-CP- RevO, ITAAC Completion Package

8. NEI 08-01, "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"

U.S. Nuclear Regulatory Commission ND-18-1103 Enclosure Page 5 of 5 Attachment A System: Chemical and Volume Control System (CVS)

Active EQ Reports As-Built EQRR Equipment Name

• Tag No.

• Function * (Reference 3) (Reference 5)*

APP-PV01-VBR-RCS Purification Motor- CVS-PL- Transfer 011 / 2.3.02.11a.i-U3-operated Isolation Valve V001 Closed APP-PV01-VBR- EQRR-PCDXXX 012 APP-PV01-VBR-RCS Purification Motor- CVS-PL- Transfer 011 / 2.3.02.11a.i-U3-operated Isolation Valve V002 Closed APP-PV01-VBR- EQRR-PCDXXX 012 APP-PV01-VBR-RCS Purification Motor- CVS-PL- Transfer 013/ 2.3.02.11a.i-U3-operated Isolation Valve V003 Closed APP-PV01-VBR- EQRR-PCDXXX 014 APP-PV01-VBR-CVS Makeup Line CVS-PL- Transfer 011 / 2.3.02.11a.i-U3-Containment Isolation Motor-V090 Closed APP-PV01-VBR- EQRR-PCDXXX operated Valve 012 APP-PV01-VBR-CVS Makeup Line Transfer 011 / 2.3.02.11a.i-U3-CVS-PL-Containment Isolation Motor- EQRR-PCDXXX V091 Closed APP-PV01-VBR-operated Valve 012 Notes:

Excerpt from COL Appendix C Table 2.3.2-1

• The Unit 4 As-Built EQRR are numbered "2.3.02.11a.i-U4-EQRR-PCDXXX"