ND-19-0039, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.1.02.11b.i (Index Number 481)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.1.02.11b.i (Index Number 481)

ML19024A334
Person / Time
Site:	Vogtle
Issue date:	01/23/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0039
Download: ML19024A334 (7)

Text

Michael J. Yox 7825 River Road

,~ Southern Nuclear Regulatory Affairs Director Waynesboro . GA 30830 Vogtle 3 & 4 706-848-6459 te l 410-474-8587 cell JAN 2 3 2019 myox@southernco.com Docket Nos. : 52-025 52-026 ND-19-0039 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-days Prior to Initial Fuel Load Item 2.1.02.11 b.i [Index Number 481 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of January 21 , 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspection , Test, Analysis , and Acceptance Criteria (ITAAC) Item 2.1.02.11b.i

[Index Number 481 has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.1.02.11 b.i [Index Number 481 . 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 NEl-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 lTAAC 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 ,

Regulatory Affairs . irector Vogtle 3&4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.1.02.11 b.i [Index Number 48)

MJY/JBN/sfr

U.S. Nuclear Regulatory Commission ND-19-0039 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. Yox Mr. A. S. Parton Ms. K. A Roberts 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. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Ms. J. M. Heisserer Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0039 Page 3 of 3 Dalton Utilities Mr. T. Bundros Westinghouse 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., GOS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-0039 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-19-0039 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.1.02.11 b.i [Index Number 48]

U.S. Nuclear Regulatory Commission ND-19-0039 Enclosure Page 2 of 4 ITAAC Statement Design Commitment 11.b) The valves identified in Table 2.1.2-1 as having PMS control perform an active safety function after receiving a signal from the PMS.

lnspections/Tests/Analyses i) Testing will be performed on the squib valves identified in Table 2.1.2-1 using real or simulated signals into the PMS without stroking the valve.

Acceptance Criteria i) The squib valves receive a signal at the valve electrical leads that is capable of actuating the squib valve.

ITAAC Completion Description Multiple ITAAC are performed to verify that the valves identified in Combined License (COL)

Appendix C Table 2.1.2-1 (Attachment A) as having Protection and Safety Monitoring System (PMS) control perform an active safety function after receiving a signal from PMS. The subject ITAAC performs testing on the squib valves listed in Attachment A.

Testing is performed in accordance with preoperational tests 3/4-PMS-ITPP-522 and 3/4-PMS-ITPP-523 (References 1 through 4) to verify that the valves identified in Attachment A as having PMS control perform an active safety function after receiving a signal from PMS. Testing is performed on the squib valves identified using real and simulated signals into the PMS without stroking the valve and ensures the squib valves receive a signal at the valve electrical leads that is capable of actuating the squib valve.

Squib valve actuation signals generated in the PMS are sent to the Component Interface Modules (CIM), resulting in an actuation of the CIM for the respective squib valve. The CIM is a safety-related component located inside the respective PMS cabinets which provides the capability for on/off control of individual safety-related plant components. Squib valve actuation signals output from the actuated CIM are sent to the respective squib valve through the squib valve controller. To provide overlap, testing in 3/4-PMS-ITPP-523 verifies the output of the CIM when signals are input into the PMS and testing in 3/4-PMS-ITPP-522 manually actuates the CIM and verifies the signal at the squib valve electrical leads.

Testing in 3/4-PMS-ITPP-523 initiates an Automatic Depressurization System (ADS) Stage Four actuation in the PMS. The squib valve actuation signals are measured and timed using a temporary data acquisition system connected to the output of the CIM to verify the CIM outputs a squib valve actuation signal capable of actuating the valves. Each squib valve identified in Attachment A has the electrical leads disconnected to prevent stroking the valve.

During testing in 3/4-PMS-ITPP-522, each squib valve identified in Attachment A has the squib valve igniters replaced with test resistor fixtures. Test resistance is corrected to the maximum resistance expected during accident conditions. The CIMs are manually actuated and a

U.S. Nuclear Regulatory Commission ND-19-0039 Enclosure Page 3 of 4 multimeter along with a temporary data acquisition system is used to measure both firing current and voltage.

Circuit resistance is measured and inside and outside containment temperatures are measured at multiple locations and are used to calculate the circuit resistance expected during accident conditions and at the minimum ambient temperature. The calculated circuit resistances are verified to meet the minimum and maximum allowable resistances.

The minimum signal necessary to actuate the squib valves is specified in valve design information as at least 3.7 amperes for 10 milliseconds. The information recorded during testing of voltage and firing current is utilized to confirm that a sufficient test signal is received at each of the squib valves.

Together, these test results (References 1 through 4) confirm that each squib valve, identified in Attachment A, receives a signal at the valve electrical leads that is capable of actuating the squib valve.

References 1, 2, 3 and 4 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC Completion Packages (Reference 5 and 6, respectively).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there are no relevant ITAAC findings associated with this ITAAC.

References (available for NRC inspection)

1. 3-PMS-ITPP-522, "PMS Squib Valve Controller Performance Preoperational Test"

2. 4-PMS-ITPP-522, "PMS Squib Valve Controller Performance Preoperational Test"

3. 3-PMS-ITPP-523, "Containment Pressure High-2 Actuation Preoperational Test Procedure"

4. 4-PMS-ITPP-523, "Containment Pressure High-2 Actuation Preoperational Test Procedure"

5. 2.1.02.11b.i-U3-CP-Rev 0, ITAAC Completion Package

6. 2.1.02.11 b.i-U4-CP-Rev 0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-0039 Enclosure Page 4 of 4 Attachment A*

Eauipment Name Taa No. Control PMS/ DAS Fourth-stage ADS Squib RCS-PL-V004A YesNes Valve Fourth-stage ADS Squib RCS-PL-V004B YesNes Valve Fourth-stage ADS Squib RCS-PL-V004C YesNes Valve Fourth-stage ADS Squib RCS-PL-V004D YesNes Valve

• Excerpt from COL Appendix C Table 2.1.2-1