ND-19-0061, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.03.11a.i (Index Number 207)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.03.11a.i (Index Number 207)

ML19031A960
Person / Time
Site:	Vogtle
Issue date:	01/28/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0061
Download: ML19031A960 (7)

Text

Michael J. Yox 7825 River Road

>. Southern Nuclear Regulatory Affai rs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel 410-474-8587 cell JAN 2 8 2019 myox@southernco.com Docket Nos. : 52-025 52-026 ND-19-0061 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 2.2.03.11 a.i [Index Number 2071 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3) , Southern Nuclear Operating Company hereby notifies the NRC that as of January 25, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.03.11a.i

[Index Number 2071 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 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. Yax Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.03.11a.i [Index Number 2071 MJY/LBP/sfr

U.S. Nuclear Regulatory Commission ND-19-0061 Page2of 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 Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-19-0061 Page3of 3 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-19-0061 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-19-0061 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.03.11 a.i [Index Number 207]

U.S. Nuclear Regulatory Commission ND-19-0061 Enclosure Page2of 4 ITAAC Statement Design Commitment 11.a} Controls exist in the MCR to cause the remotely operated valves identified in Table 2.2.3-1 to perform their active function(s).

Inspections, Tests, Analyses i) Testing will be performed on the squib valves identified in Table 2.2.3-1 using controls in the MCR, without stroking the valve.

Acceptance Criteria i) Controls in the MCR operate to cause a signal at the squib valve electrical leads that is capable of actuating the squib valve.

ITAAC Completion Description Multiple ITAAC are performed to verify that controls exist in the Main Control Room (MCR) to cause the remotely operated valves identified in Combined License (COL) Appendix C Table 2.2.3-1 (Attachment A) to perform their active functions. 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-521 and 3/4-PMS-ITPP-522 (References 1 through 4) to verify that controls exist in the MCR to cause the valves identified in Attachment A to perform active functions. Testing is performed on the squib valves identified using controls in the MCR without stroking the valve and ensures the controls in the MCR operate to cause a signal at the squib valve electrical leads which is capable of actuating the squib valve.

Squib valve actuation signals generated in the Protection and Safety Monitoring System (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-521 verifies the CIM is actuated when PMS controls are operated 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-521 initiates a containment recirculation actuation and in-containment refueling water storage tank injection in the PMS using PMS controls in the MCR. The squib valve actuation signals are verified at the CIM. 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-19-0061 Enclosure Page3of 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 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-521, "Protection and Safety Monitoring System Logic Test Preoperational Test Procedure"

2. 4-PMS-ITPP-521, "Protection and Safety Monitoring System Logic Test Preoperational Test Procedure"

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

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

5. 2.2.03.11a.i-U3-CP-Rev 0, ITAAC Completion Package

6. 2.2.03.11 a.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-19-0061 Enclosure Page4of 4 Attachment A*

Equipment Tag No. Control PMS/DAS Containment Recirculation A Squib Valve PXS-PL-V118A Yes/Yes Containment Recirculation 8 Squib Valve PXS-PL-V1188 Yes/Yes Containment Recirculation A Squib Valve PXS-PL-V120A Yes/Yes Containment Recirculation 8 Squib Valve PXS-PL-V1208 Yes/Yes IRWST Injection A Squib Valve PXS-PL-V123A Yes/Yes IRWST Injection 8 Squib Valve PXS-PL-V1238 Yes/Yes IRWST Injection A Squib Valve PXS-PL-V125A Yes/Yes IRWST Injection 8 Squib Valve PXS-PL-V1258 Yes/Yes

• Excerpt from Combined License Appendix C Table 2.2.3-1