ND-19-0271, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.4.02.02a (Index Number 497)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.4.02.02a (Index Number 497)

ML19085A386
Person / Time
Site:	Vogtle
Issue date:	03/25/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0271
Download: ML19085A386 (8)

Text

^Southern Nuclear Michael J. Yox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tei MAR 2 5 2019 Docket Nos.: 52-025 52-026 ND-19-0271 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 2.4.02.02a [Index Number 4971 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of March 21, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections Tests Analyses and Acceptance Criteria (ITAAC) Item 2.4.02.02a

[Index Number 497] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.4.02.02a [Index Number 497]. 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)(3) 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.

U.S. Nuclear Regulatory Commission ND-19-0271 Page 2 of 4 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 2.4.02.02a [Index Number 497]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0271 Page 3of 4 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. 8. 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 Reaulatorv 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 Oalethoroe Power Corooration Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0271 Page 4 of 4 Dalton Utilities Mr. T. Bundros 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 Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hosier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, inc.

Mr. 8. Roetger, Georgia Pubiio Service Commission Ms. 8. W. Kemizan, Georgia Pubiio Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-19-0271 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-19-0271 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.4.02.02a [Index Number 497]

U.S. Nuclear Regulatory Commission ND-19-0271 Enclosure Page 2of 4 ITAAC Statement Desion Commitment 2.a) Controls exist in the MCR to trip the main turbine-generator.

2.c) The main turbine-generator trips after receiving a signal from the DAS.

3) The trip signals from the two turbine eiectricai overspeed protection trip systems are isolated from, and independent of, each other.

I nsoections/Tests/Analvses Testing will be performed on the main turbine-generator using controls in the MCR.

Testing will be performed using real or simulated signals into the DAS.

ii) Testing of the as-built system will be performed using simulated signals from the turbine speed sensors.

Acceptance Criteria Controls in the MCR operate to trip the main turbine-generator.

The main turbine-generator trips after receiving a signal from the DAS.

ii) The main turbine-generator trips after overspeed signals are received from the speed sensors of the 110% emergency electrical overspeed trip system, and the main turbine-generator trips after overspeed signals are received from the speed sensors of the 111% backup electrical overspeed trip system.

ITAAC Completion Description This ITAAC requires testing to be performed to verify that controls exist in the Main Control Room (MCR)and operate to trip the main turbine-generator and that the main turbine-generator trips after receiving a real or simulated signal from the Diverse Actuation System (DAS). This ITAAC also verifies the turbine electrical overspeed protection trips system are isolated and independent of each other and that the main turbine-generator trips after receiving simulated trip signals from the emergency electrical overspeed trip system and the backup electrical overspeed trip system.

Controls in the MCR operate to trio the main turbine-generator.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-TOS-ITPP-501 and 4-TOS-ITPP-501 (References 1 and 2)to verify that controls in the MCR operate to trip the main turbine-generator.

Testing is initiated by resetting the main turbine, verifying the turbine is not tripped, and verifying the main turbine stop and control valves are open. The turbine trip hand switch at the Primary

U.S. Nuclear Regulatory Commission ND-19-0271 Enclosure Page 3of 4 Dedicated Safety Panel(PDSP) is placed in trip, tfie turbine mode turbine trip display is verified, and the turbine stop and controi valves are verified to be closed.

This testing confirms that for Unit 3 and Unit 4, controls in the MGR operate to trip the main turbine-generator.

The main turbine-generator trios after receiving a sional from the DAS.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-TOS-ITPP-501 and 4-TOS-iTPP-501 (References 1 and 2)and 3-DAS-ITPP-501 and 4-DAS-ITPP-501 (References 3 and 4)to verify the main turbine-generator trips after receiving a signal from the DAS.

Testing in references 1 and 2 perform a trip solenoid valve functional test by verifying that when master trip pilot solenoids(TOS-V174A1/A2, TOS-V174B1/B2)are de-energized, the spool moves to the tripped position and the main turbine and extraction non-return valves are verified to close locally thereby tripping the main turbine. Testing in references 3 and 4 verifies the master trip pilot solenoids de-energize due to a DAS manual Reactor and Turbine Trip switch operation resulting in a signal from DAS to the main turbine-generator trip.

Results of the preoperational testing for Unit 3 and Unit 4 confirm that the main turbine-generator trips after receiving a signai from the DAS.

iif The main turbine-oenerator trios after oversoeed sionals are received from the soeed sensors of the 110% emeraencv electrical oversoeed trio svstem. and the main turbine-generator trios after oversoeed sionals are received from the speed sensors of the 111% backup electricai oversoeed trio svstem.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-TOS-ITPP-501 and 4-TOS-ITPP-501 (References 1 and 2)to verify the main turbine-generator trips after overspeed signals are received from the speed sensors of the 110%

emergency eiectrical overspeed trip system, and the main turbine-generator trips after overspeed signals are received from the speed sensors of the 111% backup electrical overspeed trip system.

Testing in references 1 and 2 perform a trip solenoid vaive functional test by verifying when master trip pilot solenoids(TOS-V174A1/A2, TOS-V174B1/B2)are de-energized, the spool moves to the tripped position and the main turbine and extraction non-return valves are verified to close locally thereby tripping the main turbine. The test then simulates a overspeed condition at the speed sensors for the 110% emergency electrical overspeed trip and verifies the trip solenoids are tripped. The test then simulates an overspeed condition at the speed sensors for the 111% backup electrical overspeed trip and verifies the trip solenoids are tripped.

Results of the preoperational testing for Unit 3 and Unit 4 confirm that the main turbine-generator trips after overspeed signals are received from the speed sensors for the 110%

emergency electrical overspeed trip system, and the main turbine-generator trips after overspeed signals are received from the speed sensors for the 111% backup electrical overspeed trip system.

U.S. Nuclear Regulatory Commission ND-19-0271 Enclosure Page 4 of 4 The completed test results (References 1 through 4), confirm that that DAS controls exist in the MGR and operate to trip the main turbine-generator, that the main turbine-generator trips after receiving a real or simulated signal from the DAS,and that the main turbine-generator trips after receiving trip signals from the emergency electrical overspeed trip system and the backup electrical overspeed trip system.

References 1 through 4 are available for NRG inspection as part of Unit 3and Unit 4ITAAG Completion Packages(Reference 5 and 6).

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

References favailable for NRC inspection^

1. 3-TOS-ITPP-501,"Main Turbine Control and Diagnostics System Preoperational Test Procedure"

2. 4-TOS-ITPP-501,"Main Turbine Control and Diagnostics System Preoperational Test Procedure"

3. 3-DAS-ITPP-501,"Diverse Actuation System Preoperational Test Procedure"

4. 4-DAS-ITPP-501,"Diverse Actuation System Preoperational Test Procedure"

5. 2.4.02.02a-U3-GP-Rev 0, ITAAG Completion Package

6. 2.4.02.02a-U4-GP-Rev 0, ITAAG Completion Package

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