ND-19-0757, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.05.02a (Index Number 253)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.05.02a (Index Number 253)

ML19177A301
Person / Time
Site:	Vogtle
Issue date:	06/26/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0757
Download: ML19177A301 (12)

Text

Michael J. Yox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel JUN 2 6 2013 Docket Nos.: 52-025 52-026 ND-19-0757 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 2.2.05.02a [Index Number 2531 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of June 21, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 2.2.05.02a [Index Number 253]

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.

r 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 2.2.05.02a [Index Number 253]

MJY/GCW/sfr

U.S. Nuclear Regulatory Commission ND-19-0757 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. R.G. West(w/o enclosures)

Mr. D. L. McKlnney(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 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. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Ms. T. Lamb Mr. M. Webb Mr. P. O'Bryan Mr. T. Fredette Mr. C. Weber Ooiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-0757 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. OrlanI(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. Hosier, 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. Kernlzan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-19-0757 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.05.02a [Index Number 253]

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 2 of 9 ITAAC Statement Desion Commitment:

2.a) The components Identified In Table 2.2.5-1 as ASME Code Section III are designed and constructed In accordance with ASME Code Section III requirements.

2.b) The piping Identified In Table 2.2.5-2 as ASME Code Section III Is designed and constructed In accordance with ASME Code Section III requirements.

3.a) Pressure boundary welds In components Identified In Table 2.2.5-1 as ASME Code Section III meet ASME Code Section III requirements.

3.b) Pressure boundary welds In piping Identified In Table 2.2.5-2 as ASME Code Section III meet ASME Code Section III requirements.

4.a) The components Identified In Table 2.2.5-1 as ASME Code Section III retain their pressure boundary Integrity at their design pressure.

4.b) The piping Identified In Table 2.2.5-2 as ASME Code Section III retains Its pressure boundary Integrity at Its design pressure.

5.b) Each of the lines Identified In Table 2.2.5-2 for which functional capability Is required Is designed to withstand combined normal and seismic design basis loads without a loss of Its functional capability.

Inspections. Tests. Analyses:

Inspection will be conducted of the as-bullt components and piping as documented In the ASME design reports.

Inspection of the as-bullt pressure boundary welds will be performed In accordance with the ASME Code Section III.

A pressure test will be performed on the components and piping required by the ASME Code Section III to be pressure tested.

Inspection will be performed for the existence of a report verifying that the as-bullt piping meets the requirements for functional capability.

Acceptance Criteria:

The ASME Code Section III design reports exist for the as-bullt components and piping Identified In Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III.

A report exists and concludes that the ASME Code Section III requirements are met for non destructive examination of pressure boundary welds.

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 3 of 9 A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

A report exists and concludes that each of the as-built lines identified in Table 2.2.5-2 for which functional capability is required meets the requirements for functional capability.

ITAAC Completion Description This ITAAC requires inspections, tests, and analyses be performed and documented to ensure the Main Control Room Emergency Habitability System (VES)components and piping listed in the Combined License(COL) Appendix C, Table 2.2.5-1 (Attachment A)and Table 2.2.5-2 (Attachment B)that are identified as American Society of Mechanical Engineers(ASME)Code Section III or Functional Capability Required are designed and constructed in accordance with applicable requirements.

2.a and 2.b) The ASME Code Section III desion reoorts exist for the as-built comoonents and Dioino identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III.

Inspection of each component listed in Table 2.2.5-1 as ASME Code Section III is performed to demonstrate they are designed and constructed in accordance with the VEGP Updated Final Safety Analysis Report(UFSAR)and the ASME Code Section III requirements. The ASME Code Section III certified Design Reports for these components exist and document that the as-built components conform to the approved design details. The ASME Section III Design Report for each component is documented in the component's completed ASME Section III Code Data Report. The individual component ASME Section III Code Data Reports are documented on the ASME Section III N-5 Code Data Report(s)for the applicable piping system (Reference 1).

The as-built piping listed in Table 2.2.5-2 including the components listed in Table 2.2.5-1 as ASME Code Section III, is subjected to a reconciliation process(Reference 2), which verifies that the as-built piping is analyzed for applicable loads (e.g. stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-built systems, including installed components, validates that construction completion, including field changes and any nonconforming condition dispositions, is consistent with and bounded by the approved design. All applicable fabrication, installation and testing records, as well as, those for the related Quality Assurance(OA)verification/ inspection activities, which confirm adequate construction in compliance with the ASME Code Section III and design provisions, are referenced in the N-5 data report and/or its sub-tier references.

The applicable ASME Section III N-5 Code Data Report(s), which include the location of the certified Design Reports for all the components listed in Table 2.2.5-1 (Attachment A)and piping listed in Table 2.2.5-2(Attachment B)as ASME Code Section III, exist and conclude that these installed components are designed and constructed (including their installation within the applicable as-built piping system) in accordance with the ASME Code(1998 Edition, 2000 Addenda and 1989 Edition, 1989 Addenda),Section III requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference 3). The N-5 Code Data Reports for the piping system(s) containing the components listed in the Table 2.2.5-1 and Table 2.2.5-2 are identified in Attachments A and B, respectively.

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 4 of 9 3.a and 3.bf A reoort exists and concludes that the ASME Code Section III reouirements are met for non-destructive examination of pressure boundary welds.

Inspections are performed in accordance with ASME Code Section III (1998 Edition, 2000 Addenda)to demonstrate that as-built pressure boundary welds in components identified in Table 2.2.5-1 as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications).

The applicable non-destructive examinations (including liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the components' pressure boundary welds are documented in the Non-destructive Examination Report(s), which support completion of the respective ASME Section ill N-5 Code Data Report(s) certified by the Authorized Nuclear Inspector, as listed in Attachment A.

Per ASME Code Section III, Subarticle NCA-8300,"Code Symbol Stamps," the ASME Section III N-5 Code Data Report(s)(Reference 1)documents satisfactory completion of the required examination and testing of the item, which includes non-destructive examinations of pressure boundary welds. Satisfactory completion of the non-destructive examination of pressure boundary welds ensures that the pressure boundary welds in components identified in Table 2.2.5-1 as ASME Code Section III meet ASME Code Section Mi requirements.

An inspection is performed in accordance with Reference 2to demonstrate that the as-buiit pressure boundary welds in piping identified in Table 2.2.5-2(Attachment B)as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications). This portion of the ITAAC is complete when the piping identified in Tabie 2.2.5-2, which is encompassed within the respective piping system Code Symboi N-Stamp and the corresponding piping system ASME Section III Code N-5 Data Report(s)(Reference 1), is complete.

The non-destructive examinations (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the piping pressure boundary welds are documented in the Non-destructive Examination Report(s) within the piping system's supporting data package, which support completion of the respective Code Stamping and Code N-5 Data Report(s).

The completion of stamping the respective piping system along with the corresponding ASME Code N-5 Data Report Form(s)(certified by the Authorized Nuclear Inspector) ensure that the piping is constructed in accordance with the design specification(s) and the ASME Code Section III, and that the satisfactory completion of the non-destructive examinations of piping pressure boundary welds for the pipe lines identified in Table 2.2.5-2 meet ASME Code Section Mi requirements and are documented in the Non-destructive Examination Report(s).

4.a and 4.b1 A reoort exists and concludes that the results of the pressure test of the components and oioino identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section Ml conform with the requirements of the ASME Code Section Ml.

A pressure test is performed by the vendor to demonstrate that the components identified in Table 2.2.5-1 (Attachment A)as ASME Code Section ill retain their pressure boundary integrity at their design pressure. The completion of the N-5 Data Reports is governed by Reference 2.

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 5 of 9 This portion of the ITAAC is complete once each component identified in Table 2.2.5-1 has their individual Code Symbol N-Stamp and corresponding ASME Section III Code Data Report (Reference 1) completed, and the components are installed into the respective Code Symbol N-Stamped piping system and documented on the corresponding ASMES^bn III N-5 Code Data Report(s)(Reference 1). The pressure testing results of the component's pressure boundary are documented in the Pressure Testing Report(s) within the supporting component's quality data package, which support completion of the respective Code Stamping and Code Data Report(s).

The completion of stamping the individual components and the respective piping system along with the corresponding ASME Code Data Reports (certified by the Authorized Nuclear Inspector) ensures that the components are constructed in accordance with the Design Specifications and the ASME Code Section III and that the satisfactory completion of the pressure testing of each component identified in Table 2.2.5-1 as ASME Code Section III are documented in the Pressure Testing Report(s) within the supporting data packages and meets ASME Code Section III requirements.

This ITAAC also verifies that the piping identified in Table 2.2.5-2 (Attachment B)fully meets all applicable ASME Code,Section III requirements and retains its pressure boundary integrity at its design pressure.

A pressure test is performed that complies with the ASME Code(1998 Edition, 2000 Addenda),

Section III requirements to demonstrate that the ASME Code Section III piping identified in Table 2.2.5-2 retains its pressure boundary integrity at its design pressure.

A pressure test verifies that there are no leaks at welds or piping, and that the pressure boundary integrity is retained at its design pressure. The pressure testing results of the pipe lines are documented in the Pressure Testing Report(s). The Pressure Testing Report(s) supports completion of the ASME Section III N-5 Code Data Report(s)for the applicable piping system (i.e., VES)(Reference 1).

The applicable ASME Section III N-5 Code Data Report(s)(Reference 1) identified in Attachments A and B documents that the results of the pressure testing of the components and piping identified in Table 2.2.5-1 and Table 2.2.5-2 respectively conform with the requirements of the Code(1998 Edition, 2000 Addenda),Section III.

5.b1 A reoort exists and concludes that each of the as-built lines identified in Table 2.2.5-2 for which functional caoabilitv is reouired meets the reouirements for functional caoabilitv.

An inspection is performed of the ASME Section III as-built piping design reports to verify that the report demonstrates that each of the VES piping lines identified in ITAAC Table 2.2.5-2 that requires functional capability is designed to withstand combined normal and seismic design basis loads without a loss of its functional capability. "Functional capability," in this context, refers to the capability of the piping to withstand the effects of earthquakes, without a loss of safety function (to convey fluids from one location to another). Specific functional capability requirements are defined in the VEGP UFSAR Table 3.9-11 (Reference 3).

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 6 of 9 Piping functional capability is not a specific ASME Code requirement but it is a requirement in tfie VEGP UFSAR (Reference 3). As sucti, information demonstrating that UFSAR functional capability requirements are met is included in the ASME Section III As-Built Design Reports for safety class piping prepared in accordance with ASME Section III NCA-3550 under the ASME Boiler & Pressure Vessel Code(1998 Edition, 2000 Addenda)Section III requirements. The as-built piping systems are subjected to a reconciliation process(Reference 2), which verifies that the as-built piping systems are analyzed for functional capability and for compliance with the design specification and ASME Code provisions. Design reconciliation of the as-built systems validates that construction completion, including field changes and any nonconforming condition dispositions, is consistent with and bounded by the approved design. As required by ASME Code, the As-Built Design Report includes the results of physical inspection of the piping and reconciliation to the design pipe stress report.

Inspections of the ASME Code Section III As-Built Piping Design Reports(Reference 3)for the VES piping lines identified in Table 2.2.5-2 are complete and conclude that each of the as-built VES piping lines for which functional capability is required meets the requirements for functional capability. The ASME Section III As-Built Piping Design Reports for each of the as-built VES piping lines in Table 2.2.5-2 are identified in Attachment B.

References 1 and 4 provide the evidence that the ITAAC Acceptance Criteria requirements are met:

The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III; A report exists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds; A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III conform with the requirements of the ASME Code Section III; and

• A report exists and concludes that each of the as-built lines identified in Table 2.2.5-2 for which functional capability is required meets the requirements for functional capability.

References 1 and 4 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.2.05.02a Completion Packages(References 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 ITAAC findings and associated corrective actions.

This review, which included now consolidated ITAAC Indexes 254, 255, 256, 257, 258 and 262, found no relevant ITAAC findings associated with this ITAAC.

U.S. Nuclear Regulatory Commission N D-19-0757 Enclosure Page 7 of 9 References favailable for NRG inspection)

1. VES ASME Section III N-5 Code Data Report(s)

2. APP-GW-GAP-139,"Westinghouse/WECTEC ASME N-5 Interface Procedure"

3. VEGP 3&4 Updated Final Safety Analysis Report, Subsection 5.2.1, Compliance with Codes and Code Cases

4. VES ASME Section III As-Built Design Report(s)

5. 2.2.05.02a-U3-CP-Rev0, ITAAC Completion Package

6. 2.2.05.02a-U4-CP-Rev0, 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-19-0757 Enclosure Page 8 of 9 Attachment A SYSTEM: Main Control Room Emergency Habitability System (VES)

ASME III as-ASME Code Equipment Name

• Tag No.* built Design N-5 Report Section ill*

Report Air Delivery Alternate N-5 Code Data VES-PL-V001 Yes XXX Isolation Valve Report Eductor Flow Path N-5 Code Data VES-PL-V045 Yes XXX Isolation Valve Report Eductor Bypass Isolation N-5 Code Data VES-PL-V046 Yes XXX Valve Report Pressure Regulating N-5 Code Data VES-PL-V002A Yes XXX Valve A Report Pressure Regulating N-5 Code Data VES-PL-V002B Yes XXX Valve B Report MCR Air Delivery N-5 Code Data VES-PL-V005A Yes XXX Isolation Valve A Report MCR Air Delivery N-5 Code Data VES-PL-V005B Yes XXX Isolation Valve B Report Temporary Instrument N-5 Code Data VES-PL-V018 Yes XXX Isolation Valve A Report Temporary Instrument N-5 Code Data VES-PL-V019 Yes XXX Isolation Valve B Report MCR Pressure Relief N-5 Code Data VES-PL-V022A Yes XXX Isolation Valve A Report MCR Pressure Relief N-5 Code Data VES-PL-V022B Yes XXX Isolation Valve B Report Air Tank Safety Relief N-5 Code Data VES-PL-V040A Yes XXX Valve A Report Air Tank Safety Relief N-5 Code Data VES-PL-V040B Yes XXX Valve B Report Air Tank Safety Relief N-5 Code Data VES-PL-V040C Yes XXX Valve C Report Air Tank Safety Relief N-5 Code Data VES-PL-V040D Yes XXX Valve D Report Main Air Flow Path N-5 Code Data VES-PL-V044 Yes XXX Isolation Valve Report MCR Air Filtration Line N-5 Code Data VES-PY-N01 Yes XXX Eductor Report "Excerpts from COL Appendix C Table 2.2.5-1

U.S. Nuclear Regulatory Commission ND-19-0757 Enclosure Page 9 of 9 Attachment B SYSTEM: Main Control Room Emergency Habitability System (VES)

ASME ill Functional Line ASM E Code As-Built N-5 Report Line Name* Capability Number* Section ill* Design Required*

Report N-5 Code Data MCR Relief Line VES-PL-022A Yes Yes XXX Report N-5 Code Data MCR Relief Line VES-PL-022B Yes Yes XXX Report

'Excerpts from COL Appendix C, Table 2.2.5-2