ND-19-0896, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.06.11a (Index Number 382)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.06.11a (Index Number 382)

ML19206A436
Person / Time
Site:	Vogtle
Issue date:	07/25/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0896
Download: ML19206A436 (14)

Text

Michael J. Yox 7825 River Road Sk Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel JUL 2 5 2019 Docket Nos.: 52-025 52-026 ND-19-0896 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-davs Prior to Initial Fuel Load Item 2.3.06.11 a (Index Number 3821 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of July 22, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.06.1 la [Index Number 382] 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. Yox Regulatory Affairs irector Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.06.1 la [Index Number 382]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0896 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. Vox Mr. A. 8. Ration 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 go:

Nuclear Regulatory 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. T. Fredette Mr. C. Weber Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-0896 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Eiectric Company, LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Mr. Z. S. Harper Mr. J. L. Coward Other Mr. J. E. Hosier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUB, Inc.

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

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 1 of 11 Southern Nuclear Operating Company ND-19-0896 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.06.11a [Index Number 382]

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 2 of 11 ITAAC Statement Desion Commitment

10. Safety-related displays identified in Table 2.3.6-1 can be retrieved in ttie MCR.

11.a) Controls exist in the MCR to cause those remotely operated valves identified in Table 2.3.6-1 to perform active functions.

11.b) The valves identified in Table 2.3.6-1 as having RMS control perform active safety functions after receiving a signal from the PMS.

12.b) After loss of motive power, the remotely operated valves identified in Table 2.3.6-1 assume the indicated loss of motive power position.

13. Controls exist in the MCR to cause the pumps identified in Table 2.3.6-3 to perform the control function.

14. Displays of the RMS parameters identified in Table 2.3.6-3 can be retrieved in the MCR.

I nsoections/Tests/Analvses Inspection will be performed for retrievability of the safety-related displays in the MCR.

Stroke testing will be performed on the remotely operated valves identified in Table 2.3.6-1 using the controls in the MCR.

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

Testing of the remotely operated valves will be performed under the conditions of loss of motive power.

Testing will be performed to actuate the pumps identified in Table 2.3.6-3 using controls in the MCR.

Inspection will be performed for retrievability in the MCR of the displays identified in Table 2.3.6-3 Acceptance Criteria Safety-related displays identified in Table 2.3.6-1 can be retrieved in the MCR.

Controls in the MCR operate to cause those remotely operated valves identified in Table 2.3.6-1 to perform active functions.

The valves identified in Table 2.3.6-1 as having PMS control perform the active function identified in the table after receiving a signal from the PMS.

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 3 of 11 Upon loss of motive power, eacfi remotely operated valve Identified In Table 2.3.6-1 assumes tfie Indicated loss of motive power position.

Controls In the MCR cause pumps Identified In Table 2.3.6-3 to perform the control function.

Displays of the RNS parameters Identified In Table 2.3.6-3 are retrieved In the MCR.

ITAAC Completion Description Testing or inspections are performed to verify that the Normal Residual Heat Removal System (RNS) provides the following functions:

• Inspections performed demonstrate the safety-related displays Identified In Combined License(COL)Appendix C Table 2.3.6-1 (Attachment A)can be retrieved In the Main Control Room (MCR).

• Testing performed demonstrates that controls In the MCR operate to cause those remotely operated valves Identified In Table 2.3.6-1 (Attachment B)to perform active functions.

• Testing performed demonstrates that the valves Identified In table 2.3.6-1 (Attachment C)as having Protection and Monitoring System (PMS)control perform the active function Identified In the table after receiving a signal from the PMS.

• Testing performed demonstrates that after a loss of motive power, the remotely operated valves Identified In Table 2.3.6-1 (Attachment D)assumes the Indicated loss of motive power position.

• Testing performed demonstrates that controls In the MCR cause pumps Identified In Table 2.3.6-3(Attachment E)to perform the control function.

• Inspections performed demonstrate the displays of the RNS parameters Identified In Table 2.3.6-3(Attachment F) are retrieved In the MCR.

Safetv-related dlsolavs Identified In Table 2.3.6-1 can be retrieved In the MCR.

An Inspection Is performed In accordance with Unit 3 and Unit 4 component test work packages, SNC922091 and SNCYYYYYY (References 1 and 2)to verify the safety-related displays Identified In Attachment A can be retrieved In the MCR.

The Inspection Is performed using references 1 and 2 and Is conducted at the MCR PMS Visual Display Units(VDUs)and verifies the safety-related displays In Attachment A can be retrieved In the MCR. Each valve and Indication listed In Attachment A Is located on the VDUs and verified to display.

The Inspection results confirm that the safety-related displays Identified In Table 2.3.6-1 can be retrieved In Unit 3 and Unit 4 MCR.

Controls In the MCR ooerate to cause those remotelv operated valves Identified In Table 2.3.6-1 to perform active functions.

Testing Is performed In accordance with Unit 3 and Unit 4 component test work packages, SNC922091 and SNCYYYYYY (References 1 and 2)to verify that controls In the MCR operate to cause those remotely operated valves Identified In Attachment B to perform active functions.

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 4 of 11 Testing is conducted at an operator work station, and Division B and D RMS VDUs in Unit 3 and Unit 4 MGR to verify the valves identified in Attachment B as being remotely operated and having active functions are stroked open and closed from the MGR. The valve positions are verified locally and in the MGR. This confirms that controls in Unit 3 and Unit 4 MGR operate to cause the remotely operated valves to perform active safety functions.

Unit 3 and Unit 4 component test results (References 1 and 2)confirm that controls in the MGR operate to cause those remotely operated valves identified in Table 2.3.6-1 to perform active functions.

The valves identified in Table 2.3.6-1 as having RMS control perform the active function identified in the table after receivino a sional from the RMS.

Testing is performed in accordance with Unit 3 and Unit 4 component test packages SNGXXXXXX and SNGYYYYYY (References 3 and 4). These component test packages utilize B-GEN-ITRGI-039(Reference 5)to direct the performance of test procedures 3/4-RNS-OTS 004(References 6 and 7), 3/4-GEN-OTS-10-001 (References 8 and 9)and 3/4-GEN-OTS 002(References 10 and 11)to verify that the valves identified in Attachment G as having RMS control perform the active function identified in the Attachment after receiving a signal from the RMS.

References 6 through 11 establish initial conditions with each valve verified locally and in the MGR to be in the Open position. An actuation signal is generated by RMS using the RMS Maintenance and Test Panel(MTR)to generate a signal to Glose the valves in Attachment G.

Each valve is verified locally and in the MGR to be Glosed.

The completed Unit 3 and Unit 4 component test results (references 3 and 4) confirm that the valves identified in Table 2.3.6-1 as having RMS control perform the active function identified in the table after receiving a signal from the RMS.

Upon loss of motive power, each remotelv operated valve identified in Table 2.3.6-1 assumes the indicated loss of motive power position.

Testing is performed in accordance with Unit 3 and Unit 4 component test work packages, SNG922091 and SNGYYYYYY (References 1 and 2)to verify that upon loss of motive power, each remotely operated valve identified in Attachment D assumes the indicated loss of motive power position.

References 1 and 2 establish initial conditions with each Motor Operated Valve(MOV)verified locally and in the MGR to be in the Open position. Rower is removed from the motor and the valves are verified to fail to their loss of motive power position (As-ls) locally. RNS-RL-V061 (RNS Retum from Ghemical and Volume Gontrol System (GVS)Gontainment Isolation Valve) is Opened and verified to be Open locally and in the MGR, power is removed from the solenoid valve supplying air to the valve actuator which removes motive power to the valve. RNS-RL-V061 is verified to Glose locally and in the MGR. RNS-RL-V057A and V057B(RNS Rump Miniflow Air-Operated Isolation Valves) are Glosed, power is removed from the solenoid valves supplying air to the valve actuators which removes motive power to the valves and the valves are verified to Open locally and in the MGR.

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 5 of 11 The completed Unit 3 and Unit 4 component test results (references 3 and 4)confirm that upon loss of motive power, each remotely operated valve identified in Table 2.3.6-1 assumes the indicated loss of motive power position.

Controls in the MGR cause oumos identified in Table 2.3.6-3 to perform the control function.

Testing is performed in accordance with Unit 3 and Unit 4 component test work packages, SNC922091 and SNCYYYYYY (References 1 and 2)to verify that controls in the MCR cause pumps identified in Attachment E to perform the control function.

References 1 and 2 establish the initial conditions with both RMS pumps stopped. The RNS operating procedure, RNS-SOP-001, is utilized and the pumps are started using Plant Control System (PLS)controls in the MCR. Both RNS pumps are verified to start locally.

The completed Unit 3 and Unit 4 component test results(References 1 and 2)confirm that controls in the MCR cause pumps identified in Table 2.3.6-3 to perform the control function.

Disolavs of the RNS oarameters identified in Table 2.3.6-3 are retrieved in the MCR.

An inspection is performed in accordance with Unit 3 and Unit 4 component test work packages, SNC922091 and SNCYYYYYY (References 1 and 2)to verify displays of the RNS parameters identified in Attachment F are retrieved in the MCR.

References 1 and 2 direct performance of the inspection at an MCR operator workstation and visually confirms that when each of the displays of parameters identified in Attachment F is summoned at an MCR workstation, the summoned plant parameter appears on a display monitor at the MCR workstation.

The completed Unit 3 and Unit 4 component test results (References 1 and 2) confirm that displays of the RNS parameters identified in Table 2.3.6-3 are retrieved in the MCR.

References 1 through 11 are available for NRC inspection as part of ITAAC 2.3.06.11 a Unit 3 and 4 Completion Packages(References 12 and 13).

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.

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 6 of 11 References(available for NRG inspection)

1. SNC922091,"RMS Component Testing - ITAAC: 8V3-2.3.06.11a, Items 10, 14,11.a, 12.b, 13"

2. SNCYYYYYY,"RNS Component Testing -ITAAC: SV4-2.3.06.1 la. Items 10,14, 11.a, 12.b, 13"

3. SNCXXXXXX

4. SNCYYYYYY

5. B-GEN-ITPCI-039,"PMS CIM Component Test Procedure"

6. 3-RNS-0TS-17-004,"Normal Residual Heat Removal System Valve Stroke Tesf

7. 4-RNS-0TS-17-004,"Normal Residual Heat Removal System Valve Stroke Tesf

8. 3-GEN-0TS-10-001,"Division A Quarterly Valve Stroke Tesf

9. 3-GEN-0TS-10-001,"Division A Quarterly Valve Stroke Test" 10.3-GEN-0TS-10-002,"Division B Quarterly Valve Stroke Tesf 11.4-GEN-0TS-10-002,"Division B Quarterly Valve Stroke Test" 12.2.3.06.11a-U3-CP-Rev 0, ITAAC Completion Package 13.2.3.06.11a-U4-CP-Rev 0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 7 of 11 Attachment A

'Excerpt from COL Appendix 0 Table 2.3.6-1 Table 2.3.6-1

'Equipment Name 'Tag No. 'Safety-Related Display RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001A Yes Isolation Valve (Valve Position)

RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001B Yes Isolation Valve (Valve Position)

RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002A Yes Isolation Valve (Valve Position)

RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002B Yes Isolation Valve (Valve Position)

RNS Discharge Motor-operated Containment RNS-PL-V011 Yes Isolation Valve (Valve Position)

RNS Suction Header Motor-operated RNS-PL-V022 Yes Containment Isolation Valve (Valve Position)

RNS Suction from IRWST Motor-operated RNS-PL-V023 Yes Isolation Valve (Valve Position)

RNS Return from Chemical and Volume Control RNS-PL-V061 Yes System (CVS)Containment Isolation Valve (Valve Position)

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 8 of 11 Attachment B

'Excerpt from COL Appendix 0 Table 2.3.6-1 Table 2.3.6-1

^Equipment Name *Tag No. "Remotely "Active Operated Function Valve RGB Inner Hot Leg Suction Motor- RNS-PL-V001A Yes Transfer operated Isolation Valve Closed RGB Inner Hot Leg Suction Motor- RNS-PL-V001B Yes Transfer operated Isolation Valve Closed RGB Outer Hot Leg Suction Motor- RNS-PL-V002A Yes Transfer operated Isolation Valve Closed RGB Outer Hot Leg Suction Motor- RNS-PL-V002B Yes Transfer operated Isolation Valve Closed RNS Discharge Motor-operated RNS-PL-V011 Yes Transfer Containment Isolation Valve Closed RNS Suction Header Motor-operated RNS-PL-V022 Yes Transfer Containment Isolation Valve Closed RNS Suction from IRWST Motor- RNS-PL-V023 Yes Transfer operated Isolation Valve Closed RNS Return from Chemical and RNS-PL-V061 Yes Transfer Volume Control System (CVS) Closed Containment Isolation Valve

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 9 of 11 Attachment 0 "Excerpt from COL Appendix 0 Table 2.3.6-1 Table 2.3.6-1

^Equipment Name *Tag No. *Control RMS *Actlve Function RGB Inner Hot Leg Suction RNS-PL-V001A Yes Transfer Motor-operated Isolation Valve Closed RGB Inner Hot Leg Suction RNS-PL-V001B Yes Transfer Motor-operated Isolation Valve Closed RGB Outer Hot Leg Suction RNS-PL-V002A Yes Transfer Motor-operated Isolation Valve Closed RGB Outer Hot Leg Suction RNS-PL-V002B Yes Transfer Motor-operated Isolation Valve Closed RMS Discharge Motor-operated RNS-PL-V011 Yes Transfer Containment Isolation Valve Closed RNS Suction Header Motor- RNS-PL-V022 Yes Transfer operated Containment Isolation Closed Valve RNS Suction from IRWST Motor- RNS-PL-V023 Yes Transfer operated Isolation Valve Closed RNS Return from Chemical and RNS-PL-V061 Yes Transfer Volume Control System (CVS) Closed Containment Isolation Valve

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 10 of 11 Attachment D

'Excerpt from COL Appendix 0 Table 2.3.6-1 Table 2.3.6-1

• Equipment Name *Tag No.

• Loss of Motive Power Position RGB Inner Hot Leg Suction Motor-operated Isolation RNS-PL-V001A As Is Valve RGB Inner Hot Leg Suction Motor-operated Isolation RNS-PL-V001B As Is Valve RGB Outer Hot Leg Suction Motor-operated Isolation RNS-PL-V002A As Is Valve RGB Outer Hot Leg Suction Motor-operated Isolation RNS-PL-V002B As Is Valve RNS Discharge Motor-operated Containment Isolation RNS-PL-V011 As Is Valve RNS Suction Header Motor-operated Containment RNS-PL-V022 As Is Isolation Valve RNS Suction from IRWST Motor-operated Isolation Valve RNS-PL-V023 As Is RNS Discharge to IRWST Motor-operated Isolation Valve RNS-PL-V024 As Is RNS Suction from Cask Loading Pit Motor-operated RNS-PL-V055 As Is Isolation Valve RNS Pump Miniflow Air-Operated Isolation Valve RNS-PL-V057A Open RNS Pump Miniflow Air-Operated Isolation Valve RNS-PL-V057B Open RNS Return from Chemical and Volume Control System RNS-PL-V061 Closed (CVS) Containment Isolation Valve

U.S. Nuclear Regulatory Commission ND-19-0896 Enclosure Page 11 of 11 Attachment E "Excerpt from COL Appendix C Table 2.3.6-3 Table 2.3.6-3 "Equipment Name "Tag No. "Control Function RNS Pump 1A (Motor) RNS-MP-01A Start RNS Pump 1B (Motor) RNS-MP-01B Start Attachment F "Excerpt from COL Appendix C Table 2.3.6-3 Table 2.3.6-3 "Equipment Name "Tag No. "Display RNS Pump 1A (Motor) RNS-MP-01A Yes RNS Pump 1B (Motor) RNS-MP-01B Yes RNS Flow Sensor RNS-01A Yes RNS Flow Sensor RNS-01B Yes RNS Suction from Cask Loading Pit Isolation Valve RNS-PL-V055 Yes (Position Indicator)

RNS Pump Miniflow Isolation Valve RNS-PL-V057A Yes (Position Indicator)

RNS Pump Miniflow Isolation Valve RNS-PL-V057B Yes (Position Indicator)