ND-19-1090, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.13.08 (Index Number 470)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.13.08 (Index Number 470)

ML19254D166
Person / Time
Site:	Vogtle
Issue date:	09/11/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-1090
Download: ML19254D166 (11)

Text

Michael J. Yox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro. GA 30830 706-848-6459 tel SEP I 12019 Docket Nos.;52-025 52-026 ND-19-1090 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 2.3.13.08 (Index Number 4701 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of September 11, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.13.08

[Index Number 470] 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 ^ I Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.13.08 [Index Number 470]

MJY/CWM/sfr

U.S. Nuclear Regulatory Commission ND-19-1090 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III (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. G. Chick Mr. M. J. Vox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak 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 Mr. S. Smith 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-19-1090 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 Mr. Z. 8. Harper 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., 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, Baich BIngham

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-19-1090 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.13.08[Index Number 470]

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 2 of 8 ITAAC Statement Design Commitment

8. The PSS provides the nonsafety-related function of providing the capability of obtaining reactor coolant and containment atmosphere samples.

9. Safety-related displays identified in Table 2.3.13-1 can be retrieved in the MCR.

10.a) Controls exist in the MCR to cause those remotely operated valves identified in Table 2.3.13-1 to perform active functions.

lO.b) The valves identified in Table 2.3.13-1 as having PMS control perform an active function after receiving a signal from the PMS.

1 l.b) After loss of motive power, the remotely operated valves identified in Table 2.3.13-1 assume the indicated loss of motive power position.

12. Controls exist in the MCR to cause the valves identified in Table 2.3.13-2 to perform the listed function.

Inspections/Tests/Analvses Testing will be performed to obtain samples of the reactor coolant and containment atmosphere.

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 2.3.13-1 using the controls in the MCR.

Testing will be performed on remotely operated valves listed in Table 2.3.13-1 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 on the components in Table 2.3.13-2 using controls in the MCR.

Acceptance Criteria A sample is drawn from the reactor coolant and the containment atmosphere.

The safety-related displays identified in Table 2.3.13-1 can be retrieved in the MCR.

Controls in the MCR operate to cause those remotely operated valves identified in Table 2.3.13-1 to perform active functions.

The remotely operated valves identified in Table 2.3.13-1 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-19-1090 Enclosure Page 3 of 8 After loss of motive power, each remotely operated valve identified in Table 2.3.13-1 assumes the indicated loss of motive power position.

Controls in the MCR cause valves identified in Table 2.3.13-2 to perform the listed functions.

ITAAC Completion Description Testing and inspections are performed to verify that the Primary Sampling System (PSS) performs the following:

• The PSS provides the nonsafety-related function of providing the capability of obtaining reactor coolant and containment atmosphere samples.

• Safety-related displays identified in the Combined License(COL)Appendix C Table 2.3.13-1 (Attachment A)can be retrieved in the Main Control Room (MCR).

• Controls exist in the MCR to cause those remotely operated valves identified in COL Appendix C Table 2.3.13-1 (Attachment B)to perform active functions.

• The valves identified in COL Appendix C Table 2.3.13-1 (Attachment C)as having Protection and Safety Monitoring System (PMS)control perform an active function after receiving a signal from the PMS.

• After loss of motive power, the remotely operated valves identified in COL Appendix C Table 2.3.13-1 (Attachment D)assume the indicated loss of motive power position.

• Controls exist in the MCR to cause the valves identified in COL Appendix C Table 2.3.13-2(Attachment E)to perform the listed function.

A sample is drawn from the reactor coolant and the containment atmosphere.

Testing is performed to obtain samples of the reactor coolant and containment atmosphere using 3/4-PSS-ITPP-502(Reference 1 and 2). A sample is drawn from each sample point for reactor coolant system and containment atmosphere.

The completed test procedure results (Reference 1 and 2)confirm that for Unit 3 and Unit 4 a sample is drawn from the reactor coolant and the containment atmosphere.

The safetv-related disolavs identified in Table 2.3.13-1 can be retrieved in the MCR.

Inspections performed in accordance with the Unit 3 and Unit 4 component test package work orders SNC921604 and SNCYYYYYY (References 3 and 4), visually confirm that when each of the displays of the plant parameter identified in Attachment A is summoned using the MCR PMS Visual Display Units (VDUs), the expected display appears on the PMS VDU.

The completed inspection results confirm that safety-related displays identified in Table 2.3.13-1 can be retrieved in Unit 3 and Unit 4 MCR.

Controls in the MCR operate to cause those remotelv operated valves identified in Table 2.3.13-1 to perform active functions.

Testing is performed using Plant Control System (PLS)controls in the MCR to stroke test each valve in Attachment 8 in accordance with Unit 3 and Unit 4 component test package work orders SNC921604 and SNCYYYYYY (References 3 and 4).

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 4 of 8 Reference 3 and 4 establish Initial conditions with each valve Identified In Attachment B verified locally and In the MGR to be In the open position. Each valve Is stroked to Its active function using PLS controls and proper valve position Indication Is verified locally and In the MGR.

The completed test results (References 3 and 4)confirm that controls In Unit 3 and Unit 4 MGR operate to cause the remotely operated valves Identified In Table 2.3.13-1 to perform active functions.

The remotelv operated valves Identified In Table 2.3.13-1 as having PMS control perform the active function Identified In the table after receiving a signal from the PMS.

Testing Is performed In accordance with Unit 3 and Unit 4 component test packages SNGXXXXXX and SNGYYYYYY (References 5 and 6). These component test packages utilize B-GEN-ITPGI-039(Reference 7)to direct the performance of test procedures 3/4-GEN-OTS 001 (References 8 and 9), 3/4-GEN-OTS-10-002(References 10 and 11), 3/4-GEN-OTS 003(References 12 and 13), and 3/4-GEN-OTS-10-004(References 14 and 15)to confirm that the remotely operated valves perform the active function Identified In Attachment G after a signal Is Input to the PMS.

References 8 through 15 establish Initial conditions with each valve verified locally and In the MGR to be In the open position. An actuation signal Is generated by PMS using the PMS Maintenance and Test Panel(MTP)to generate a signal to cause the valves In Attachment G to transfer to the active function position (closed) and each valve position Is verified locally and In the MGR.

The completed test results (References 5 and 6)confirm the Unit 3 and Unit 4 remotely operated valves Identified In Table 2.3.13-1 as having PMS control perform the active function Identified In the table after receiving a signal from the PMS.

After loss of motive power, each remotelv operated valve Identified In Table 2.3.13-1 assumes the Indicated loss of motive oower position.

Testing Is performed In accordance with Unit 3 and Unit 4 component test work packages, SNG921604 and SNGYYYYYY (References 3 and 4)to verify that each remotely operated valve Identified In Attachment D assumes the Indicated loss of motive power position upon a loss of motive power.

Testing on the solenoid operated valves(SOV)In Attachment D Is performed by placing the valves In the open position and opening the power supply to their solenoid. This causes the solenoid to de-energIze which closes the valve. The valves are verified locally and In the MGR to transfer to their loss of motive power position (closed).

Testing on the air operated valves(AOV)In Attachment D Is performed by placing the valves In the open position and opening the power supply to their air supply solenoid. This causes the solenoid to de-energIze which closes the air supply to the valve and opens a vent port to vent off the air In the actuator. The valves are verified locally and In the MGR to transfer to their loss of motive power position (closed).

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 5 of 8 The completed test results (References 3 and 4) confirm that after loss of motive power, each remotely operated valve identified in Table 2.3.13-1 assumes the indicated loss of motive power position for Unit 3 and Unit 4.

Controls in the MCR cause valves identified in Table 2.3.13-2 to perform the listed functions.

Testing is performed using Plant Control System (PLS)controls in the MCR to stroke test each valve in Attachment E in accordance with Unit 3 and Unit 4 component test package work orders SNC921604 and SNCYYYYYY (References 3 and 4). Each valve is stroked to the listed functions(open and closed) and proper valve position indication is verified locally and in the MCR.

The completed test results (References 3 and 4)confirm that controls in Unit 3 and Unit 4 MCR cause valves identified in Table 2.3.13-2 to perform their listed functions.

References 1 through 15 are available for NRC inspection as part of ITAAC 2.3.13.08 Unit 3 and 4 Completion Packages (Reference 16 and 17).

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(avaiiabie for NRC inspection)

1. 3-PSS-ITPP-502,"Primary Sampling System Pre-Core Hot Functional Test Preoperational Test Procedure"

2. 4-PSS-ITPP-502,"Primary Sampling System Pre-Core Hot Functional Test Preoperational Test Procedure"

3. SNC921604,"Perform ITAAC 2.3.13.08 Items 9, 10a, lib, 12"

4. SNCYYYYYY,"Perform ITAAC 2.3.13.08 Items 9, 10a, lib, 12"

5. SNCXXXXXX

6. SNCYYYYYY

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

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

9. 4-GEN-0TS-10-001,"Division A Quarterly Valve Stroke Test"

10. 3-GEN-OTS-10-002,"Division B Quarterly Valve Stroke Test" 11.4-GEN-OTS-10-002,"Division B Quarterly Valve Stroke Test"

12. 3-GEN-OTS-10-003,"Division C Quarterly Valve Stroke Test" 13.4-GEN-0TS-10-003,"Division C Quarterly Valve Stroke Test"

14. 3-GEN-OTS-10-004,"Division D Quarterly Valve Stroke Test" 15.4-GEN-OTS-10-004,"Division D Quarterly Valve Stroke Test"

16. 2.3.13.08-U3-CP-Rev 0,"ITAAC Completion Package"

17. 2.3.13.08-U4-CP-Rev 0,"ITAAC Completion Package"

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

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 6 of 8 Attachment A "Excerpt from COL Appendix 0 Table 2.3.13-1 Table 2.3.13-1 "Safety-Related "Equipment Name "Tag No.

Display Containment Air Sample Containment Isolation Valve Yes(Valve PSS-PL-V008 Inside Reactor Containment(IRC) Position)

Liquid Sample Line Containment Isolation Valve IRC Yes(Valve PSS-PL-V010A Position)

Liquid Sample Line Containment Isolation Valve IRC Yes(Valve PSS-PL-V010B Position)

Liquid Sample Line Containment Isolation Valve Outside Yes(Valve PSS-PL-V011A Reactor Containment(ORC) Position)

Liquid Sample Line Containment Isolation Valve ORC Yes(Valve PSS-PL-V011B Position)

Sample Return Line Containment Isolation Valve ORC Yes (Valve PSS-PL-V023 Position)

Sample Return Containment Isolation Valve IRC Yes (Valve PSS-PL-V024 Position)

Air Sample Line Containment Isolation Valve ORC Yes(Valve PSS-PL-V046 Position)

Attachment B "Excerpt from COL Appendix C Table 2.3.13-1 Table 2.3.13-1 "Remotely "Active "Equipment Name "Tag No. Operated Function Valve Containment Air Sample Containment Isolation Transfer PSS-PL-V008 Yes Valve Inside Reactor Containment(IRC) Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V010A Yes IRC Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V010B Yes IRC Closed Liquid Sample Line Containment Isolation Valve Yes Transfer PSS-PL-V011A Outside Reactor Containment(ORC) Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V011B Yes ORC Closed Sample Return Line Containment Isolation Transfer PSS-PL-V023 Yes Valve ORC Closed Sample Return Containment Isolation Valve IRC Transfer PSS-PL-V024 Yes Closed Air Sample Line Containment Isolation Valve Transfer PSS-PL-V046 Yes ORC Closed

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 7 of 8 Attachment C

• Excerpt from COL Appendix 0 Table 2.3.13-1 Table 2.2t.13-1 "Control "Active "Equipment Name "Tag No.

RMS Function Containment Air Sample Containment Isolation Transfer PSS-PL-V008 Yes Valve Inside Reactor Containment(IRC) Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V010A Yes IRC Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V010B Yes IRC Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V011A Yes Outside Reactor Containment(ORC) Closed Liquid Sample Line Containment Isolation Valve Transfer PSS-PL-V011B Yes ORC Closed Sample Return Line Containment Isolation Transfer PSS-PL-V023 Yes Valve ORC Closed Sample Return Containment Isolation Valve IRC Transfer PSS-PL-V024 Yes Closed Air Sample Line Containment Isolation Valve Transfer PSS-PL-V046 Yes ORC Closed Attachment D "Excerpt from COL Appendix C Table 2.3.13-1 Table 2.2(.13-1 "Remotely "Loss of Operated Motive "Equipment Name "Tag No.

Valve Power Position Containment Air Sample Containment Isolation PSS-PL-V008 Yes Closed Valve Inside Reactor Containment(IRC)

Liquid Sample Line Containment Isolation Valve PSS-PL-V010A Yes Closed IRC Liquid Sample Line Containment Isolation Valve PSS-PL-V010B Yes Closed IRC Liquid Sample Line Containment Isolation Valve PSS-PL-V011A Yes Closed Outside Reactor Containment(ORC)

Liquid Sample Line Containment Isolation Valve PSS-PL-V011B Yes Closed ORC Sample Return Line Containment Isolation PSS-PL-V023 Yes Closed Valve ORC Sample Return Containment Isolation Valve IRC PSS-PL-V024 Yes Closed Air Sample Line Containment Isolation Valve PSS-PL-V046 Yes Closed ORC

U.S. Nuclear Regulatory Commission ND-19-1090 Enclosure Page 8 of 8 Attachment E Table 2.3.13-2 Equipment Name Tag No. Control Function Hot Leg 1 Sample Isolation Valve PSS-PL-V001A Transfer Open/Transfer Closed Hot Leg 2 Sample Isolation Valve PSS-PL-V001B Transfer Open/Transfer Closed