ND-19-1139, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.02.07f.i (Index Number 145)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.02.07f.i (Index Number 145)

ML19266A623
Person / Time
Site:	Vogtle
Issue date:	09/23/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-1139
Download: ML19266A623 (12)

Text

^ Southern Nuclear Michael J. Yox Regulatory Affairs Director 7820 River Road Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel SEP 2 3 2019 Docket Nos.: 52-025 52-026 ND-19-1139 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 2.2.02.071.1 (Index Number 1451 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of September 20, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections Tests Analyses and Acceptance Criteria (ITAAC) Item 2.2.02.07f.i

[Index Number 145] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.2.02.07f.i [Index Number 145]. 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.

Southern Nuclear Operating Company(SNC) previously submitted Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load for Item 2.2.02.07f.i [Index Number 145] ND-18-1590

[ML19052A376], dated Feb. 08, 2019. This resubmittal supersedes ND-18-1590 in its entirety.

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 Director Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-19-1139 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.02.07f.i [index Number 145]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-1139 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III (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. 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 cc:

Nuclear Reoulatorv 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 Qqiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authorltv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-1139 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 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., CDS 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-19-1139 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-19-1139 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.02.07f.l [Index Number 145]

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 2 of 8 ITAAC Statement Design Commitment 7.f) The PCS provides a flow path for long-term water makeup from the PCCWST to the spent fuel pool.

B.b) The PCS delivers water from the PCCAWST to the PCCWST and spent fuel pool simultaneously.

Inspections/Tests/Analvses i) Testing will be performed to measure the delivery rate from the PCCWST to the spent fuel pool.

Testing will be performed to measure the delivery rate from the PCCAWST to the PCCWST and spent fuel pool simultaneously.

Acceptance Criteria i) With the PCCWST water level at 27.4 ft + 0.2, - 0.0 ft above the bottom of the tank, the flow path from the PCCWST to the spent fuel pool delivers greater than or equal to 118 gpm.

With PCCAWST aligned to the suction of the recirculation pumps, each pump delivers greater than or equal to 100 gpm to the PCCWST and 35 gpm to the spent fuel pool simultaneously when each pump is tested separately.

ITAAC Completion Description Multiple ITAAC are performed to verify that the Passive Containment Cooling System (PCS) provides a flow path for long-term water makeup from the Passive Containment Cooling Water Storage Tank(PCCWST)to the spent fuel pool (SFP) and that the PCS delivers water from the Passive Containment Cooling Ancillary Water Storage Tank(PCCAWST)to the PCCWST and spent fuel pool simultaneously. Testing is performed to measure the delivery rate from the PCCWST to the spent fuel pool and the delivery rate from the PCCAWST,aligned to the recirculation pumps, to the PCCWST and spent fuel pool simultaneously.

i) With the PCCWST water level at 27.4 ft + 0.2. - 0.0 ft above the bottom of the tank, the flow path from the PCCWST to the spent fuel pool delivers greater than or equal to 118 oom.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-PCS-ITPP-502, 4-PCS-ITPP-502, 3-SFS-ITPP-503, and 4-SFS-ITPP-503(References 1 through 4)to verify that the flow path from the PCCWST to the spent fuel pool delivers greater than or equal to 118 gpm with the PCCWST water level at 27.4 ft + 0.2, - 0.0 ft above the bottom of the tank. The delivery rate from the PCCWST to the spent fuel pool is measured with the testing performed in two parts due to the construction and testing schedule and the very late completion of the PCCWST. During Spent Fuel Pool Cooling System (SFS)testing, flow is established with a temporary water source to provide flow into the PCCAWST supply lines at greater than or equal to 118 gpm to the spent fuel pool. The system flow and the system backpressure are measured. This flow path Is depicted in Attachment A. During PCS testing, a

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 3 of 8 temporary valve and line are installed to direct the flow from the PCCWST to the waste system instead of delivering the flow to the spent fuel pool. The PCCWST water level is verified to be at 27.4 ft + 0.2, -0.0 above the bottom of the tank, flow is initiated to establish a back pressure equal to the pressure measured during the SFS testing. The pressure and flow are monitored and verified to provide greater than or equal to 118 gpm with the same pressure provided during the SFS testing. This flow path is depicted in Attachment B. The Unit 3 PCCWST provides XXX gpm and Unit 4 provides YYY gpm and demonstrates with the PCCWST water level at 27.4 ft +

0.2, - 0.0 ft above the bottom of the tank, the flow path from the PCCWST to the spent fuel pool delivers greater than or equal to 118 gpm.

With PCCAWST aliened to the suction of the recirculation pumps, each pump delivers Greater than or equal to 100 gpm to the PCCWST and 35 gpm to the spent fuel pool simultaneouslv when each pump is tested seoaratelv.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-PCS-ITPP-502, 4-PCS-ITPP-502, 3-SFS-ITPP-503, and 4-SFS-ITPP-503(References 1 through 4)to verify that with PCCAWST aligned to the suction of the recirculation pumps, each pump delivers greater than or equal to 100 gpm to the PCCWST and 35 gpm to the spent fuel pool simultaneously when each pump is tested separately. The delivery rate from the PCCAWST to the PCCWST and SFP are measured simultaneously, with testing performed in two parts due to the construction and testing schedule and the very late completion of the PCCWST. During SFS testing, flow is established at greater than or equal to 35 gpm from a temporary water source providing flow to the SFP and the system backpressure is measured.

This flow path is depicted in Attachment C. During PCS testing, a temporary valve and line are installed to direct the flow from the PCCAWST to the waste system instead of delivering the flow to the spent fuel pool. The PCCAWST is aligned to the suction of the recirculation pumps and flow is initiated to the PCCWST and the SFP simultaneously. The flow to the SFP is throttled to provide the same pressure as recorded during the SFS testing and flow is verified to be greater than or equal to 35 gpm. The flow to the PCCWST is monitored at the same time and verified to be greater than or equal to 100 gpm. This flow path is depicted in Attachment D. Each pump is tested separately, and measurements verify that Unit 3 pump A delivers XXX gpm to the PCCWST flow path while simultaneously delivering XX gpm to SFP. The Unit 3 pump B delivers XXX gpm to the PCCWST flow path while simultaneously delivering XX gpm to the SFP flow path. Unit 4 pump A delivers XXX gpm to the PCCWST flow path while simultaneously delivering XX gpm to the SFP flow path. The Unit 4 pump B delivers XXX gpm to the PCCWST flow path while simultaneously delivering XX gpm to the SFP flow path. The results of the testing confirm that with the PCCAWST aligned to the suction of the recirculation pumps, each pump delivers greater than or equal to 100 gpm to the PCCWST flow path while simultaneously delivering 35 gpm to the SFP when each pump is tested separately, which meets the acceptance criteria.

The completed test results (References 1 through 4), confirm that with the PCCWST water level at 27.4 ft + 0.2, - 0.0 ft above the bottom of the tank, the flow path from the PCCWST to the spent fuel pool delivers greater than or equal to 118 gpm and that with the PCCASWST aligned to the suction of the recirculation pumps, each pump delivers greater than or equal to 100 gpm to the PCCWST and 35 gpm to the spent fuel pool simultaneously when each pump is tested separately.

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

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 4 of 8 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 favailable for NRG inspection)

1. 3-PCS-ITPP-502,"Passive Containment Cooling System PCCWST Preoperational Test Procedure"

2. 4-PCS-ITPP-502,"Passive Containment Cooling System PCCWST Preoperational Test Procedure"

3. 3-SFS-ITPP-503,"Spent Fuel Pool Loss of Large Area Preoperational Test Procedure"

4. 4-SFS-ITPP-503,"Spent Fuel Pool Loss of Large Area Preoperational Test Procedure"

5. 2.2.02.07f.i-U3-CP-Rev 0, ITAAC Completion Package

6. 2.2.02.07f.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-19-1139 Enclosure Page 5 of 8 ATTACHMENT A SUPPLEMENTAL FLOW PATH FOR :TAAC 2.2.02.OTf.i [145]

Ojsieo.CfiroroitmeotlJj t} Testify will be performed to measwe the delivery rate from the FCCWST to the ^er^t fud pool.

i) With the PCCV;ST water level at 27.4 ft 0.2, -

PCCWST 0.0ft above the bottom of the tank, the flow path from the PCCWST to the spent foel pool delivers greater than or equal to llSgpm.

TG-2 Blank cff at SfS-FT-023 PCi-VCOa PCS VALVE ROOM El. 100' Tie in 8tSrS-L14i TOSFP SPKAYS W-3 TG3 Remove FE-CS9 and -£x}-lS install drain/bvpass SFF

>CS-vC3<

SPENT FUEL Temporary UPM VCjC WiS-Vul/

MfrplA PCCAWST

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 6 of 8 ATTACHMEf^ B SiMPLFED FLOW ARRANGEMENT FOR flAAC 2.2.02.07f.i [145]

DesigoIimftUmentlij 5 Testing \\i 8 be perfomned to rr.easu-etbe delivery rate from the PCC.-VST to the spent fud pool.

PCCWST ilWmthe PiXWSTwaterlevelat 27.4ft*0.2,-

0.0 ft aba-e the batom of tfe tank, the flew- path from the FCC\A,'ST to the spent fuel pool delivcts greater than or equal to 118 a^m.

pci-sws X

PCS VALVE ROOM El. 100' PCS-V<>>2 TOSFP SPRAYS PCS-V049 TV-3 TG-a Remove F£-039and install drain,^bypass SFP PCS-vest PCS V<

SPENT FUEL liilf POOL Temporary URVt PCS-VOSC kh'j- vCi2 PC CAW ST MP016

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 7 of 8 ATTACHMENT C SUPPLEMENTAL FLOW PATH FOR iTAAC 2.2.02.07f .i [145]

Desien Commitment 8Jai iiTssting ivtll be performed to measu-e the delivery rate from the PCCAV.'ST to the PCCAST and spent fuel pool simultaneously.

PCCWST Wtth PCC AV.'ST algned to Te suction of the recirculation pumps, each pump delivers freater than or equal to IX gpm to the PCCV.ST and 3S gpm to the spent fuel pool simultaneousV when each pump is tested separately.

TG-2 Btankoff a: SFS-FT-C23

. TV2 rfcm Fire Prctecoor --^tXj fT' Fkisf^ Header PCS VALVE ROOM 5

Tie r. at SF5-L141 -

El. 100' KS-VCS5 TOSFF SPRAYS -txj-r'S-vis hy-3 TSi Rerrcve PE-039 and CXJ install drain/bypass SPP hCS-Vdiii PC S VC SPE^^T FUEL

-X-POOL Tempofary Unvl KS-VOSG S*VC W-OIA PCCAWST

{X3-Mf-Cl6 Recirc. Pumps

U.S. Nuclear Regulatory Commission ND-19-1139 Enclosure Page 8 of 8 ATTACHMENT D SiMPUFiED FLOW ARRANGEMENT FOR ITAAC 2.2.02.OTf.i [145]

gesisn Commitment S.b)

Terur^ vvili be perforired to measure the delivery rate frorr the PCCA'.VST to the PCCWST and spertfuel pocl sirrultareously.

PCCWST With PCCAWST al^red to the suctiohof the recirculatior pumps, each pump delivers greater than or equal to IXgpm to the PCCWST and 35 gpm to thespentfuel pool simultaneously when each pump is tested separately.

PCS VALVE ROOM

£1.100' KS-VC-SZ TOSFP SPSAYS PCS-VOiS Remove FE'D39 and 'D*<3 wstall drain/bjpass SFP FCS-VOSl FCS-VC4S SPENT FUEL n POOL Temperafy UFM PCS-V<<5Q

• . TG-l t

PCCAWST

--lXl~

Recirc. Pumps