ND-19-1047, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.5.03.02 (Index Number 555)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.5.03.02 (Index Number 555)

ML19301C966
Person / Time
Site:	Vogtle
Issue date:	10/28/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-19-1047
Download: ML19301C966 (9)

Text

^ ,t 1. I I Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel OCT 2 8 2019 Docket Nos.: 52-025 52-026 ND-19-1047 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 2.5.03.02 (Index Number 5551 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of October 25, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.5.03.02 [Index Number 555] 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. Vox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.5.03.02 [Index Number 555]

MJY/VK/sfr

U.S. Nuclear Regulatory Commission ND-19-1047 Page 2 of 3 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. Page Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Requlatorv Commission M W. Jones (w/o enclosures)

M F. D. Brown M C. P. Patel M G. J. Khourl Ms. S. E. Temple M N. D. Karlovich M A. Lerch M C. J. Even M B. J. Kemker Ms. N. C. Coovert M . C. Welch M . J. Gaslevic M . V. Hall M . G. Armstrong Ms. T. Lamb M M. Webb M T. Fredette M C. Weber M S. Smith Qqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-1047 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Daiton 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. 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 Public Service Commission Ms. 8. W. Kernlzan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Batch Bingham

U.S. Nuclear Regulatory Commission ND-19-1047 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-19-1047 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.5.03.02[Index Number 555]

U.S. Nuclear Regulatory Commission ND-19-1047 Enclosure Page 2 of 6 ITAAC Statement Design Commitment

2. The PLS provides control interfaces for the control functions listed in Table 2.5.3-1.

Inspections/Tests/Analvses An operational test of the system will be performed using simulated input signals. System outputs or component operations will be monitored to determine the operability of the control functions.

Acceptance Criteria The PLS provides control interfaces for the control functions listed in Table 2.5.3-1.

ITAAC Completion Description Testing is performed to verify the Plant Control System (PLS) provides control interfaces for the control functions listed in VEGP Combined License(COL) Appendix C Table 2.5.3-1 (Attachment A).

Testing is performed in accordance with the following Unit 3 and Unit 4 preoperational test procedures 3/4-PLS-ITPP-520 (References 1 and 2), 3/4-PLS-ITPP-507(References 3 and 4),

3/4-RCS-ITPP-504 (References 5 and 6), 3/4-SGS-ITPP-502 (References 7 and 8), 3/4-MSS-ITPP-502(References 9 and 10), 3/4-CVS-ITPP-502 (References 11 and 12). This testing verifies PLS operability of the control functions listed in Attachment A.

References 1 and 2 conduct preoperational testing of the Digital Rod Position Indication (DRPI)

System control interface with the PLS. The DRPI System is placed in a normal configuration and the Westinghouse DRPI Simulator Test Box is connected at existing connectors on the Integrated Head Package (IMP) Connector Panel. The test demonstrates that DRPI communicates with the PLS and indicates the correct rod position at the Main Control Room Workstation when simulated using the Simulator Test Box for each of the 69 control rods.

The completed test results (References 1 and 2)satisfy the Acceptance Criteria for PLS to provide control interfaces for Reactor Rod Position functions.

References 3 and 4 conduct preoperational testing of the Digital Rod Control System (DRCS)

System during Hot Functional Testing (HPT), near full temperature and pressure, to demonstrate Reactor Power and Rapid Power Reduction control functions using the PLS control interface.

The test demonstrates Reactor Power control rod withdrawal, insertion, and overlap movement by simulating a varying Tavg-Tref for temperature mismatch conditions and then verifying the corresponding Rod Bank Speed withdrawal and insertion signals. Additionally, testing is performed by inserting an axial offset condition and verifies the Axial Offset(AO) rods respond properly to negative and positive axial offsets.

U.S. Nuclear Regulatory Commission ND-19-1047 Enclosure Page 3 of 6 The test also demonstrates Rapid Power Reduction with control rods fully withdrawn, then selecting rapid power reduction banks for a rod sequence and simulating forced point values to obtain and verify the selected control rod banks release.

The completed test results (References 3 and 4)satisfy the Acceptance Criteria for PLS to provide control interfaces for Reactor Power and Rapid Power Reduction functions.

References 5 and 6 conduct preoperational testing of Reactor Coolant System (RCS)

Pressurizer(PZR) pressure control interface functions during HPT, near full temperature and pressure.

PZR pressure spray valves are placed in manual and fully opened. During the pressurizer pressure decrease, the control and backup heaters are verified to energize and fully load to attempt to maintain pressurizer pressure. The pressurizer spray valves are then closed and placed in automatic. Pressurizer pressure is monitored and verified to return to setpoint. Then the pressurizer spray valves are placed in manual, closed and the pressurizer backup heaters are placed in manual and turned on. Pressurizer pressure and heater current are monitored and when pressurizer pressure increases to system normal operating pressure, the pressurizer master controller is placed in automatic and the spray valves are placed in automatic.

Pressurizer pressure is monitored and verified to return to setpoint.

The completed test results (References 5 and 6)satisfy the Acceptance Criteria for PLS to provide control interface for Pressurizer pressure functions.

References 7 and 8 conduct preoperational testing of the Main and Startup Feedwater System (FWS)during HPT, near full temperature and pressure, to demonstrate the Steam Generator System (SGS) Feedwater control for steam generator(SGs) using the Startup Feedwater Control Valves (SFCV).

SG feedwater control test for each SG is performed with the SFCV initially in manual and the SG level is raised above the setpoint. Then the SFCV is placed in Auto, and the SG level is monitored and verified to return to setpoint. This is reperformed with the SFCV in manual and SG level is lowered and then SFCV is placed in Auto, and SG level is verified to return to setpoint.

The completed test results (References 7 and 8)satisfy the Acceptance Criteria for PLS to provide control interface for SG Feedwater control function.

References 9 and 10 conduct preoperational testing of the Main Steam System turbine bypass valves (Steam Dumps) during HFT, near full temperature and pressure, to demonstrate steam dump valves operate properly in the steam pressure mode, and the Tavg mode to verify PLS control interface functions.

The test initially isolates the steam dumps and demonstrates that in the Tavg mode the appropriate steam dump valves open on simulated Tavg High 1 and on simulated Tavg High 2 conditions to control the RCS temperature. The steam dumps are unisolated and placed in the steam pressure mode, then the setpoint is changed and the valves are monitored to control and increase steam pressure at the new setpoint.

U.S. Nuclear Regulatory Commission ND-19-1047 Enclosure Page 4 of 6 The completed test results (References 9 and 10) satisfy the Acceptance Criteria for PLS to provide control interface for Steam Dump valve control.

References 11 and 12 conduct preoperational testing of the Chemical and Volume Control System during HFT, near full temperature and pressure, to demonstrate the Pressurizer Water Level control interface functions with the PLS.

Testing to demonstrate the automatic makeup function for PZR level control is performed with Reactor Makeup Control System (RCMS)and the Makeup Pump in automatic. Manual Letdown to lower PZR Level is initiated, an automatic makeup start on Pressurizer low level is verified, and letdown is secured. Pressurizer level is monitored and when the makeup stop level is reached, makeup is verified to shut down and the makeup flow control valves close.

Testing to demonstrate the automatic letdown function for PZR level control is performed with RCMS in automatic. A manual makeup is initiated, pressurizer level is monitored, and when letdown initiates on high pressurizer level, makeup is secured and returned to automatic.

Pressurizer level is monitored and when the PZR level is below setpoint letdown is verified to automatically stop and the letdown valves close.

The completed test results (References 11 and 12) satisfy the Acceptance Criteria for PLS to provide control interface for Pressurizer level control functions.

The combination of all the successfully performed preoperational tests and corresponding results confirm that the PLS provides control interfaces for the control functions listed in Table 2.5.3-1.

References 1 through 12 are available for NRC inspection as part of Unit 3 and Unit 4 ITAAC Completion Packages (Reference 13 and 14).

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-19-1047 Enclosure Page 5 of 6 References(available for NRG inspection)

1. 3-PLS-ITPP-520,"Digital Rod Position indication System Preoperationai Test Procedure"

2. 4-PLS-iTPP-520,"Digital Rod Position indication System Preoperationai Test Procedure"

3. 3-PLS-iTPP-507,"Digital Rod Control System Hot Functional Preoperationai Test Procedure"

4. 4-PLS-ITPP-507,"Digital Rod Control System Hot Functional Preoperationai Test Procedure"

5. 3-RCS-ITPP-504,"Reactor Coolant System Pressurizer Pressure, Level, And Spray Precore Hot Functional Test Preoperationai Test Procedure"

6. 4-RCS-ITPP-504,"Reactor Coolant System Pressurizer Pressure, Level, And Spray Precore Hot Functional Test Preoperationai Test Procedure"

7. 3-SGS-ITPP-502,"Steam Generator System Hot Functional Preoperationai Test Procedure"

8. 4-SGS-ITPP-502,"Steam Generator System Hot Functional Preoperationai Test Procedure"

9. 3-MSS-ITPP-502,"Main Steam System Precore Hot Functional Test Procedure" 10.4-MSS-ITPP-502,"Main Steam System Precore Hot Functional Test Procedure" 11.3-CVS-ITPP-502,"Chemical and Volume Control System Pre-core Hot Functional Test Preoperationai Test Procedure" 12.4-CVS-ITPP-502,"Chemical and Volume Control System Pre-core Hot Functional Test Preoperationai Test Procedure" 13.2.5.03.02-U3-CP-Rev0, ITAAC Completion Package 14.2.5.03.02-U4-CP-Rev0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-1047 Enclosure Page 6 of 6 Attachment A COL Appendix C Table 2.5.3-1 Control Functions Supported by the PLS Table 2.5.3-1 Control Functions Supported by the PLS

1. Reactor Power 5. Steam Generator Feedwater

2. Reactor Rod position 6. Steam Dump

3. Pressurizer Pressure 7. Rapid Power Reduction

4. Pressurizer Water Level