ND-19-1330, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.29.02 (Index Number 489)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.29.02 (Index Number 489)

ML19304B950
Person / Time
Site:	Vogtle
Issue date:	10/29/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-19-1330
Download: ML19304B950 (6)

Text

Michael J. Vox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel OCT 2 9 2019 Docket Nos.: 52-025 52-026 ND-19-1330 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 2.3.29.02 findex Number 4891 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 2.3.29.02

[Index Number 489] 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 reguiatory 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 2.3.29.02 [Index Number 489]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-1330 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. 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 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

U.S. Nuclear Regulatory Commission ND-19-1330 Page 3 of 3 Municipal Eiectric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Eiectric Company, LLC Dr. L. Orlani (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, TetraTech NU8, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GD8 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-19-1330 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-19-1330 Enclosure Vogtle Electric Generating Riant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.29.02[Index Number 489]

U.S. Nuclear Regulatory Commission ND-19-1330 Enclosure Page 2 of 3 ITAAC Statement Desion Commitment

2. The WRS collects liquid wastes from the equipment and floor drainage of the radioactive portions of the auxiliary building, annex building, and radwaste building and directs these wastes to a WRS sump or WLS waste holdup tanks located in the auxiliary building.

3. The WRS collects chemical wastes from the auxiliary building chemical laboratory drains and the decontamination solution drains in the annex building and directs these wastes to the chemical waste tank of the liquid radwaste system.

I nspections/Tests/Analvses A test is performed by pouring water into the equipment and floor drains in the radioactive portions of the auxiliary building, annex building, and radwaste building.

A test is performed by pouring water into the auxiliary building chemical laboratory and the decontamination solution drains in the annex building.

Acceptance Criteria The water poured into these drains is collected either in the auxiliary building radioactive drains sump or the WLS waste holdup tanks.

The water poured into these drains is collected in the chemical waste tank of the liquid radwaste system.

ITAAC Completlon Description Testing is performed in accordance with Unit 3 and Unit 4 preoperational tests (References 1 and 2)to confirm the Radioactive Waste Drain System (WRS)collects liquid wastes from the equipment and floor drainage of the radioactive portions of the auxiliary building, annex building, and radwaste building and directs these wastes to a WRS sump or Liquid Radwaste System (WLS) waste holdup tanks located in the auxiliary building. Additionally, testing is performed to confirm WRS collects chemical wastes from the auxiliary building chemical laboratory drains and the decontamination solution drains in the annex building and directs these wastes to the chemical waste tank of the liquid radwaste system.

The drains affected by this ITAAC are listed in attachments in the preoperational test procedures(References 1 and 2) and have been verified by current piping and instrument drawings.

The water poured into these drains is collected either in the auxiliarv building radioactive drains sump or the WLS waste holdup tanks.

Testing is performed by pumping down the WRS sump and installing drain plugs or covers, as appropriate, for all the affected drain paths. Water is poured into the equipment and floor drains of the radioactive portions of the auxiliary building, annex building, and radwaste building. Each

U.S. Nuclear Regulatory Commission ND-19-1330 Enclosure Page 3 of 3 drain Is tested individually while monitoring the sump level and verifying sump level increase or verifying flow from the correct pipe into the sump when water is poured into a drain path.

Additional testing is performed on the WLS waste holdup tanks room drains and auxiliary building elevator pit drain which have normally isolated drain paths. Water is poured into the floor drain and then isolation valves are opened to align the drain to the sump pump suction line to pump the water to one of the WLS waste holdup tanks. Each drain is tested individually while monitoring the tank level and verifying the waste holdup tank level increase.

The Unit 3 and Unit 4 preoperational test results (References 1 and 2)confirm that the water poured into these drains is collected either in the auxiliary building radioactive drains sump or the WLS waste holdup tanks The water poured into these drains is collected in the chemical waste tank of the liquid radwaste svstem.

Testing is performed by initially ensuring an adequate volume is available in the chemical waste tank to accept the water from the testing and installing drain plugs or covers, as appropriate, for all the affected drains. The cover for the drain to be tested is removed and water is poured into each of the drains in the auxiliary building chemical laboratory and the decontamination solution drains in the annex building, one drain at a time, while monitoring the chemical waste tank level of the WLS and verifying the tank level increases for each drain tested.

The Unit 3 and Unit 4 preoperational test results (References 1 and 2)confirm that the water poured into these drains is collected in the chemical waste tank of the liquid radwaste system.

References 1 and 2 are available for NRC inspection as part of ITAAC 2.3.29.02 Unit 3 and 4 Completion Packages(Reference 3 and 4).

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 NRC inspection^

1. 3-WRS-ITPP-501,"Radioactive Waste Drain System Preoperational Test Procedure"

2. 4-WRS-ITPP-501,"Radioactive Waste Drain System Preoperational Test Procedure"

3. 2.3.29.02-U3-CP-Rev0, ITAAC Completion Package

4. 2.3.29.02-U4-CP-Rev0, ITAAC Completion Package

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