ND-20-0099, Notice of Uncompleted ITAAC 225-Days Prior to Initial Fuel Load Item 2.2.01.11a.iii (Index Number 116)

Notice of Uncompleted ITAAC 225-Days Prior to Initial Fuel Load Item 2.2.01.11a.iii (Index Number 116)

ML20031D681
Person / Time
Site:	Vogtle
Issue date:	01/31/2020
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-0099
Download: ML20031D681 (8)

Text

>-e. Southern Nuclear Michael J . Yox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel JAN 3 1 2020 Docket Nos.: 52-025 52-026 ND-20-0099 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-days Prior to Initial Fuel Load Item 2.2.01 .11 a.iii [Index Number 116)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of Jan. 30, 2020, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspection, Test, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.01 .11 a.iii

[Index Number 116) has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.2.01 .11 a.iii [Index Number 116]. 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 2.2.01 .11 a.iii [Index Number 116) ND 1134 [ML17186A036), dated June 30, 2017. This resubmittal supersedes ND-17-1134 in its entirety.

This notification is informed by the guidance described in NEl-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 ITMC for which required inspections, tests, or analyses have not been performed or have been only partially completed.

All lTAAC 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, Regulatory Affairs D" ector Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-20-0099 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.01 .11 a.iii [Index Number 116]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-20-0099 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena Ill (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. P. Martino 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 Regulatory Commission Mr. W. Jones (w/o enclosures)

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 Mr. C. Santos Mrs. M. Bailey Mr. S. Rose Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Ms. K. Carrington

U.S. Nuclear Regulatory Commission ND-20-0099 Page 4 of 4 Mr. P. Heher Mr. M. King Mr. E. Davidson Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson 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 Mr. Z. S. 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., GOS Associates, Inc.

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

U.S. Nuclear Regulatory Commission ND-20-0099 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-20-0099 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and 4 Completion Plan for Uncompleted ITAAC 2.2.01 .11 a.iii [Index Number 116]

U.S. Nuclear Regulatory Commission ND-20-0099 Enclosure Page 2 of 4 ITAAC Statement Design Commitment 11.a) The motor-operated and check valves identified in Table 2.2.1-1 perform an active safety-related function to change position as indicated in the table.

Inspections/Tests/Analyses iii) Tests of the motor-operated valves will be performed under preoperational flow, differential pressure, and temperature conditions.

Acceptance Criteria iii) Each motor-operated valve changes position as indicated in Table 2.2.1-1 under pre-operational test conditions.

IT AAC Completion Description Multiple ITAAC are performed to verify that the motor-operated and check valves identified in Combined License (COL) Appendix C Table 2.2.1-1 (Attachment A) perform an active safety-related function to change position as indicated in Attachment A. The subject ITAAC verifies testing of the motor-operated valves (MOVs) under preoperational flow, differential pressure, and temperature conditions.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-SFS-ITPP-502 and 4-SFS-ITPP-502 (References 1 and 2), 3-CCS-ITPP-501 and 4-CCS-ITPP-501 (References 3 and 4), and 3-VFS-ITPP-501 and 4-VFS-ITPP-501 (References 5 and

6) to verify that the motor-operated valves identified in Attachment A perform an active safety-related function to change position as indicated in Attachment A. Testing is performed on the MOVs under pre-operational flow, differential pressure, and temperature conditions and each MOV is verified to change positions as indicated in Attachment A.

References 1 and 2 confirm that each of the Spent Fuel Pool Cooling System (SFS) MOVs listed in Attachment A can be closed under preoperational flow, differential pressure, and temperature conditions. The SFS is aligned to take a suction from the refueling cavity and discharge back to the refueling cavity. The SFS valves listed in Attachment A are verified to be open, an SFS pump is placed in service recirculating the refueling cavity, SFS-PL-V034 is placed in local control, and a spent fuel pool low level signal is generated to close the SFS valves in Attachment A. SFS-PL-V035 and SFS-PL-V038 are verified to close locally and in the Main Control Room (MCR) and the SFS pump is verified to trip on low flow. SFS-PL-V034 is returned to remote control and SFS-PL-V035 is placed in local control. The SFS valves in Attachment A are verified open, an SFS pump is placed in service recirculating the refueling cavity and the spent fuel pool low level signal is generated again causing the SFS valves to close. SFS-PL-V034 is verified to close locally and in the MCR. The results of the Unit 3 and Unit 4 tests are documented in References 1 and 2.

References 3 and 4 confirm that each of the Unit 3 and Unit 4 Component Cooling Water System (CCS) MOVs listed in Attachment A can be closed under preoperational flow,

U.S. Nuclear Regulatory Commission ND-20-0099 Enclosure Page 3 of 4 differential pressure, and temperature conditions. The CCS system is aligned with normal flow to and from containment with the A CCS pump in service. The CCS MOVs in Attachment A are closed one at a time, verified to be closed by MCR indication and locally and then reopened to reestablish system flow. The results of the Unit 3 and Unit 4 tests are documented in References 3 and 4.

References 5 and 6 confirm that each of the Containment Air Filtration System (VFS) MOVs listed in Attachment A can be closed and opened under preoperational flow, differential pressure, and temperature conditions. The VFS is in a normal system alignment and each of the MOVs listed in Attachment A are operated to the open position, verified locally and in the MCR and then operated to the closed position and verified locally and in the MCR. The results of the Unit 3 and Unit 4 tests are documented in References 5 and 6.

References 1 through 6 confirm that each motor-operated valve changes position as indicated in Attachment A under pre-operational test conditions. References 1 through 6 are available for NRC inspection as part of the ITAAC 2.2.01 .11 a.iii Completion Package (Reference 7).

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 (available for NRC inspection)

1. 3-SFS-ITPP-502, "Spent Fuel Pool Cooling System Flow Path Preoperational Test Procedure"

2. 4-SFS-ITPP-502, "Spent Fuel Pool Cooling System Flow Path Preoperational Test Procedure"

3. 3-CCS-ITPP-501, "Component Cooling Water System Preoperational Test Procedure"

4. 4-CCS-ITPP-501, "Component Cooling Water System Preoperational Test Procedure"

5. 3-VFS-ITPP-501, "Containment Air Filtration System Preoperational Test Procedure"

6. 4-VFS-ITPP-501, "Containment Air Filtration System Preoperational Test Procedure"

7. ITAAC 2.2.01 .11a.iiii Completion Package

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

U.S. Nuclear Regulatory Commission ND-20-0099 Enclosure Page 4 of 4 Attachment A Excerpt from COL Appendix C Table 2.2.1-1 Equipment Name Tag No. Active Function Component Cooling Water System (CCS) Containment Isolation Motor-operated Valve CCS-PL-V200 Transfer Closed (MOV) - Inlet Line Outside Reactor Containment (ORC)

CCS Containment Isolation CCS-PL-V207 Transfer Closed MOV - Outlet Line IRC CCS Containment Isolation CCS-PL-V208 Transfer Closed MOV - Outlet Line ORC SFS Discharge Line Containment Isolation MOV - SFS-PL-V038 Transfer Closed ORC SFS Suction Line Containment SFS-PL-V034 Transfer Closed Isolation MOV - IRC SFS Suction Line Containment SFS-PL-V035 Transfer Closed Isolation MOV - ORC Vacuum Relief Containment Transfer Closed/ Transfer VFS-PL-VB00A Isolation A MOV - ORC Open Vacuum Relief Containment Transfer Closed/ Transfer VFS-PL-VB00B Isolation B MOV - ORC Open