ND-18-0123, Notice of Uncompleted ITAAC 225-Days Prior to Initial Fuel Load Item 2.3.10.02a (Index Number 431)

Notice of Uncompleted ITAAC 225-Days Prior to Initial Fuel Load Item 2.3.10.02a (Index Number 431)

ML18032A586
Person / Time
Site:	Vogtle
Issue date:	01/30/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-18-0123
Download: ML18032A586 (13)

Text

Michael J. Yox 7825 River Road Regulatory Affairs Director Waynestx)ro, GA 30830 hk. Southern Nuclear Vogtle 3 & 4 706-848-6459 tel 410-474-8587 cell myox@southernco.coni JAN 3 0 2018 Docket Nos.: 52-025 52-026 ND-18-0123 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 2.3.10.02a findex Number 4311 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of January 29, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.10.02a

[Index Number431] 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 priorto 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-18-0123 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.10.02a [Index Number431]

MJY/pgl/amw

U.S. Nuclear Regulatory Commission ND-18-0123 Page 3 of 4 To:

Southern Nuclear Operating Company / Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. M. D. Rauckhorst (w/o enclosures)

Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKlnney Mr. M. J. Vox Mr. D. L. Fulton Mr. J. D. Williams Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. 0. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. R. L. Beiike Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reoulatorv Commission Mr. W. Jones (w/o enclosures)

Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. T. C. Brimfield Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Oolethorpe Power Corporation Mr. K. T. Haynes Mr. R. B. Brinkman Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-18-0123 Page 4 of 4 Dalton Utilities Mr. T. Bundros Westinahouse 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. D. Hawkins Ms. 8. DiTommaso Mr. J. L. Coward Ms. N. E. Deangelis 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 Pubiic Sen/ice Commission Ms. 8. W. Kernizan, Georgia Pubiic Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-18-0123 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.10.02a [Index Number 431]

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 2 of 9 ITAAC Statement Design Commitment:

2.a) The components identified in Table 2.3.10-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

2.b) The piping identified in Table 2.3.10-2 as ASME Code Section III is designed and constructed in accordance with ASME Code Section III requirements.

3.a) Pressure boundary welds in components identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements.

3.b) Pressure boundary welds in piping identified in Table 2.3.10-2 as ASME CodeSection III meet ASME Code Section III requirements.

4.a) The components identified in Table2.3.10-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified inTable 2.3.10-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure.

5.b) Each of the lines identified in Table 2.3.10-2 for which functional capability is required is designed to withstand combined normal and seismic design basis loads without a lossof its functional capability.

Insoections. Tests. Analyses:

Inspection will be conducted of the as-built components and piping as documented in the ASME design reports.

Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section III.

Ahydrostatic test will be performed onthe components and piping required by the ASME Code Section III to be hydrostatically tested.

Inspection will be performed for the existence ofa report verifying thatthe as-built piping meets the requirements for functional capability.

Acceptance Criteria:

The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III.

Areport exists and concludes thatthe ASME Code Section III requirements are met for non destructive examination of pressure boundary welds.

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 3 of 9 A report exists and concludes that the results of the hydrostatictest of the components and piping Identified In Tables 2.3.10-1 and 2.3.10-2as ASME Code Section III conform with the requirements of the ASME Code Section III.

A report exists and concludes that each of the as-bullt lines Identified In Table 2.3.10-2 for which functional capability Is required meets the requirements for functional capability.

ITAAC ComDietlon Description This ITAAC requires Inspections, tests, and analyses be performed and documented to ensure the Liquid Radwaste System (WLS) components and piping listed In the Combined License (COL) Appendix C, Table 2.3.10-1 (Attachment A) and Table 2.3.10-2 (Attachment B) that are Identified as American Society of Mechanical Engineers (ASME) Code Section III or Functional Capability Required are designed and constructed In accordance with applicable requirements.

2.a and 2.b) The ASME Code Section III deslon reoorts exist for the as-bullt components and ololno Identified In Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III.

Each component listed In Table 2.3.10-1 as ASME Code Section III Is fabricated In accordance with the VEGP Updated Final Safety Analysis Report (UFSAR) and the ASME Code Section III requirements. The ASME Code Section III certified Design Reports for these components exist and document that the as-bullt components conform to the approved design details. The ASME Section III Design Report for each component Is documented In the component's completed ASME Section III Code Data Report. The Individual component ASME Section III Code Data Reports are documented on the ASME Section III N-5 Code Data Report(s) for the applicable piping system (Reference 1).

The as-bullt piping listed In Table 2.3.10-2 Including the components listed In Table 2.3.10-1 as ASME Code Section III, Is subjected to a reconciliation process (Reference 2), which verifies that the as-bullt piping Is analyzed for applicable loads (e.g., stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-bullt systems.

Including Installed components, validates that construction completion. Including field changes and any nonconforming condition dispositions. Is consistent with and bounded by the approved design. All applicable fabrication. Installation and testing records, as well as, those for the related QualityAssurance (OA) verification/Inspection activities, which confirm adequate construction In compliance with the ASME Code Section III and design provisions, are referenced In the N-5 data report and/or Its sub-tier references.

The applicable ASME Section III N-5 Code Data Report(s), which Include the location of the certified Design Reports for all the components listed In Table 2.3-10-1 (Attachment A) and piping listed In Table 2.3.10-2 (Attachment B) as ASME Code Section III, exist and conclude that these Installed components are designed and constructed (Including their Installation within the applicable as-bullt piping system) In accordance with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements as applicable, as described In UFSAR Subsection 5.2.1 (Reference 3). The N-5 Code Data Reports for the piping system(s) containing the components listed In the Table 2.3.10-1 and Table 2.3.10-2 are Identified In Attachments A and B, respectively.

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 4 of 9 3.a and 3.bf A report exists and concludes that the ASME Code Section III reouirements are met for non-destructive examination of oressure boundary welds.

Inspections are performed in accordance with ASME Code Section III (1998 Edition, 2000 Addenda) to demonstrate that as-built pressure boundary welds in components identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications).

The applicable non-destructive examinations (including liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the components' pressure boundary welds are documented in the Non-destructive Examination Report(s), which support completion of the respective ASME Section III N-5 Code Data Report(s) certified by the Authorized Nuclear Inspector, as listed in Attachment A.

Per ASME Code Section III, Subarticle NCA-8300, "Code Symbol Stamps," the N-5 Code Data Report(s) (Reference 1) documents satisfactory completion of the required examination and testing of the item, which includes non-destructive examinations of pressure boundary welds. Satisfactory completion of the non-destructive examination of pressure boundary welds ensures that the pressure boundary welds in components identified in Table 2.3.10-1 as ASME Code Section III meet ASME Code Section III requirements.

An inspection is performedin accordance with Reference 3 to demonstrate that the as-built pressure boundary welds in piping identified in Table 2.3.10-2 (Attachment B) as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications). This portion of the ITAAC is complete when the piping identified in Table 2.^10-2, which is encompassed within the respective pipingsystem Code Symbol N-Stamp and the corresponding piping system Code N-5 Data Report Form(s) (Reference 1), is complete. The non-destructive examinations (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the piping pressure boundary welds are documented inthe Non-destructive Examination Report(s) within the piping system's supporting data package, which support completion ofthe respective Code Stamping and Code N-5 Data Report(s). The completion of stamping the respective piping system along with the corresponding ASME Code N-5 Data Report Form(s) (certified by the Authorized Nuclear Inspector) ensure that the piping is constructed in accordance with the design specification(s) and the ASME CodeSection III and that the satisfactoiy completion of the non-destructive examinations of piping pressure boundary welds for the pipe lines identified in Table 2.3.10-2 meet ASME Code Section III requirements and are documented in the Non destructive Examination Report(s) within the supporting data packages.

4.a and 4.b1 A report exists and concludes that the results of the hvdrostatic test of the comoonents and pipino identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III conform with the reouirements of the ASME Code Section III.

A hydrostatic test is performed bythe vendor to demonstrate that the components identified in Table 2.3.10-1 (Attachment A) as ASME Code Section III retain their pressure boundary integrity at theirdesign pressure. The completion of the N-5 Data Reports is governed by Reference 2.

This portion of the ITAAC is completeonce each component identified in Table 2.3.10-1 has their individual Code Symbol N-Stamp and corresponding Code Data Report (Reference 1)

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 5 of 9 completed, and the components are installed intothe respective Code Symbol N-Stamped piping system and documented on the corresponding N-5 Code Data Report(s) (Reference1).

The hydrostatic testing results of the component's pressure boundaryare documented in the Hydrostatic Testing Report(s) within the supporting component's data package, which support completion of the respective Code Stamping and Code Data Report(s).

The completion of stamping the individual components and the respective piping system along with the corresponding ASME Code Data Reports (certified by the Authorized Nuclear Inspector) ensures that the components are constructed in accordance with the Design Specifications and the ASME Code Section III and that the satisfactory completion of the hydrostatic pressure testing of each component identified in Table 2.3.10-1 as ASME Code Section III are documented in the HydrostaticTesting Report(s) within the supporting data packages and meets ASME Code Section III requirements.

This ITAAC also verifies that the piping identified in Table 2.3.10-2 (Attachment B) fully meets all applicable ASME Code,Section III requirements and retains its pressure boundary integrity at its design pressure.

A hydrostatic test is performed in accordance with procedure XYZ (as applicable) that complies with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements to demonstrate that the ASME Code Section III piping identified in Table 2.3.10-2 retains its pressure boundary integrity at its design pressure.

A hydrostatic test verifies there are no leaks at welds or piping, and that the pressure boundary integrity is retained at its design pressure. The hydrostatic testing results ofthe pipe lines are documented in the Hydrostatic Testing Report(s). The Hydrostatic Testing Report(s) supports completion of the ASME Section III N-5 Code Data Report(s) for the applicable piping system (i.e., WLS) (Reference 1).

The applicable ASME Section III N-5 Code Data Report(s) (Reference 1) identified in Attachments A and B documents that the results of the hydrostatic testing of the components and piping identified in Table 2.3.10-1 and Table 2.3.10-2 respectively conform with the requirements of the Code (1998 Edition, 2000 Addenda),Section III.

5.b1 A reoort exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional caoabilitv is reauired meets the reouirements for functional capability.

An inspection is performed ofthe ASME Section III as-built piping design report XXX to verify that the report demonstrates that each of the WLS piping lines identified in ITAAC Table 2.3.10-2 that requires functional capability is designed to withstand combined normal and seismicdesign basis loads without a loss of itsfunctional capability. "Functional capability," in this context, refers to the capability of the piping to withstand the effects of earthquakes, without a loss of safety function (to convey fluids from one location to another). Specific functional capability requirements are defined in the VEGP UFSAR Table 3.9-11 (Reference 3).

Piping functional capability is not a specific ASME Code requirement but it is a requirement in the VEGP UFSAR (Reference 3). As such, information demonstrating that UFSAR functional capability requirements are met is included in the ASME Section III As-Built Design Reports for safety class piping prepared in accordance with ASME Section III NCA-3550 under theASME

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 6 of 9 Boiler & Pressure Vessel Code (1998 Edition, 2000 Addenda)Section III requirements. The as-built piping systems are subjected to a reconciliation process (Reference 2), which verifies that the as-built piping systems are analyzed for functional capability and for compliance with the design specification and ASME Code provisions. Design reconciliation of the as-built systems validates that construction completion, includingfield changes and any nonconforming condition dispositions, is consistent with and bounded by the approved design. As required by ASME Code, the As-Built Design Report includes the results of physical inspection of the piping and reconciliation to the design pipe stress report.

Inspections of the ASME Code Section III As-Built Piping Design Reports (Reference 4) for the WLS piping lines identified in Table 2.3.10-2 are complete and conclude that each of the as-built WLS piping lines for which functional capability is required meets the requirements for functional capability. The ASME Section III As-Built Piping Design Reports for each of the as-builtWLS piping lines in Table 2.3.10-2 are identified in Attachment B.

References 1 and 4 provide the evidence that the ITAAC Acceptance Criteria requirements are met:.

• The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III;

• A reportexists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds;

• A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III conform with the requirements of the ASME Code Section III; and

• A report exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional capability is required meets the requirements for functional capability.

References 1 and 4 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.3.10.02a Completion Packages (References 5 and 6, respectively).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern NuclearOperating Company (SNC) performed a review of all ITAAC findings and associated corrective actions.

This review, which included now consolidated ITAAC Indexes 432, 433, 434, 435, 436 and 440, found no relevant ITAAC findings associated with this ITAAC.

References favailable for NRC inspection)

1. WLS ASME N-5 Code Data Report(s)

2. APP-GW-GAP-139, 'Westinghouse/WECTEC ASME N-5 Interface Procedure"

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 7 of 9

3. VEGP 3&4 Updated Final Safety Analysis Report

a. Subsection 5.2.1 Compliance with Codes and Code Cases

b. Table 3.9 Piping Functional Capability - ASME Class 1, 2, and 3

4. WLS ASME III As Built Design Repoil(s)

5. Completion Package for Unit 3 ITAAC 2.3.10.02a [COL Index Number431]

6. Completion Package for Unit 4 ITAAC 2.3.10.02a [COL Index Number 431]

7. NEI 08-01, "Industry Guideline forthe ITAAC Closure Process Under 10 CFR Part 52"

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 8 of 9 Attachment A SYSTEM: Liquid Radwaste System (WLS)

ASME III as-ASME Code Equipment Name

• Tag No.

• bullt Design N-5 Report Section III*

Report WLS Drain from Passive Core Cooling System (PXS) Compartment A WLS-PL-V071B Yes XXX N-5 Code Data Report (Room 11206) Check Valve WLS Drain from PXS Compartment A (Room WLS-PL-V072B Yes XXX N-5 Code Data Report 11206) Check Valve WLS Drain from PXS Compartment B (Room WLS-PL-V071C Yes XXX N-5 Code Data Report 11207) Check Valve WLS Drain from PXS Compartment B (Room WLS-PL-V072C Yes XXX N-5 Code Data Report 11207) Check Valve WLS Drain from Chemical and Volume Control System (CVS) WLS-PL-V071A Yes XXX N-5 Code Data Report Compartment (Room 11209) Check Valve WLS Drain from CVS Compartment (Room WLS-PL-V072A Yes XXX N-5 Code Data Report 11209) Check Valve "Excerptsfrom COLAppendix C Table 2.3.10-1

U.S. Nuclear Regulatory Commission ND-18-0123 Enclosure Page 9 of 9 Attachment B SYSTEM: Liquid Radwaste System (WLS)

ASME Functional ASME III As-Line Code Line Name* Capability Built Design Number* Section N-5 Report Required* Report ill*

WLS Drain from PXS N-5 Code Data WLS-PL-L062 Yes Yes XXX Compartment A Report WLS Drain from PXS N-5 Code Data WLS-PL-L063 Yes Yes XXX Compartment B Report WLS Drain from CVS N-5 Code Data WLS-PL-L061 Yes Yes XXX Compartment Report

'Excerpts from COL Appendix C, Table 2.3.10-2