ND-18-0227, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.5.05.02.i (Index Number 565)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.5.05.02.i (Index Number 565)

ML18054A565
Person / Time
Site:	Vogtle
Issue date:	02/22/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.5.05.02.i, ND-18-0227
Download: ML18054A565 (10)

Text

Michael J. Yox 7825 River Road Regulatory Affairs Director Waynesfxtro, GA 30830 A Southern Nuclear Vogtle 3 & 4 706-848-6459 tei 410-474-8587 ceii FEB 2 2 2018 myox@southernco.com Docket Nos.: 52-025 52-026 ND-18-0227 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 2.5.05.02.1 [Index Number 5651 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of February 16, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 2.5.05.02.1 [Index Number 565] 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 Directbr Vogtle 3 &4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.5.05.02.1 [Index Number 565]

MJY/RAS/amw

U.S. Nuclear Regulatory Commission ND-18-0227 Page 2 of 3 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. McKinney Mr. M. J. Yox 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. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reaulatorv 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 Ms. L. A. Kent Oaiethoroe Power Corporation Mr. R. B. Brinkman Municipal Electric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-18-0227 Page 3 of 3 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. D. Hawkins Ms. J. Monahan Mr. J. L. Coward Ms. N. E. Deangelis 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, Baich Bingham

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 1 of 7 Southern Nuclear Operating Company ND-18-0227 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.5.05.02.1 [Index Number 565]

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 2 of 7 ITAAC Statement Design Commitment

2. The seismic Category I equipment identified in Table 2.5.5-1 can withstand seismic design basis dynamic loads without loss of safety function.

3.a) The Class 1E equipment identified in Table 2.5.5-1 as being qualified for a harsh environment can withstand the environmental conditions that would exist before, during, and following a design basis accident without loss of safety function, for the time required to perform the safety function.

Insoections. Tests. Analvses i) Inspection will be performed to verify that the seismic Category I equipment identified in Table 2.5.5-1 is located on the Nuclear Island.

11) Type tests, analyses, or a combination of type tests and analyses of seismic Category I equipment will be performed.

ill) Inspection will be performedfor the existence of a report verifying that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions.

i) Type tests, analysis, or a combination of type tests and analysis will be performed on Class 1E equipment located in a harsh environment.

ii) Inspection will be performed of the as-built Class 1E equipment and the associated wiring, cables, and terminations located in a harsh environment.

Acceotance Criteria i) The seismic Category I equipment identified in Table 2.5.5-1 is locatedon the Nuclear Island.

ii) A report exists and concludes that the seismic Category I equipmentcan withstand seismic design basis dynamic loads without loss of safety function.

iii) A report exists and concludes that the as-built equipment including anchorage is seismicaliy bounded by the tested or analyzed conditions.

i) A report exists and concludes that the Class 1E equipment identified in Table 2.5.5-1 as being qualified for a harsh environment. This equipmentcan withstand the environmental conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

ii) A report exists and concludes that the as-built Class 1E equipment and the associated wiring, cables, and terminations identified in Table 2.5.5-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and anaiyses.

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 3 of 7 ITAAC Completion Description This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the In-core Instrumentation System (IIS) equipment identified as seismic Category I or Class 1E in the Combined License (COL) Appendix C, Table 2.5.5-1 (the Table) is designed and constructed in accordance with applicable requirements.

i) The seismic Category I eouioment identified in Table 2.5.5-1 is located on the Nuclear Island.

To assure that seismic Category I equipment can withstand seismic design basis loads without loss of safety function, all the equipment in the Table is designed to be located on the seismic Category I Nuclear Island. In accordance with Equipment Qualification (EG) Walkdown ITAAC Guideline (Reference 1), an inspection is conducted of the IISto confirm the satisfactory installation of the seismically qualified equipment. The inspection includes verification of equipment make/model/serial number and verification of equipment location (Building, Elevation, Room). The EG As-Built Reconciliation Reports (EQRR) (Reference 2) identified in Attachment A document the results of the inspection and conclude that the seismic Category I equipment is located on the Nuclear Island.

ii) A report exists and concludes that the seismic Cateoorv I equipment can withstand seismic design basis dvnamic loads without loss of safetv function.

Seismic Category I equipment in the Table requires type tests and/or analyses to demonstrate structural integrity and operability. Structural integrity of the passive seismic Category I mechanical equipment is demonstrated by analysis in accordance with American Society of Mechanical Engineers (ASME) Code Section III (Reference 3).

Safety-related (Class 1E) electrical equipment in the Table is seismically qualified by type testing combinedwith analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference4). This equipment includes safety-related (Class 1E) field sensors and the safety-related electrical connectorassemblies. The specific qualification method (i.e., type testing, analysis, or combination) used for each piece of equipment in the Table is identified in Attachment A. Additional information about the methods used to qualify API000 safety-related equipment is provided inthe Updated Final Safety Analysis Report (UFSAR) Appendix 3D (Reference 5). The EG Reports (Reference 6) identified in Attachment A contain applicable test reports and associated documentation and conclude that the seismic Category Iequipment can withstand seismic design basis loads without loss of safety function.

iiil A reoort exists and concludes that the as-built eouioment including anchorage is seismicallv bounded bv the tested or analvzed conditions.

An inspection (Reference 1) is conducted to confirm the satisfactory installation of the seismicallyqualified equipment in the Table. The inspection verifies the equipment make/model/serial number, as-designed equipment mounting orientation, anchorage and clearances, and electrical and other interfaces. The documentation of installed configuration of seismically qualified equipment includes photographs and/or sketches/drawings of equipment/mounting/interfaces.

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 4 of 7 As part of the seismic qualification program, consideration is given to the definition of the clearances needed around the equipment mounted in the plant to permit the equipment to move during a postulated seismic event without causing impact between adjacent pieces of safety-related equipment. This is done as part of seismic testing by measuring the maximum dynamic relative displacement of the top and bottom of the equipment. EQ Reports (Reference 6) identify the equipment mounting employed for qualification and establish interface requirements for assuring that subsequent in-plant installation does not degrade the established qualification.

Interface requirements are defined based on the test configuration and other design requirements.

Attachment A identifies the EQRR (Reference 2) completed to verify that the as-built seismic Category Iequipment listed in the Table, including anchorage, is seismically bounded by the tested or analyzed conditions, IEEE Standard 344-1987 (Reference 4), and NRC Regulatory Guide (RG) 1.100 (Reference 7).

h A reoort exists and concludes that the Class 1E eauioment identified in Table 2.5.5-1 as being Qualified for a harsh environment. This eouioment can withstand the environmental conditions that would exist before, durino. and followino a desion basis accident without loss of safetv function for the time reouired to perform the safetv function.

The harsh environment Class 1E equipment in the Table is qualified by type testing and/or analyses. Class 1E electrical equipment type testing is performed in accordance with IEEE Standard 323-1974 (Reference 8) and RG 1.89 (Reference 9) to meet the requirements of 10 CFR 50.49. Type testing of safety-related equipment meets the requirements of 10 CFR Part 50, Appendix A, General Design Criterion 4. Attachment Aidentifies the EQ program and specific qualification method for each piece of Class IE electrical equipment located in a harsh environment. Additional information about the methods used to qualify API 000 safety-related equipment is provided in the UFSAR Appendix 3D (Reference 5). EQ Reports (Reference 6) identified in Attachment A contain applicable test reports and associated documentation and concludethat the equipment can withstand the environmental conditions that would exist before, during, andfollowing a design basis accident without loss of safety function for the time required to perform the safety function.

iil A reoort exists and concludes that the as-built Class 1E eouioment and the associated wirino. cables, and terminations identified in Table 2.5.5-1 as beino Qualified for a harsh environment are bounded bv tvpe tests, analvses. or a combination of tvoe tests and analvses.

An inspection (Reference 1) is conducted of the IIS to confirm the satisfactory installation ofthe Class 1E equipment in the Table. The inspection verifies the equipment location, make/model/serial number, as-designed equipment mounting, wiring, cables, and terminations, and confirms that the environmental conditions for the zone (Attachment A) in which the equipment is mounted are bounded bythe tested and/oranalyzed conditions. It also documents the installed configuration with photographs or sketches/drawings of equipment mounting and connections. The EQRR (Reference 2) identified in Attachment Adocument this inspection and conclude that the as-built harsh environment Class 1E equipment and the associated wiring, cables, and terminations are bounded bythe qualified configuration and IEEE Standard 323-1974 (Reference 8).

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 5 of 7 Together, these reports (References 2 and 6) provide evidence that the ITAAC Acceptance Criteria requirements are met:

• The seismic Category I equipment identified in Table 2.5.5-1 is located on the Nuclear Island;

• A report exists and concludes that the seismic Category I equipment can withstand seismic design basis dynamic loads without loss of safety function;

• A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions;

• A report exists and concludes that the Class 1E equipment identified in Table 2.5.5-1 as being qualified for a harsh environment. This equipment can withstand the environmental conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function; and

• A report exists and concludes that the as-built Class 1E equipment and the associated wiring, cables, and terminations identified in Table 2.5.5-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

References 2 and 6 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 2.5.05.02.1 Completion Packages (References 10 and 11, respectively).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern Nuclear Operating Company (SNC) performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This finding review, which included now-consolidated ITAAC Indexes 566, 567, 568, and 569, found no relevant ITAAC findings associated with this ITAAC.

References (available for NRC inspection)

1. ND-xx-xx-001, "EG Walkdown ITAAC Guideline"

2. EQ As-Built Reconciliation Reports (EQRR) as identified in AttachmentA for Units 3 and 4

3. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code,Section III, "Rules for Construction of Nuclear Power Plant Components," 1998 Edition with 2000 Addenda

4. IEEE Standard 344-1987, "IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations"

5. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, "Methodology for Qualifying API 000 Safety-Related Electrical and Mechanical Equipment"

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 6 of 7

6. Equipment Qualification (EG) Reports as identified in Attachment A

7. Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"

8. IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"

9. Regulatory Guide 1.89, Rev 1, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants" 10.2.5.05.02.i-U3-CP-Rev X, "Completion Package for Unit 3 ITAAC 2.5.05.02.i [Index Number 565]"

11.2.5.05.02.i-U4-CP-Rev X, "Completion Package for Unit 4 ITAAC 2.5.05.02.1 [Index Number 565]"

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

U.S. Nuclear Regulatory Commission ND-18-0227 Enclosure Page 7 of 7 Attachment A System: In-core Instrumentation System (IIS)

CiasslE/

Seismic Quai. For Envir Quai Type of EG Reports As-Buiit EORR Equipment Name ^ Envir. Zone ^

Cat. i

• Harsh Envir. Program ^ Quai. (Reference 6) (Reference 2) ^

+

Incore Thimble Assemblies (at APP-JS94-VBR-002 /

Type Tests & 2.5.05.02.i-U3-EQRR-least three assemblies in each Yes Yes^Wes^^> 1 E*S APP-JS94-VBR-001/

Analysis PCDXXX core quadrant) APP-JS94-VFR-XXX Notes:

+ Excerpt from COL Appendix C Tabie 2.5.5-1

1. See Table 3D.5-1 of UFSAR

2. E - Electrical Equipment Program S = Quaiified for submergence or operation with spray

• - Harsh Environment

3. The Unit 4 As-Built EORR are numbered "2.5.05.02.i-U4-EQRR-PCDXXX"

4. Only applies to the safety-related assemblies. There are at ieast two safety-reiated assemblies in each core quadrant.