ND-18-0317, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.02.02a (Index Number 120)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.02.02a (Index Number 120)

ML18074A041
Person / Time
Site:	Vogtle
Issue date:	03/15/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.2.02.02a, ND-18-0317
Download: ML18074A041 (14)

Text

Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tei 410-474-8587 ceii myox @southernco.com Docket Nos.: 52-025 52-026 ND-18-0317 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 2.2.02.02a [Index Number 1201 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of March 5, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.02.02a [Index Number 120]

has not been completed greater than 225-days priorto 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. Yox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.02.02a [Index Number 120]

MJY/KJD/amw

U.S. Nuclear Regulatory Commission ND-18-0317 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. Vox Mr. D. L. Fulton Mr. J. B. Klecha 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. N. D. Karlovich 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 Mr. P. B. Donnelly Ooiethoroe Power Corporation Mr. R. B. Brinkman Municioai Eiectric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-18-0317 Page 3 of 3 Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. C. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Mr. D. Hawkins Ms. J. Monahon 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. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 1 of 11 Southern Nuclear Operating Company ND-18-0317 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.02.02a [Index Number 120]

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 2 of 11 ITAAC Statement Design Commitment:

2.a) The components identified in Table 2.2.2-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

2.b) The pipelines identified in Table 2.2.2-2 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

3.a) Pressure boundary welds in components identified in Table 2.2.2-1 as ASME Code Section III meet ASME Code Section III requirements.

3.b) Pressure boundary welds in the pipelines identified in Table 2.2.2-2 as ASME Code Section III meet ASME Code Section III requirements.

4.a) The components identified in Table 2.2.2-1 as ASME CodeSection III retain their pressure boundary integrity at their design pressure.

4.b) The pipelines identified in Table 2.2.2-2 as ASME CodeSection III retain their pressure boundary integrity at their design pressure.

5.b) Each of the pipelines identified in Table 2.2.2-2 for which functional capability is required is designed to withstand combined normal and seismic design basis loads without a loss of its functional capability.

Insoections. Tests. Analyses:

Inspection will beconducted 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 on the components and piping required by the ASME Code Section III to be hydrostatically tested.

Inspection will be performed for the existence of a report concluding that the as-built pipelines meet 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 2.2.2-1 and 2.2.2-2 as ASME Code Section III.

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

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 3 of 11 A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.2-1 and 2.2.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

A report exists and concludes that each of the as-built pipelines identified in Table 2.2.2-2 for which functional capability is required meets the requirements for functional capability.

ITAAC Completion Description This ITAAC requires inspections, tests, and analyses be performed and documented to ensure the Passive Containment Cooling System (PCS) components and piping listed in the Combined License (COL) Appendix C, Table 2.2.2-1 (Attachment A) and Table 2.2.2-2 (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.b1 The ASME Code Section III desion reoorts exist for the as-built components and Dioina identified in Tables 2.2.2-1 and 2.2.2-2 as ASME Code Section III.

Each component listed in Table 2.2.2-1 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-built 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 onthe ASME Section III N-5 Code Data Report(s) for the applicable piping system (Reference 1).

The as-built piping listed in Table 2.2.2-2 including the components listed in Table2.2.2-1 as ASME Code Section III, are subjected to a reconciliation process (Reference 2), which verifies that the as-built piping are analyzed for applicable loads (e.g., stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-built systems, including installed components, validates that construction completion, including field changes and any nonconforming condition dispositions, isconsistent with and bounded by the approved design. All applicable fabrication, installation andtesting records, as well as, those for the related Quality Assurance (OA) verification/ inspection activities, which confirm adequate construction in compliance with the ASME Code Section III anddesign 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 2.2.2-1 (Attachment A) and piping listed in Table 2.2.2-2 (Attachment B) as ASME CodeSection III, exist and conclude that these installed components are designed and constructed (including their installation within the applicable as-built piping system) in accordance with the ASME Code (1998 Edition, 2000 Addenda and 1989 Edition, 1989 Addenda),Section III requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference3). The N-5 Code Data Reportsforthe piping system(s) containing the components listed in the Table 2.2.2-1 and Table 2.2.2-2 are identified in Attachments A and B, respectively.

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 4 of 11 3.a) and 3.b) A report exists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds.

Inspections are performed in accordance witfi ASME Code Section III (1998 Edition, 2000 Addenda) to demonstrate tfiat as-built pressure boundary welds in components identified in Table 2.2.2-1 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 inTable 2.2.2-1 as ASME Code Section III meet ASME Code Section III requirements.

An inspection is performed in accordance with Reference 2 to demonstrate thatthe as-built pressure boundary welds in piping identified in Table 2.2.2-2 (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 2.2.2-2, which is encompassed within the respective piping system 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 in the Non-destructive Examination Report(s) within the piping system's supporting data package, which support completion of the 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 accordancewith the design specification(s) and theASME Code Section III and that the satisfactory completion of the non-destructive examinations of piping pressure boundary weldsforthe pipe linesidentified in Table 2.2.2-2 meet ASME Code Section III requirements and are documented in the Non destructive Examination Report(s) within the supporting data packages.

4.a1 and 4.b1 A report exists and concludes that the results of the hvdrostatic test of the comoonents and pioina identified in Tables 2.2.2-1 and 2.2.2-2 as ASME Code Section III conform with the reouirements of the ASME Code Section III.

Ahydrostatic test is performed by the vendor to demonstrate that the components identified in Table 2.2.2-1 (Attachment A) as ASME Code Section III retain their pressure boundary integrity at their design pressure. Thecompletion of the N-5 Data Reports is govemed by Reference 2.

This portion of the ITAAC is complete once each component identified in Table 2.2.2-1 hastheir individual Code Symbol N-Stamp and corresponding Code Data Report (Reference 1) completed, and the components are installed into the respective Code Symbol N-Stamped

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 5 of 11 piping system and documented on the corresponding N-5 Code Data Report(s) (Reference 1).

The hydrostatic testing results of the component's pressure boundary are 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 2.2.2-1 as ASME Code Section III are documented in the Hydrostatic Testing Report(s) within the supporting data packages and meets ASME Code Section III requirements.

This ITAAC also verifies that the piping identified in Table 2.2.2-2 (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 2.2.2-2 retains its pressure boundary integrity at its design pressure.

A hydrostatic test verifies that there are no leaks at weldsor 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) supportscompletion ofthe ASME Section III N-5 Code Data Report(s) forthe applicable piping system (i.e., PCS) (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 2.2.2-1 and Table 2.2.2-2 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 pipelines identified in Table 2.2.2-2 for which functional caoabilitv is required meets the reouirements for functional caoabilitv.

An inspection is performed of the ASME Section ill as-built piping design report XXX to verify thatthe report demonstrates that each of the PCS piping lines identified in ITAAC Table 2.2.2-2 that requires functional capability is designed to withstand combined normal and seismic design basis loads without a lossof its functional 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 isa 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 classpiping prepared in accordance with ASME Section III NCA-3550 under theASME Boiler &Pressure Vessel Code (1998 Edition, 2000 Addenda)Section III requirements. The as-

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 6 of 11 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, including field 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 PCS piping lines identified in Table 2.2.2-2 are complete and conclude that each of the as-built PCS 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 ofthe as-built PCS piping lines in Table 2.2.2-2 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 2.2.2-1 and 2.2.2-2 as ASME Code Section III;

• A report exists and concludes thatthe ASME CodeSection III requirements are metfor non-destructive examination of pressure boundary welds;

• A report existsand concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.2-1 and 2.2.2-2 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 pipelines identified in Table 2.2.2-2 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 2.2.02.02a Completion Packages (References 5 and 6, respectively).

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

This review, which included nowconsolidated ITAAC Indexes 121,122,123,124,125, and 129, found no relevant ITAAC findings associated with this ITAAC:

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 7 of 11 References ^available for NRG inspection)

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

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

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. PCS ASME III As Built Design Repoil(s)

5. Completion Package for Unit 3 ITAAC 2.2.02.02a [COL Index Number 120]

6. Completion Package for Unit 4 ITAAC 2.2.02.02a [COL Index Number 120]

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

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 8 of 11 Attachment A SYSTEM: Passive Containment Cooling System (PCS)

ASME ill as-ASME Code Equipment Name

• Tag No.

• bullt Design N-5 Report Section ill*

Report PCCWST Isolation PCS-PL-V001A Yes XXX N-5 Code Data Report Valve PCCWST Isolation PCS-PL-V001B Yes XXX N-5 Code Data Report Valve PCCWST Isolation PCS-PL-V001C Yes XXX N-5 Code Data Report Valve MOV PCCWST Isolation PCS-PL-V002A Yes XXX N-5 Code Data Report Block MOV PCCWST Isolation PCS-PL-V002B Yes XXX N-5 Code Data Report Block MOV PCCWST Isolation PCS-PL-V002C Yes XXX N-5 Code Data Report Block MOV PCS Recirculation Return Isolation PCS-PL-V023 Yes XXX N-5 Code Data Report Valve PCCWST Supply to Fire Protection N-5 Code Data Report PCS-PL-V005 Yes XXX System Isolation Valve PCS Makeup to SFS PCS-PL-V009 Yes XXX N-5 Code Data Report Isolation Valve Water Makeup PCS-PL-V044 Yes XXX N-5 Code Data Report Isolation Valve Water Bucket Makeup Line Drain PCS-PL-V015 Yes XXX N-5 Code Data Report Valve Water Bucket Makeup Line Isolation PCS-PL-V020 Yes XXX N-5 Code Data Report Valve PCCWST Long-Term Makeup Line Check PCS-PL-V039 Yes XXX N-5 Code Data Report Valve PCCWST Long-Term Makeup Drain PCS-PL-V042 Yes XXX N-5 Code Data Report Isolation PCS Discharge to SFS Pool Isolation PCS-PL-V045 Yes XXX N-5 Code Data Report Valve

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 9 of 11 Attachment A SYSTEM: Passive Containment Cooling System (PCS)

ASME III as-ASME Code Equipment Name

• Tag No.

• built Design N-5 Report Section III*

Report Recirc Header Discharge to PCS-PL-V046 Yes XXX N-5 Code Data Report PCCWST isolation Valve PCCWST Drain PCS-PL-V049 Yes XXX N-5 Code Data Report isolation Valve Recirc Header Discharge to SFS PCS-PL-V050 Yes XXX N-5 Code Data Report Pool isolation Valve PCCWST Discharge to SFS Pool isolation PCS-PL-V051 Yes XXX N-5 Code Data Report Valve "Excerpts from COL Appendix C Table 2.2.2-1

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 10 of 11 Attachment B SYSTEM: Passive Containment Cooling System (PCS)

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

Required** Report PCS-PL- N-5 Code PCCWST Discharge Lines Yes Yes XXX LOOIA/B'^/C/D'^ Data Report N-5 Code PCCWST Discharge Cross-connect Line PCS-PL-L002 Yes Yes XXX Data Report PCS-PL-L003A/B N-5 Code PCCWST Discharge Header Lines Yes Yes XXX PCS-PL-L005 Data Report PCS-PL-L051 N-5 Code PCS-PL-L054 Yes XXX Post-72-hour Supply Line Connection Yes Data Report PCS-PL-L065"^

PCS-PL-L004 PCS-PL-L007 Post-72-hour Containment Cooling Makeup N-5 Code PCS-PL-L008 Yes Yes XXX From Supply Line Connections PCS-PL-L023 Data Report PCS-PL-L050"^

PCS-PL-L011 PCS-PL-L017 PCS-PL-L018 PCS-PL-L030*'^ N-5 Code Post-72-hour SFS Makeup From PCCWST PCS-PL-L039* Yes Yes XXX Data Report PCS-PL-L041"^

PCS-PL-L049*"^

PCS-PL-L073'^

U.S. Nuclear Regulatory Commission ND-18-0317 Enclosure Page 11 of 11 Attachment B SYSTEM: Passive Containment Cooling System (PCS)

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

Required** Report PCS-PL-L025 PCS-PL-L029 PCS-PL-L030*"^

Post-72-hour SFS Makeup From Supply Line N-5 Code PCS-PL-L039* Yes Yes XXX Connection PCS-PL-L048 Data Report PCS-PL-L049*"^

PCS-PL-L052"^

Note:

• Lines PCS-PL-L049, L039, and L030 comprise a common makeup line from both sources.

• • Excerpts from COL Appendix C, Table 2.2.2-2

"** These lines PCS-PL-L001B/D, L065, L050, L030, L041, L049, L073, and L052 require that dynamic loads in its pipe stress analysis satisfythe requirements of ASME Code Section ill (1989 Edition, 1989 Addenda) for girth fillet welds between piping and socket welded fittings, valves and flanges per VEGP UFSAR Section 5.2.1.1 (Reference 3)