ND-18-1102, Resubmittal Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.04.12a.i (Index Number 2481

Resubmittal Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.04.12a.i (Index Number 2481

ML18235A290
Person / Time
Site:	Vogtle
Issue date:	08/20/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.2.04.12a, ND-18-1102
Download: ML18235A290 (8)

Text

Michael J. Yox 7825 River Road Sk Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel 410-474-8587 cell myox@southernco.com AUG 2 0 2018 Docket Nos.: 52-025 52-026 ND-18-1102 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 Resubmittal Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.2.04.12a.i [Index Number 2481 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of August 14, 2018, Vogtle Electric Generating Plant (VEGf^) Unit 3and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.04.12a.i [Index Number 248] 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.

Southern Nuclear Operating Company (SNC) previously submitted Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load for Item 2.2.04.12a.i [Index Number 248] ND-18-0806

[ML18171A038] dated June 18, 2018. This resubmittal supersedes ND-18-0806 in its entirety.

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,

<4^

Michael J. Yox Regulatory Affairs Direc^r Vogtle 3 &4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.04.12a.i [Index Number 248]

MJY/SBB/amw

U.S. Nuclear Regulatory Commission ND-18-1102 Page 2 of 3 To:

Southern Nuclear Operating ComDanv/ Georgia Power Company Mr. D. A. Bost (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. J. B. Klecha Mr. G. Chick Mr. M. J. Yox Mr. A. 8. Parton Ms. A. L. Pugh Mr. T. G. Petrak Mr. W. A. Sparkman Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. C. T. Defnall Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Ms. J. M. Heisserer Ms. A. E. Rivera-Varona Mr. M. E. Ernstes Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Convert Ooiethorpe Power Corporation Mr. R. B. Brinkman Municipal Electric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-18-1102 Page 3 of 3 Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

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

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan 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., GDS 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, Balch Bingham

U.S. Nuclear Regulatory Commission ND-18-1102 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-18-1102 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.04.12a.l [Index Number 248]

U.S. Nuclear Regulatory Commission ND-18-1102 Enclosure Page 2 of 5 ITAAC Statement Design Commitment 12.a) The motor-operated valves identified in Table 2.2.4-1 perform an active safety-related function to change position as indicated in the table.

Insoections/Tests/Analvses i) Tests or type tests of motor-operated valves will be performed to demonstrate the capability of the valve to operate under its design conditions.

ii) Inspection will be performed for the existence of a report verifying that the as-built motor-operated valves are bounded by the tests or type tests.

Acceptance Criteria i) Atest report exists and concludes that each motor-operated valve changes position as indicated in Table 2.2.4-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

ITAAC Completion Description Multiple Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) are performed to demonstrate that the Steam Generator System (SGS) motor-operated valves identified in the Combined License (COL) Appendix C, Table 2.2.4-1 perform an active safety-related function to change position as indicated in the table.

\) A test report exists and concludes that each motor-ooerated valve changes position as indicated in Table 2.2.4-1 under design conditions.

This portion of the subject ITAAC requires tests or type tests of motor-operated valves to be performed to demonstrate the capability ofthe valve to operate under its design conditions.

The motor-operated valves identified in COL Appendix C, Table 2.2.4-1 are qualified in accordance with the provisions of American Societyof Mechanical Engineers (ASME)

QME-1-2007, "Qualification of Active Mechanical Equipment Used in Nuclear Power Plants" (Reference 1).

Functional qualification is performed under the design conditions identified in the design specification for the valves (Reference 2) to demonstrate that each motor-operated valve is qualified to perform its designated function when used in its intended service. In accordance with ASME QME-1-2007, qualification is substantiated by demonstrating the relationship between the sen/ice requirements and the type testing and analysis that was conducted as part of this qualification program.

Type testing is performed, including natural frequency determination, side load static deflection testing, final staticseat and stem leakage testing, steam testing, and watertesting, for the

U.S. Nuclear Regulatory Commission ND-18-1102 Enclosure Page 3 of 5 ranges of the pressure, temperature and flow for each valve and the maximum seat-sealing differential pressure. In accordance with ASME QME-1-2007, the functional qualification process for these motor-operated valve assemblies also included valve and actuator internal inspections and measurement, orientation requirements, seat and stem leakage limitations, diagnostic data collection and analysis methods, static and dynamic flow diagnostic testing, and pressure locking and thermal binding evaluations. The qualification also followed the provisions of ASME QME-1-2007 for the extrapolation of functional qualification to another valve assembly, and demonstration of functional capability of production valve assemblies.

The results of the qualification are documented in the Equipment Qualification (EQ) Reports (Reference 3) which are identified in Attachment A for each applicable valve. These reports summarize the test methodology and ASME QME-1-2007 functional qualification that demonstrate that each motor-operated valve changes position as indicated in VEGP Unit 3 and Unit 4 COL Appendix 0 Table 2.2.4-1 under design conditions.

ii) A reoort exists and concludes that the as-built motor-operated valves are bounded bv the tests or tvpe tests.

This portion of the subject ITAAC requires that an inspection is performedfor the existence of a report verifying that the as-built motor-operated valves are bounded by the tests or type tests.

The motor-operated valves in VEGP Unit 3 and Unit 4 COL Appendix C Table 2.2.4-1 are verified by tests in accordance with section i) above, to demonstrate the capability of the valves to operate under their design conditions. The EQ Reports in AttachmentA identify the equipment mounting employed for the testing and the specific conditions tested.

In accordance with the EQ Walkdown ITAAC Guideline (Reference 4), an inspection is conducted of the SGS to confirm the satisfactory installation of the motor-operated valves. The inspection includes verification of equipment make/model/serial number, verification of equipment mounting and location, and verification that the mechanical and electrical connections are bounded by the tested conditions.

The documentation of installed configuration of the motor-operated valves includes photographs and/or sketches of equipment mounting and connections. The verification of installed component configuration is documented in the As-Built EQ Reconciliation Report(s) (EQRR)

(Reference 5).

Attachment A identifies the EQRR which verify that the installed configuration of the motor-operated valves identified in VEGP Unit 3 and Unit 4 COLAppendix 0 Table 2.2.4-1 are bounded by the tests or type tests.

Together, these EQ Reports and EQRR (References 3 and 5), provide evidence that the ITAAC Acceptance Criteria requirements are met:

• A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.2.4-1 under design conditions; and

• A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

U.S. Nuclear Regulatory Commission ND-18-1102 Enclosure Page 4 of 5 References 3 and 5 are available for NRG inspection as part of the Unit 3 and Unit 4 ITAAC 2.2.04.12a.i Completion Packages (References 6 and 7, respectively).

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 finding review which includes now-consolidated ITAAC 249, found there are no relevant ITAAC findings associated with this ITAAC.

References ^available for NRG inspection)

1. American Society of Mechanical Engineers (ASME) QME-1 -2007, "Qualification of Active Mechanical Equipment Used in Nuclear Power Plants"

2. APP-PV01 -ZO-001 Revision X, "3" and Larger Motor Operated Gate and Globe Valves, ASME Boiler and Pressure Vessel Code Section III, Class 1, 2, and 3"

3. Equipment Qualification (EQ) Reports as identified in Attachment A

4. ND-XX-XX-001, EQ Walkdown ITAAC Guideline

5. As-Built Equipment Qualification Reconciliation Reports (EQRR) as identified in Attachment A for Units 3 and 4

6. 2.2.04.12a.i-U3-CP-RevO, "Completion Package for Unit 3 ITAAC 2.2.04.12a.i [Index Number 248]"

7. 2.2.04.12a.i-U4-CP-RevO, "Completion Package for Unit 4 ITAAC 2.2.04.12a.i [Index Number 248]"

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

U.S. Nuclear Regulatory Commission ND-18-1102 Enclosure Page 5 of 5 Attachment A System: Steam Generator System (SGS)

Active EQ Reports As-Built EQRR Equipment Name

• Tag No. + (Reference 5)*

Function * (Reference 3)

Power-operated Relief Valve Transfer APP-PV01-VBR-013/ 2.2.04.12a.l-U3-EQRR-Block Motor-operated Valve SGS-PL-V027A Closed APP-PV01-VBR-014 PCDXXX Steam Generator 01 Power-operated Relief Valve Transfer APP-PV01-VBR-013/ 2.2.04.12a.l-U3-EQRR-Block Motor-operated Valve SGS-PL-V027B Closed APP-PV01-VBR-014 PCDXXX Steam Generator 02 Startup Feedwater Isolation Transfer APP-PV01-VBR-011 / 2.2.04.12a.l-U3-EQRR-SGS-PL-V067A Motor-operated Valve Closed APP-PV01-VBR-012 PCDXXX Startup Feedwater Isolation Transfer APP-PV01-VBR-011 / 2.2.04.12a.l-U3-EQRR-SGS-PL-V067B Motor-operated Valve Closed APP-PV01-VBR-012 PCDXXX Notes:

+Excerpt from COL Appendix 0 Table 2.2.4-1

• The Unit 4 As-Bullt EQRR are numbered "2.2.04.12a.l-U4-EQRR-PCDXXX"