ND-18-1121, Administrative Chances to Align Initial Test Program (ITP) with Regulatory Guide 1.68 (PAR-18-024)

Administrative Chances to Align Initial Test Program (ITP) with Regulatory Guide 1.68 (PAR-18-024)

ML18243A041
Person / Time
Site:	Vogtle
Issue date:	08/31/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-18-1121, PAR-18-024
Download: ML18243A041 (7)

Text

Michael J. Vox Plant Vogtle 3 & 4 Southern Nuclear Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 &4 706-848-6459 tel 410-474-8587 cell myox@southernco.com August 31, 2018 Docket Nos.: 52-025 ND-18-1121 52-026 10CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Preliminary Amendment Request (PAR):

Administrative Chances to Align Initial Test Program (ITP) with Reoulatorv Guide 1.68 (PAR-18-024)

Ladies and Gentlemen:

The U.S. Nuclear Regulatory Commission (NRC) issued the Vogtle Electric Generating Plant (VEGP) Units 3 and 4 combined licenses (COLs) (License Numbers NPF-91 and NPF-92, respectively) to Southern Nuclear Operating Company (SNC) on February 12, 2012.

SNC submitted a License Amendment Request (LAR) and exemption request, LAR-18-024 on August 30, 2018, by SNC letter ND-18-1120 [ADAMs Accession Number ML18242A039]. The LAR proposes to revise administrative aspects of the Initial Test Program (ITP) described in the VEGP 3 and 4 Updated Final Safety Analysis Report (UFSAR) and associated Tier 1 material.

The change would involve removing component testing as a phase of the ITP in order to better align with Regulatory Guide 1.68. SNC is submitting a Preliminary Amendment Request (PAR),

PAR-18-024, to avoid significant loss of efficiency related to component testing. The determination of whether the NRC has any objection to SNC proceeding with testing consistent with the proposed plant licensing basis changes is needed on or before October 1, 2018.

A description of the requested change and the reason for the change are contained in Enclosure 1 to this letter. This PAR has been developed in accordance with guidance provided in the most recent revision to the Interim Staff Guidance on Changes during Construction Under 10 CFR Part 52, COL-ISG-25 [ADAMS Accession Number ML13045A125] and corresponds accurately and technically with the above-mentioned LAR-18-024. The technical scope of this PAR is consistent with the technical scope of the submitted l_AR. Section 7 of Enclosure 1 identifies the scope of the "no objection" sought in this PAR.

U.S. Nuclear Regulatory Commission ND-18-1121 Page 2 of 4 This letter does not contain any regulatory commitments. This letter has been reviewed and confirmed to not contain security-related information.

Should you have any questions, please contact Ms. Kelli Roberts at 706-848-6991.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st of August 2018.

Respectfully submitted, Michael J. Yo>

Regulatory AffairsDifector Vogtle 3&4 Southern Nuclear Operating Company Enclosure 1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Preliminary Amendment Request: Administrative Changes to Align Initial Test Program (ITP) with Regulatory Guide 1.68 (PAR-18-024)

MJY/LRG/amm

U.S. Nuclear Regulatory Commission ND-18-1121 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. 8. E. KuczynskI Mr. D. G. Bost Mr. M. D. Meier Mr. D. H. Jones Mr. J. 8. Klecha Mr. G. Chick Mr. D. L. McKinney Mr. T. W. Yelverton Mr. B. H. Whitley Ms. 0. A. Gayheart Mr. 0. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Vox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. 0. Chamberlain Ms. A. L. Pugh Ms. P. Reister Mr. C. 8. Waldrup Ms. K. A. Roberts Ms. A. A. Gibson Document Services RTYPE: VND.LI.LOO File AR.01.02.06 Nuclear Reoulatorv Commission Mr. W. Jones Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. 8. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. 8. Walker

U.S. Nuclear Regulatory Commission ND-18-1121 Page 4 of 4 State of Georgia Mr. R. Dunn Oaiethorpe Power CorDoration Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. OrlanI Mr. C. D. Churchman Ms. L. G. Iller Mr. M. M. CorlettI Mr. M. L. Clyde Mr. D. Hawkins Ms. J. Monahan Mr. J. L. Coward Other Mr. 8. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NU8, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GD8 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 Mr. R. Grumblr, APOG NDDocumentlnBox@duke-energy.com, Duke Energy Mr. 8. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-18-1121 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Preliminary Amendment Request:

Administrative Changes to Align Initial Test Program (ITP) with Reguiatory Guide 1.68 (PAR-18-024)

(This Enclosure consists of 3 pages, including this cover page)

ND-18-1121 PAR-18-024: Administrative Changes to Align initial Test Program (ITP) with Regulatory Guide 1.68 in accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) submitted License Amendment Request (LAR)-18-024 to change the Vogtie Electric Generating Plant (VEGP), Units 3 and 4, licensing basis documents associated with Combined License Nos. NPF-91 and NPF-92, respectively. Accordingly, SNC requests the determination of whether the NRC has any objection to proceeding with testing consistent with the proposed removal of component testing as a phase of the initial test program (ITP), which would further align the ITP witfi Regulatory Guide 1.68.

Removal of component testing as a phase of the ITP is subject to the changes proposed in LAR-18-024. As the nature of the workforce transitions from one used for concrete placement and steel erection to one more related to electrical and instrumentation installation and testing, the need to perform component tests prior to turnover from construction to ITP will increase.

Because these component tests are currently required to be performed after turnover from construction, there is increased opportunity to complete testing of components on an accelerated schedule (i.e., prior to turnover). Accordingly, SNC requests the determination of whether the NRC has any objection to proceeding with testing consistent with the proposed removal of component testing as a phase ofthe ITP as identified below.

PAR Request Number: Station Name: Unit Number(s): PAR Request Date:

SNC PAR-18-024 VEGP Kl 3 K! 4 October 1, 2018

1. NRC PAR Notification Requested Date (see Biock 7 for basis): October 1,2018

2. License Amendment Request References (as applicable):

ra LAR submittal date and SNC Correspondence Number: LAR-18-024 - August 30, 2018 /

ND-18-1120

• Expected LAR submittal date:

3. Brief Description of Proposed Change:

The proposed amendment would impact Tier 1 with regard tocommitments described in the VEGP 3 and 4 Updated Final Safety Analysis Report (UFSAR) related to the initial Test Program (ITP). No ITAAC changes are proposed. Currently, Tier 1, Section 3.4, states that the initial test program is performed after turnover from construction. The proposed changes remove component testing as a phase ofthe ITP such that the licensing basis ITP consists only of preoperational and startup testing, which is consistent with Regulatory Guide (RG) 1.68, Initial Test Programs for Water-fDooled Nuclear Power Plants, Revision 3,

[ADAMS Accession Number ML070260039]. Therefore, there would be no need to wait for turnover from construction to the ITP because component testing is a subset of construction testing.

Tier 1 currently states that the ITP is performed after tumover from construction. RG 1.68 notes the initial test program consists of preoperational and startup testing but does not address sequencing of testing wi^

regard to tumover from construction. This change does not affect the health and safety of the public because construction and related component testing, although not controlled by the ITP, is conducted under 10CFR Part 50, Appendix B, and NQA-1 1994 (see UFSAR Sections 17.1 and 17.5).

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ND-18-1121 PAR-18-024: Administrative Changes to Align Initial Test Program (IIP) with Regulatory Guide 1.68

4. Reason for License Amendment Request:

This change is needed to align the licensing basis with RG 1.68. The current licensing basis is more restrictive in terms of sequence of testing and testing controlsof the component test program than what is provided in the guidance from RG 1.68. Further aligning the licensing basis with RG 1.68 will allow for component tests to be completed before full jurisdictional turnover from construction, which in turn allows for early detection of issues on various components.

5. Is Exemption Request Required? Yes

• No if Yes, Briefly Describe the Reason for the Exemption. The request for exemption proposes changes to Tier 1 Section 3.4 that would redefine the ITP scope to consist of preoperational and startup testing, which is consistent with RG 1.68. Discussions oftest specifications andtest procedures are changed to refer only to test procedures, which is also consistent with RG 1.68. Further aligning the licensing basis with RG 1.68 will allow for component tests to be completed before full jurisdictional turnover from construction, which in turn allows for early detection of issues on various components.

6. identify Applicable Precedents: No precedents identified.

7. impact of Change on installation and Testing Schedules:

There is no direct impact to the construction schedule. However, there are components that are currently available for testing but have not yet been turned over from construction. The scope of the"no objection" letter includes components that could be tested immediately without turnover from construction. Examples of these types of components include, but not are limited to, potential transformers, current transformers, control circuits, relays, and valves. Such component tests could proceed prior to turnover and would not be required tobe performed under the administrative control of the ITP.

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