ND-18-1424, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.03.11b.i (Index Number 209)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.03.11b.i (Index Number 209)

ML18355A794
Person / Time
Site:	Vogtle
Issue date:	12/19/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.2.03.11b.i, ND-18-1424
Download: ML18355A794 (7)

Text

& Southern Nuclear Michael J. Yox Regulatory Affairs Director Vogtle 3 &4 7825 River Road Waynesboro, GA 30830 706-848-6459 tel 410-474-8587 cell DEC 1 9 2018 myox@southemco.com Docket Nos.: 52-025 52-026 ND-18-1424 10 CFR 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-days Prior to Initial Fuel Load Item 2.2.03.11 b.i [Index Number 209)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3}, Southern Nuclear Operating Company hereby notifies the NRC that as of December 5, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspection, Test, Analysis, and Acceptance Criteria (ITMC) Item 2.2.03.11b.i

[Index Number 209] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.2.03.11 b.i [Index Number 209]. 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 NEl-08-01, Industry Guideline for the

/TAAC 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 ITMC for which required inspections, tests, or analyses have not been performed or have been only partially completed.

All lTMC will be fully completed and all Section 52.99(c)(1) ITMC 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, Mic?t.~

Regulatory Affairs D ~ r Vogtle 3&4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITMC 2.2.03.11 b.i [Index Number 209]

MJY/J BN/sfr

U.S. Nuclear Regulatory Commission ND-18-1424 Enclosure Page2 of3 To:

Southern Nuclear Operating Company/ 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. S. 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. J.C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01 .02.06 cc:

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

Mr. F. D. Brown Ms. J.M. Heisserer Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. 8. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oglethorpe Power Corporation Mr. R. 8. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-18-1424 Enclosure Page3 of 3 Dalton Utilities Mr. T. Bundros Westinghouse 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. S. Roetger, Georgia Public Service Commission Ms. S. W. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-18-1424 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-18-1424 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.03.11 b.i [Index Number 209]

U.S. Nuclear Regulatory Commission

.ND-18-1424 Enclosure Page 2 of 4 ITAAC Statement Design Commitment 11.b) The valves identified in Table 2.2.3-1 as having PMS control perform their active function after receiving a signal from the PMS.

Inspectionsrrests/Analyses i) Testing will be performed on the squib valves identified in Table 2.2.3-1 using real or simulated signals into the PMS without stroking the valve.

Acceptance Criteria i) Squib valves receive an electrical signal at the valve electrical leads that is capable of actuating the valve after a signal is input to the PMS.

ITAAC Completion Description Multiple ITAAC are performed to verify that the valves identified in Combined License (COL)

Appendix C Table 2.2.3-1 (Attachment A) as having Protective and Safety Monitoring System (PMS) control perform an active safety function after receiving a signal from PMS. The subject ITAAC performs testing on the squib valves listed in Attachment A.

Testing is performed in accordance with preoperational tests 3/4-PMS-ITPP-522 and 3/4-PMS-ITPP-523 (References 1 through 4) to verify that the valves identified in Attachment A as having PMS control perform an active safety function after receiving a signal from PMS. Testing is performed on the squib valves identified using real and simulated signals into the PMS without stroking the valve and ensuring the squib valves receive a signal at the valve electrical leads that is capable of actuating the squib valve.

Squib valve actuation signals generated in the PMS are sent to the Component Interface Modules (CIM), resulting in an actuation of the CIM for the respective squib valve. The CIM is a safety-related component located inside the respective PMS cabinets which provides the capability for on/off control of individual safety-related plant components. Squib valve actuation signals output from the actuated CIM are sent to the respective squib valve through the squib valve controller. To provide overlap, testing in 3/4-PMS-ITPP-523 verifies the output of the CIM when signals are input into the PMS and testing in 3/4-PMS-ITPP-522 manually actuates the Cl M and verifies the signal at the squib valve electrical leads.

Testing in 3/4-PMS-ITPP-523 initiates an In-Containment Refueling Water Storage Tank (IRWST) injection and Containment Recirculation actuation in the PMS. The squib valve actuation signals are measured and timed using a temporary data acquisition system connected to the output of the CIM to verify the CIM outputs a squib valve actuation signal capable of actuating the valves. Each squib valve identified in Attachment A has the electrical leads disconnected to prevent stroking the valve.

During testing in 3/4-PMS-ITPP-522, each squib valve identified in Attachment A has the squib valve igniters replaced with test resistor fixtures. Test resistance is corrected to the maximum resistance expected during accident conditions. The CIMs are manually actuated and a

U.S. Nuclear Regulatory Commission ND-18-1424 Enclosure Page 3 of 4 multimeter along with a temporary data acquisition system is used to measure both firing current and voltage.

Circuit resistance is measured and inside and outside containment temperatures are measured at multiple locations and are used to calculate the circuit resistance expected during accident conditions and at the minimum ambient temperature. The calculated circuit resistances are verified to meet the minimum and maximum allowable resistances.

The minimum signal necessary to actuate the squib valves is specified in valve design information as at least 3. 7 amperes for 1O milliseconds. The information recorded during testing of voltage and firing current is utilized to confirm that a sufficient test signal is received at each of the squib valves.

Together, these test results (References 1 through 4) confirm that each squib valve, identified in the Attachment A, receives an electrical signal at the valve electrical leads that is capable of actuating the squib valve after a signal is input to the PMS.

References 1, 2, 3 and 4 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC Completion Packages (Reference 5 and 6, 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 review found there are no relevant ITAAC findings associated with this ITAAC.

References {available for NRC inspection)

1. 3-PMS-ITPP-522, "PMS SQUIB VALVE CONTROLLER PERFORMANCE PREOPERATIONAL TEST'

2. 4-PMS-ITPP-522, "PMS SQUIB VALVE CONTROLLER PERFORMANCE PREOPERATIONAL TEST"

3. 3-PMS-ITPP-523, "Containment Pressure High-2 Actuation Preoperational Test Procedure"

4. 4-PMS-ITPP-523, "Containment Pressure High-2 Actuation Preoperational Test Procedure"

5. 2.2.03.11 b.i-U3-CP-Rev 0, ITAAC Completion Package

6. 2.2.03.11 b.i-U4-CP-Rev 0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-18-1424 Enclosure Page 4 of 4 Attachment A*

Eauipment Name Taa No. Control PMS/ DAS Containment Recirculation A PXS-PL-V118A YesNes Squib Valve Containment Recirculation B YesNes PXS-PL-V118B Squib Valve Containment Recirculation A PXS-PL-V120A YesNes Sauib Valve Containment Recirculation B PXS-PL-V1208 YesNes Sauib Valve I RWST Injection A Squib PXS-PL-V123A YesNes Valve IRWST Injection 8 Squib PXS-PL-V1238 YesNes Valve IRWST Injection A Squib PXS-PL-V125A YesNes Valve IRWST Injection 8 Squib PXS-PL-V1258 YesNes Valve

• Excerpt from COL Appendix C Table 2.2.3-1