ND-18-1469, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.04.04.ii (Index Number 331)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.04.04.ii (Index Number 331)

ML18346A039
Person / Time
Site:	Vogtle
Issue date:	12/10/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.3.04.04.ii, ND-18-1469
Download: ML18346A039 (8)

Text

Southern Nuclear Michael J. Vox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtie 3 & 4 706-848-6459 tei 410-474-8587 ceii myox@southernco.corn DEC I 0 2018 Docket Nos.: 52-025 52-026 ND-18-1469 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtie Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.3.04.04.11 fIndex Number 3311 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of November 26, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspection, Test, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.04.04.ii

[Index Number 331] has not been completed greater than 225-days priorto initial fuel load. The Enclosure describes the plan for completing ITAAC 2.3.04.04.ii [Index Number 331]. 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)(3) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding tfiat 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. Vox Regulatory Affairs Director Vogtie 3 &4

U.S. Nuclear Regulatory Commission ND-18-1469 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.04.04.11 [Index Number 331]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-18-1469 Page 3 of 4 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. Vox 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. J. C. Haswell 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 Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oalethoroe Power Corooration Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-18-1469 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinohouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hosier, 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. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-18-1469 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-18-1469 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.04.04.11 [Index Number 331]

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U.S. Nuclear Regulatory Commission ND-18-1469 Enclosure Page 2 of 3 ITAAC Statement Desion Commitment

4. The FPS provides for manual fire fighting capability In plant areas containing safety-related equipment.

Insoectlons/Tests/Analvses II) Testing will be performed by measuring the water flow rate as It Is simultaneously discharged from the two highest fire-hose stations and when the water for the fire Is supplied from the PCS storage tank.

Acceptance Criteria II) Water Issimultaneously discharged from each of the two highest fire-hose stations In plant areas containing safety-related equipment at not less than 75 gpm.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate the Fire Protection System (FPS) provides for manual fire fighting capability In plant areas containing safety-related equipment. This ITAAC requiresthat testing will be performed by measuring the water flow rate as It Is simultaneously dischargedfrom the two highestfire-hose stations and when the water for the fire Is supplied from the Passive Containment Cooling System (PCS) storage tank.

Testing Is performed In accordance with Unit 3 and Unit 4 preoperatlonal test 3-PCS-ITPP-502 and 4-PCS-ITPP-502, (References 1 and 2), to confirm that when the water for the FPS Is supplied from the PCS storage tank, water Issimultaneously discharged from each ofthe two highest fire-hose stations In plant areas containing safety-related equipment at not less than 75 gallons per minute (gpm). The 2 highest fire-hose stations In plant areas containing safety-related equipment was determined to be F151A (room 12506) and F151B (room 12504). The flow measurement can be performed at any level above the PCCWST technical specification minimum since the level In the tank will have negligible Impact on gravity flow. There Is a 1.1 foot elevation difference between the maximum PCCWST level and the technical specification minimum and a 187 foot elevation difference between the maximum PCCWST level and the highest fire-hose stations. Thefire protection system Is aligned to Isolate the normal fire protection from the tested fire hose stations and the PCS storagetank Isaligned to provide water to the fire-hose stations being tested. Ultrasonic flow Instruments are Installed upstream of the fire-hose stations and the fire hose Is run and secured to a suitable drain. The fire-hose station Isolation valves are opened, flow Is monitored at each flow Instrument and recorded approximately every 10 seconds and 30 readings are taken. Theflow readings are corrected for measurement uncertainty and compared to the acceptance criteria. The flow for Unit 3 F151A Is XX gpm and YY gpm for Unit 3 F151B. Theflow for Unit 4 F151A Is XX gpm and YY gpm for F151B. The completed Unit 3 and Unit 4 Preoperatlonal Test Results, references 1 and 2, confirm that water Is simultaneously discharged from each of the two highest fire-hose stations In plant areas containing safety-related equipment at not less than 75 gpm.

References 1 and 2 are available for NRC Inspection as part of the ITAAC 2.3.04.04.11 Completion Packages (References 3 &4).

U.S. Nuclear Regulatory Commission ND-18-1469 Enclosure Page 3 of 3 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 favaiiable for NRG inspection)

1. 3-PCS-ITPP-502," Passive Containment Cooling System PCCWST Preoperational Test Procedure"

2. 4-PCS-ITPP-502," Passive Containment Cooling System PCCWST Preoperational Test Procedure"

3. 2.3.04.04.ii-U3-CP-Rev0, ITAAC Completion Package

4. 2.3.04.04.ii-U4-CP-Rev0, ITAAC Completion Package

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