ND-19-0077, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.02.08a.i (Index Number 301)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.02.08a.i (Index Number 301)

ML19043A947
Person / Time
Site:	Vogtle
Issue date:	02/11/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0077
Download: ML19043A947 (20)

Text

7825 River Road

i. Southern Nuclear Michael J. Yox Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel 410-474-8587 cell FEB t 1 2019 myox@southernco.com Docket Nos.: 52-025 52-026 ND-19-0077 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 2.3.02.08a.i [Index Number 3011 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of February 1, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections Tests Analyses and Acceptance Criteria (ITAAC) Item 2.3.02.08a.i

[Index Number 301] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.3.02.08a.i [Index Number 301]. 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 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.

U.S. Nuclear Regulatory Commission ND-19-0077 Page 2 of 4 Respectfully submitted, Michael J. Yox Regulatory Affairs Dfrector Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.02.08a.i [Index Number 301]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0077 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost(w/o enclosures)

Mr. D. L. McKlnney (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. Ration Ms. K. A. Roberts 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 Reouiatorv Commission Mr. W.Jones (w/o enclosures)

Mr. F. D. Brown Ms. J. M. Heisserer Mr. C. P. Patel Mr. G. J. Khourl 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 Qqiethoroe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municlpai Eiectric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0077 Page 4 of 4 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 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., CDS 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-19-0077 Enclosure Page 1 of 16 Southern Nuclear Operating Company ND-19-0077 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.02.08a.l [Index Number 301]

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 2 of 16 ITAAC Statement Design Commitment 8.a) The CVS provides makeup water to the RCS.

8.b) The CVS provides the pressurizer auxiliary spray.

9. Safety-related displays identified in Table 2.3.2-1 can be retrieved in the MCR.

10.a) Controls exist in the MCR to cause the remotely operated valves identified in Table 2.3.2-I to perform active functions.

lO.b) The valves identified in Table 2.3.2-1 as having RMS control perform an active safety function after receiving a signal from the RMS.

II.a) The motor-operated and check valves identified in Table 2.3.2-1 perform an active safety-related function to change position as indicated in the table.

11.b) After loss of motive power, the remotely operated valves identified in Table 2.3.2-1 assume the indicated loss of motive power position.

12.a) Controls exist in the MCR to cause the pumps identified in Table 2.3.2-3 to perform the listed function.

12.b) The pumps identified in Table 2.3.2-3 start after receiving a signal from the RLS.

13. Displays of the parameters identified in Table 2.3.2-3 can be retrieved in the MCR.

I nsoections/Tests/Analvses i) Testing will be performed by aligning a flow path from each CVS makeup pump, actuating makeup flow to the RCS at pressure greater than or equal to 2000 psia, and measuring the flow rate in the makeup pump discharge line with each pump suction aligned to the boric acid storage tank.

Testing will be performed by aligning a flow path from each CVS makeup pump to the pressurizer auxiliary spray and measuring the flow rate in the makeup pump discharge line with each pump suction aligned to the boric acid storage tank and with RCS pressure greater than or equal to 2000 psia.

Inspection will be performed for retrievability of the safety-related displays in the MCR.

Stroke testing will be performed on the remotely operated valves identified in Table 2.3.2-1 using the controls in the MCR.

i) Testing will be performed using real or simulated signals into the RMS.

ii) Testing will be performed to demonstrate that the remotely operated CVS isolation valves CVS-V090, V091, V136A/B close within the required response time.

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 3 of 16 iii) Tests of the motor-operated valves will be performed under pre-operational flow, differential pressure, and temperature conditions.

iv) Exercise testing of the check valves with active safety functions identified in Tabie 2.3.2-1 wiil be performed under pre-operationai test pressure, temperature and fluid flow conditions.

Testing of the remoteiy operated vaives will be performed under the conditions of ioss of motive power.

Testing will be performed to actuate the pumps identified in Table 2.3.2-3 using controis in the MGR.

Testing wiii be performed to confirm starting of the pumps identified in Table 2.3.2-3.

Inspection wili be performed for retrievability of the dispiays identified in Table 2.3.2-3 in the MGR.

Acceptance Criteria i) Each GVS makeup pump provides a fiow rate of greater than or equal to 100 gpm.

Each GVS makeup pump provides spray flow to the pressurizer.

Safety-related displays identified in Table 2.3.2-1 can be retrieved in the MGR.

Controls in the MGR operate to cause the remotely operated valves identified in Table 2.3.2-1 to perform active functions.

i) The vaives identified in Tabie 2.3.2-1 as having PMS control perform the active function identified in the tabie after receiving a signal from the PMS.

ii) These valves close within the following times after receipt of an actuation signal:

V090, V091 < 30 sec, V136A/B < 20 sec.

iii) Each motor-operated vaive changes position as indicated in Tabie 2.3.2-1 under pre-operational test conditions.

iv) Each check valve changes position as indicated in Tabie 2.3.2-1.

Upon loss of motive power, each remotely operated valve identified in Tabie 2.3.2-1 assumes the indicated loss of motive power position.

Controls in the MGR cause pumps identified in Table 2.3.2-3 to perform the listed function.

The pumps identified in Tabie 2.3.2-3 start after a signal is generated by the PLS.

Displays identified in Table 2.3.2-3 can be retrieved in the MGR.

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 4 of 16 ITAAC Completion Description Multiple ITAAC are performed to verify by inspections and tests that each of the Chemical and Volume Control System (CVS) makeup pumps provide a flow rate of greater than or equal to 100 gpm to the Reactor Coolant System (RCS)and provides spray flow to the pressurizer. This ITAAC also ensures safety-related displays identified in Combined License(COL)Table 2.3.2-1 can be retrieved in the Main Control Room (MCR), displays identified in COL Table 2.3.2-3 can be retrieved in the MCR,controls in the MCR operate to cause the remotely operated valves identified in COL Table 2.3.2-1 to perform active functions, controls in the MCR cause pumps identified in COL Table 2.3.2-3 to perform the listed function, and the pumps identified in COL Table 2.3.2-3 start after a signal is generated by the Plant Control System (PLS). Additionally, this ITAAC verifies the valves identified in COL Table 2.3.2-1 as having Protection and Safety Monitoring System (PMS)control perform the active function identified in the table after receiving a signal from the PMS, valves close within the following times after receipt of an actuation signal: V090, V091 < 30 sec; V136A, V136B < 20 sec, each motor-operated valve and check valve change positions as indicated in COL Table 2.3.2-1 under preoperational test conditions. Upon loss of motive power, each remotely operated valve identified in COL Table 2.3.2-1 assumes the loss of motive power position.

i) Each CVS makeup pumo provides a flow rate of Greater than or eoual to 100 com.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-CVS-ITPP-502 and 4-CVS-ITPP-502(References 1 & 2)to confirm that with suction aligned to the boric acid storage tank, the Reactor Coolant System (RCS)at greater than or equal to 2000 psia and a flow path established to the RCS,that each CVS makeup pump provides greater than or equal to 100 gpm flow measured at the pump discharge.

With the RCS at 555°F - 559°F and 2220 psig -2250 psig, the CVS system is aligned to perform a batch boron addition to the RCS. The A CVS makeup pump suction is aligned to the boric acid storage tank and a batch boron addition is initiated using the operating procedure.

The flow on the discharge of the CVS makeup pump is monitored and trended. This testing is repeated utilizing the B CVS makeup pump. The Unit 3 A CVS makeup pump flow is XXX gpm and the Unit 3 B CVS makeup pump flow is YYY gpm. The Unit 4 A CVS makeup pump flow is XXX gpm and the Unit 4 B CVS makeup pump flow is YYY gpm. This confirms that each CVS makeup pump provides a flow rate of greater than or equal to 100 gpm with the RCS at greater than or equal to 2000 psia.

Each CVS makeup pump provides sorav flow to the pressurizer.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-CVS-ITPP-502 and 4-CVS-ITPP-502(References 1 & 2)to confirm that with suction aligned to the boric acid storage tank, the Reactor Coolant System (RCS)at greater than or equal to 2000 psia and a flow path established to the pressurizer auxiliary spray, that each CVS makeup pump provides spray flow to the pressurizer.

With the RCS at 555°F - 559°F degrees and 2220 psig - 2250 psig, the CVS system is aligned to perform an automatic blended makeup to the RCS. The makeup flow control valve is placed in manual and the A CVS makeup pump is started. The auxiliary spray valve is opened and the makeup flow control valve is throttled open until flow rate is equal to or greater than 100 gpm.

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 5 of 16 The discharge flow is monitored and trended. The B CVS makeup pump is started and the A GVS makeup pump is stopped. The makeup flow control valve is throttled to provide greater than or equal to 100 gpm at the pump discharge and the flow is monitored and trended. The Unit 3 A CVS makeup pump flow is XXX gpm and the Unit 3 B CVS makeup pump flow is YYY gpm. The Unit 4 A CVS makeup pump flow is XXX gpm and the Unit 4 B CVS makeup pump flow is YYY gpm. This demonstrates that each VCS makeup pump provides spray flow to the pressurizer with the PCS at greater than or equal to 2000 psia.

Safetv-related displavs identified in Table 2.3.2-1 can be retrieved in the MCR.

An inspection is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Item 09,10a, and lib and SV4-ITAAC-ST-2.3.02.08a.i, Item 09, 10a, and lib (References 3 & 4)to ensure the safety-related displays identified in Combined License (COL)Table 2.3.2-1 (Attachment A)can be retrieved in the MCR.

The valves listed in Attachment A as having safety-related displays for valve position are located on the MCR PMS Visual Display Units(VDUs) and verified to indicate on each of the VDUs. This confirms that safety-related displays identified in Attachment A can be retrieved in the Unit 3 and Unit 4 MCR.

Controls in the MCR operate to cause the remotelv operated valves identified in Table 2.3.2-1 to perform active functions.

Stroke testing is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Item 09,10a, and lib and SV4-ITAAC-ST-2.3.02.08a.i, Item 09, 10a, and lib (References 3 & 4) using controls in the MCR to confirm that the remotely operated valves identified in COL Table 2.3.2-1 (Attachment B) perform their active function.

The valves identified in Attachment B are stroke tested using an operator work station in the MCR. The valves are initially opened and are stroked closed using the Plant Control System (PLS) and verified locally to have gone closed. This demonstrates that controls in the Unit 3 and Unit 4 MCR operate to cause the remotely operated valves identified in Attachment B to perform active functions.

i) The valves identified in Table 2.3.2-1 as having PMS control perform the active function identified in the table after receiving a signal from the PMS.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-PMS-ITPP-504 and 4-PMS-ITPP-504(References 5 & 6), 3-PMS-ITPP-523 and 4-PMS-ITPP-523(References 7 & 8), and 3- PMS-ITPP-524 and 4-PMS-ITPP-524(References 9 & 10)to demonstrate that the valves identified in COL Table 2.3.2-1 (Attachment C)as having PMS control perform the active function identified in the table after receiving a signal from the PMS.

Testing is performed in references 5 & 6 that positions valves CVS-PL-V136A, CVS-PL-V136B to the open position. A PMS PRHR Actuation signal is generated by opening the PRHR heat exchanger outlet flow control valve. This generates an automatic PRHR actuation from PMS.

The valves are verified to perform their active function to transfer closed.

Testing is performed in references 7 & 8 that positions valves CVS-PL-V045, CVS-PL-V047, CVS-PL-V092, CVS-PL-V094, and CVS-PL-V219 to the open position. A high-2 containment

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 6 of 16 pressure signal is generated by simulating a signal on the output terminals of the containment pressure instruments which generates a PMS safeguards signal and a containment Isolation signal. The valves are verified to perform their active function to transfer closed.

Testing is performed in references 9 & 10 that positions valves CVS-PL-V001, GVS-PL-V0002, CVS-PL-V003, CVS-PL-V084, CVS-PL-V090, and CVS-PL-V091 to the open position. A PMS CVS Makeup Isolation is initiated by manual actuation and valves CVS-PL-V001, CVS-PL-V0002, CVS-PL-V003 and CVS-PL-V084 are verified to perform their active function to transfer closed. A PMS Boron Dilution Block is initiated by simulating a source range flux doubling and valves CVS-PL-V090 and CVS-PL-V091 are verified to perform their active function to transfer closed.

The test results demonstrate that the valves identified in Attachment0for Unit 3 and Unit 4 as having PMS control perform the active function identified in the table after receiving a signal from the PMS.

W) These valves close within the followino times after receipt of an actuation signal:

V090. V091 < 30 sec. V136A/B < 20 sec.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-PMS-ITPP-504 and 4-PMS-ITPP-504(References 5 & 6) and 3-PMS-ITPP-524 and 4-PMS-ITPP-524(references 9 & 10) to demonstrate that the remotely operated CVS isolation valves CVS-V090, V091, V136A/B listed in Attachment D close within the following times after receipt of an actuation signal: V090, V091 < 30 sec, V136A/B < 20 sec.

Testing is performed in references 5 & 6 that positions valves CVS-PL-V136A, CVS-PL-V136B to the open position. A PMS PRHR Actuation signal is generated by opening the PRHR heat exchanger outlet flow control valve. This generates an automatic PRHR actuation from PMS.

The valves are timed using a PMS tabular trend and verified to meet the acceptance criteria.

The valve closure times are listed in Attachment D.

Testing is performed in references 9 & 10 that positions valves CVS-PL-V090 and CVS-PL-V091 to the open position. A source range flux doubling signal is generated by simulating a flux doubling signal PMS reactor trip and Boron Dilution Block signal. The valves are timed using a PMS tabular trend and verified to meet the acceptance criteria. The valve closure times are listed in Attachment D.

The test results demonstrate that the Unit 3 and Unit 4 valves close within the following times after receipt of an actuation signal: V090, V091 < 30 sec, V136A/B < 20 sec.

iih Each motor-operated valve changes position as indicated in Table 2.3.2-1 under pre operational test conditions.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-CVS-ITPP-502 and 4-CVS-ITPP-502(References 1 & 2)to confirm the motor-operated valves listed in COL Appendix C Table 2.3.2-1 (Attachment E)change position under pre-operational flow, differential pressure, and temperature conditions.

Testing establishes the preoperational test conditions of RCS at atmospheric pressure and ensures the RCS makeup rate is greater than or equal to 135 gpm and less than or equal to 175

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 7 of 16 gpm which provides the greatest differentiai pressure for makeup line Motor-operated Valve (MOV)operation. CVS-PL-V090 is closed and verified to be closed locally and then reopened.

The preoperational test conditions are re-verified and CVS-PL-V091 is closed and verified to be closed locally.

Preoperational test conditions are established with the PCS at 555°F - 559°F degrees and 2220 psig -2250 psig with purification in service at normai operating temperature and pressure.

CVS-PL-V001 is closed and verified to be ciosed locaiiy and then CVS-PL-V001 wiii be re opened. Preoperational test conditions are re-verified and CVS-PL-V002 is closed and verified to be closed locally, then CVS-PL-V002 will be opened. The preoperational test conditions are re-verified and CVS-PL-V003 is closed and verified to be closed locally.

The test results demonstrate that each motor-operated valve for Unit 3 and Unit 4 changes position as indicated in Attachment E under pre-operationai test conditions.

iv) Each check vaive chances position as indicated in Tabie 2.3.2-1.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-CVS-ITPP-502 and 4-CVS-ITPP-502(References 1 & 2)to confirm that each check valve with an active safety function changes position as indicated in COL Table 2.3.2-1 (Attachment F) under pre-operational test pressure, temperature, and fluid flow conditions.

Preoperationai test conditions are established with the PCS at 555°F - 559°F degrees and 2220 psig -2250 psig for the performance of the check valve testing that foiiows.

With preoperationai test conditions established and purification fiow established, CVS-PL-V001 is closed and check valves CVS-PL-V080, CVS-PL-V081, and CVS-PL-V082 are verified to close using non-intrusive valve disc position verification.

With preoperational test conditions estabiished and makeup and purification in service, CVS-PL-V081 is ciosed and CVS-PL-V067 is verified to be open by uitrasonic flow indication. CVS-PL-V081 is reopened and the uitrasonic flow indication (no flow) is used to demonstrate that CVS-PL-V067 is closed.

With preoperational test conditions established and makeup and purification in service, CVS-PL-V091 is closed and CVS-PL-V100 is verified to open by ultrasonic flow instrument indication.

CVS-PL-V091 is opened and CVS-PL-V100 is verified to ciose by flow indication (no flow).

With preoperational test conditions established, hydrogen addition is performed to the PCS which demonstrates the CVS-PL-217 is open. The hydrogen injection package is isolated, the hydrogen injection valve CVS-PL-219 is verified to be open and the hydrogen injection line is vented off upstream of CVS-PL-V217. The pressure upstream of CVS-PL-217 is verified to lower which demonstrates the check vaive has ciosed.

With preoperationai test conditions established, pressurizer auxiiiary spray is placed into service, the auxiliary spray air-operated valve is closed and CVS-PL-V085 is verified to close using non-intrusive valve disc position verification.

The test resuits demonstrate that each check valve for Unit 3 and Unit 4 changes position as indicated in Attachment F.

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 8 of 16 Upon loss of motive power, each remotely operated valve identified in Table 2.3.2-1 assumes the Indicated loss of motive power position.

Testing is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Item 09,10a, and lib and SV4-ITAAC-ST-2.3.02.08a.i, Item 09, 10a, and lib (References 3 & 4)to verify that each remotely operated valve identified in COL Table 2.3.2-1 (Attachment G)assume the indicated loss of motive power position upon a loss of motive power.

The motor-operated valves are placed in the closed position and the power supply to the motor operator is opened. The valves are verified to remain in the closed position and an attempt is made to open the valves with controls in the MCR.The valves are verified to remain in the closed position locally. The air operated valves are placed in the open position and verified to be open locally. Power to the air supply solenoids are opened and the valves are verified to close locally. An attempt to open the valves is made using the controls in the MCR and the valves are verified to remain closed locally.

The test results confirm that upon loss of motive power on Unit 3 and Unit 4, each remotely operated valve identified in Attachment G assumes the indicated loss of motive power position.

Controls in the MCR cause pumps identified in Table 2.3.2-3 to perform the listed function.

Testing is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13 and SV4-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13 (References 11 & 12)to confirm controls in the MCR cause the pumps identified in COL Table 2.3.2-3(Attachment H)to perform the listed function.

Testing is performed at an operator work station by navigating to the CVS makeup and letdown system screen. The A CVS makeup pump is started and verified to be running locally. The A CVS makeup pump is stopped and the B CVS makeup pump is started and verified to be running locally.

The test results confirm that controls in Unit 3 and Unit 4 MCR cause pumps identified in Attachment H to perform the listed function.

The pumps identified in Table 2.3.2-3 start after a sional is generated bv the PLS.

Testing is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13 and SV4-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13(References 11 & 12) to confirm controls in the MCR cause the pumps identified in COL Table 2.3.2-3(Attachment H)to perform the listed function.

Testing is performed at a PLS operator work station by navigating to the CVS - makeup and letdown system screen. The A CVS makeup pump Is started and verified to be running locally.

The A CVS makeup pump is stopped and the B CVS makeup pump is started and verified to be running locally.

The test results confirm that controls in Unit 3 and Unit 4 MCR cause pumps identified in Attachment H to perform the listed function.

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 9 of 16 Displays identified in Table 2.3.2-3 can be retrieved in the MGR.

An inspection is performed in accordance with Unit 3 and Unit 4 component test procedures SV3-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13 and SV4-ITAAC-ST-2.3.02.08a.i, Items 12a, 12b, 13(References 11 & 12)to confirm displays identified in COL Table 2.3.2-3(Attachment I) can be retrieved in the MGR.

Testing is performed at an operator work station by navigating to several CVS system screens, locating the items identified in Attachment I, and ensuring the items identified can be retrieved in the MGR.

The test results demonstrate that displays identified in Table 2.3.2-3 can be retrieved in the Unit 3 MGR and in the Unit 4 MGR.

References 1 through 12 are available for NRG inspection as part of Unit 3 and Unit 4 ITAAG Completion Packages(Reference 13 and 14).

List of ITAAC Findings In accordance with plant procedures for ITAAG completion. Southern Nuclear Operating Company(SNG) performed a review of all findings pertaining to the subject ITAAG and associated corrective actions. This review found there are no relevant ITAAG findings associated with this ITAAG.

References favaiiabie for NRC inspection)

1. 3-GVS-ITPP-502,"Chemical and Volume Control System Pre-core Hot Functional Test Preoperational Test Procedure"

2. 4-GVS-ITPP-502,"Chemical and Volume Control System Pre-core Hot Functional Test Preoperational Test Procedure"

3. SV3-ITAAG-ST-2.3.02.08a.i, Item 09, 10a, and 1 lb "CVS Remotely Operated Valve Stroke Test- ITAAG: SV3-2.3.02.08a.i, Item 09,10a, and lib"

4. SV4-ITAAG-ST-2.3.02.08a.i, Item 09, 10a, and 1 lb "CVS Remotely Operated Valve Stroke Test- ITAAG: SV3-2.3.02.08a.i, Item 09,10a, and lib"

5. 3-PMS-ITPP-504,"PMS REACTOR TRIP BREAKERS"

6. 4-PMS-ITPP-504,"PMS REACTOR TRIP BREAKERS

7. 3-PMS-ITPP-523,"Containment Pressure High-2 Actuation Preoperational Test Procedure"

8. 4-PMS-ITPP-523,"Containment Pressure High-2 Actuation Preoperational Test Procedure"

9. 3- PMS-ITPP-524,"PMS Gold Actuations Preoperational Test Procedure" 10.4- PMS-ITPP-524,"PMS Gold Actuations Preoperational Test Procedure"

11. SV3-ITAAG-ST-2.3.02.08a.i, Items 12a, 12b, 13,"CVS Component Indication Verifications"

12. SV4-ITAAG-ST-2.3.02.08a.i, Items 12a, 12b, 13,"CVS Component Indication Verifications" 13.2.3.02.08a.i-U3-GP-Rev 0, ITAAG Completion Package 14.2.3.02.08a.i-U4-GP-Rev 0, ITAAG Completion Package

15. NEI 08-01,"Industry Guideline for the ITAAG Closure Process Under 10 GFR Part 52"

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 10 of 16 Attachment A Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Safety-Related Display RCS Purification Motor-Operated Isolation CVS-PL-V001 Yes Valve (Valve Position)

RCS Purification Motor-Operated Isolation CVS-PL-V002 Yes Valve (Valve Position)

RCS Purification Motor-Operated Isolation CVS-PL-V003 Yes Valve (Vaive Position)

CVS Letdown Containment Isolation Valve CVS-PL-V045 Yes (Valve Position)

CVS Letdown Containment Isolation Valve CVS-PL-V047 Yes (Valve Position)

CVS Auxiliary Pressurizer Spray Line CVS-PL-V084 Yes Pressure Boundary Valve (Valve Position)

CVS Makeup Line Containment Isolation CVS-PL-V090 Yes Motor-operated Valve (Valve Position)

CVS Makeup Line Containment Isolation CVS-PL-V091 Yes Motor-operated Valve (Valve Position)

CVS Zinc Injection Containment Isolation CVS-PL-V092 Yes Valve ORC (Valve Position)

CVS Zinc Injection Containment Isolation CVS-PL-V094 Yes Valve IRC (Valve Position)

CVS Demineralized Water Isolation Valve CVS-PL-V136A Yes (Valve Position)

CVS Demineralized Water Isolation Valve CVS-PL-V136B Yes (Valve Position)

CVS Hydrogen Injection Containment CVS-PL-V219 Yes Isolation Valve ORC (Valve Position)

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 11 of 16 Attachment B Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Remotely Active Function Operated Valve RCS Purification Motor-Operated CVS-PL-V001 Yes Transfer Isolation Valve Closed RCS Purification Motor-Operated CVS-PL-V002 Yes Transfer Isolation Valve Closed RCS Purification Motor-Operated CVS-PL-V003 Yes Transfer Isolation Valve Closed CVS Letdown Containment Isolation CVS-PL-V045 Yes Transfer Valve Closed CVS Letdown Containment Isolation CVS-PL-V047 Yes Transfer Valve Closed CVS Auxiliary Pressurizer Spray CVS-PL-V084 Yes Transfer Line Pressure Boundary Valve Closed CVS Makeup Line Containment CVS-PL-V090 Yes Transfer Isolation Motor-operated Valve Closed CVS Makeup Line Containment CVS-PL-V091 Yes Transfer Isolation Motor-operated Valve Closed CVS Zinc Injection Containment CVS-PL-V092 Yes Transfer Isolation Valve ORC Closed CVS Zinc Injection Containment CVS-PL-V094 Yes Transfer Isolation Valve IRC Closed CVS Demineralized Water Isolation CVS-PL-V136A Yes Transfer Valve Closed CVS Demineralized Water Isolation CVS-PL-V136B Yes Transfer Valve Closed CVS Hydrogen Injection CVS-PL-V219 Yes Transfer Containment Isolation Valve ORC Closed

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 12 of 16 Attachment0 Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Control PMS Active Function PCS Purification Motor-Operated CVS-PL-V001 Yes Transfer Isolation Valve Closed PCS Purification Motor-Operated CVS-PL-V002 Yes Transfer Isolation Valve Closed PCS Purification Motor-Operated CVS-PL-V003 Yes Transfer Isolation Valve Closed CVS Letdown Containment Isolation CVS-PL-V045 Yes Transfer Valve Closed CVS Letdown Containment Isolation CVS-PL-V047 Yes Transfer Valve Closed CVS Auxiliary Pressurizer Spray CVS-PL-V084 Yes Transfer Line Pressure Boundary Valve Closed CVS Makeup Line Containment CVS-PL-V090 Yes Transfer Isolation Motor-operated Valve Closed CVS Makeup Line Containment CVS-PL-V091 Yes Transfer Isolation Motor-operated Valve Closed CVS Zinc Injection Containment CVS-PL-V092 Yes Transfer Isolation Valve OPC Closed CVS Zinc Injection Containment CVS-PL-V094 Yes Transfer Isolation Valve IPC Closed CVS Deminerallzed Water Isolation CVS-PL-V136A Yes Transfer Valve Closed CVS Deminerallzed Water Isolation CVS-PL-V136B Yes Transfer Valve Closed CVS Hydrogen Injection CVS-PL-V219 Yes Transfer Containment Isolation Valve OPC Closed

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 13 of 16 Attachment D Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Remotely Control Closure Operated PMS Time Valve CVS Makeup Line 3-CVS-PL- Yes Yes XX sec Containment V090 isolation Motor-operated Valve CVS Makeup Line 3-CVS-PL- Yes Yes XX sec Containment V091 Isolation Motor-operated Valve CVS Demineralized 3-CVS-PL- Yes Yes XX sec Water Isolation V136A Valve CVS Demineralized 3-CVS-PL- Yes Yes XX sec Water Isolation V136B Valve CVS Makeup Line 4-CVS-PL- Yes Yes XX sec Containment V090 Isolation Motor-operated Valve CVS Makeup Line 4-CVS-PL- Yes Yes XX sec Containment V091 Isolation Motor-operated Valve CVS Demineralized 4-CVS-PL- Yes Yes XX sec Water Isolation V136A Valve CVS Demineralized 4-CVS-PL- Yes Yes XX sec Water Isolation V136B Valve

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 14 of 16 Attachment E Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Active Function RCS Purification Motor-Operated Isolation CVS-PL-V001 Transfer Closed Valve RCS Purification Motor-Operated Isolation CVS-PL-V002 Transfer Closed Valve RCS Purification Motor-Operated Isolation CVS-PL-V003 Transfer Closed Valve CVS Makeup Line Containment Isolation CVS-PL-V090 Transfer Closed Motor-operated Valve CVS Makeup Line Containment Isolation CVS-PL-V091 Transfer Closed Motor-operated Valve Attachment F Excerpt from COL Appendix C Table 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Active Function CVS Makeup Return Line CVS-PL-V067 Transfer Bypass Check Valve Open/

Transfer Closed CVS Purification Return Line CVS-PL-V080 Transfer Pressure Boundary Check Valve Closed CVS Purification Return Line CVS-PL-V081 Transfer Pressure Boundary Isolation Closed Check Valve CVS Purification Return Line CVS-PL-V082 Transfer Pressure Boundary Check Valve Closed CVS Auxiliary Pressurizer CVS-PL-V085 Transfer Spray Line Pressure Boundary Closed Check Valve CVS Makeup Line Containment CVS-PL-V100 Transfer Isolation Thermal Relief Valve Open/

Transfer Closed CVS Hydrogen Injection CVS-PL-V217 Transfer Containment Isolation Check Closed Valve IRC

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 15 of 16 Attachment G Excerpt from COL Appendix C Tabie 2.3.2-1 Table 2.3.2-1 Equipment Name Tag No. Remotely Loss of Operated Motive Valve Power Position RCS Purification Motor-Operated CVS-PL-V001 Yes As Is Isolation Valve RCS Purification Motor-Operated CVS-PL-V002 Yes As Is Isolation Valve RCS Purification Motor-Operated CVS-PL-V003 Yes As Is Isolation Valve CVS Letdown Containment Isolation CVS-PL-V045 Yes Closed Vaive CVS Letdown Containment Isoiation CVS-PL-V047 Yes Closed Valve CVS Auxiliary Pressurizer Spray Line CVS-PL-V084 Yes Closed Pressure Boundary Valve CVS Makeup Line Containment CVS-PL-V090 Yes As Is Isolation Motor-operated Valve CVS Makeup Line Containment CVS-PL-V091 Yes As Is Isolation Motor-operated Valve CVS Zinc Injection Containment CVS-PL-V092 Yes Closed Isolation Vaive ORC CVS Zinc Injection Containment CVS-PL-V094 Yes Closed Isoiation Valve IRC CVS Demineralized Water Isolation CVS-PL-V136A Yes Closed Valve CVS Demineralized Water Isolation CVS-PL-V136B Yes Closed Valve CVS Hydrogen Injection Containment CVS-PL-V219 Yes Closed Isolation Valve ORC Attachment H Excerpt from COL Appendix C Table 2.3.2-3 Table 2.3.2-1 Equipment Tag No. Control Function CVS Makeup Pump A CVS-MP-01A Start CVS Makeup Pump B CVS-MP-01B Start

U.S. Nuclear Regulatory Commission ND-19-0077 Enclosure Page 16 of 16 Attachment I Excerpt from COL Appendix C Table 2.3.2-3 Equipment Name Tag No. Display CVS Makeup Pump A CVS-MP-01A Yes (Run Status)

CVS Makeup Pump B CVS-MP-01B Yes (Run Status)

Purification Flow Sensor CVS-001 Yes Purification Return Flow Sensor CVS-025 Yes CVS Purification Return Line (Position Indicator) CVS-PL-V081 Yes Auxiliary Spray Line Isolation Valve CVS-PL-V084 Yes (Position Indicator)

Boric Acid Storage Tank Level Sensor CVS-109 Yes Boric Acid Flow Sensor CVS-115 Yes Makeup Blend Valve (Position Indicator) CVS-PL-V115 Yes CVS Demineralized Water Isolation Valve CVS-PL-V136A Yes (Position Indicator)

CVS Demineralized Water Isolation Valve CVS-PL-V136B Yes (Position Indicator)

Makeup Pump Discharge Flow Sensor CVS-157 Yes Makeup Flow Control Valve (Position Indicator) CVS-PL-V157 Yes