ND-19-0113, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.05.07c (Index Number 270)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.2.05.07c (Index Number 270)

ML19051A082
Person / Time
Site:	Vogtle
Issue date:	02/20/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0113
Download: ML19051A082 (7)

Text

Michael J. Yox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynestxiro, GA 30830 706-848-6459 tel 410-474-8587 cell FEB 2 0 2019 myox@southernco.com Docket Nos.: 52-025 52-026 ND-19-0113 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 2.2.05.07c [Index Number 2701 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of February 5, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.05.07c [Index Number 270] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.2.05.07c [Index Number 270]. 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)(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.

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 2.2.05.07c [Index Number 270]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0113 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power ComDanv 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. 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 Reoulatorv 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 Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-19-0113 Page 3of 3 Westlnqhouse Electric Companv. 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. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-19-0113 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-19-0113 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.05.07c[Index Number 270]

U.S. Nuclear Regulatory Commission ND-19-0113 Enclosure Page 2of 4 ITAAC Statement Design Commitment 7.c) The heat loads within the MCR,the l&C equipment rooms, and the Class 1E dc equipment rooms are within design basis assumptions to limit the heatup of the rooms identified in Table 2.2.5-4.

Inspections. Tests. Analyses An analysis will be performed to determine that the heat loads from as-built equipment within the rooms identified in Table 2.2.5-4 are less than or equal to the design basis assumptions.

Acceptance Criteria A report exists and concludes that: the heat loads within rooms identified in Table 2.2.5-4 are less than or equal to the specified values or that an analysis report exists that concludes:

- The temperature and humidity in the MCR remain within limits for reliable human performance for the 72-hour period.

- The maximum temperature for the 72-hour period for the l&C rooms is less than or equal to 120°F.

- The maximum temperature for the 72-hour period for the Class 1E dc equipment rooms is less than or equal to 120°F.

ITAAC Completion Description An analysis is performed based on measured test data to confirm that the heat loads from as-built equipment within the Main Control Room (MCR), Instrument and Controls(l&C) equipment rooms, and the class 1E direct current (dc) equipment rooms are less than or equal to the design basis assumptions identified in Combined License(COL)Appendix C, Table 2.2.5-4 (Attachment A).

Preoperational test procedures 3-VES-ITPP-501 and 4-VES-ITPP-501 (References 1 and 2) performs the MCR heat load test by installing 16 resistance temperature detectors(RTDs) connected to a data acquisition system (DAQ). MCR temperature and relative humidity are recorded for a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and access to the MCR is restricted during the test. To test the MCR heat loads, the MCR boundary is manually isolated by the Nuclear Island Nonradioactive Ventilation System (VBS)and the MCR Emergency Habitability System (VES) is actuated. Designated heat loads are shed per design during the test, and a temporary heat source(as necessary) is used to simulate the heat load of 11 MCR occupants for the duration of the test. Testing results are used to either determine the MCR heat loads are within limits or are provided as input to perform an analysis and create a report that concludes that the temperature and humidity in the MCR remain within limits for reliable human performance for the 72-hour period.

References 1 and 2 performs l&C equipment rooms and the Class 1E dc equipment rooms heat load testing. Each room is equipped with RTDs connected to a DAQ, access to the room is restricted, ventilation supply and exhaust dampers are closed, all equipment in the rooms is energized and temperature data is recorded for a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Testing results are used

U.S. Nuclear Regulatory Commission ND-19-0113 Enclosure Page 3of 4 to either determine the l&C rooms and dc equipment rooms heat loads are within limits or are provided as input to perform an analysis and create a report that concludes the maximum temperature for the 72-hour period for the l&C rooms and dc equipment rooms is less than or equal to 120°F.

Heat load analysis based on test data will take into account the rooms' configuration and heat transfer characteristics (design basis assumptions) to conclude that the heat loads within rooms identified in Table 2.2.5-4 are less than or equal to the design basis assumptions or that:

- The temperature and humidity in the MCR remain within limits for reliable human performance for the 72-hour period.

-The maximum temperature for the 72-hour period for the l&C rooms is less than or equal to 120°F.

-The maximum temperature for the 72-hour period for the Class 1E dc equipment rooms is less than or equal to 120°F.

Results of the preoperational testing are documented in Unit 3 and Unit 4 preoperational test procedures(References 1 and 2)and a report exists(References 3 and 4)and concludes that the heat loads within rooms identified in Table 2.2.5-4 are less than or equal to the design basis assumptions or that an analysis report exists that concludes:

-The temperature and humidity in the MCR remain within limits for reliable human performance for the 72-hour period.

-The maximum temperature for the 72-hour period for the l&C rooms is less than or equal to 120°F.

-The maximum temperature for the 72-hour period for the Class 1E dc equipment rooms is less than or equal to 120°F.

References 1 through 4 are available for NRC inspection as part of Unit 3 and Unit 4 ITAAC 2.2.05.07c Completion Packages(Reference 5 and 6).

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

References(available for NRC inspection)

1. 3-VES-ITPP-501,"Main Control Room Emergency Habitability System Preoperational Test Procedure"

2. 4-VES-ITPP-501,"Main Control Room Emergency Habitability System Preoperational Test Procedure"

3. SV3-XXX,"ITAAC 270 Heat Load Analysis"

4. SV4-XXX,"ITAAC 270 Heat Load Analysis"

5. 2.2.05.07c-U3-CP-Rev 0, ITAAC Completion Package

6. 2.2.05.07c-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-19-0113 Enclosure Page 4 of 4 Attachment A "Excerpted from COL Table 2.2.5-4 Room Name and Heat Load 0 to 24 Calculated Heat Load Calculated Numbers* Hours(Btu/s)* Heat Load 24 to 72 Heat Load etc 24 hours 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Btu/s)* hours (Btu/s) (Btu/s)

MOP Envelope Room 23.5(hour 0 through 0.5) 12401 14.5(hour 0.5 through 3.5) 3.95 4.75(hour 3.5 through 24) l&C Room 12301 8.8 0 l&C Room 12302 13.0 4.2 l&C Room 12304 13.0 4.2 l&C Room 12305 8.8 0 DC Equipment Room 3.7(hour 0 through 1) 0 12201 2.4(hour 2 through 24)

DC Equipment Room 5.8(hour 0 through 1) 2.0 12203 4.5(hour 2 through 24)

DC Equipment Room 3.7(hour 0 through 1) 0 12205 2.4(hour 2 through 24)

DC Equipment Room 5.8(hour 0 through 1) 2.0 12207 4.5(hour 2 through 24)