ND-19-0702, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.07.07c (Index Number 408)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.07.07c (Index Number 408)

ML19162A230
Person / Time
Site:	Vogtle
Issue date:	06/11/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.3.07.07c, ND-19-0702
Download: ML19162A230 (9)

Text

Michael J. Yox 7825 River Road A Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tei JUN 1 1 2019 Docket Nos.: 52-025 52-026 ND-19-0702 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 2.3.07.07c [Index Number 4081 Ladies and Gentlemen; Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of June 10, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.07.07c [Index Number 408]

has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing this ITAAC. 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 Dir ctor Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.07.07c [Index Number 408]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0702 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. R.G. West(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 Regulatory Commission Mr. W. Jones(w/o enclosures)

Mr. F. D. Brown 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. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Mr. T. Lamb Mr. M. Webb Mr. P. O'Bryan Mr. T. Fredette Mr. C. Weber Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-0702 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse 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. Hesler, 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-19-0702 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-19-0702 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.07.07c [Index Number 408]

U.S. Nuclear Regulatory Commission ND-19-0702 Enclosure Page 2 of 6 ITAAC Statement Desion Commitment 7c)The SFS provides check valves in the drain line from the refueling cavity to prevent flooding of the refueling cavity during containment flooding.

8. The SFS provides the nonsafety-related function of removing spent fuel decay heat using pumped flow through a heat exchanger.

9. Safety-related displays identified in Table 2.3.7-1 can be retrieved in the MCR.

10. Controls exist in the MCR to cause the pumps identified in Table 2.3.7-3 to perform their listed functions.

11. Displays of the SFS parameters identified in Table 2.3.7-3 can be retrieved in the MCR.

I nsoections/Tests/Analvses Exercise testing of the check valves with active safety-functions identified in Table 2.3.7-1 will be performed under pre-operational test pressure, temperature and flow conditions.

ii) Testing will be performed to confirm that each SFS pump provides flow through its heat exchanger when taking suction from the SFP and returning flow to the SFP.

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

Testing will be performed to actuate the pumps identified in Table 2.3.7-3 using controls in the MCR.

Inspection will be performed for retrievability in the MCR of the displays identified in Table 2.3.7-3.

Acceptance Criteria Each check valve changes position as indicated on Table 2.3.7-1.

ii) Each SFS pump produces at least 900 gpm through its heat exchanger.

Safety-related displays identified in Table 2.3.7-1 can be retrieved in the MCR.

Controls in the MCR cause pumps identified in Table 2.3.7-3 to perform the listed functions.

Displays of the SFS parameters identified in Table 2.3.7-3 are retrieved in the MCR.

ITAAC Completlon Description Testing is performed to demonstrate that the Spent Fuel Pool Cooling System (SFS) provides check valves in the drain line from the refueling cavity to prevent flooding of the refueling cavity during containment flooding, verifies the SFS provides the nonsafety-related function of removing spent fuel decay heat using pumped flow through a heat exchanger, and that controls

U.S. Nuclear Regulatory Commission ND-19-0702 Enclosure Page 3 of 6 exist in the Main Control Room (MCR)to cause the pumps identified in Table 2.3.7-3 to perform their listed functions. Inspections are performed to verify that safety-related displays identified in Table 2.3.7-1 can be retrieved in the MCR and that displays of the SFS parameters identified in Table 2.3.7-3 can be retrieved in the MCR.

Each check valve chances position as indicated on Table 2.3.7-1.

Testing is performed in accordance with the Unit 3 and Unit 4 Preoperational Tests 3-SFS-ITPP-502 and 4-SFS-ITPP-502(References 1 and 2) with the initial conditions of refueling cavity drain isolation valve closed, refueling cavity level of approximately 28 ft., temporary drain hose attached to the cavity drain with a valve attached and routed to a floor drain, and non-intrusive valve disk monitoring installed on SFS-PL-V071 and SFS-PL-V072. The refueling cavity drain isolation valve and the temporary valve on the drain hose is opened to initiate flow and both check valves are verified to open by flow and the non-intrusive monitoring instruments.

The temporary valve on the drain hose is closed to stop flow and both check valves are verified to close using the non-intrusive monitoring instruments. This flow path is depicted on Piping and Instrument Drawing 3-SFS-M6-001.

This testing verifies that for Unit 3 and Unit 4 each check valve changes position as indicated on Table 2.3.7-1 (Attachment A).

ih Each SFS oump produces at least 900 aom throuoh its heat exchanoer.

Testing is performed in accordance with the Unit 3 and Unit 4 preoperational test procedures 3-SFS-ITPP-502 and 4-SFS-ITPP-502(References 1 and 2). The test is conducted by running each of the SFS pumps individually, taking suction from and returning flow to the SFP. Once steady flow is established, instrument readings are taken at the respective SFS pump discharge flow sensor, recorded in the test procedure and corrected for measurement uncertainty. The test is performed using multiple system alignments with the demineralizers in/out of service and single and dual pump configurations.

The Unit 3 A SFS pump(SFS-MP-01 A) produced a minimum flow of XXX gpm for all alignments and the B SFS pump (SFS-MP-01 B) produced a minimum flow of YYY gpm for all alignments during testing. The Unit 4 A SFS pump (SFS-MP-01 A) produced a minimum flow of XXX gpm for all alignments and the B SFS pump (SFS-MP-01 B) produced a minimum flow of YYY gpm for all alignments during testing.

The Unit 3 and Unit 4 preoperational test results (References 1 and 2)confirm that each SFS pump produces at least 900 gpm through its heat exchanger when taking suction from and returning flow to the SFP.

Safetv-related disolavs identified in Table 2.3.7-1 can be retrieved in the MCR.

The inspection is performed in accordance with Unit 3 and Unit 4 component test packages SNC922101 and SNCXXXXXX (References 3 & 4)to confirm that safety-related displays identified in COL Table 2.3.7-1 (Attachment B)can be retrieved in the MCR.

The inspection visually confirms that when each of the safety-related displays identified in Attachment A is summoned at the MCR Protection and Safety Monitoring System (PMS) Visual Display Units(VDUs),the summoned safety-related display appears on the PMS VDU. This

U.S. Nuclear Regulatory Commission ND-19-0702 Enclosure Page 4 of 6 confirms tfiat the safety-related displays identified in Table 2.3.7-1 can be retrieved in the Unit 3 and Unit 4 MGR.

Controls in the MGR cause oumos identified in Table 2.3.7-3 to perform the listed functions.

Testing is performed in accordance with Unit 3 and Unit 4 component test packages SNC922101 and SNCXXXXXX (References 3 & 4)to verify controls in the MGR cause pumps identified in Table 2.3.7-3(Attachment G)to perform the listed functions.

Testing is performed by ensuring the SFS A Train is filled and vented and then it is started per the operating procedure in the MGR. The pump start is verified locally and documented in the test package. The test then ensures the SFS B Train is filled and vented and then it is started per the operating procedure in the MGR. The pump start is verified locally and documented in the test package. This confirms that controls in the MGR cause pumps identified in Table 2.3.7-3 to perform the listed functions.

Disolavs of the SFS oarameters identified in Table 2.3.7-3 are retrieved in the MGR.

The inspection is performed in accordance with Unit 3 and Unit 4 component test packages SNG922101 and SNGXXXXXX (References 3 & 4)to confirm that the displays identified in GOL Table 2.3.7-3(Attachment D)can be retrieved in the MGR.

The inspection visually confirms that when each of the displays of parameters identified in Attachment D is summoned at an MGR workstation, the summoned plant parameter appears on a display monitor at that MGR workstation.

References 1 and 4 are available for NRG inspection as part of Unit 3 and Unit 4 ITAAG Gompletion Packages(Reference 5 and 6).

List of ITAAC Findings In accordance with plant procedures for ITAAG completion, Southern Nuclear Operating Gompany(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(available for NRC inspection)

1. 3-SFS-ITPP-502,"Spent Fuel Pool Gooling System Flow Path Preoperational Test Procedure"

2. 4-SFS-ITPP-502,"Spent Fuel Pool Gooling System Flow Path Preoperational Test Procedure"

3. SNG922101,"Spent Fuel System Indication and Gontrol Function Verifications- ITAAG:

SV3-2.3.07.07C Items 9, 10, & 11"

4. SNGXXXXXX,"Spent Fuel System Indication and Gontrol Function Verifications - ITAAG:

SV4-2.3.07.07C Items 9,10, & 11"

5. 2.3.07.07c-U3-GP-Rev 0, ITAAG Gompletion Package

6. 2.3.07.07c-U4-GP-Rev 0, ITAAG Gompletion Package

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

U.S. Nuclear Regulatory Commission ND-19-0702 Enclosure Page 5 of 6 Attachment A

'Excerpt from COL Appendix 0 Table 2.3.7-1

^Component Name *Tag No. *Actlve Function Refueling Cavity Drain Line SFS-PL-V071 Transfer Open Check Valve Transfer Closed Refueling Cavity Drain Line SFS-PL-V072 Transfer Open Check Valve Transfer Closed Attachment B

'Excerpt from COL Appendix C Table 2.3.7-1 "Component Name "Tag No. "Safety-Related Display Spent Fuel Pool Level Sensor SFS-019A Yes Spent Fuel Pool Level Sensor SFS-019B Yes Spent Fuel Pool Level Sensor SFS-019C Yes Refueling Cavity Drain to SGS SFS-PL-V031 Yes Compartment Isolation Valve Refueling Cavity Drain to Containment Sump SFS-PL-V033 Yes Isolation Valve SFS Containment Floodup Isolation Valve SFS-PL-V075 Yes Attachment C

• Excerpt from COL Appendix C Table 2.3.7-3 "Component Name "Tag No. "Control Function SFS Pump 1A SFS-MP-01A Start SFS Pump 1B SFS-MP-01B Start

U.S. Nuclear Regulatory Commission ND-19-0702 Enclosure Page 6 of 6 Attachment D

• Excerpt from COL Appendix 0 Table 2.3.7-3

^Component Name *Tag No. Display SFS Pump 1A SFS-MP-01A Yes(Run Status)

BPS Pump 1B SFS-MP-01B Yes(Run Status)

SFS Flow Sensor SFS-13A Yes SFS Flow Sensor SFS-13B Yes Spent Fuel Pool Temperature Sensor SFS-018 Yes Cask Loading Pit Level Sensor SFS-022 Yes