ND-19-0339, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.06.09b.ii (Index Number 375)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.3.06.09b.ii (Index Number 375)

ML19109A239
Person / Time
Site:	Vogtle
Issue date:	04/19/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0339
Download: ML19109A239 (12)

Text

^Southern Nuclear Michael J. Yox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 & 4 APR 1 9 2019 706-848-6459 tel Docket Nos.: 52-025 52-026 ND-19-0339 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 2.3.06.09b.ii [Index Number 3751 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of April 4, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections Tests Analyses and Acceptance Criteria (ITAAC) Item 2.3.06.09b.ii [Index Number 375] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.3.06.09b.ii[Index Number 375]. 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-19-0339 Page 2 of 4 Respectfully submitted, Mlchiael J. Yoj Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.06.09b.ll [Index Number 375]

MJY/DLW/sfr

U.S. Nuclear Regulatory Commission ND-19-0339 Page 3of 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. Vox 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 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 Qqiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0339 Page 4 of 4 Dalton Utilities Mr. T. Bundros Westinahouse 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., CDS 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-19-0339 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-19-0339 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.3.06.09b.ll [Index Number 375]

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 2of 8 ITAAC Statement Design Commitment 9.b) The RNS provides heat removal from the reactor coolant during shutdown operations.

9.c) The RNS provides low pressure makeup flow from the cask loading pit to the RCS for scenarios following actuation of the ADS.

9.d) The RNS provides heat removal from the in-containment refueling water storage tank (IRWST).

12.a) The motor-operated and check valves identified in Table 2.3.6-1 perform an active safety-related function to change position as indicated in the table.

I nspections/Tests/Analvses ii) Testing will be performed to confirm that the RNS can provide flow through the RNS heat exchangers when the pump suction is aligned to the RCS hot leg and the discharge is aligned to both PXS DVI lines with the RCS at atmospheric pressure.

iii) Inspection will be performed of the reactor coolant loop piping.

iv) Inspection will be performed of the RNS pump suction piping.

v) Inspection will be performed of the RNS pump suction nozzle connection to the RCS hot leg.

Testing will be performed to confirm that the RNS can provide low pressure makeup flow from the cask loading pit to the RCS when the pump suction is aligned to the cask loading pit and the discharge is aligned to both PXS DVI lines with RCS at atmospheric pressure.

Testing will be performed to confirm that the RNS can provide flow through the RNS heat exchangers when the pump suction is aligned to the IRWST and the discharge is aligned to the IRWST.

iii) Tests of the motor-operated valves will be performed under preoperational flow, differential pressure and temperature conditions.

iv) Exercise testing of the check valves active safety functions identified in Table 2.3.6-1 will be performed under preoperational test pressure, temperature and fluid flow conditions.

Acceotance Criteria ii) When tested individually, each RNS pump provides at least 1400 gpm net flow to the RCS when the hot leg water level is at an elevation 15.5 inches +/- 2 inches above the bottom of the hot leg.

iii) The RCS cold legs piping centerline is 17.5 inches +/- 2 inches above the hot legs piping centerline.

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 3of 8 iv) The RNS pump suction piping from the hot leg to the pump suction piping low point does not form a local high point (defined as an upward slope with a vertical rise greater than 3 inches).

v) The RNS suction line connection to the RCS is constructed from 20-inch Schedule 140 pipe.

When tested individually, each RNS pump provides at least 1100 gpm net flow to the RCS with the water level maintained within the range of > 10 ft and < 15 ft from the bottom of the cask loading pit.

Two operating RNS pumps provide at least 2000 gpm to the IRWST.

ill) Each motor-operated valve changes position as indicated in Table 2.3.6-1 under preoperational test conditions.

iv) Each check valve changes position as indicated in Table 2.3.6-1.

ITAAC ComDietion Description Multiple ITAAC are performed with inspections and tests to verify that the Normal Residual Heat Removal System (RNS) provides at least 1400 gpm net flow to the Reactor Coolant System (RCS) when the hot leg water level is at an elevation 15.5 inches +/- 2 inches above the bottom of the hot leg, the RCS cold leg piping centerline is 17.5 inches +/- 2 inches above the hot leg piping centerline, the RNS pump suction piping from the hot leg to the pump suction does not form a local high point, and the RNS suction line connection to the RCS is constructed from 20-inch schedule 140 pipe. This ITAAC also verifies that each RNS pump provides at least 1100 gpm net flow to the RCS when the water level is maintained within the range of > 10 ft and < 15 ft from the bottom of the cask loading pit and the two operating RNS pumps provide at least 2000 gpm to the In-containment Refueling Water Storage Tank(IRWST). This ITAAC also verifies each motor-operated valve(MOV)changes positions as indicated in Table 2.3.6-1 under preoperational test conditions and each check valve changes position as indicated in Table 2.3.6-1.

ii) When tested individuallv. each RNS pumo provides at least 1400 com net flow to the RCS when the hot lea water level is at an elevation 15.5 inches +/- 2 inches above the bottom of the hot lea.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-RNS-ITPP-501 and 4-RNS-ITPP-501 (References 1 and 2)to verify that each RNS pump provides at least 1400 gpm net flow to the RCS when the hot leg water level is at an elevation 15.5 inches +/- 2 inches above the bottom of the hot leg.

The test is initiated by verifying the hot leg level is between 13.5 inches and 17.5 inches, the RCS is at atmospheric pressure, and temporary flow instruments and pump suction gages are installed and connected to a Data Acquisition System (DAQ). The RNS is aligned to take suction from the RCS hot leg and discharge back to the RCS DVI lines and the A RNS pump is started. The RNS flow control valves are adjusted to provide maximum flow and flow is measured and verified to meet the acceptance criteria. This testing is repeated using the B RNS pump.

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 4 of 8 The Unit 3 RNS pump A provides XXXX gpm and Unit 3 RNS pump B provides YYYY gpm. The Unit 4 RNS pump A provides XXXX gpm and Unit 4 RNS pump B provides YYYY gpm. This demonstrates each RNS pump provides at least 1400 gpm net flow to the ROS when the hot leg water level is at an elevation 15.5 inches +/- 2 inches above the bottom of the hot leg.

iih The ROS cold leas piping centerline is 17.5 inches +/- 2 inches above the hot leas pioino centerline.

An inspection is performed to ensure the ROS cold leg piping centerline is 17.5 inches +/- 2 inches above the hot legs piping centerline utilizing NCSP0324"Request for Sun/ey Support".

The survey data is taken using the guidance in the request for survey support and delivered for evaluation. The evaluation results are tabulated in Unit 3 Inspection Report YYY and Unit 4 Inspection Report YYY (References 3& 4)and demonstrate that Unit 3 cold leg 1A is XX.X inches above hot leg 1, cold leg 1B is XX.X inches above hot leg 1, cold leg 2A is XX.X inches above hot leg 2, and cold leg 2B is XX.X inches above hot leg 2. Unit 4 cold leg 1A is XX.X inches above hot leg 1, cold leg 1B is XX.X inches above hot leg 1, cold leg 2A is XX.X inches above hot leg 2, and cold leg 2B is XX.X inches above hot leg 2.

The results of the inspection confirm for Unit 3 and Unit 4 that the RCS cold legs piping centerline is 17.5 inches +/- 2 inches above the hot legs piping centerline iv) The RNS oump suction pioina from the hot lea to the oumo suction oipina low point does not form a local hioh point (defined as an uoward slooe with a vertical rise Greater than 3 inches).

An inspection is performed to ensure the RNS pump suction piping from the hot leg to the pump suction piping low point does not form a local high point. A walk down inspection of the as-built pipelines is performed for observable downward sloping sections and verifications with a digital level are taken at piping sections, where deemed necessary, to verify downward slope. The inspection found the RNS suction piping sloped downward from the RCS hot leg connection to the low point at the RNS pump suction.

The inspection results are documented in Unit 3 inspection Report XXX and Unit 4 Inspection Report XXX (References 5 & 6)and confirm that Unit 3 and Unit 4 RNS pump suction piping from the hot leg to the pump suction piping low point does not form a local high point(defined as an upward slope with a vertical rise greater than 3 inches).

v) The RNS suction line connection to the RCS is constructed from 20-inch Schedule 140 pipe.

An inspection of the RNS pump suction nozzle connection to the RCS hot leg is performed to verify the pipe schedule and size connection is constructed from 20-inch Schedule 140 pipe.

The inspection is performed by a review of the Certified Material Test Report(CMTR)and the work package that installed this specific piping section. The results of the inspection are documented in Unit 3 Inspection Report XYZ and Unit 4 Inspection Report XYZ(References 7 &

8) and confirm that the RNS suction line connection to the RCS is constructed from 20-inch schedule 140 pipe for both Unit 3 and Unit 4.

When tested individuallv. each RNS oumo orovides at least 1100 com net flow to the RCS with the water level maintained within the ranoe of > 10 ft and < 15 ft from the bottom of the cask loadino pit.

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 5 of 8 Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-RNS-ITPP-501 and 4-RNS-ITPP-501 (References 1 and 2)to verify that when tested individually, each RMS pump provides at least 1100 gpm net flow to the RGB with the water level maintained within the range of > 10 ft. and < 15 ft. from the bottom of the cask loading pit (CLP).

The test is initiated by verifying the CLP water level is > 10 ft to < 15.0 ft above the bottom of the CLP, RCS is depressurized, lower internals installed in the reactor vessel, and temporary flow and pressure gauges are installed and connected to a DAQ. The RNS system is aligned to take suction from the CLP and discharge back to the Direct Vessel Injection (DVI) lines. The A RNS pump is started, RNS injection flow is increased to maximum,flow is measured and verified to meet acceptance criteria. This testing is repeated using the B RNS pump.

The Unit 3 RNS pump A provides XXXX gpm and Unit 3 RNS pump B provides YYYY gpm. The Unit 4 RNS pump A provides XXXX gpm and Unit 4 RNS pump B provides YYYY gpm. This verifies that for Unit 3 and Unit 4 when tested individually, each RNS pump provides at least 1100 gpm net flow to the RCS with the water level maintained within the range of > 10 ft and

< 15 ft ifrom the bottom of the cask loading pit.

Two operatino RNS pumos provide at least 2000 com to the IRWST.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-RNS-ITPP-501 and 4-RNS-ITPP-501 (References 1 and 2)to verify that two RNS pumps provide at least 2000 gpm to the In-containment Refueling Water Storage Tank(IRWST) which demonstrates the RNS will provide heat removal from the IRWST.

The test is initiated by verifying the IRWST level, temporary flow, and pressure instruments are installed and connected to the DAQ. The RNS system is aligned to recirculate the IRWST. Both RNS pumps are started, flow is established to the IRWST through each RNS heat exchanger and flow is measured and recorded.

The Unit 3 RNS pumps provide XXXX gpm and Unit 4 RNS pumps provide YYYY gpm. This demonstrates two operating RNS pumps on Unit 3 and Unit 4 provide at least 2000 gpm to the IRWST.

ill) Each motor-operated valve chances oosition as indicated in Table 2.3.6-1 under preoperational test conditions.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-RNS-ITPP-501 and 4-RNS-ITPP-501 (References 1 and 2)and 3-RNS-ITPP-502 and 4-RNS-ITPP-502(References 9 and 10)to confirm the motor-operated valves(MOVs)listed in COL Appendix C Table 2.3.6-1 (Attachment A)change position under pre-operational flow, differential pressure, and temperature conditions.

References 1 and 2 establish the preoperational test conditions by ensuring the RCS is in a mid-loop level condition and the IRWST is filled to greater than 25% level. These conditions establish the greatest differential pressure and flow conditions for RNS-PL-V023(RNS Suction from IRWST Motor-operated Isolation Valve). The RNS suction is aligned to the RCS, RNS-PL-V023 is opened, RCS level is verified to increase, then RNS-PL-V023 is closed. This

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page6d 8 demonstrates that this MOV changes position as indicated in Attachment A under preoperational test conditions.

References 9 and 10 establish the preoperational test conditions by ensuring the RGB temperature is > 275°F and RGB pressure between 370 psig and 400 psig, with a single train of RNS in service utilizing a single suction header. Power to one of the open suction header valves is removed and a manual actuation of RNB isolation is performed. RNB-PL-V011 (RNB Discharge MOV Containment Isolation), RNB-PL-V022(RNB Buction Header MOV Containment Isolation), and the tested suction header MOV are verified to close. This testing is repeated and a different suction header MOV is tested each time until all 4 suction header MOVs(RNB-PL-V001AA/001BA/002AA/002B) have been tested.

The test results confirm that each motor-operated valve, on Unit 3 and Unit 4, change positions as indicated in Table 2.3.6-1 under preoperational test conditions.

iv) Each check valve chances position as indicated in Table 2.3.6-1.

Testing is performed in accordance with Unit 3 and Unit 4 preoperational test procedures 3-RNB-ITPP-501 and 4-RNB-ITPP-501 (References 1 and 2)to confirm that each check valve with an active safety function changes position as indicated in COL Table 2.3.6-1 (Attachment B) under pre-operational test pressure, temperature, and fluid flow conditions.

References 1 and 2 establish the preoperational test conditions by ensuring the RGB is in a mid-loop level condition and the IRWBT is filled to greater than 25% level. These conditions establish the differential pressure and flow conditions for testing the RGB Pressure Boundary Thermal Relief Check Valves(RNB-PL-V003A/B). RNB is aligned to allow the IRWBT to gravity drain to the RGB via RNB-PL-V003A and the check valve is verified to open by observing a level rise in the RGB.This alignment is secured and realigned to test the opening of RNB-PL-V003B.

References 1 and 2 establish the preoperational test conditions by ensuring the RGB is between 73.5% and 86.5% hot leg level, installs temporary flow instruments on each DVI line and aligns the RNB system for dual RNB pump recirculation of the RGB. Both RNB pumps are placed in service recirculating the RGB and flow readings are taken on the DVI line flow instruments. The remaining check valves in Attachment B (RNB-PL-V013A/015AA/015B/V017AA/017B) are verified to open based on the flow verification.

Testing is performed in accordance with Unit 3 and Unit 4 surveillance test procedures BV3-RNB-OTB-17-005 and BV4-RNB-0TB-17-005(References 11 and 12) to confirm that each check valve listed in Attachment B closes. This testing is performed with the RNB system removed from service and utilizes the Passive Gore Gooling Bystem (PXB)test header. Each check valve, except RNB-PL-V013, is tested utilizing system pressure and fluid to seat the check valve and verify acceptable leakage. Gheck valve RNB-PL-V013(RNB Discharge Header Gontainment Isolation Gheck Valve) is tested by isolating the valve, draining the fluid from both sides and utilizing test connections to pressurize the upstream side with air and verifying no leakage past the check valve.

This testing ensures each check valve on Unit 3 and Unit 4 changes position as indicated in Table 2.3.6-1.

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 7 of 8 References 1 tfirougfi 12 are available for NRG inspection as part of Unit 3 and Unit 4 ITAAC Completion Packages(Reference 13 and 14).

List of ITAAC Findings In accordance witfi plant procedures for ITAAC completion, Soutfiern Nuclear Operating Company(SNC) performed a review of all findings pertaining to tfie subject ITAAC and associated corrective actions. Tfiis review found tfiere are no relevant ITAAC findings associated witfi this ITAAC.

References(available for NRG inspection)

1. 3-RNS-ITPP-501,"Normal Residual Heat Removal System Preoperational Test Procedure"

2. 4-RNS-ITPP-501,"Normal Residual Heat Removal System Preoperational Test Procedure"

3. Unit 3 Inspection Report YYY,"RCS hot and cold leg centerline determination"

4. Unit 4 Inspection Report YYY,"RCS hot and cold leg centerline determination"

5. Unit 3 Inspection Report XXX,"RNS suction piping slope"

6. Unit 4 Inspection Report XXX,"RNS suction piping slope"

7. Unit 3 Inspection Report XYZ,"RNS suction piping connection to the RCS"

8. Unit 4 Inspection Report XYZ,"RNS suction piping connection to the RCS"

9. 3-RNS-ITPP-502,"Normal Residual Heat Removal System Precore Hot Functional Test Procedure" 10.4-RNS-ITPP-502,"Normal Residual Heat Removal System Precore Hot Functional Test Procedure" 11.3-RNS-0TS-17-005,"Normal Residual Heat Removal System Check Valve Exercise Tesf

12. 4-RNS-0TS-17-005,"Normal Residual Heat Removal System Check Valve Exercise Test"

13. 2.3.06.09b.ii-U3-CP-Rev 0, ITAAC Completion Package

14. 2.3.06.09b.ii-U4-CP-Rev 0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-0339 Enclosure Page 8 of 8 Attachment A Excerpt from COL Appendix C Table 2.3.6-1 Equipment Name Tag No. Active Function RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001A Transfer Isolation Valve Closed RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001B Transfer Isolation Valve Closed RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002A Transfer Isolation Valve Closed RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002B Transfer Isolation Valve Closed RNS Discharge Motor-operated Containment RNS-PL-V011 Transfer Isolation Valve Closed RNS Suction Header Motor-operated Containment RNS-PL-V022 Transfer Isolation Valve Closed RNS Suction from IRWST Motor-operated Isolation RNS-PL-V023 Transfer Valve Closed Attachment B Excerpt from COL Appendix C Table 2.3.6-1 Equipment Name Tag No. Active Function RCS Pressure Boundary Thermal Relief Check RNS-PL-V003A Transfer Open/

Valve Transfer Closed RCS Pressure Boundary Thermal Relief Check RNS-PL-V003B Transfer Open/

Valve Transfer Closed RNS Discharge Header Containment Isolation RNS-PL-V0013 Transfer Open/

Check Valve Transfer Closed RNS Discharge RCS Pressure Boundary Check RNS-PL-V015A Transfer Open/

Valve Transfer Closed RNS Discharge RCS Pressure Boundary Check RNS-PL-V0115B Transfer Open/

Valve Transfer Closed RNS Discharge RCS Pressure Boundary Check RNS-PL-V017A Transfer Open/

Valve Transfer Closed RNS Discharge RCS Pressure Boundary Check RNS-PL-V017B Transfer Open/

Valve Transfer Closed