ND-18-0290, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.5.00.01.i (Index Number 823)
| ML18065A073 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/05/2018 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| ITAAC 3.5.00.01.i, ND-18-0290 | |
| Download: ML18065A073 (11) | |
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Southern Nuclear mar 05 2018 Docket Nos.:
52-025 52-026 Michael J. Yox Regulatory Affairs Director Vogtie 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6459 tei 410-474-8587 ceii myox@southernco.com ND-18-0290 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 3.5.00.01.1 [Index Number 8231 Ladies and Gentlemen:
Pursuantto 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of March 1, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 3.5.00.01.1
[Index Number 823] has not been completed greaterthan225-days prior to initial fuel load. The Enclosure describes the plan for completing this ITAAC. Southern Nuclear Operating Company will, at a laterdate, 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, IndustryGuideline forthe 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, oranalyses 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, I
Michael J.
Regulatory Affairs'Director Vogtie 3 &4
Enclosure:
Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 3.5.00.01.1 [Index Number 823]
MJY/PGL/amw
U.S. Nuclear Regulatory Commission ND-18-0290 Page 2 of 3 To:
Southern Nuclear Operating Company / Georgia Power Company Mr. D. A. Bost (w/o enclosures)
Mr. M. D. Rauckhorst (w/o enclosures)
Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)
Mr. D. L. McKinney Mr. M. J. Yox Mr. D. L. Fulton Mr. J. D. Williams Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. 0. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:
Nuclear Reouiatorv Commission Mr. W. Jones (w/o enclosures)
Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. N. D. Karlovich Mr. P. B. Donnelly Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Ms. L. A. Kent Oaiethoroe Power Corporation Mr. R. B. Brinkman Municipal Eiectric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson
U.S. Nuclear Regulatory Commission ND-18-0290 Page 3 of 3 Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)
Mr. D. 0. Durham (w/o enclosures)
Mr. M. M. Corletti Ms. L. G. Iller Mr. D. Hawkins Ms. J. 8. Monahan Mr. J. L. Coward Ms. N. E. Deangells 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. Kernlzan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-18-0290 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Compietion Plan for Uncompleted ITAAC 3.5.00.01.1 [Index Number 823]
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 2 of 8 ITAAC Statement Design Commitment
- 1. The seismic Category Iequipment identified inTable 3.5-1 can withstand seismic design basis loads without loss of safety function.
- 2. The Class IE equipment identified inTable 3.5-1 as being qualified for a harsh environment can withstand the environmental conditions that would exist before, during, and following a design basis accident without lossofsafetyfunction for the time required to perform the safety function.
Inspections. Tests. Analvses i) Inspection will be performed to verify thatthe seismic Category Iequipment identified in Table 3.5-1 is located on the Nuclear Island.
ii) Type tests, analyses, ora combination of type tests and analysesofseismic Category I equipment will be performed.
ill) Inspection will be performed for the existence ofa report verifying thatthe as-built equipment including anchorage is seismically boundedbythe tested or analyzedconditions.
i) Type tests, analyses, ora combination of type tests andanalyses will be performed onClass 1E equipment located in a harsh environment.
ii) Inspection will be performed of the as-built Class 1Eequipment andthe associated wiring, cables, and terminations located in a harsh environment.
Acceptance Criteria i) Theseismic Category Iequipment identified in Table 3.5-1 is located onthe Nuclear Island.
ii) Areport exists andconcludes thatthe seismic Category Iequipment canwithstand seismic design basis loads without loss of safety function.
iii) Areport exists andconcludes thatthe as-built equipment including anchorage isseismically bounded by the tested or analyzed conditions.
i) Areport exists and concludes thatClass 1Eequipment identified in Table 3.5-1 as being located in a harsh environment can withstand the environmental conditions that would exist before, during, andfollowing a design basisaccident without lossof safety function for the time required to perform the safety function.
ii) Areport exists andconcludes thatthe as-built Class 1Eequipment andtheassociated wiring, cables, and terminationsidentified inTable 3.5-1 as being qualified fora harsh environmentare bounded bytype tests, analyses, or a combination oftype tests and analyses.
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 3 of 8 ITAAC Completion Description This ITAAC requiresthat inspections, tests, and analyses be performed and documented to ensure the Radiation Monitoring System (RMS) equipment identified as seismic Category i or Class 1E inthe Combined License (COL) AppendixC, Table 3.5-1 (the Table) is designed and constructed in accordance with applicable requirements.
h The seismic Cateoorv I eouioment identified in Table 3.5-1 is located on the Nuclear Island.
To assure that seismic Category Iequipment can withstandseismic design basis loads without loss ofsafetyfunction, all the equipment in the Table isdesignedto be located on the seismic Category INuclear Island. In accordance with Equipment Qualification (EG) Walkdown ITAAC Guideline (Reference1),an inspection is conductedofthe RMS to confirm the satisfactory installation ofthe seismically qualified equipment. The inspection includes verification of equipment make/model/serial number and verification ofequipment location (Building, Elevation, Room). The EGAs-Built Reconciliation Reports (EQRR) (Reference 2) identified in Attachment A document the results of the inspection and conclude that the seismic Category I equipment is located on the Nuclear Island.
ii) A report exists and concludes that the seismic Cateoorv I equipment can withstand seismic desion basis loads without loss of safetv function.
Seismic Category Iequipment in the Table requirestype tests and/or analyses to demonstrate structural integrity and operability. Safety-related (Class1E) electrical equipment in the Table is seismically qualified bytype testing combined with analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference 3). This equipment includes safety-related (Class 1E) field sensors. The specific qualification method (i.e., type testing, analysis, orcombination) usedfor each piece of equipment in theTable is identified in Attachment A. Additional informationabout the methods used to qualifyAPI000 safety-related equipment is provided in the Updated Final Safety Analysis Report (UFSAR) Appendix 3D (Reference 4). The EG Reports (Reference 5)identified in Attachment Acontain applicable test reports and associated documentation and conclude thatthe seismic Category Iequipment can withstand seismic design basis loads without loss of safety function.
iiil A reoort exists and concludes that the as-built equipment including anchoraoe is seismicallv bounded bv the tested or analvzed conditions.
An inspection (Reference 1)isconducted to confirm the satisfactory installation ofthe seismically qualified equipment in the Table. The inspection verifies the equipment make/model/serial number, as-designed equipment mounting orientation, anchorage and clearances, and electrical and other interfaces. The documentation ofinstalled configuration of seismically qualified equipment includes photographs and/orsketches/drawings of equipment/mounting/interfaces.
As part of the seismic qualification program, consideration isgiven tothe definition ofthe clearances needed around the equipment mounted In the plantto permitthe equipment to move during a postulated seismic event without causing impact between adjacent pieces of safety-related equipment. This isdone as part of seismic testing by measuring the maximum dynamic relative displacement of the topand bottom ofthe equipment. EG Reports (Reference 5) identify the equipment mounting employed for qualification and establish interface requirements
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 4 of 8 forassuringthat subsequent in-plant installation does notdegrade the establishedqualification.
Interface requirements are definedbased on the test configuration and other design requirements.
Attachment A identifiesthe EQRR (Reference 2) completed to verify that the as-built seismic Category Iequipment listed in the Table, including anchorage, are seismically bounded bythe tested or analyzed conditions, IEEE Standard 344-1987(Reference 3) and NRC Regulatory Guide (RG) 1.100 (Reference 6).
h A report exists and concludes that Class 1E eouioment identified in Table 3.5-1 as being located in a harsh environment can withstand the environmental conditions that would exist before, durino. and following a desion basis accident without loss of safetv function for the time reouired to perform the safetv function.
The harsh environmentClass 1E equipment inthe Table is qualified by type testing and/or analyses. Class 1Eelectrical equipment type testing isperformed in accordance with IEEE Standard 323-1974(Reference7) and RG 1.89 (Reference 8) to meet the requirementsof 10 CFR50.49. Typetestingofsafety-related equipment meets the requirements of10 CFR Part50, Appendix A, General Design Criterion 4. Attachment Aidentifies the EQ program and specific qualification method for each pieceofsafety-related Class 1Eelectrical equipment located in a harsh environment. Additional information about the methods used to qualify API000safety-related equipment is provided in the UFSAR Appendix 3D (Reference 4). EQ Reports (Reference 5)identified in Attachment Acontain applicable test reports and associated documentation and conclude that the equipment can withstand the environmental conditions that would exist before, during, and following a design basis accident without loss ofsafety function for the time required to perform the safety function.
W) A reoort exists and concludes that the as-built Class 1E eouioment and the associated wirino. cables, and terminations identified in Table 3.5-1 as being qualified for a harsh environment are bounded bv tvoe tests, analvses. or a combination of tvoe tests and analvses.
An inspection (Reference 1) isconducted of the RMS to confirm the satisfactory installation of the Class 1E equipmentin the Table. The inspection verifies the equipment location, make/model/serial number, as-designed equipmentmounting, wiring, cables, and terminations, and confirms that the environmental conditions for the zone (Attachment A) in which the equipment is mounted are bounded bythe tested and/oranalyzed conditions. It also documents the installed configuration with photographs or sketches/drawingsof equipment mounting andconnections. The EQRR (Reference 2) identified in Attachment Adocument this inspection and conclude thatthe as-built harshenvironment Class 1Eequipment andthe associated wiring, cables, and terminations are bounded bythe qualified configuration and IEEE Standard 323-1974 (Reference 7).
Together, these reports (References 2 and 5) provide evidence thatthe ITAAC Acceptance Criteria requirements are met:
The seismicCategory Iequipment identified in Table3.5-1 is located on the Nuclear Island;
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 5 of 8 A reportexists and concludes that the seismic Category Iequipment can withstand seismic design basis loads without loss of safety function; A reportexists and concludes that the as-builtequipment including anchorage is seismically bounded by the tested or analyzed conditions; A reportexists and concludes that Class 1E equipmentidentified in Table 3.5-1 as being located in a harsh environment can withstand the environmental conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function; and A report exists and concludes that the as-built Class 1E equipmentand the associated wiring, cables, and terminations identified in Table3.5-1 as being qualified fora harsh environment are bounded bytype tests, analyses, or a combination oftype tests and analyses.
References 2 and 5 are available for NRC inspection as part of the Unit 3 and Unit 4 ITAAC 3.5.00.01.iCompletion Packages (References 9 and 10, respectively).
List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern NuclearOperating Company (SNC) performed a review ofall ITAAC findings pertaining tothe subject ITAAC and associated correctiveactions. Thisfinding review, which included now-consolidated ITAAC Indexes 824, 825, 826, and 827, found there are no relevant ITAAC findings associated with this ITAAC.
References (availabie for NRC inspection) 1.
ND-xx-xx-001, "EG Walkdown ITAAC Guideline"
- 2. EQAs-Built Reconciliation Reports(EQRR) as identified inAttachment Afor Units 3 and 4 3.
IEEE Standard 344-1987, "IEEE Recommended Practices for Seismic Qualification of Class 1E Equipmentfor Nuclear Power Generating Stations"
- 4. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, "Methodology for Qualifying API000 Safety-Related Electrical and Mechanical Equipment"
- 5. Equipment Qualification (EQ) Reports as identified inAttachmentA
- 6. Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants" 7.
IEEE Standard 323-1974, "IEEEStandard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"
- 8. Regulatory Guide 1.89, Rev 1,"Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants"
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 6 of 8
- 9. 3.5.00.01.i-U3-CP-Rev X, "Completion Package for Unit 3 ITAAC 3.5.00.01.i [Index Number 823]"
10.3.5.00.01.i-U4-CP-Rev X,"Completion Package for Unit 4 ITAAC 3.5.00.01.1 [Index Number 823]"
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 7 of 8 Attachment A System: Radiation Monitoring System (RMS)
Equipment Name^
Tag No.^
Seismic Cat. 1^
Class 1E/ Qual.
For Harsh Envir.^
Envir.
Zone^
Envir Qual Program^
Type of Qual.
EQ Reports (Reference 5)
As-Built EQRR (Reference 2)^
Containment High Range Monitor PXS-RE160 Yes YesA'es 1
E*S Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX Containment High Range Monitor PXS-RE161 Yes Yes/Yes 1
E*S Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX Containment High Range Monitor PXS-RE162 Yes YesA'es 1
E*S Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX Containment High Range Monitor PXS-RE163 Yes YesA'es 1
E*S Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX MCR Radiation Monitoring Package A" VBS-JS01A Yes Yes/No NA NA Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX MCR Radiation Monitoring Package B^
VBS-JS01B Yes Yes/No NA NA Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX
U.S. Nuclear Regulatory Commission ND-18-0290 Enclosure Page 8 of 8 Equipment Name^
Tag No.^
Seismic Cat. i^
Class 1E/ Quai.
For Harsh Envir.^
Envir.
Zone^
Envir Quai Program^
Type of Quai.
EQ Reports (Reference 5)
As-Buiit EQRR (Reference 2)^
Containment Atmosphere Monitor (Gaseous)
PSS-RE026 Yes No/No NA NA Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX Containment Atmosphere Monitor (partlculate, for RCS pressure boundary leakage detection)
PSS-RE027 Yes No/No NA NA Type Testing &
Analysis APP-XXX-XXX-XXX 3.5.00.01.i-U3-EQRR-PCDXXX Notes:
+Excerpt from COL Appendix C Table 3.5-1
- 1. See Table 3D.5-1 of UFSAR 2.
E = Electrical Equipment Program S = Qualified for submergence or operation with spray
- = Harsh Environment
- 3. The Unit 4 As-Built EQRR are numbered "3.5.00.01.i-U4-EQRR-PCDXXX-Rev 0" 4.
Each MCR Radiation Monitoring Package includes partlculate, iodine and gaseous radiation monitors.