ML19189A182
| ML19189A182 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/08/2019 |
| From: | Southern Nuclear Operating Co |
| To: | Office of New Reactors |
| Shared Package | |
| ML19189A180 | List: |
| References | |
| ND-19-0764 | |
| Download: ML19189A182 (85) | |
Text
Southern Nuclear Operating Company ND-19-0764 Vogtle Electric Generating Piant (VEGP) Units 3 and 4 Request for License Amendment:
Functional Arrangement ITAAC Optimization (LAR-19-002)
(This Enclosure consists of 85 pages, including this cover page.)
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table of Contents
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION AND TECHNICAL EVALUATION
- 3. TECHNICAL EVALUATION (Included In Section 2)
- 4. REGULATORY EVALUATION 4.1.
Applicable Regulatory Requirements/Criteria 4.2.
Precedent 4.3.
Significant Hazards Consideration Determination 4.4.
Conclusions
- 5. ENVIRONMENTAL CONSIDERATIONS
- 6. REFERENCES Page 2 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Pursuant to 10 CFR 52.98(c), and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC)
(the "Licensee") hereby requests an amendment to Combined License (COL)
Nos. NPF-91 and NPF-92, for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.
- 1.
SUMMARY
DESCRIPTION The proposed changes would make changes to COL Appendix C (and corresponding plant-specific Tier 1) information. The changes include removing Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for the functional arrangement of systems, by showing that the ITAAC design commitment (DC) is verified by other ITAAC or is otherwise verified by other means.
The requested amendment proposes changes to COL Appendix C information, with corresponding changes to plant-specific DCD Tier 1 information, as appropriate. This enclosure requests approval of the license amendment necessary to implement the COL Appendix C changes described below. Enclosure 2 requests the exemption necessary to implement the changes to the plant-specific DCD Tier 1 information.
- 2. DETAILED DESCRIPTION AND TECHNICAL EVALUATION The functional arrangement ITAAC require the performance of inspections of the as-built system to verify the as-built system conforms with the functional arrangement, as described in the Design Description. The Design Description, in general, includes the key functions of the system, and in some instances references a simplistic figure and/or a table of components.
The inspection for the functional arrangement ITAAC would demonstrate that the components exist with no demonstration of functionality. These systems may also include other ITAAC that demonstrate functionality of the system or verify that they are functionally arranged, including the same components and piping identified in the figures and / or tables referenced in the ITAAC. Testing and inspection of the components, piping, and interfaces through these other ITAAC confirms existence of the components in their correct arrangement. As such, the scope of functional arrangement ITAAC is bounded by the ITAAC demonstrating the functionality, or otherwise verified by other means, and the functional arrangement ITAAC in and of themselves do not verify any unique design attributes. Functional arrangement ITAAC have been identified in COL Appendix C (and plant-specific Tier 1) to contain redundant requirements with other ITAAC. For each of these functional arrangement ITAAC proposed to be removed, the Tier 1 Design Description (including tables and figures) and associated UFSAR design information is not proposed to be changed and remains consistent with the current plant design. Therefore, no structure, system, or component (SSC), design function, or analysis, as described in the UFSAR, is affected by the proposed changes.
Regulatory Guide 1.206, Revision 0, defines functional arrangement ITAAC as "the physical arrangement of systems and components to provide the service for which the system is intended and that is described in the ITAAC design description and as shown in the figures" (Reference 1). Appendix C of the Vogtle 3 & 4 COLs gives a similar definition, as "the physical arrangement of systems and components to provide the service for which the system is intended, and which is described in the system design description." NEI 08-01 Revision 5 goes into further detail on the functional arrangement ITAAC, stating that the purpose of the ITAAC is two-fold: "(1) that components are physically arranged as shown in any referenced Page 3 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) figure, and located as identified in any referenced table; and (2) that system components identified in the Tier 1 Design Descriptions are physically arranged as specified by the design" (Reference 2).
Updated Final Safety Analysis Report (UFSAR) Tier 2 design descriptions are derived from plant design documents. 10 CFR Part 52, Appendix D,Section II.D, states that Tier 1 design information is "derived from Tier 2 information." UFSAR subsection 14.3.2.2 discusses that the intent of ITAAC is '1o define activities that will be undertaken to verify the as-built system conforms with the design features and characteristics defined in the design description". When other ITAAC verify the functional arrangement of the system, i.e. no additional information is verified by completion of the functional arrangement ITAAC, the functional arrangement ITAAC are not necessary.
There are three categories of ITAAC whose inspections, tests and analyses (ITA) can verify the design features and characteristics of a system: ASME ITAAC, EQ ITAAC, and functional testing ITAAC.
For the ITAAC that are completed under the American Society of Mechanical Engineers Boiler
& Pressure Vessel (ASME B&PV) Code Section III, hereafter called "the ASME Code", certain requirements for the documents produced to satisfy the acceptance criteria (AC) need to be met. The ASME Code is a standard for constructing safe, reliable nuclear plants. It is a mature set of rules that has evolved over the years. This Code has come to represent one of the highest standards of quality to which a nuclear plant is constructed. The ASME Code Subsection NCA-9000 defines Data Report as a document that certifies that an item was constructed in accordance with the requirements of this Section. NCA-9000 definition of construction is an all-inclusive term comprising materials, design, fabrication, examination, testing, inspection, and certifications required in the manufacture and installation of an item.
By adding these two definitions one can determine that the N-5 Data Report is a document that certifies that materials, design, fabrication, examination, testing and inspection of an item are in accordance with the requirements of the ASME Code.
Per the UFSAR Subsection 3.6.2.5, the ASME Code requires that each plant have a Design Report for the piping system that includes as-built information. The final piping stress analysis includes design properties and characteristics of procured components selected to be included in the piping system that are not available for the as-designed evaluation. The as-built reconciliation is required prior to fuel load and includes evaluation of the ASME Code fatigue analysis, pipe break dynamic loads, reconciliation to the certified design floor response spectra, confirmation of the reactor coolant loop time history seismic analyses, changes in support locations, preoperational testing, and construction deviations.
Inherent to an N-5 Data Report is the listing and certification of the system's installation to the design and that it meets all the allowable stresses for which it was designed and built as determined by the final as-built System Design Report(s). To demonstrate the system's final configuration, as-built drawings are compiled which are based on QC inspected final isometric drawings. These detailed construction drawings were inspected and recorded as closed in the work packages that performed the installation. These as-built drawings are then reconciled to the as-designed analysis to ensure the system remains bounded by the original analysis.
The drawings are used in the final Design Report to certify the system was built as designed.
This level of detail is above and beyond that which is demonstrated in the Functional Page 4 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Arrangement ITAAC. Through the design control process, the as-built drawings are also ensured to match the simplified figures and listing of components and lines in the Functional Arrangement COL tables. Therefore, when an ASME report covers the same components as the functional arrangement ITAAC, no additional information is verified by completion of that functional arrangement ITAAC.
For the ITAAC that are completed under the Equipment Qualification program, certain requirements for the documents produced to satisfy the AC need to be met. The equipment qualification program is described in UFSAR Appendix 3D and conforms to Regulatory Guide 1.89 and IEEE standards 323-1974 for qualification of electrical and mechanical equipment and 344-1987 for seismic qualification. These form the basis of the API 000 equipment qualification program compliance with 10 CFR 50.49.
As part of the equipment qualification program, equipment is qualified using analysis, testing, or a combination of these methods. The results of this qualification are described in an Equipment Qualification Data Package (EQDP), per UFSAR Subsections 3D.7.1 and 3D.7.2.
The EQDPs include information related to equipment identification and installation requirements. These attributes include specific component tag numbers and room locations for each piece of equipment, as well as physical attributes of installation, such as component orientation, bolting requirements, and wiring configurations. These attributes are veriified as part of the as-built walkdowns required for EQ ITAAC closure, to ensure that the as-built components are bounded by the type testing and/or analyses utilized to qualify the equipment.
The EQ as-built walkdowns are generated using the EQDPs and as-built detailed construction drawings and are performed by those qualified to the licensee's EQ walkdown procedure. The level of detail verified during the EQ as-built walkdowns is above and beyond that which is demonstrated in the functional arrangement ITAAC. Through the design control process, the as-built drawings are also ensured to match the simplified figures and listing of components and lines in the functional arrangement CQL tables. Therefore, when EQ as-built ITAAC covers the same components as the functional arrangement ITAAC, no additional information is verified by completion of that functional arrangement ITAAC.
For the ITAAC that are completed under the initial test program (ITP), certain requirements for the documents produced to satisfy the AC need to be met. The ITP is described in UFSAR Chapter 14 and conforms to Regulatory Guide 1.68. The ITP has procedural requirements for pre-operational tests used to satisfy ITAAC, as well as procedural requirements for component tests, which are pre-requisites to pre-operational tests and can also be used to satisfy ITAAC.
Through the administrative controls of the ITP, pre-operational tests require a pre-test walkdown to confirm the as-built system configuration matches the detailed system drawings.
As-built walkdowns are suggested prior to component tests, as well. The actual testing of the components verifies functionality of the component and/or the integrated system, which validates the system is arranged and functions as designed. For the ITAAC whose ITA are performed under the ITP, the documentation which verifies the AC has been met includes system arrangement verification to a finer degree of detail than that which would be required by the functional arrangement ITAAC. Therefore, when ITP ITAAC cover the same components as the functional arrangement ITAAC, no additional information is verified by completion of that functional arrangement ITAAC.
Page 5 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
As discussed above, the ITAAC that bound the functional arrangement ITAAC inherently verify functional arrangement of the systems; therefore, reliance on the subsequent ITAAC:
encompasses the scope identified in the design commitment for the functional arrangement ITAAC, which will be shown through the ITAAC demonstrating the functionality, retains performance of the other required ITA for each impacted system, and does not impact the scope of the 10 CFR 52.103(g) finding to be made by the Commission, indicating that the AC in COL Appendix C are met.
The systems whose functional arrangement ITAAC are bounded by other ITAAC and / or verified by other means are as follows:
Fuel Handling and Refueling System (FHS)
Component Cooling Water System (CCS)
Chemical and Volume Control System (CVS)
Standby Diesel Fuel Oil System (DOS)
Fire Protection System (FPS)
Mechanical Handling System (MHS)
Normal Residual Heat Removal System (RNS)
Spent Fuel Pool Cooling System (SFS)
Service Water System (SWS)
Containment Hydrogen Control System (VLS)
Liquid Radwaste System (WLS)
Gaseous Radwaste System (WGS)
Solid Radwaste System (WSS)
Primary Sampling System (PSS)
Demineralized Water Transfer and Storage System (DWS)
Compressed and Instrumentation Air System (CAS)
Radioactive Waste Drain System (WRS)
Main and Startup Feedwater System (FWS)
Page 6 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Main Turbine System (MTS)
Condensate System (CDS) in-Core instrumentation System (iiS)
Special Monitoring System (SMS)
Seismic Monitoring System (SJS)
Main ac Power System (ECS)
Onsite Standby Power System (ZDS)
Nuclear island Nonradioactive Ventilation System (VBS)
Central Chilled Water System (VWS)
Annex / Auxiliary Buildings Nonradioactive Ventilation System (VXS)
Diesel Generator Building Ventilation System (VZS)
Radiologically Controlled Area Ventilation System (VAS)
Containment Air Filtration System (VFS)
Containment Recirculation Cooling System (VCS) 2.1.
Fuel Handling and Refueling System (FHS)
COL Appendix C (and plant-specific Tier 1) Table 2.1.1-1 includes ITAAC No. 1 (ITAAC 2.1.01.01), the FHS functional arrangement ITAAC:
Table 2.1.1-1 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the FHS Is as described in the Design Description of this Section 2.1.1.
Inspection of the as-built system will be performed.
The as-built FHS conforms with the functional arrangement as described in the Design Description of this Section 2.1.1.
The Design Description for the FHS includes the following key attributes:
Page 7 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
The FHS transfers fuel assemblies and core components during fueling operations and stores new and spent fuel assemblies in the new and spent fuel storage racks.
The component locations of the FHS are as shown in Table 2.1.1-2.
has no simplified figure.
Note, the FHS The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the integrated system inspections and testing ITAAC. The FHS is unique in that its design description relates to individual components that transfer fuel assemblies and core components during refueling operations. As such the functional arrangement simply locates these components in different buildings to demonstrate that functional purpose. Inspection of these components demonstrates that the required components exist and that they are located in a manner needed to perform the intended function. See below for a list of the ITAAC that demonstrate the design commitment of the FHS functional arrangement ITAAC (Index No. 1, ITAAC 2.1.01.01).
Component Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Refueling Machine (RM)
FHS-FH-01 2.1.01.04 (4)
ITAAC #4, parts 6 and 7 include inspection of the as-built FHS to locate the RM, FHM, spent fuel storage racks, and new fuel storage racks on the nuclear island. The location of the RM, FHM, spent fuel storage racks, and new fuel storage racks are verified through this ITAAC; no additional information is verified by completion of the functional arrangement ITAAC.
Fuel Handling Machine (FHM)
FHS-FH-02 Spent Fuel Storage Racks FHS-FS-02 New Fuel Storage Racks FHS-FS-01 Fuel Transfer Tube FHS-FT-01 2.2.01.07.1 (107)
ITAAC #107 is the Integrated Leak Rate Test that includes a test of the entire Containment Vessel Boundary; including the fuel transfer tube. The location and function of the fuel transfer tube is verified through this ITAAC; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the FHS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.2.
Component Cooling Water System (CCS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.1-2 includes ITAAC No. 278 (ITAAC 2.3.01.01), the CCS functional arrangement ITAAC:
Page 8 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.1-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the CCS is as described in the Design Description of this Section 2.3.1.
Inspection of the as-built system will be performed.
The as-built CCS conforms with the functional arrangement as described in the Design Description of this Section 2.3.1.
The Design Description for COS includes the following key attributes:
The COS removes heat from various plant components and transfers this heat to the service water system (SWS) during normal modes of plant operation including power generation, shutdown and refueling. The COS has two pumps and two heat exchangers.
The COS is as shown in Figure 2.3.1-1 and the component locations of the CCS are as shown in Table 2.3.1-3.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the testing and inspections performed for CCS, which include functional testing and integrated system inspections that demonstrate the required components exist and that they are connected in a manner to perform the intended function. See below for a list of the functional ITAAC associated with CCS components in Figure 2.3.1-1 and Table 2.3.1-3 that demonstrate the design commitment of the CCS functional arrangement ITAAC (Index No.
278, ITAAC 2.3.01.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA CCS Pumps CCS-MP-01A/B 2.3.01.03.ii (281)
ITAAC #281, part 3 performs testing of the CCS pumps to provide cooling water from the CCS HX to CCS Heat Exchangers (MX)
CCS-ME-01A/B RNS MX A & B RNS-ME-01A/B Page 9 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functionai ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA SFS HX A & B SFS-ME-01A/B the RNS HXs and SFS HXs part 4 performs tests to actuate the CCS pumps using controls in the MCR.
Part 5 performs inspections for the retrievability of a number of CCS parameters associated with these components; no additional information is verified by completion of the functional arrangement ITAAC.
CONTAINMENT HEAT LOADS ITAAC #281, part 3 performs testing of the CCS pumps to provide cooling water from the CCS HX to the RNS HX and SFS HX, while also providing flow to other users of cooling water, as shown on Figure 2.3.1-1; no additional information is verified by completion of the functional arrangement ITAAC.
RCPs RCS-MP-01A/B, -
02A/B ova Letdown HX CVS-ME-02 WLS Reactor Coolant Drain Tank HX WLS-ME-01 OTHER HEA" LOADS CVS Miniflow HXs CVS-ME-03A/B RNS Pump Seals RNS-MP-01A/B PSS Sample Cooler PSS-ME-01A/B VWS Chillers VWS-ME-02A/B CAS Air Compressors CAS-MS-01A/B, -
03A/B CDS Pump Motor Oil Coolers CDS-MP-01A/B RCP Variable Frequency Drives ECS-EV-31/41/51/61 CCS Containment Isolation MOV -
Inlet Line ORC CCS-PL-V200 2.2.01.07.ii (108)
IT/\\AC #108 tests remotely operated containment isolation valves to ensure they close within the required response times; no additional information is verified by completion of the functional arrangement ITAAC.
CCS Containment Isolation MOV -
Outlet Line IRC CCS-PL-V207 CCS Containment Isolation MOV -
Outlet Line ORC CCS-PL-V220 Page 10 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
As the functional arrangement of the COS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.3.
Chemical and Volume Control System (CVS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.2-4 includes ITAAC No. 284 (ITAAC 2.3.02.01), the CVS functional arrangement ITAAC:
Table 2.3.2-4 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the CVS is as described in the Design Description of this Section 2.3.2.
Inspection of the as-built system will be performed.
The as-built CVS conforms with the functional arrangement as described in the Design Description of this Section 2.3.2.
The Design Description for CVS includes the following key attributes:
The CVS provides reactor coolant system (RCS) purification, RCS inventory control and makeup, chemical shim and chemical control, oxygen control, and auxiliary pressurizer spray.
The CVS is as shown in Figure 2.3.2-1 and the component locations of the CVS are as shown in Table 2.3.2-5.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the testing and inspections performed for CVS, which include functional testing and integrated system inspections that demonstrate the required components exist and that they are connected in a manner to perform the intended function. See below for a list of the functional ITAAC associated with CVS components in Figure 2.1.2-1 and Table 2.1.2-5 that demonstrate the design commitment of the CVS functional arrangement ITAAC (Index No.
284, ITAAC 2.3.02.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA CVS Makeup Pumps CVS-MP-01A/B 2.3.02.08a.i (301)
ITAAC #301 parts 8.a) and 8.b) perform testing of the flow path from the Boric Acid Storage Tank, through the CVS pumps and all associated heat exchangers, demineralizers and Boric Acid Storage Tank CVS-MT-01 Regenerative HX CVS-ME-01 Letdown HX CVS-ME-02 Mixed Bed Demineralizers CVS-MV-01A/B Cation Bed Demineralizer CVS-MV-02 Page 11 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Reactor Coolant Filters CVS-MV-03A/B filters to tfie RCS and to the RCS Pressurizer Auxiliary Spray; no additional information is verified by completion of the functional arrangement ITAAC.
RCS Purification Motor-operated Isolation Valves CVS Letdown Containment Isolation Valves CVS-PL-V001 through V003 CVS-PL-V045A/047 CVS Auxiliary Pressurizer Spray Line Pressure Boundary Valve CVS-PL-V084 CVS Makeup Line Containment Isolation Motor-operated Valves CVS-PL-V090A/091 CVS Zinc Injection Containment Isolation Valves CVS-PL-V092A/094 CVS Demineralized Water Isolation Valves CVS-PL-V136A/B CVS Hydrogen Injection Containment Isolation Valve ORC CVS-PL-V219 CVS Makeup Return Line Bypass Check Valve CVS-PL-V067 CVS Purification Return Line Pressure Boundary Check Valves CVS-PL-V080 through -082 CVS Auxiliary Pressurizer Spray Line Pressure Boundary Check Valve CVS-PL-V085 CVS Makeup Pumps CVS-MP-01A/B 2.3.02.08a.i (301)
ITAAC #301 parts 9, lO.a, lO.b, 11.a and 11.b) perform testing on these components identified in Table 2.3.2-1 to demonstrate safety related displays (valve position) in the MCR perform an active safety function after receiving a signal from PMS, change position under pre-operational test conditions if an MOV and assume the appropriate position after a loss of motive power; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #301 part 11.a) perform testing on these check valves identified in Table 2.3.2-1 to demonstrate that they will change position as indicated in the Table under pre-operational test conditions; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #301 part 12.a) and 12.b) perform testing on these pumps to demonstrate starting function from the MCR and after receipt of a signal from the PLS; no additional information is verified by completion of the functional arrangement ITAAC.
CVS Makeup Pumps CVS-MP-01A/B 2.3.02.08a.iii (303)
ITAAC #303 performs testing on these pumps to measure the delivery rate of CVS makeup flow to the RCS is less than or Page 12 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional iJAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA equal to 175 gpm with RCS pressure below 6 psig; no additional information is verified by completion of the functional arrangement ITAAC.
RCS Purification Motor-operated Isolation Valves CVS Purification Return Line Pressure Boundary Check Valves CVS Auxiliary Pressurizer Spray Line Pressure Boundary Valves CVS Resin Flush Line Containment Isolation Valves CVS Demineralizer Resin Flush Line Containment Isolation Thermal Relief Valve CVS Letdown Containment Isolation Valves CVS Letdown Line Containment Isolation Thermal Relief Valve CVS Makeup Line Containment Isolation Motor-operated Valves CVS Zinc Injection Containment Isolation Valve ORC CVS Zinc Injection Containment Isolation Valve IRC CVS Zinc Addition Line Containment Isolation Thermal Relief Valve CVS-PL-V001 through V003 CVS-PL-V080 through -082 CVS-PL-V084A/085 CVS-PL-V040A/041 CVS-PL-V042 CVS-PL-V045A/047 CVS-PL-V058 CVS-PL-V090A/091 CVS-PL-V092 CVS-PL-V094 CVS-PL-V098 CVS Makeup Line Containment Isolation Thermal Relief Valve CVS-PL-V100 CVS Demineralized Water Isolation Valves CVS-PL-V136A/B 2.3.02.02a (285)
ITAAC #285, part 2b inspect as-built piping as documented in ASME Code Section III design reports (CVS system design reports) recorded on ASME N-5 certified data reports for lines in Table 2.3.2-1, which include the valves found on Figure 2.3.2-1.
The location and function of these valves are verified through this ITAAC; no additional information is verified by completion of the functional arrangement ITAAC.
Page 13 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA CVS Hydrogen Injection Containment Isolation Valve ORC CVS-PL-V219 CVS Hydrogen Injection Containment Isolation Check Valve IRC CVS-PL-V217 CVS Letdown Containment Isolation Valves CVS-PL-V045A/047 2.2.01.07.11 (108)
ITAAC #108 tests remotely operated containment isolation valves to ensure they close within the required response times; no additional information is verified by completion of the functional arrangement ITAAC.
CVS Makeup Line Containment Isolation Motor-operated Valves CVS-PL-V090A/091 CVS Zinc Injection Containment Isolation Valve ORC CVS-PL-V092 CVS Zinc Injection Containment Isolation Valve IRC CVS-PL-V094 CVS Hydrogen Injection Containment Isolation Valve ORC CVS-PL-V219 As the functional arrangement of the CVS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.4.
Standby Diesel Fuel Oil System (DOS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.3-2 includes ITAAC No. 318 (ITAAC 2.3.03.01), the DOS functional arrangement ITAAC:
Table 2.3.3-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the DOS is as described in the Design Description of this Section 2.3.3.
Inspection of the as-built system will be performed.
The as-built DOS conforms with the functional arrangement as described in the Design Description of this Section 2.3.3.
The Design Description for DOS includes the following key attributes:
Page 14 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
The DOS supplies diesel fuel oil for the onsite standby power system. The diesel fuel oil is supplied by two above-ground fuel oil storage tanks. The DOS also provides fuel oil for the ancillary diesel generators. A single fuel oil storage tank services both ancillary diesel generators.
The DOS is as shown in Figure 2.3.3-1 and the component locations of the DOS are as shown in Table 2.3.3-3.
The DC for this iTAAC is demonstrated through the ITA and AC of other ITAAC, specifically the testing and inspections performed for DOS, which include functional testing and system inspections that demonstrate the required components exist and that they are connected in a manner to perform the intended function. See below for a list of the functional ITAAC associated with DOS components in Figure 2.3.3-1 and Table 2.3.3-3 that demonstrate the design commitment of the DOS functional arrangement ITAAC (Index No. 318, ITAAC 2.3.03.01).
Component Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Diesel Oil Transfer Packages DOS-MS-01A/B 2.3.03.03c (322)
ITAAC #322 performs testing that the fuel oil flow rate to the day tank of each standby diesel generator provides for continuous operation of the associated diesei generator, which invoives ail eight of these components: no additional information is verified by completion of the functional arrangement ITAAC.
Fuel Oil Storage Tanks DOS-MT-01A/B Diesel Generator Fuel Oil Day Tanks DOS-MT-02A/B Diesel Fuel Oil Pumps DOS-MP-01A/B Ancillary Diesel Fuel Oil Storage Tank DOS-MT-03 2.3.03.02 (319)
ITAAC #319 performs inspection that the as-built ancillary diesel generator fuel oil storage tank and anchorage are designed using seismic Category II methods and criteria; no additional information is verified by completion of the functional arrangement ITAAC.
Fuel Oil Storage Tanks DOS-MT-01A/B 2.3.03.03a (320)
ITAAC #320 performs inspection to determine that the voiume of each fuel oil storage tank available to the standby diesel generator is s 55,000 gallons; no additional information is verified by compietion of the functional arrangement ITAAC.
Diesel Generator Fuel Oil Day Tanks DOS-MT-02A/B 2.3.03.03b (321)
ITAAC #321 performs inspection to determine that the volume of each fuel oil day tank is 5 1300 gallons; no Page 15 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) additional information is verified by completion of the functional arrangement ITAAC.
Ancillary Diesel Fuel Oil Storage Tank DOS-MT-03 2.3.03.03d (323)
ITAAC #323 performs inspection to determine that the volume of the ancillary diesel generator fuel oil tank is > 650 gallons: no additional information is verified by completion of the functional arrangement ITAAC.
Diesel Fuel Oil Pumps DOS-MP-01A/B 2.3.03.04 (324)
ITAAC #324 performs testing and inspections to demonstrate that the pumps will operate from controls in the MCR and that all four of the component's parameters can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Diesel Generator Fuel Oil Day A/B Level DOS-016A/B As the functional arrangement of the DOS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.5.
Fire Protection System (FPS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.4-2 includes ITAAC No. 326 (ITAAC 2.3.04.01), the FPS functional arrangement ITAAC:
Table 2.3.4-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the FPS is as described in the Design Description of this Section 2.3.4.
Inspection of the as-built system will be performed.
The as-built FPS conforms with the functional arrangement as described in the Design Description of this Section 2.3.4.
The Design Description for FPS includes the following key attributes:
The FPS detects and suppresses fires in the plant. The FPS consists of water distribution systems, automatic and manual suppression systems, a fire detection and alarm system, and portable fire extinguishers.
Page 16 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The FPS provides fire protection for the nuclear island, the annex building, the turbine building, the radwaste building and the diesel generator building.
The FPS is as shown in Figures 2.3.4-1 (Sheets 1 and 2) and 2.3.4-2, and the locations of the components in these systems are shown in Table 2.3.4-3.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC.
See below for a list of the functional ITAAC associated with FPS components in Figures 2.3.4-1 (Sheets 1 and 2) and 2.3.4-2 and Table 2.3.4-3 that demonstrate the design commitment of the FPS functional arrangement ITAAC (Index No. 326, ITAAC 2.3.04.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Motor-driven Fire Pump FPS-MP-01A 2.3.04.05 (332)
ITAAC #332 includes testing of the retrievability of the parameters in the MCR. The displays identified in Table 2.3.4-1 can be retrieved in the MCR which includes these components; no additional information is verified by completion of the functional arrangement ITAAC.
Diesel-driven Fire Pump FPS-MP-01B Jockey Pump FPS-MP-02 Primary Fire Water Tank FPS-MT-01A 2.3.04.04.i (330)
ITAAC #330, part 7 includes inspection of the as-built fire water storage tanks; no additional information is verified by completion of the functional arrangement ITAAC.
Secondary Fire Water Tank FPS-MT-01B Fire Pump Diesel Fuel Day Tank FPS-MT-02 2.3.04.09 (336)
ITAAC #336 performs an inspection of the as-built diesel-driven fire pump day tank; no additional information is verified by completion of the functional arrangement ITAAC.
Passive Containment Cooling System (PCS)
Storage Tank PCS-MT-01 2.3.04.04.i (330)
ITAAC #330, part 4 includes inspection of the PCS storage tank to ensure that the volume of the PCS tank above the standpipe feeding the FPS and below the overflow is at least 18,000 gallons; no additional information is verified Page 17 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA by completion of the functional arrangement ITAAC.
Containment FPS Spray Headers N/A 2.3.04.04.1 (330)
ITAAC #330, part 6 includes inspection of the containment spray headers to ensure that the FPS has at least 44 nozzles at plant elevation of at least 260 feet and 24 nozzles at plant elevation of at least 275 feet; no additional information is verified by completion of the functional arrangement ITAAC.
FPS Spray Headers N/A 2.3.04.04.11 (331)
IT/\\AC #331 performs flow rate testing of each of the two highest fire-hose stations in plant areas containing safety-related equipment to be not less than 75 gpm when the water is supplied from the PCS storage tank; no additional information is verified by completion of the functional arrangement IT/\\AC.
Fire Detectors N/A 2.3.04.10 (337)
ITAAC #337 performs testing of each of the as-built individual fire detectors in the fire areas identified in subsection 3.3, Table 3.3-3 using simulated fire conditions; no additional information is verified by completion of the functional arrangement ITAAC.
FPS Seismic Standpipe Subsystem to FPS Plant Fire Main Cross Connect Valve FPS-PL-V101 2.3.04.11 (338)
IT/VAC #338 performs an inspection to confirm that FPS-PL-VI01 exists and can connect the FPS seismic standpipe subsystem to the FPS plant fire main; no additional information is verified by completion of the functional arrangement IT/\\AC.
Page 18 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Piping shown on Figure 2.3.4-2 N/A 2.3.04.02.1 (327) iTAAC #327 performs an inspection to verify that the piping shown on Figure 2.3.4-2 is installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
Fire Water Containment Supply Isolation Valve -
Outside FPS-PL-V050 2.2.01.07.1 (107)
ITAAC #107 is the Integrated Leak Rate Test that includes a test of the entire Containment Vessel Boundary; including the non-remotely operated containment isolation valves, such as those in FPS; no additional information is verified by completion of the functional arrangement ITAAC.
Fire Water Containment Isolation Supply Check Valve -
Inside FPS-PL-V052 The FPS contains a number of components not listed in the above table that are outside the scope of ITAAC. The remaining functions of the FPS are defense-in-depth or non-safety related. The arrangement of the FPS equipment necessary to perform the defense-in-depth functions are verified via other ITAAC, as shown in the above table. The remaining FPS components in Figure 2.3.4-1 Sheets 1 and 2 are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.8, which provides verification that the as-installed system properly functions. The FPS does not have any features or functions credited for mitigation of design basis events, nor are there any features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the FPS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the defense-in-depth functions are appropriately arranged, and the additional FPS equipment in Figure 2.3.4-1 Sheets 1 and 2 are tested in the iTP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.6.
Mechanical Handling System (MHS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.5-2 includes ITAAC No. 339 (ITAAC 2.3.05.01), the MHS functional arrangement ITAAC:
Page 19 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.5-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment inspections. Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the MHS is as described in the Design Description of this Section 2.3.5.
Inspection of the as-built system will be performed.
The as-built MHS conforms with the functional arrangement as described in the Design Description of this Section 2.3.5.
The Design Description for MHS includes the following key attributes:
The MHS provides for lifting heavy loads. The MHS equipment can be operated during shutdown and refueling.
The MHS component locations are as shown in Table 2.3.5-3. Note, the MHS has no simplified figure.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for MHS, which demonstrate the required components exist and are sized to perform the intended function. See below for a list of the functional ITAAC associated with MHS components in Table 2.3.5-3 that demonstrate the design commitment of the MHS functional arrangement ITAAC (Index No. 339, ITAAC 2.3.05.01).
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Containment Polar Crane MHS-MH-01 2.3.05.02.1 (340)
ITAAC #340 performs inspection that the seismic Category 1 equipment identified in Table 2.3.5-1, the MHS cranes and hoists are located on the Nuclear Island; no additional information is verified by completion of the functional arrangement ITAAC.
Cask Handling Crane MHS-MH-02 Equipment Hatch Hoist MHS-MH-05 Maintenance Hatch Hoist MHS-MH-06 Containment Polar Crane MHS-MH-01 2.3.05.03a.ii (344)
ITAAC #344, part 3.a) performs tests on the polar crane to include static-load and a test load to lower, stop and hold the 100% load; no additional information is verified by completion of the functional arrangement ITAAC.
Page 20 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Cask Handling Crane MHS-MH-02 2.3.05.03b.iii (348)
ITAAC #348, parts 3.b) and 4.)
perform tests on the cask handling crane to include static-load and a test load to lower and stop and hold 100% load; no additional information is verified by completion of the functional arrangement ITAAC.
Equipment Hatch Hoist MHS-MH-05 2.3.05.03c.ii (350)
ITAAC #350, part 3.c) performs tests on the equipment hatch hoist holding mechanism to stop and hold the hatch; no additional information is verified by completion of the functional arrangement ITAAC.
Maintenance Hatch Hoist MHS-MH-06 2.3.05.03d.ii (352)
ITAAC #352, part 3.d) performs tests on the maintenance hatch hoist holding mechanism to stop and hold the hatch; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the MRS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.7.
Normal Residual Heat Removal System (RNS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.6-4 includes ITAAC No. 354 (ITAAC 2.3.06.01), the RNS functional arrangement ITAAC:
Page 21 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.6-4 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the RNS is as described in the Design Description of this Section 2.3.6.
Inspection of the as-built system will be performed.
The as-built RNS conforms with the functional arrangement as described in the Design Description of this Section 2.3.6.
The Design Description for RNS includes the following key attributes:
The RNS removes heat from the core and RCS and provides RCS low temperature over-pressure (LTOP) protection at reduced RCS pressure and temperature conditions after shutdown. The RNS also provides a means for cooling the in-containment refueling water storage tank (IRWST) during normal plant operation.
The RNS is as shown in Figure 2.3.6-1, and the RNS component locations are as shown in Table 2.3.6-5.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with RNS components in Figure 2.3.6-1, and Table 2.3.6-5. that demonstrate the design commitment of the RNS functional arrangement ITAAC (Index No. 354, ITAAC 2.3.06.01).
Page 22 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA RNS Pumps RNS-MP-01A/B RNS HXs RNS-ME-01A/B 2.3.06.09b.ii (375)
ITAAC #375, part 9.b.ii) tests that the RNS pumps can provide flow through the RNS heat exchangers when the pump suction is aligned to the RCS hot leg, part O.b.iii) inspects the RCS piping to insure the cold leg centerline elevation is 17.5 +/-2 inches above the hot leg, part O.b.iv) inspects the RNS pump suction piping to ensure no local high point exists, part 9.b.v) inspects the RNS pump suction line connection to the RCS is constructed from 20-inch Schedule 140 pipe, part 9.c) tests each RNS pump to ensure they can provide at least 1100 gpm net flow to the RCS from the cask loading pit with the RCS depressurized, and part 9.d) tests to ensure the RNS pumps can provide at least 2000 gpm to the IRWST; no additional information is verified by completion of the functional arrangement ITAAC.
RCS Inner Hot Leg Suction Motor-operated Isolation Valves RNS-PL-V001A/B 2.3.06.09b.ii (375)
RCS Outer Hot Leg Suction Motor-operated Isolation Valves RNS-PL-V002A/B RNS Discharge Motor operated Containment Isolation Valve RNS-PL-V011 ITAAC #375, part 12.a.iii) tests the motor-operated valves in Table 2.3.6-1 under preoperational test conditions; no additional information is verified by completion of the functional arrangement ITAAC.
RNS Suction Header Motor-operated Containment Isolation Valve RNS-PL-V022 Page 23 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functionai iTAAC Coverage of FA RNS Suction from IRWST Motor-operated Isolation Valve RNS-PL-V023 RNS Discharge to IRWST Motor-operated Isolation Valve RNS-PL-V024 RNS Suction from Cask Loading Pit Motor operated Isolation Valve RNS-PL-V055 RCS Pressure Boundary Thermal Relief Check Valves RNS-PL-V003A/B 2.3.06.09b.ii (375)
ITAAC #375, part 12.a.iv) tests the check valves in Table 2.3.6-1 with active safety functions under preoperational test conditions; no additional information is verified by completion of the functional arrangement ITAAC.
RNS Discharge Header Containment Isolation Check Valve RNS-PL-V013 RNS Discharge RCS Pressure Boundary Check Valves RNS-PL-V015A/B RNS-PL-V017A/B RNS Discharge to IRWST Motor-operated Isolation Valve RNS-PL-V024 2.3.06.02a (355) 2.3.06.05a.i (361)
ITAAC #355, part 2.a) inspects the as-built components identified in Table 2.3.6-1 is included in the ASME Code Section III design reports.
ITAAC #361, part 5.a.i) verifies that the seismic Category 1 equipment identified in Table 2.3.6-1 is Installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
RNS Discharge RCS Pressure Boundary Check Valves RNS-PL-V015A/B RNS-PL-V017A/B RNS Discharge Header Containment Isolation Check Valve RNS-PL-V013 RNS Discharge Containment Isolation Test Connection RNS-PL-V012 RNS Discharge Motor operated Containment Isolation Valve RNS-PL-V011 RNS Suction from Cask Loading Pit Motor operated Isolation Valve RNS-PL-V055 RNS Suction from Cask Loading Pit Check Valve RNS-PL-V056 RNS Pump Miniflow Air-Operated Isolation Valves RNS-PL-V057A/B RNS Return from CVS Containment Isolation Valve RNS-PL-V061 Page 24 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA RNS Hot Leg Suction Pressure Relief Valves RNS-PL-V020A/021 RNS Suction Header Motor-operated Containment isolation Valve RNS-PL-V022 RNS Suction from IRWST Motor-operated Isoiation Valve RNS-PL-V023 RCS Inner Hot Leg Suction Motor-operated Isolation Valves RNS-PL-V001A/B RCS Outer Hot Leg Suction Motor-operated Isolation Vaives RNS-PL-V002A/B RCS Pressure Boundary Thermai Reiief Check Valves RNS-PL-V003A/B RCS Inner Hot Leg Suction Motor-operated Isolation Valves RNS-PL-V001A/B 2.3.06.07b (368)
ITAAC #361 tests the Class 1E components identified in Table 2.3.6-1 by providing a simulated test signal in each Class IE division; no additional information is verified by completion of the functional arrangement ITAAC.
RCS Outer Hot Leg Suction Motor-operated Isolation Vaives RNS-PL-V002A/B RNS Discharge Motor operated Containment Isolation Valve RNS-PL-V011 RNS Suction Header Motor-operated Containment Isolation Valve RNS-PL-V022 RNS Suction from IRWST Motor-operated Isolation Valve RNS-PL-V023 RNS Return from CVS Containment Isoiation Valve RNS-PL-V061 RNS Discharge Motor operated Containment Isolation Valve RNS-PL-V011 2.2.01.07.11 (108)
ITAAC #108 tests remotely operated containment isolation valves to ensure they close within the required response times; no additional information is verified by RNS Suction Header Motor-operated Containment isolation Valve RNS-PL-V022 Page 25 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA RNS Return from CVS Containment Isolation Valve RNS-PL-V061 completion of the functional arrangement ITAAC.
As the functional arrangement of the RNS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.8.
Spent Fuel Pool Cooling System (SFS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.7-4 includes ITAAC No. 391 (ITAAC 2.3.07.01), the SFS functional arrangement ITAAC:
Inspections, 1 Table 2.3.7-4 rests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the SFS is as described in the Design Description of this Section 2.3.7.
Inspection of the as-built system will be performed.
The as-built SFS conforms with the functional arrangement as described in the Design Description of this Section 2.3.7.
The Design Description for SFS includes the following key attributes:
The SFS removes decay heat from spent fuel by transferring heat from the water in the spent fuel pool to the component cooling water system during normal modes of operation. The SFS purifies the water in the spent fuel pool, fuel transfer canal, and in-containment refueling water storage tank during normal modes of operation.
Following events such as earthquakes, or fires, if the normal heat removal method is not available, decay heat is removed from spent fuel by boiling water in the pool. In the event of long-term station blackout, makeup water is supplied to the spent fuel pool from onsite storage tanks The SFS is as shown in Figure 2.3.7-1, and the SFS component locations are as shown in Table 2.3.7-5.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with SFS components in Figure 2.3.7-1, and Table 2.3.7-5. that demonstrate the design commitment of the SFS functional arrangement ITAAC (Index No. 391, ITAAC 2.3.07.01).
Page 26 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA SFS Pumps SFS-MP-01A/B 2.3.07.07c (408)
ITAAC #408, part 8 tests that the SFS pumps can provide flow through the SFS heat exchangers when taking suction from the SFP and returning flow to the SFP, Part 10 tests that the pumps identified in Table 2.3.7-3 can be controlled from the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
SFS HXs SFS-ME-01A/B Spent Fuel Pool (SFP)
FHS-MT-01 Spent Fuel Pool Level Sensors SFS-019A/B/C 2.3.07.07c (408)
ITAAC #408, part 9 performs an inspection to confirm that Safety-Related displays identified in Table 2.3.7-1 can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Refueling Cavity Drain to SGS Compartment Isolation Valve SFS-PL-V031 SFS Containment Floodup Isolation Valve SFS-PL-V075 SFS Pumps SFS-MP-01A/B 2.3.07.07c (408)
ITAAC #408, part 11 performs an inspection to confirm the retrievability in the MCR of displays identified in Table 2.3.7-3; no additional information is verified by completion of the functional arrangement ITAAC.
SFS Flow Sensors SFS-013A/B Spent Fuel Pool Temperature Sensor SFS-018 SFS Containment Floodup Sensor SFS-022 Spent Fuel Pool Level Sensors SFS-019A/B/C 2.3.07.06a (399)
ITAAC #399 tests the Class 1E Components identified in Table 2.3.7-1 by providing a simulated test signal in each Class 1E division; no additional information is verified by completion of the functional arrangement ITAAC.
Page 27 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA PCS Water Storage Tank PCS-MT-01 2.2.02.07f.i (145)
ITAAC #145, part 7.f) tests the delivery rate from the PCCWST to the spent fuel pool.
Cask Loading Pit FHS-MT-05 2.3.07.07b.vii (881)
ITAAC #881 inspects the water volume of the cask loading pit; no additional information is verified by completion of the functional arrangement ITAAC.
Cask Washdown Pit FHS-MT-06 2.3.07.07b.ii (403)
ITAAC #403 inspects the water volume of the cask washdown pit; no additional information is verified by completion of the functional arrangement ITAAC.
Fuel Transfer Canal FHS-MT-02 2.3.07.07b.i (402)
ITAAC #402 inspects the volume of the fuel transfer canal; no additional information is verified by completion of the functional arrangement ITAAC.
Refueling Cavity FHS-MT-03 2.3.07.07c (408)
ITAAC #408, part 7c) exercise tests the SFS check valves in the refueling cavity drain line, under pre-operational conditions, to demonstrate that these valves prevent flooding of the refueling cavity during containment flooding; no additional information is verified by completion of the functional arrangement ITAAC.
Refueling Cavity Drain Line Check Valves SFS -PL-V071/072 Page 28 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functionai iTAAC Coverage of FA Cask Loading Pit to SFS -PL-V041/042 2.3.07.02a ITAAC #392, part 2.a)
SFS Pump Suction Isolation Valves (392) inspects the as-built components identified in Table 2.3.7-1 is included in the ASME Code Section III design reports.
SFS Pump Discharge Line to Cask Loading Pit Isolation Valve SFS -PL-V045 Cask Loading Pit to WLS Isolation Valve SFS -PL-V049 2.3.07.05.i (396)
ITAAC #396 part 5.i) verifies that the seismic Category 1 Spent Fuel Pool to Cask SFS -PL-V066 equipment identified in Table Washdown Pit Isolation 2.3.7-1 is installed in the Valve correct location; no additional Cask Washdown Pit SFS -PL-V068 information is verified by Drain Isolation Valve completion of the functional Fuel Transfer Canal to SFS -PL-V040 arrangement ITAAC.
SFS Pump Suction Isolation Valve IRWSTtoSFSPump SFS -PL-V039 Suction Line Isolation Valve Refueling Cavity to SFS SFS -PL-V032 Pump Suction Isolation Valve Refueling Cavity Drain SFS -PL-V031 to SGS Compartment Isolation Valve Refueling Cavity Drain SFS -PL-V033 to Containment Sump Isolation Valve SFS Containment SFS-PL-V075 Floodup Isolation Valve SFS Suction Line SFS -PL-V034 2.2.01.07.ii ITAAC #108 tests remotely Containment Isolation (108) operated containment MOV-IRC isolation valves to ensure SFS Suction Line SFS -PL-V035 they close within the required Containment Isolation response times; no additional MOV-ORC information is verified by completion of the functional arrangement ITAAC.
Page 29 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA SFS Discharge Line Check Valve IRC SFS -PL-V037 2.2.01.1 la.iv (117)
ITAAC #117 tests check valves with active safety functions identified in Table 2.2.1-1 under preoperational test pressure, temperature and flow conditions; no additional information is verified by completion of the functional arrangement ITAAC.
SFS Discharge Line Containment Isolation MOV-ORC SFS -PL-V038 2.2.01.05.i (98)
ITAAC #98, part 5.1) verifies that the seismic Category 1 equipment identified in identified in Table 2.2.1-1 is installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
The SFS contains components not listed in the above table that are outside the scope of ITAAC: two each of the demineralizers and filters. The SFS safety-related and defense-in-depth functions do not rely on these components. These components are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.7, which provides verification that the as-installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any SFS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the SFS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related and defense-in-depth functions are appropriately arranged, and the additional four SFS components not tested by other ITAAC are tested in the ITP.
Therefore, the functional arrangement ITAAC is proposed to be removed.
2.9.
Service Water System (SWS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.8-2 includes ITAAC No. 414 (ITAAC 2.3.08.01), the SWS functional arrangement ITAAC:
Page 30 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Inspections, 1 Table 2.3.8-2 Pests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Anaiyses Acceptance Criteria
- 1. The functional arrangement of the SWS is as described in the Design Description of this Section 2.3.8.
Inspection of the as-built system will be performed.
The as-built SWS conforms with the functional arrangement as described in the Design Description of this Section 2.3.8.
The Design Description for SWS includes the following key attributes:
The SWS transfers heat from the component cooling water heat exchangers to the atmosphere. The SWS operates during normal modes of plant operation, including startup, power operation (full and partial loads), cooldown, shutdown, and refueling.
The SWS is as shown in Figure 2.3.8-1 and the component locations of the SWS are as shown in Table 2.3.8-3.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with SWS components in Figure 2.3.8-1 and Table 2.3.8-3 that demonstrate the design commitment of the SWS functional arrangement ITAAC (Index No. 414, ITAAC 2.3.08.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Service Water Pumps SWS-MP-01A/B 2.3.08.02.1 (415)
ITAAC #415, part 2 tests both SWS pump's capacity through the CCS HXs; no additional information is verified by completion of the functional arrangement ITAAC.
Service Water Cooling Tower Fans SWS-MA-01A/B 2.3.08.02.1 (415)
ITAAC #415, part 3 tests that controls in the MCR operate to cause the components listed in Table 2.3.8-1 to perform the listed function; no additional information is verified by completion of the functional arrangement ITAAC.
Service Water Pump A Discharge Valves SWS-PL-V002A/B Page 31 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA SWS Cooling Tower SWS-ME-01 2.3.08.02.i (415) 2.3.08.02.iii (417)
ITAAC #415, part 4 inspects that dispiays identified in Table 2.3.8-1 can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #417 performs testing to confirm that the SWS tower basin contains a usable volume of at least 230,000 gallons at the basin low level alarm point; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the SWS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.10.
Containment Hydrogen Control System (VLB)
COL Appendix C (and plant-specific Tier 1) Table 2.3.9-3 includes ITAAC No. 420 (ITAAC 2.3.09.01), the VLS functional arrangement ITAAC:
inspections, 1 Table 2.3.9-3 Pests, Analyses, and Acceptance Criteria Design Commitment inspections. Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VLS is as described in the Design Description of this Section 2.3.9.
Inspection of the as-built system will be performed.
The as-built VLS conforms with the functional arrangement as described in the Design Description of this Section 2.3.9.
The Design Description for VLS includes the following key attributes:
The VLS limits hydrogen gas concentration in containment during accidents.
The VLS has catalytic hydrogen recombiners that are located inside containment.
The VLS has hydrogen igniters located as shown on Table 2.3.9-2. Note, the VLS has no simplified figure.
Page 32 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for VLS, which demonstrate the required components exist and are located to perform the intended function. See below for a list of the functional ITAAC associated with VLS components in Table 2.3.9-2 that demonstrate the design commitment of the VLS functional arrangement ITAAC (Index No. 420, ITAAC 2.3.09.01).
Equipment Name Tag No.
Functional ITAAC Number Equipment Name Hydrogen Monitors VLS-001/002/003 2.3.09.02.a (421) 2.3.09.03.ii (424)
Hydrogen Igniters VLS-EH-01 through -66 2.3.09.02.b (422) 2.3.09.03.ii (424)
ITAAC #421 performs testing of the hydrogen monitors by providing a simulated test signal in each power group of the non-Class IE do and UPS Systems: no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #424, part 5 confirms that the hydrogen monitor displays can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #422 performs testing of the hydrogen igniters by providing a simulated test signal in each non-Class 1E power group; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #424, part 3.i) performs inspections for the number and location of hydrogen igniters. Part 3.ii) performs operability testing of all the igniters to ensure the surface temperature meets or exceeds 1700°F, Part 4.a) tests the igniters from controls in the MCR; no additional information is verified Page 33 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number Equipment Name by completion of the functional arrangement ITAAC.
Containment Vessel CNS-MV-01 2.3.09.03.111 (425)
ITAAC #425 performs an inspection of the as-built containment internal structures to confirm the location of vent paths; no additional information is verified by completion of the functional arrangement ITAAC.
IRWST Vents N/A 2.3.09.03.iv (426)
ITAAC #426 performs an inspection of the as-built IRWST vent located in the room of the IRWST along the side next to the containment shell to confirm these vents are generally oriented away from the shell; no additional information is verified by completion of the functional arrangement ITAAC.
The VLS contains two catalytic hydrogen recombiners not listed in the above table, which are outside the scope of ITAAC. The VLS performs no safety-related functions, and the defense-in-depth functions do not rely on the recombiners. The recombiners are tested in the ITP as described in UFSAR Subsection 14.2.9.1.11, which provides verification that the as-installed system properly functions. These components are not used to satisfy any requirements in 10 CFR 50.34(f) or 10 CFR 50.44.
It is appropriate to remove the functional arrangement ITAAC for the VLS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the defense-in-depth functions are appropriately arranged, and the additional two VLS components not tested by other ITAAC are tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.11.
Liquid Radwaste System (WLS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.10-4 includes ITAAC No. 430 (ITAAC 2.3.10.01), the WLS functional arrangement ITAAC:
Page 34 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.10-4 inspections, Tests, Analyses, and Acceptance Criteria Design Commitment inspections. Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the WLS is as described in the Design Description of this Section 2.3.10.
Inspection of the as-built system will be performed.
The as-built WLS conforms with the functional arrangement as described in the Design Description of this Section 2.3.10.
The Design Description for WLS includes the following key attributes:
The WLS receives, stores, processes, samples and monitors the discharge of radioactive wastewater.
The WLS has components which receive and store radioactive or potentially radioactive liquid waste. These are the reactor coolant drain tank, the containment sump, the effluent holdup tanks and the waste holdup tanks.
The WLS is as shown in Figure 2.3.10-1, and the component locations of the WLS are as shown on Table 2.3.10-5.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for WLS, which demonstrate the required components exist and are located to perform the intended function. See below for a list of the functional ITAAC associated with WLS components in Figure 2.3.10-1 and/or Table 2.3.10-5 that demonstrate the design commitment of the WLS functional arrangement ITAAC (Index No.
430, ITAAC 2.3.10.01).
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA WLS Drain from (CVS)
Compartment (Room 11209) Check Valves WLS-PL-V071AA/072A 2.3.10.02a (431) 2.3.10.05a.i (437)
ITAAC #431, part 2.a) verifies that the components identified in Table 2.3.10-1 as ASME Code Section III are as-built to code requirements.
ITAAC #437, part i) verifies that the seismic Category 1 equipment identified in Table 2.3.10-1 is WLS Drain from Passive Core Cooling System (PXS) Compartment A (Room 11206) Check Valves WLS-PL-V071BA/072B Page 35 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA WLS Drain from PXS Compartment B (Room 11207) Check Valves WLS-PL-V071CA/072C installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
Sump Discharge Containment Isolation Valve -
IRC WLS-PL-V055 2.2.01.07.11 (108)
IT/\\AC #108 performs tests to demonstrate that remotely operated containment isolation valves close within required response times; no additional information is verified by completion of the functional arrangement ITAAC.
Sump Discharge Containment Isolation Valve -
ORC WLS-PL-V057 CVS Letdown Containment Isolation Valves CVS-PL-V045A/047 Containment Sump Level Channels WLS-034/035/036 2.3.10.07a.ii (444)
ITAAC #444, part 7.a.i) tests that the containment sump level channels can be retrieved in the MCR, part 7.a.ii) tests that the containment sump level channels can detect a change of 1.34 +/- 0.5 inches, part 7.b) tests that a high radiation signal causes WLS-PL-V223 valve to close, part 8) tests that this valve can be closed from the MCR, part 9 performs exercise testing of the check valves with active safety functions in Table 2.3.10-1 under pre-operational test conditions, part 10 inspects to confirm that the displays identified in Table 2.3.10-3 can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement IT/\\AC.
WLS Effluent Discharge Isolation Valve WLS-PL-V223 WLS Drain from (CVS)
Compartment (Room 11209) Check Valves WLS-PL-V071AA/072A WLS Drain from Passive Core Cooling System (PXS) Compartment A (Room 11206) Check Valves WLS-PL-V071B/V072B WLS Drain from PXS Compartment B (Room 11207) Check Valves WLS-PL-V071CA/072C RCDT Level WLS-JE-LT002 Letdown Flow from CVS to WLS WLS-JE-FT020 WLS Aux Building RCA Floodup Level Sensors WLS-400A/B Page 36 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA WLS Aux Building RCA Floodup Level Sensors WLS-400A/B 2.3.10.11a (878) 2.3.10.12 (879)
ITAAC #878 tests Class 1E components in Table 2.3.10-1 by providing a simulated test signal in each Class 1E division.
ITAAC #879 confirms the safety-related displays in Table 2.3.10-1 can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
The WLS contains a number of components not listed in the above table that are outside the scope of ITAAC. The WLS safety-related functions are performed by components that are shown to be covered by other ITAAC in the above table. The WLS has no defense-in-depth functions. The additional components not tested in ITAAC are tested in the ITP, as described in UFSAR Subsection 14.2.9.3.1, which provides verification that the as-installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any WLS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the WLS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related functions are appropriately arranged, and the additional WLS components not tested by other ITAAC are tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.12.
Gaseous Radwaste System (WGS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.11-2 includes ITAAC No. 449 (ITAAC 2.3.11.01), the WGS functional arrangement ITAAC:
Page 37 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.11-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the WGS is as described in the Design Description of this Section 2.3.11.
Inspection of the as-built system will be performed.
The as-built WGS conforms with the functional arrangement as described in the Design Description of this Section 2.3.11.
The Design Description for WGS includes the following key attributes:
The WGS receives, processes, and discharges the waste gases received within acceptable off-site release limits during normal modes of plant operation including power generation, shutdown and refueling.
The WGS is as shown in Figure 2.3.11-1 and the component locations of the WGS are as shown on Table 2.3.11-3.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for WGS, which demonstrate the required components exist and are located to perform the intended function. See below for a list of the functional ITAAC associated with WGS components in Figure 2.3.11-1 and/or Table 2.3.11-3 that demonstrate the design commitment of the WGS functional arrangement ITAAC (Index No. 449, ITAAC 2.3.11.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA WGS Activated Carbon Delay Beds WGS-MV-02A/02B 2.3.11.02.1 (450)
ITAAC #450 verifies that the equipment identified as having seismic design requirements in Table 2.3.11-1 is installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
Page 38 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA WGS Discharge Isolation Valve WGS-PL-V051 2.3.11.03b (454)
ITAAC #454 tests to confirm that the presence of a simulated high radiation signal from the discharge radiation monitor WGS-JS-17 causes WGS-PL-V051 to close; no additional Information Is verified by completion of the functional arrangement ITAAC.
WGS Discharge Radiation Monitor WGS-JS-17 WGS Oxygen Monitors WGS-025A/B 2.3.11.03c (455)
ITAAC #455 tests to confirm that the presence of a simulated high oxygen level signal from the oxygen monitors (WGS-025A/B) causes the nitrogen purge valve (WGS-PL-V002) to open and the WLS Degaslfler Pumps (WLS-MP-03A/B) to stop; no additional Information Is verified by completion of the functional arrangement ITAAC.
WGS Nitrogen Purge Valve WGS-PL-V002 WGS Degaslfler Vacuum Pumps WLS-MP-03A/B The WGS contains a number of components not listed In the above table that are outside the scope of ITAAC. The WGS has no safety-related or defense-In-depth functions. The additional components not tested In ITAAC are tested In the ITP, as described In UFSAR Subsection 14.2.9.3.2, which provides verification that the as-Installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any WGS features or functions that have been Identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It Is appropriate to remove the functional arrangement ITAAC for the WGS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform some non-safety-related, non-defense-ln-depth functions are appropriately arranged, and the additional WLS components not tested by other ITAAC are tested In the ITP. Therefore, the functional arrangement ITAAC Is proposed to be removed.
Page 39 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.13.
Solid Radwaste System (WSS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.12-1 includes ITAAC No. 456 (ITAAC 2.3.12.01), tfie WSS functional arrangement ITAAC:
Table 2.3.12-1 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment inspections. Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the WSS is as described in the Design Description of this Section 2.3.12.
Inspection of the as-built system will be performed.
The as-built WSS conforms with the functional arrangement as described in the Design Description of this Section 2.3.12.
Tfie Design Description for WSS includes the following key attributes:
The solid radwaste system (WSS) receives, collects, and stores the solid radioactive wastes received prior to their processing and packaging by mobile equipment for shipment off-site.
The component locations of the WSS are as shown on Table 2.3.12-2. Note, the WSS has no simplified figure.
The DC for this ITAAC is not demonstrated through the ITA and AC of other ITAAC.
However, it is still appropriate to remove the functional arrangement ITAAC for the WSS.
The WSS has no safety-related or defense-in-depth functions. The WSS components are not required for any features or functions credited for mitigation of design basis events, nor are there any WSS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3. The WSS components are tested in the ITP, as described in UFSAR Subsection 14.2.9.3.3, which provides verification that the as-installed system properly functions. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.14.
Primary Sampling System (PSS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.13-3 includes ITAAC No. 458 (ITAAC 2.3.13.01), the PSS functional arrangement ITAAC:
Page 40 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.13-3 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the PSS is as described in the Design Description of this Section 2.3.13.
Inspection of the as-built system will be performed.
The as-built PSS conforms with the functional arrangement as described in the Design Description of this Section 2.3.13.
The Design Description for PSS includes the following key attributes:
The primary sampling system collects samples of fluids in the reactor coolant system (RCS), and the containment atmosphere during normal operations.
The PSS is as shown in Figure 2.3.13-1. The PSS Grab Sampling Unit (PSS-MS-01) is located in the Auxiliary Building. Note, the PSS has no table of component locations.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for PSS, which demonstrate the required components exist and are sized to perform the intended function. See below for a list of the functional ITAAC associated with PSS components in Table 2.3.13-1 that demonstrate the design commitment of the PSS functional arrangement ITAAC (Index No. 458, ITAAC 2.3.13.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Containment Air Sample PSS-PL-V008 2.3.13.02 ITAAC #459, part 2 verifies that the Containment Isolation (459) components identified in Table Valve IRC 2.3.13-1 as ASME Code Section III Liquid Sample Line PSS-PL-are as-built to code requirements.
Containment Isolation V010AA/010B Valves -
IRC 2.3.13.05.1 ITAAC #462, part 5.1 verifies that Liquid Sample Line PSS-PL-(462) the seismic Category 1 equipment Containment Isolation V011AA/011B identified in Table 2.3.13-1 is Valves -
ORC installed in the correct location; no Sample Return Line PSS-PL-V023 additional information is verified by Containment Isolation completion of the functional Valve ORC arrangement ITAAC.
Sample Return Line PSS-PL-V024 2.3.13.06b ITAAC #467 tests by providing a Containment Isolation (467) simulated test signal in each Class Valve IRC 1E Division to the Class 1E Page 41 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Air Sample Line Containment Isolation Valve ORC PSS-PL-V046 2.3.13.08 (470) equipment identified in Table 2.3.13-1.
ITAAC #470, part 9 inspects to ensure ttie safety-related displays identified in Table 2.3.13-1 can be retrieved in tfie MCR, part lO.a) and lO.b) performs stroke testing using MCR controls and simulated signals into the PMS of the remotely operated valves in the Table, part 11 tests to ensure that the remotely operated valves in the table assume the indicated position on loss of power; no additional information is verified by completion of the functional arrangement ITAAC.
Containment Air Sample Containment Isolation Valve IRC PS8-PL-V008 2.2.01.07.11 (108)
Liquid Sample Line Containment Isolation Valves -
IRC PSS-PL-V010AA/010B Liquid Sample Line Containment Isolation Valves -
ORC PSS-PL-V011AA/011B ITAAC #108 tests remotely operated containment isolation valves to ensure they close within the required response times; no additional information is verified by completion of the functional arrangement ITAAC.
Sample Return Line Containment Isolation Valve ORC PSS-PL-V023 Sample Return Line Containment Isolation Valve IRC PSS-PL-V024 Air Sample Line Containment Isolation Valve ORC PSS-PL-V046 Hot Leg 1 Sample Isolation Valve PSS-PL-V001A 2.3.13.08 (470)
ITAAC #470, part 12 tests the components in Table 2.3.13-2 Page 42 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Hot Leg 2 Sample Isolation Valve PSS-PL-V001B using controls in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
PSS Grab Sampling Unit PSS-MS-01 2.3.13.08 (470)
ITAAC #470, part 8 obtains samples of the reactor coolant and containment atmosphere from the Grab Sampling Unit; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the PSS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.15.
Demineralized Water Transfer and Storage System (DWS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.14-2 includes ITAAC No. 477 (ITAAC 2.3.14.01), the DWS functional arrangement ITAAC:
Table 2.3.14-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the DWS is as described in the Design Description of this Section 2.3.14.
Inspection of the as-built system will be performed.
The as-built DWS conforms with the functional arrangement as described in the Design Description of this Section 2.3.14.
The Design Description for DWS includes the following key attributes:
The DWS receives water from the demineralized water treatment system (DTS) and provides a reservoir of demineralized water to supply the condensate storage tank and for distribution throughout the plant. Demineralized water is processed in the DWS to remove dissolved oxygen.
In addition to supplying water for makeup of systems which require pure water, the demineralized water is used to sluice spent radioactive resins from the ion exchange Page 43 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) vessels in the chemical and volume control system (CVS), the spent fuel pool cooling system (SFS), and the liquid radwaste system (WLS) to the solid radwaste system (WSS).
The component location of the DWS are shown in Table 2.3.14-3. Note, the DWS has no simplified figure.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC, specifically the inspections performed for DWS, which demonstrate the required components exist and are sized to perform the intended function. See below for a list of the functional ITAAC associated with DWS components in Table 2.3.14-3 that demonstrate the design commitment of the DWS functional arrangement ITAAC (Index No. 477, ITAAC 2.3.14.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Condensate Storage Tank (CST)
DWS-MT-02 2.3.14.03 (479)
ITAAC #479 inspects the as-built CST to confirm the volume between the tank overflow and the startup feedwater supply connection is greater than or equal to 325,000 gallons; no additional information is verified by completion of the functional arrangement ITAAC.
Condensate Storage Tank Water Level DWS-006 2.3.14.04 (480)
ITAAC #480 inspects for the retrievability of displays identified in Table 2.3.14-1 in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Demineralized Water Supply Containment Isolation Valve - ORC DWS-PL-V244 2.2.01.07.1 (107)
ITAAC #107 is the Integrated Leak Rate Test that includes a test of the entire Containment Vessel Boundary; including the non-remotely operated containment isolation valves, such as those in DWS; no additional information is verified by completion of the functional arrangement ITAAC.
Demineralized Water Supply Containment Isolation Valve - IRC DWS-PL-V245 The DWS contains a number of components not listed in the above table that are outside the scope of ITAAC. The DWS has one safety-related function of containment isolation, which is verified via CNS system ITAAC. The remaining functions of the DWS are defense-in-depth or non-safety related. The arrangement of the DWS equipment necessary to perform the Page 44 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) defense-in-depth function, providing water from the CST to the FWS startup feedwater pumps, is verified via other ITAAC, as shown in the above table. The remaining DWS components in Table 2.3.14-3 are tested in the ITP as described in UFSAR Subsection 14.2.9.4.9, which provides verification that the as-installed system properly functions. The DWS does not have any features or functions credited for mitigation of design basis events, nor are there any features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the DWS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the defense-in-depth function is appropriately arranged, and the additional DWS equipment in Table 2.3.14-3 is tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.16.
Compressed and Instrumentation Air System (CAS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.15-2 includes ITAAC No. 481 (ITAAC 2.3.15.01), the CAS functional arrangement ITAAC:
Table 2.3.15-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the CAS is as described in the Design Description of this Section 2.3.15.
Inspection of the as-built system will be performed.
The as-built CAS conforms with the functional arrangement as described in the Design Description of this Section 2.3.15.
The Design Description for CAS includes the following key attributes:
The CAS consists of three subsystems: instrument air, service air, and high-pressure air. The instrument air subsystem supplies compressed air for air-operated valves and dampers. The service air subsystem supplies compressed air at outlets throughout the plant to power air-operated tools and is used as a motive force for air-powered pumps. The service air subsystem is also utilized as a supply source for breathing air. The high-pressure air subsystem supplies air to the main control room emergency habitability system (VES) and fire-fighting apparatus recharge station.
The component locations of the CAS are shown in Table 2.3.15-3. Note, the CAS has no simplified figure.
The DC for this ITAAC is partially demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with CAS components in Table 2.3.15-3 that demonstrate the design commitment of the CAS functional arrangement ITAAC (Index No. 481, ITAAC 2.3.15.01).
Page 45 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Instrument Air Pressure CAS-011 2.3.15.03 (483)
ITAAC #483 Inspects for the retrlevablllty of displays Identified In Table 2.3.15-1 In the MCR; no additional Information Is verified by completion of the functional arrangement ITAAC.
Instrument Air Supply Outside Containment Isolation Valve CAS-PL-V014 2.2.01.07.11 (108)
ITAAC #108 tests remotely operated containment Isolation valves to ensure they close within the required response times; no additional Information Is verified by completion of the functional arrangement ITAAC.
The location of the components described In Table 2.3.15-3 Is not addressed by other ITAAC. However, It Is still appropriate to remove the functional arrangement ITAAC for the CAS. The CAS has one safety-related function of containment Isolation, which Is verified via CMS system ITAAC. The CAS has no defense-In-depth functions. The CAS components In Table 2.3.15-3 are not required for any features or functions credited for mitigation of design basis events, nor are there any CAS features or functions that have been Identified as candidates for additional regulatory oversight per UFSAR Section 16.3. The CAS components are tested In the ITP, as described In UFSAR Subsection 14.2.9.4.10, which provides verification that the as-Installed system properly functions. Therefore, the functional arrangement ITAAC Is proposed to be removed.
2.17.
Radioactive Waste Drain System (WRS)
COL Appendix C (and plant-specific Tier 1) Table 2.3.29-1 Includes ITAAC No. 488 (ITAAC 2.3.29.01), the WRS functional arrangement ITAAC:
Page 46 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.3.29-1 inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the WRS is as described in the Design Description of this Section 2.3.29.
Inspection of the as-built system will be performed.
The as-built WRS conforms with the functional arrangement as described in the Design Description of this Section 2.3.29.
The Design Description for WRS includes the following key attributes:
The radioactive waste drain system (WRS) collects radioactive and potentially radioactive liquid wastes from equipment and floor drains during normal operation, startup, shutdown, and refueling. The liquid wastes are then transferred to appropriate processing and disposal systems.
The WRS is as shown in Figure 2.3.29-1. Note, the WRS has no table of component locations.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with WRS components in Figure 2.3.29-1 that demonstrate the design commitment of the WRS functional arrangement ITAAC (Index No. 488, ITAAC 2.3.29.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA WRS Aux Building Rad.
Drains Sump WRS-MT-01 2.3.29.02 (489)
ITAAC #489, parts 2 and 3 test the WRS and WLS system line up from the equipment and floor drains in the auxiliary and annex buildings and radwaste building to the sump and holdup tanks; no additional information is verified by completion of the functional arrangement ITAAC.
WLS Waste Holdup Tanks WLS-MT-06A/B WLS Chemical Waste Tank WLS-MT-11 Turbine Building Sump Discharge Radiation Monitor WWS-021 2.3.29.04 (491)
ITAAC #491 tests to confirm that the presence of a simulated high radiation signal from the turbine building sump discharge radiation monitor (WWS-021) causes the sump pumps (WWS-MP-01A/B &
Turbine Building Sump Pumps WWS-MP-01A/B
&07A/B Page 47 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA WWS-MP-07A/B) to stop; no additional information is verified by completion of the functional arrangement ITAAC.
WLS Cont. Sump WLS-MT-02 2.3.10.07a.ii (444)
ITAAC #444, part 7.a tests the WLS containment sump levels; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the WRS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and can be removed.
2.18.
Main and Startup Feedwater System (FWS)
COL Appendix C (and plant-specific Tier 1) Table 2.4.1-2 includes ITAAC No. 492 (ITAAC 2.4.01.01), the FWS functional arrangement ITAAC:
Table 2.4.1-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the startup feedwater system is as described in the Design Description of this Section 2.4.1.
Inspection of the as-built system will be performed.
The as-built startup feedwater system conforms with the functional arrangement as described in the Design Description of this Section 2.4.1.
The Design Description for the startup feedwater system includes the following key attributes:
The startup feedwater system supplies feedwater to the steam generators during plant startup, hot standby and shutdown conditions, and during transients in the event of main feedwater system unavailability.
Note; the startup feedwater system design description does not contain a table of components, nor does it refer to a simplified figure; although Figure 2.4.1-1 is included in Section 2.4.1 of the COL Appendix C.
Page 48 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with the startup feedwater system components in Figure 2.4.1-1 that demonstrate the design commitment of the startup feedwater system functional arrangement ITAAC (Index No. 492, ITAAC 2.4.01.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA CST DWS-MT-02 2.4.01.02 (493)
ITAAC #493, part 2 tests that each startup feedwater pump provides water from the CST to both steam generators. Parts 3 & 4 tests the components in Table 2.4.1-1, using controls in the MCR to perform the listed functions and displays are retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Startup Feedwater Pumps FWS-MP-03A/B Startup Feedwater Pump Isolation Valves FWS-PL-V013A/B As the functional arrangement of the FWS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.19.
Main Turbine System (MTS)
COL Appendix C (and plant-specific Tier 1) Table 2.4.2-1 includes ITAAC No. 496 (ITAAC 2.4.02.01), the MTS functional arrangement ITAAC:
Inspections, 1 Table 2.4.2-1 rests, Analyses, and Acceptance Criteria Design Commitment inspections. Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the MTS is as described in the Design Description of this Section 2.4.2.
Inspection of the as-built system will be performed.
The as-built MTS conforms with the functional arrangement as described in the Design Description of this Section 2.4.2.
The Design Description for MTS includes the following key attributes:
The MTS is designed for electric power production consistent with the capability of the reactor and the reactor coolant system.
The component locations of the MTS are shown in Table 2.4.2-2. Note, the MTS has no simplified figure.
Page 49 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC, specifically the main turbine electrical overspeed protection system testing. See below for a list of the functional ITAAC associated with MTS components in Table 2.4.2-2 that demonstrate the design commitment of the MTS functional arrangement ITAAC (Index No.
496, ITAAC 2.4.02.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA HP Turbine MTS-MG-01 LP Turbines MTS-MG-02A/B/C 2.4.02.02a (497)
Electrical Overspeed Trip Device N/A Emergency Electrical Overspeed Trip Device N/A 2.4.02.02b (498)
ITAAC #497, part 2.a) test controls in the MCR to trip the main turbine-generator, part 2.c) test that the main turbine-generator trips after receiving a signal from the DAS, part 3 test the two turbine electrical overspeed protection trip systems to trip the main turbine-generator after overspeed signals are received; ITAAC #498 tests that the main turbine-generator trips after receiving a signal from the PMS; no additional information is verified by completion of the functional arrangement ITAAC.
The MTS functional arrangement ITAAC contains three components from the Gland Seal System (GSS) not listed in the above table that are outside the scope of ITAAC. The MTS and GSS have no safety-related or defense-in-depth functions. The additional components not tested in ITAAC are tested in the ITP, as described in UFSAR Subsection 14.2.9.4.3, which provides verification that the as-installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any MTS or GSS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the MTS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform some non-safety-related, non-defense-in-depth functions are appropriately arranged, and the additional GSS components not tested by other IT/\\AC are tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
Page 50 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002) 2.20.
Condensate System (CDS)
COL Appendix C (and plant-specific Tier 1) Table 2.4.6-2 includes ITAAC No. 503 (ITAAC 2.4.06.01), the CDS functional arrangement ITAAC:
Table 2.4.6-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the CDS is as described in the Design Description of this Section 2.4.6.
Inspection of the as-built system will be performed.
The as-built CDS conforms with the functional arrangement as described in the Design Description of this Section 2.4.6.
The Design Description for CDS includes the following key attributes:
The CDS provides feedwater at the required temperature, pressure, and flow rate to the deaerator. Condensate is pumped from the main condenser hotwell by the condensate pumps and passes through the low-pressure feedwater heaters to the deaerator. The circulating water system (CWS) removes heat from the condenser and is site specific starting from the interface at the locations where the CWS piping enters and exits the turbine building.
The component locations of the CDS are shown in Table 2.4.6-3. Note, the CDS has no simplified figure.
The DC for this iTAAC is not demonstrated through the ITA and AC of other iTAAC, with the exception of ITAAC 2.4.06.02 (504) that performs an inspection of the Condenser Backpressures in the MCR as iisted in Table 2.4.6-1. However, it is stili appropriate to remove the functional arrangement ITAAC for the CDS. The CDS has no safety-related or defense-in-depth functions. The CDS components are not required for any features or functions credited for mitigation of design basis events, nor are there any CDS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3. The CDS components are tested in the iTP, as described in UFSAR Subsection 14.2.9.4.1, which provides verification that the as-installed system properly functions. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.21.
In-Core Instrumentation System (IIS)
COL Appendix C (and plant-specific Tier 1) Table 2.5.5-2 includes ITAAC No. 564 (ITAAC 2.5.05.01), the IIS functional arrangement ITAAC:
Page 51 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Table 2.5.5-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the IIS is as described in the Design Description of this Section 2.5.5.
Inspection of the as-built system will be performed.
The as-built IIS conforms with the functional arrangement as described in the Design Description of this Section 2.5.5.
The Design Description for IIS includes the following key attributes:
The IIS provides safety-related core exit thermocouple signals to the PMS.
The IIS provides nonsafety-related core exit thermocouple signals to the diverse actuation system (DAS).
The core exit thermocouples are housed in the core instrument assemblies. Multiple core instrument assemblies are used to provide radial coverage of the core. At least three core instrument assemblies are provided in each core quadrant.
Note, the IIS has no simplified figure nor table of component locations.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with IIS components that demonstrate the design commitment of the IIS functional arrangement ITAAC (Index No. 564, ITAAC 2.5.05.01).
Page 52 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Safety related incore Thimble Assemblies iiS-JY-01 thru 08, 10 thru 12, 14 thru 29, 31 thru 33, 35 thru 42 2.5.05.04 (572) 2.5.05.02.i (565) 2.5.05.03b (570)
ITAAC #572 includes testing of the retrievabiiity of the parameters in the MGR.
The displays identified in Table 2.5.5-1 can be retrieved in the MGR which includes verification of the number of assemblies in each core quadrant; no additional information is verified by completion of the functional arrangement ITAAG.
ITAAG #565, part 2 includes inspection of safety related as-built Incore Thimble Assemblies iocation and to verify anchorage is seismically bounded by the tested or anaiyzed conditions. Part3.a) includes inspections of safety reiated as built wiring, cables and terminations are bounded by equipment quaiification type tests and/or analyses.
ITAAG #570 is an inspection the as-buiit cables between the Incore Thermocouple elements and the connector boxes on the integrated head package to verify they have sheaths.
Non-safety reiated Incore Thimble Assemblies iiS-JY-09, 13, 30, and 34 2.5.05.02.
(565) iTAAG 565, part 2 includes inspection of non-safety related as built Incore Thimble Assemblies location and to verify Page 53 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA 2.5.05.03b (570) anchorage is seismically bounded by tested or analyzed conditions.
ITAAC #570 is an inspection the as-built cables between the Incore Thermocouple elements and the connector boxes on the integrated head package to verify they have sheaths.
As the functional arrangement of the IIS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and can be removed.
2.22.
Special Monitoring System (SMS)
COL Appendix C (and plant-specific Tier 1) Table 2.5.6-1 includes ITAAC No. 573 (ITAAC 2.5.06.01), the SMS functional arrangement ITAAC:
Inspections, 1 Table 2.5.6-1 rests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the SMS is as described in the Design Description of this Section 2.5.6.
Inspection of the as-built system will be performed.
The as-built SMS conforms with the functional arrangement as described in the Design Description of this Section 2.5.6.
The Design Description for SMS includes the following key attributes:
The SMS monitors the reactor coolant system (RCS) for the occurrence of impacts characteristic of metallic loose parts. Metal impact monitoring sensors are provided to monitor the RCS at the upper and lower head region of the reactor pressure vessel, and at the reactor coolant inlet region of each steam generator.
Note, the SMS has no simplified figure nor table of component locations.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with SMS components that demonstrate the design commitment of the SMS functional arrangement ITAAC (Index No. 573, ITAAC 2.5.06.01).
Page 54 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Metal Impact Monitoring Cabinet SMS-JD-MIM01 2.5.06.02 (574)
ITAAC #574 retrieves data from the metal impact monitoring sensors in the MCR, which requires these components; no additional information is verified by completion of the functional arrangement ITAAC.
Reactor Upper Head Accelerometers SMS-JE-YE001 through YE003 Reactor Lower Head Accelerometers SMS-JE-YE004 through YE006 RCP Accelerometers SMS-JE-YE007 through YE010 SG Accelerometers SMS-JE-YE011 through YE016 Reactor Upper Head Vibration Sensor Preamps SMS-JD-MIP01 through MIP03 Reactor Lower Head Vibration Sensor Preamps SMS-JD-MIP04 through MIP06 RCP Vibration Sensor Preamps SMS-JD-MIP07 through MIP10 SG Vibration Sensor Preamps SMS-JD-MIP11 through Ml PI 6 As the functional arrangement of the SMS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
2.23.
Seismic Monitoring System (SJS)
COL Appendix C (and plant-specific Tier 1) Table 2.5.9-1 includes ITAAC No. 575 (ITAAC 2.5.09.01), the SJS functional arrangement ITAAC:
Table 2.5.9-1 Inspections, Tests, Anaiyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the SJS is as described in the Design Description of this Section 2.5.9.
Inspection of the as-built system will be performed.
The as-built SJS conforms with the functional arrangement as described in the Design Description of this Section 2.5.9.
The Design Description for SJS includes the following key attributes:
Page 55 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The SJS provides for the collection of seismic data in digital format, analysis of seismic data, notification of the operator if the ground motion exceeds a threshold value, and notification of the operator (after analysis of data) that a predetermined cumulative absolute velocity (CAV) has been exceeded.
The SJS has at least four triaxial acceleration sensor units and a time-history analyzer and recording system. The time-history analyzer and recording system are located in the auxiliary building.
Note, the SJS has no simplified figure nor table of component locations.
The DC for this ITAAC is not demonstrated through the ITA and AC of other ITAAC.
However, it is still appropriate to remove the functional arrangement ITAAC for the SJS. The SJS has no safety-related or defense-in-depth functions. The SJS components are not required for any features or functions credited for mitigation of design basis events, nor are there any SJS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3. The SJS components are tested in the ITP, as described in UFSAR Subsection 14.2.9.4.15, which provides verification that the as-installed system properly functions. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.24.
Main ac Power System (ECS)
COL Appendix C (and plant-specific Tier 1) Table 2.6.1-4 includes ITAAC No. 578 (ITAAC 2.6.01.01), the ECS functional arrangement ITAAC:
Table 2,6.1-4 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the ECS is as described in the Design Description of this Section 2.6.1.
Inspection of the as-built system will be performed.
The as-built ECS conforms with the functional arrangement as described in the Design Description of this Section 2.6.1.
The Design Description for ECS includes the following key attributes:
The ECS provides electrical ac power to nonsafety-related loads and non-Class 1E power to the Class 1E battery chargers and regulating transformers during normal and off-normal conditions.
The ECS is as shown in Figure 2.6.1-1 and the component locations of the ECS are as shown in Table 2.6.1-5.
Page 56 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with ECS components in Figure 2.6.1-1 and Table 2.6.1-5 that demonstrate the design commitment of the ECS functional arrangement ITAAC (Index No. 578, ITAAC 2.6.01.01).
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA 6900V-480Y/277V Transformer for Load Center 12 ECS-ET-12 2.1.02.14 (66)
ITAAC #66 tests the ability to start and stop the pressurizer fieater groups from the MCR, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
Pressurizer Heaters Backup Group A MCC 124 ECS-EC-124 6900V-480Y/277V Transformer for Load Center 14 ECS-ET-14 Annex BIdg 480 VAC Load Center 14 ECS-EK-14 Pressurizer Heaters Control Group MCC 142 ECS-EC-142 Pressurizer Heaters Backup Group C MCC 143 ECS-EC-143 Pressurizer Heaters Backup Group B MCC 224 ECS-EC-224 Annex BIdg 480 VAC Load Center 24 ECS-EK-24 Pressurizer Heaters Backup Group D MCC 243 ECS-EC-243 Bus Duct, GCB to Main Step-up Transformer (MSU)
ZAS-EB-B01 2.1.02.09a (41)
ITAAC #41 tests Reactor Coolant System flow with all RCPs operating, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
Bus Duct, GCB to MSU Transformer 1A ZAS-EB-B01A Bus Duct, GCB to MSU Transformer IB ZAS-EB-B01B Bus Duct, GCB to MSU Transformer 1C ZAS-EB-B01C Main Step-up Transformer, A Phase ZAS-ET-1A Main Step-up Transformer, B Phase ZAS-ET-1B Main Step-up Transformer, C Phase ZAS-ET-1C Page 57 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Bus Duct, Unit Auxiliary Transformers ZAS-EB-B02 Bus Duct, Unit Auxiliary Transformer A ZAS-EB-B03A Bus Duct, Unit Auxiliary T
ransformer B ZAS-EB-B03B Unit Auxiliary Transformer A ZAS-ET-2A 2.1.02.09a (41) 2.3.01.03.ii (281)
ITAAC #41 tests Reactor Coolant System flow with all RCPs operating, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #281, part 3 tests CCS pumps A/B, CCS-MP-01A/B, from the MCR, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
Unit Auxiliary Transformer B ZAS-ET-2B Bus Duct, ECS-ES-5 Main Feed ZAS-EB-B2AX Bus Duct, ECS-ES-3 Main Feed ZAS-EB-B2AY Bus Duct, ECS-ES-6 Main Feed ZAS-EB-B2BX Bus Duct, ECS-ES-4 Main Feed ZAS-EB-B2BY 6900 V Switchgear Bus 3 ECS-ES-3 RCP 1A Circuit Breaker ECS-ES-31 RCP 1AVFD ECS-EV-31 RCP 1A Circuit Breaker ECS-ES-32 RCP 1A VFD Switchgear ECS-ES-33 6900 V Switchgear Bus 4 ECS-ES-4 RCP 1B Circuit Breaker ECS-ES-41 RCP 1BVFD ECS-EV-41 RCP 1B Circuit Breaker ECS-ES-42 RCP 1B VFD Switchgear ECS-ES-43 6900 V Switchgear Bus 5 ECS-ES-5 RCP 2A Circuit Breaker ECS-ES-51 RCP 2AVFD ECS-EV-51 RCP 2A Circuit Breaker ECS-ES-52 RCP 2A VFD Switchgear ECS-ES-53 6900 V Switchgear Bus 6 ECS-ES-6 RCP 2B Circuit Breaker ECS-ES-61 RCP 2B VFD ECS-EV-61 RCP 2B Circuit Breaker ECS-ES-62 RCP 2B VFD Switchgear ECS-ES-63 Ctmt480VAC MCC 132 ECS-EC-132 2.2.03.10 (206)
ITAAC #206, part 11.a.ii stroke tests Accumulator A/B Discharge Isolation Valves, PXS-PL-V027A/B, from the MCR, which requires a wiring path that involves Ctmt 480 VAC MCC 232 ECS-EC-232 Page 58 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA these components; no additional information is verified by completion of the functional arrangement ITAAC.
Reserve Auxiliary Transformer A ZAS-ET-4A 2.4.01.02 (493)
ITAAC #493 tests the FWS Pumps A/B, FWS-MP-03A/B, by starting the pumps from the MCR, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
Reserve Auxiliary Transformer B ZAS-ET-4B Bus Duct, ECS-ES-1 Reserve Feed ZAS-EB-B4AX Bus Duct, ECS-ES-5 Reserve Feed ZAS-EB-B4AX Bus Duct, ECS-ES-3 Reserve Feed ZAS-EB-B4AY Bus Duct, ECS-ES-2 Reserve Feed ZAS-EB-B4BX Bus Duct, ECS-ES-4 Reserve Feed ZAS-EB-B4BY 6900 V Switchgear Bus 1 ECS-ES-1 6900 V Switchgear Bus 2 ECS-ES-2 Annex BIdg 480 VAC Load Center 12 ECS-EK-12 2.4.01.02 (493)
ITAAC #493, part 3 tests the FWS Pump Isolation Valve, FWS-PL-V013A, from the MCR, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
TB 480 VAC MCC 122 ECS-EC-122 6900V-480Y/277V Transformer for Load Center 22 ECS-ET-22 Annex BIdg 480 VAC Load Center 22 ECS-EK-22 TB 480 VAC MCC 222 ECS-EC-222 Main Turbine Generator 2AS-MG-01 2.4.02.02a (497)
ITAAC #497, part 2.a trips the main turbine generator; no additional information is verified by completion of the functional arrangement ITAAC.
Ancillary Diesel Generator #1 ECS-MG-01 2.6.01.04d (587)
ITAAC #587 performs load testing of the ancillary diesel generators; no additional information is verified by completion of the functional arrangement ITAAC.
Ancillary Diesel Generator #2 ECS-MG-02 Page 59 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Annex BIdg 480 VAC MOO 211 ECS-EC-211 2.6.01.04e (588)
ITAAC #588, part 4.a verifies an electrical patfi from tfie ES2 bus to the battery room exhaust fan, VXS-MA-09B, which Includes the wiring path for this component; no additional Information Is verified by completion of the functional arrangement ITAAC.
Aux BIdg 480 VAC MCC 121 ECS-EC-121 2.6.03.04c (603)
ITAAC #603, part 5.a performs load testing of the IDS 24-hour battery charger, IDSC-DC-1, which Includes a wiring path that Involves these components; no additional Information Is verified by completion of the functional arrangement ITAAC.
Aux BIdg 480 VAC MCC 221 ECS-EC-221 Ancillary Diesel Generator Distribution Panel 1 ECS-ED-01 2.6.03.05d.l (613)
ITAAC #613 Inspects the connections for the two ancillary diesel generators, which Includes the wiring path for these components; no additional Information Is verified by completion of the functional arrangement ITAAC.
Ancillary Diesel Generator Distribution Panel 2 ECS-ED-02 PCS Reclrculatlon Pump A
PCS-MP-01A 2.2.02.07b.l (138)
ITAAC #138 tests each PCS reclrculatlon pump which verifies a wiring path exists for these components; no additional Information Is verified by completion of the functional arrangement ITAAC.
PCS Reclrculatlon Pump B
PCS-MP-01B 6900V-480Y/277V Transformer for Load Center 11 ECS-ET-11 2.7.02.03a (703)
ITAAC #703, part 4 tests the components In Table 2.7.2-1 from the MCR, which requires a wiring path that Involves these components; no additional Information Is verified by completion of the Annex BIdg 480 VAC Load Center 11 ECS-EK-11 Aux BIdg 480 VAC MCC 112 ECS-EC-112 Page 60 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA 6900V-480Y/277V Transformer for Load Center 13 ECS-ET-13 functional arrangement ITAAC.
Annex BIdg 480 VAC Load Center 13 ECS-EK-13 Aux BIdg 480 VAC MCC 133 ECS-EC-133 6900V-480Y/277V Transformer for Load Center 21 ECS-ET-21 Annex BIdg 480 VAC Load Center 21 ECS-EK-21 Annex BIdg 480 VAC MCC 212 ECS-EC-212 6900V-480Y/277V Transformer for Load Center 23 ECS-ET-23 Annex BIdg 480 VAC Load Center 23 ECS-EK-23 Aux BIdg 480 VAC MCC 233 ECS-EC-233 6900V-480Y/277V Transformer for Load Center 24 ECS-ET-24 Annex BIdg 480 VAC MCC 111 ECS-EC-111 2.7.03.03 (710)
ITAAC #710, part 3 tests the switchgear room AMD fan, VXS-MA-02A, from the MCR, which requires a wiring path that involves this component: no additional information is verified by completion of the functional arrangement ITAAC.
DG BIdg 480 VAC MCC 123 ECS-EC-123 2.7.04.03 (716)
ITAAC #716, part 3 tests the DG oil transfer module enclosure exhaust fans, VZS-MY-V03A/B, from the MCR, which requires a wiring path that involves this component; no additional information is verified by completion of the functional arrangement ITAAC.
DG BIdg 480 VAC MCC 223 ECS-EC-223 Annex BIdg 480 VAC MCC 141 ECS-EC-141 2.7.05.02.1 (719)
ITAAC #719, part 2.ii tests supply fans VAS-MA-01A/B Page 61 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Annex BIdg 480 VAC MCC 241 ECS-EC-241 and -05A/B, which requires a wiring path that involves this component: no additional information is verified by completion of the functional arrangement ITAAC.
Annex BIdg 480 VAC MCC 131 ECS-EC-131 2.7.06.03.i, Item 4 (726)
ITAAC #726, part 4 tests the containment exhaust fans, VFS-MA-02A/B, from the MCR, which requires a wiring path that involves these components; no additional information is verified by completion of the functional arrangement ITAAC.
Annex BIdg 480 VAC MCC 231 ECS-EC-231 RCP Circuit Breakers ECS-ES-31,32, 41, 42, 51,52, 61,62 2.6.01.02.1 (579) 2.6.01.03a (582)
ITAAC #579 verifies the location of equipment in Table 2.6.1-1 is on the nuclear island and the as built equipment and anchorage is bounded by the tested or analyzed condition.
ITAAC #582 performs tests to verify the RCP class 1E breaker control is powered from their respective class 1E division The ECS contains components not listed in the above table that are outside the scope of ITAAC. The ECS safety-related and defense-in-depth functions do not rely on these components. These components are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.15, which provides verification that the as-installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any ECS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the ECS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related and defense-in-depth functions are appropriately arranged, and the additional ECS components not tested by other ITAAC are tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
Page 62 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.25.
Onsite Standby Power System (ZDS)
COL Appendix 0 (and plant-specific Tier 1) Table 2.6.4-1 includes ITAAC No. 621 (ITAAC 2.6.04.01), the ZOS functional arrangement ITAAC:
Table 2.6.4-1 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the ZOS is as described in the Design Description of this Section 2.6.4.
Inspection of the as-built system will be performed.
The as-built ZOS conforms with the functional arrangement as described in the Design Description of this Section 2.6.4 The Design Description for ZOS includes the following key attributes:
The ZOS provides backup ac electrical power for non-safety related loads during normal and off-normal conditions.
The ZOS has two standby diesel generator units and the component locations of the ZOS are as shown in Table 2.6.4-2.
The centerline of the diesel engine exhaust gas discharge is iocated more than twenty (20) feet higher than that of the combustion air intake.
The DC for this iTAAC is demonstrated through the iTA and AC of other ITAAC, specifically the integrated system testing ITAAC. Functional testing demonstrates that the required components exist and that they are connected in a manner needed to perform the intended function. See below for a list of the iTAAC that demonstrate the design commitment of the ZOS functionai arrangement ITAAC (Index No. 621, ITAAC 2.6.04.01)
Component Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Onsite Diesel Generator A Package ZOS-MS-05A 2.6.04.02a (622)
ITAAC #622 parts 2.a) and 2.b) test the as-built system to confirm the diesei generator functions as designed, including that it reaches and maintains designed voitage and frequency. The location and function of the diesel generator is verified through this ITAAC; no additional information is verified by compietion of the functionai arrangement iTAAC.
Onsite Diesei Generator B Package ZOS-MS-05B Page 63 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The height differential between the centerline of the diesel engine exhaust gas discharge and the combustion air intake is an attribute of the design description that is not covered by another ITAAC. It is still appropriate to remove the functional arrangement ITAAC for ZOS because this specific detail does not meet the threshold for design information necessary to show via ITAAC closure per UFSAR Section 14.3.2.1. The functional testing ITAAC referenced above will demonstrate that the diesel generators run as required and perform their defense-in-depth functions, and the height differential of 20 feet is an equipment reliability design feature and is not required to verify the function of the components.
Therefore, the functional arrangement ITAAC is proposed to be removed.
2.26.
Nuclear Island Nonradloactive Ventilation System (VBS)
COL Appendix C (and plant-specific Tier 1) Table 2.7.1-4 includes ITAAC No. 677 (ITAAC 2.7.01.01), the VBS functional arrangement ITAAC:
Table 2.7.1-4 inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VBS is as described in the Design Description of this Section 2.7.1.
Inspection of the as-built system will be performed.
The as-built VBS conforms with the functional arrangement as described in the Design Description of this Section 2.7.1.
The Design Description for VBS includes the following key attributes:
The VBS serves the MCR, control support area (CSA), Class 1E do equipment rooms.
Class 1E l&C rooms. Class 1E electrical penetration rooms. Class 1E battery rooms, remote shutdown room (RSR), reactor coolant pump trip switchgear rooms, adjacent corridors, and passive containment cooling system (PCS) valve room during normal plant operation.
The VBS consists of the following independent subsystems: the main control room/control support area HVAC subsystem, the class IE electrical room HVAC subsystem, and the passive containment cooling system valve room heating and ventilation subsystem.
The VBS provides heating, ventilation, and cooling to the areas served when ac power is available.
The system provides breathable air to the control room and maintains the main control room and control support area areas at a slightly positive pressure with respect to the adjacent rooms and outside environment during normal operations.
Page 64 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The VBS monitors the MCR supply air for radioactive parllculate and Iodine concentrations and provides filtration of main control room/control support area air during conditions of abnormal "Hlgh-1" airborne radioactivity.
The VBS Is as shown In Figure 2.7.1-1 Sheets 1 and 2 and the component locations of the VBS are as shown In Table 2.7.1-5.
The DC for this ITAAC Is largely demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with VBS components In Figure 2.7.1-1 and Table 2.7.1-5 that demonstrate the design commitment of the VBS functional arrangement ITAAC (Index No. 677, ITAAC 2.7.01.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Supplemental Air Filtration Units VBS-MS-01A/B 2.7.01.14 (700)
ITAAC #700, part S.d tests the components In Table 2.7.1-3, part 12 tests these components using controls In the MCR, and part 13 Inspects to confirm that the parameters In Table 2.7.1-3 can be retrieved In the MCR; no additional Information Is verified by completion of the functional arrangement ITAAC.
MCR/CSA Supply Air Handling Units (AHUs)
VBS-MS-02A/B Division "A" and "C" Class 1E Electrical Room AHUs VBS-MS-03A/C Division "B" and "D" Class 1E Electrical Room AHU B VBS-MS-03B/D Division "A&C" Class 1E Battery Room Exhaust Fans VBS-MA-07A/C Division "B&D" Class 1E Battery Room Exhaust Fan VBS-MA-07B/D MCR Ancillary Fans VBS-MA-10A/B Division B Ancillary Fan VBS-MA-11 Division C Ancillary Fan VBS-MA-12 Main Control Room and Remote Shutdown Room Rooms 12401 and 12303 2.7.01.14 (700)
ITAAC #700, part 14 tests the as-bullt VBS during operation to ensure the background noise level In the MCR and RSR does not exceed 65 dB(A); no additional Information Is verified by completion of the functional arrangement ITAAC.
Page 65 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA MCR Toilet Exhaust Fan VBS-MA-04 CSA Toilet Exhaust Fan VBS-MA-09 2.2.05.07a.i (265)
ITAAC #265, part 7.b.i performs testing of the VES.
The toilet exhaust fans are isolated and verified as part of this test; no additional information is verified by completion of the functional arrangement ITAAC.
MCR Supply Air Isoiation Vaives VBS-PL-V186A/187 MCR Return Air Isolation Valves 2.7.01.06a (687)
VBS-PL-V188A/189 ITAAC #687 tests the Class 1E components identified in Table 2.7.7-1 by providing a Page 66 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA MGR Exhaust Air Isolation Valves VBS-PL-V190A/191 2.7.01.02.a (678) 2.7.01.05.1 (684) 2.7.01.14 (700) simulated test signal in each Class 1E division.
ITAAC #678, part 2.a) inspects the as-built components identified in Table 2.7.1-1 is included in the ASME Code Section III design reports.
ITAAC #684, part 5.1 verifies the seismic Category I equipment identified in Table 2.7.1-1 is installed in the correct location; no additional information is verified by completion of the functional arrangement ITAAC.
ITAAC #700, part 9 inspects that the safety-related displays in Table 2.7.7-1 can be retrieved in the MCR, part 10 a.) performs stroke testing of the remotely operated valves in the table from the MCR, part 10 b.)
performs testing of the remotely operated valves in the table using real or simulated signals into the PMS, and part 11 tests the remotely operated valve to assume the indicated loss of motive power position; no additional information is verified by completion of the functional arrangement ITAAC.
MCR SDS (Vent) Isolation Valves SDS-PL-V001 A/002 2.7.01.06a (687)
ITAAC #687 tests the Class 1E components identified in Table 2.7.7-1 by providing a Page 67 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA 2.7.01.14 (700) simulated test signal in each Class 1E division.
ITAAC #700, part 9 inspects that the safety-related displays in Table 2.7.7-1 can be retrieved in the MCR, part 10 a.) performs stroke testing of the remotely operated valves in the fable from the MCR, part 10 b.)
performs testing of the remotely operated valves in the table using real or simulated signals into the PMS, and part 11 tests the remotely operated valve to assume the indicated loss of motive power position; no additional information is verified by completion of the functional arrangement ITAAC.
PWS MCR Isolation Valves PWS-PL-V418A/420 2.7.01.02.a (678)
PWS MCR Vacuum Relief PWS-PL-V498 MCR SDS (Vent) isolation Valves SDS-PL-V001 A/002 MCR WWS Isolation Valve WWS-PL-V506 2.7.01.05.1 (684)
ITAAC #678, part 2.a) inspects the as-built components identified in Table 2.7.1-1 is included in the ASME Code Section Mi design reports.
iT/WC #684, part 5.i verifies the seismic Category I equipment identified in Table 2.7.1-1 is installed in the correct location; no
\\additional information is verified by completion of the functional arrangement ITAAC.
The VBS contains one component not listed in the above table that is outside the scope of ITAAC: the PCS valve room vent fan. The VBS safety-related and defense-in-depth functions do not rely on this component. This component is tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.10, which provides verification that the as-installed Page 68 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) system properly functions. This component is not required for any features or functions credited for mitigation of design basis events, nor are there any VBS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the VBS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related and defense-in-depth functions are appropriately arranged, and the additional VBS component not tested by other ITAAC is tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.27.
Central Chilled Water System (VWS)
COL Appendix C (and plant-specific Tier 1) Table 2.7.2-2 includes ITAAC No. 701 (ITAAC 2.7.02.01), the VWS functional arrangement ITAAC:
Table 2.7.2-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VWS is as described in the Design Description of this Section 2.7.2.
Inspection of the as-built system will be performed.
The as-built VWS conforms with the functional arrangement as described in the Design Description of this Section 2.7.2.
The Design Description for VWS includes the following key attributes:
The plant heating, ventilation, and air conditioning (HVAC) systems require chilled water as a cooling medium to satisfy the ambient air temperature requirements for the plant. The VWS supplies chilled water to the HVAC systems and is functional during reactor full-power and shutdown operation.
The VWS also provides chilled water to selected process systems.
The VWS is as shown in Figure 2.7.2-1 and the component locations of the VWS are as shown in Table 2.7.2-3.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC.
See below for a list of the functional ITAAC associated with VWS components in Figure 2.7.2-1 and Table 2.7.2-3 that demonstrate the design commitment of the VWS functional arrangement ITAAC (Index No. 701, ITAAC 2.7.02.01).
Page 69 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functionai ITAAC Coverage of FA Air Cooled Chillers VWS
-MS-02/03 2.7.02.03.a (703)
ITAAC #703, part 3.a tests the flow rates to the chilled water cooling coiis, which involves all components listed, part 4 performs tests to operate the components in Table 2.7.2-1 from the MCR, and part 5 confirms that the displays identified in the Table can be retrieved in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Air Cooled Chiller Pumps VWS-MP-02/03 Air Cooled Chiller Water Valves VWS -PL-V21 OA/253 MCR/CSA Supply AHU VBS-MY-C01A/B Class 1E Electrical Equipment Room AHUs VBS-MY-C02/VB/C/D CVS Pump Room Unit Coolers VAS-MY-C07/VB CVS Pump Room Unit Cooler Fans VAS-MA-07A/B RMS Pump Room Unit Coolers VAS-MY-C06/VC06B/C12A/C12B RNS Pump Room Unit Cooler Fans VAS-MA-08A/B Fan Coolers Return Containment Isolation Valve -
IRC VWS-PL-V082 2.2.01.07.ii (108)
ITAAC #108 tests remotely operated containment isolation valves to ensure they close within the required response times; no additional information is verified by completion of the functional arrangement IT/\\AC.
Fan Coolers Return Containment Isolation Valve -
ORC VWS-PL-V086 Fan Coolers Supply Containment Isolation Valve -
ORC VWS-PL-V058 The VWS contains components not listed in the above table that are outside the scope of ITAAC: two water chillers and their associated pumps. The VWS safety-related and defense-in-depth functions do not rely on these components. These components are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.9, which provides verification that the as-instailed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any VWS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functionai arrangement ITAAC for the VWS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related and defense-in-depth functions are appropriately arranged, and the additional four VWS components not tested by other ITAAC are tested in the ITP.
Therefore, the functional arrangement ITAAC is proposed to be removed.
Page 70 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.28.
Annex / Auxiliary Buildings Nonradioactive Ventilation System (VXS)
COL Appendix C (and plant-specific Tier 1) Table 2.7.3-2 includes ITAAC No. 707 (ITAAC 2.7.03.01), tfie VXS functional arrangement ITAAC:
Table 2.7.3-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VXS is as described in the Design Description of this Section 2.7.3.
Inspection of the as-built system will be performed.
The as-built VXS conforms with the functional arrangement described in the Design Description of this Section 2.7.3.
The Design Description for VXS includes the following key attributes:
The VXS serves the nonradioactive personnel and equipment areas, electrical equipment rooms, clean corridors, the ancillary diesel generator room and demineralized water deoxygenating room in the annex building, and the main steam isolation valve compartments, reactor trip switchgear rooms, and piping and electrical penetration areas in the auxiliary building.
The VXS consists of the following independent subsystems: the general area HVAC subsystem, the switchgear room HVAC subsystem, the equipment room HVAC subsystem, the MSIV compartment HVAC subsystem, the mechanical equipment area HVAC subsystem and the valve/piping penetration room HVAC subsystem.
The VXS is as shown in Figure 2.7.3-1 and the component locations of the VXS are as shown in Table 2.7.3-3.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the testing and inspections performed for VXS, which include functional testing that demonstrates the required components exist and that they are connected in a manner needed to perform the intended function. See below for a list of the functional ITAAC associated with VXS components in Table 2.7.3-3 that demonstrate the design commitment of the VXS functional arrangement ITAAC (Index No. 707, ITAAC 2.7.03.01).
Page 71 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Annex Building Equipment Room AHUs VXS-MS-02A/B 2.7.03.03 (710)
ITAAC #710, part 3 tests these AHUs using controls in the MCR.
The location and function of the AHUs are verified through this ITAAC, and part 4 inspects for the retrievability of the AHU parameters in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Switchgear Room AHUs VXS-MS-05A/B The VXS contains a number of components not listed in the above table that are outside the scope of ITAAC. The VXS does not have any safety-related functions, and the only defense-in-depth function is to maintain the design temperatures of the diesel bus switchgear rooms and battery charger rooms, to support operation of the ZOS. The necessary equipment to achieve this defense-in-depth function are the annex building equipment room AHUs and switchgear room AHUs, which are tested in ITAAC #710. The remaining VXS components in Figure 2.7.3-1 and Table 2.7.3-3 are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.21, which provides verification that the as-installed system properly functions. The VXS does not have any features or functions credited for mitigation of design basis events, nor are there any features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the VXS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the defense-in-depth functions are appropriately arranged, and the additional VXS equipment in Figure 2.7.3-1 and Table 2.7.3-3 are tested in the ITP. Therefore, the functional arrangement ITAAC is proposed to be removed.
2.29.
Diesel Generator Building Ventilation System (VZS)
COL Appendix C (and plant-specific Tier 1) Table 2.7.4-2 includes ITAAC No. 712 (ITAAC 2.7.04.01), the VZS functional arrangement ITAAC:
Inspections, 1 Table 2.7.4-2 rests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VZS is as described in the Design Description of this Section 2.7.4.
Inspection of the as-built system will be performed.
The as-built VZS conforms with the functional arrangement as described in the Design Description of this Section 2.7.4.
Page 72 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The Design Description for VZS includes the following key attributes:
The VZS provides ventilation cooling of the diesel generator building for the onsite standby power system. The VZS also provides heating and ventilation within the diesel oil transfer module enclosure. The VZS consists of the following subsystems: the normal diesel building heating and ventilation subsystem, the standby diesel building exhaust ventilation subsystem, the fuel oil day tank vault exhaust subsystem and the diesel oil transfer module enclosures ventilation and heating subsystem.
The VZS is as shown in Figure 2.7.4-1 Sheets 1 and 2 and the component locations of the VZS are as shown in Table 2.7.4-3.
The DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with VZS components in Figure 2.7.4-1 and Table 2.7.4-3 that demonstrate the design commitment of the VZS functional arrangement ITAAC (Index No. 712, ITAAC 2.7.04.01).
Equipment Name Tag No.
Functional ITAAC Number (index Number)
Logic for Functional ITAAC Coverage of FA Service Module AHUs VZS-MS-01A/B 2.7.04.03 (716)
ITAAC #716, part 3 tests these components using controls in the MCR, and part 4 inspects for the retrievability of the exhaust fan parameters in the MCR; no additional information is verified by completion of the functional arrangement ITAAC.
Diesel Oil Transfer Module Enclosure Exhaust Fans VZS-MY-V03A/B Diesel Oil Transfer Module Enclosure Unit Heaters VZS-MY-U03A/B D/G Building Standby Exhaust Fans VZS-MY-V01AA/01BA/02A/
V02B The VZS contains components not listed in the above table that are outside the scope of ITAAC: the fuel oil day tank vault exhaust fans. The VZS has no safety-related functions, and the VZS defense-in-depth functions do not rely on these components. These components are tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.17, which provides verification that the as-installed system properly functions. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any VZS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.
It is appropriate to remove the functional arrangement ITAAC for the VZS because the functional testing ITAAC referenced above will demonstrate that the equipment necessary to perform the safety-related and defense-in-depth functions are appropriately arranged, and the additional two VZS components not tested by other ITAAC are tested in the ITP.
Therefore, the functional arrangement ITAAC is proposed to be removed.
Page 73 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.30.
Radiologically Controlled Area Ventilation System (VAS)
COL Appendix 0 (and plant-specific Tier 1) Table 2.7.5-2 includes ITAAC No. 718 (ITAAC 2.7.05.01), the VAS functional arrangement ITAAC:
Table 2.7.5-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VAS is as described in the Design Description of this Section 2.7.5.
Inspection of the as-built system will be performed.
The as-built VAS conforms with the functional arrangement as described in the Design Description of this Section 2.7.5.
The Design Description for VAS includes the following key attributes:
The VAS serves the fuel handling area of the auxiliary building, and the radiologically controlled portions of the auxiliary and annex buildings.
The VAS consists of two subsystems: the auxiliary/annex building ventilation subsystem and the fuel handling area ventilation subsystem.
The component locations of the VAS are as shown in Table 2.7.5-3. Note, the VAS has no simplified figure.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC, specifically the testing and inspections performed for VAS, which include functional testing that demonstrates the required components exist and that they are connected in a manner needed to perform the intended function. See below for a list of the functional ITAAC associated with VAS components in Table 2.7.5-3 that demonstrate the design commitment of the VAS functional arrangement ITAAC (Index No. 718, ITAAC 2.7.05.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Auxiliary/Annex Building Supply Air Handling Unit (AHU)s VAS-MS-01A/B 2.7.05.02.i (719)
ITAAC #719, part 2.1) performs a test that confirms the VAS maintains each building at a slightly negative pressure when operating all VAS supply AH Us and all VAS exhaust fans, part 2.ii) performs a test that confirms the ventilation flow rate through the Fuel Handling Area Supply AH Us VAS-MS-02A/B Auxiliary/Annex Building Exhaust Fans VAS-MA-02A/B Page 74 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA auxiliary building fuel handling area Is
>10,710 cfm when operating all VAS supply AHUs and all VAS exhaust fans, part 2.
Ill) performs a test that confirms the ventilation flow rate through the auxiliary building radlologlcally controlled area Is S22,500 cfm when operating all VAS supply AHUs and all VAS exhaust fans.
The location and function of the supply AHUs and exhaust fans are verified through this ITAAC; no additional Information Is verified by completion of the functional arrangement ITAAC.
Annex Building Pressure Differential Indicator VAS-032 2.7.05.021 (719)
ITAAC #719, part 3 performs an Inspection to confirm that the displays Identified In Table 2.7.5-1 can be retrieved In the MCR; no additional Information Is verified by completion of the functional arrangement ITAAC.
Auxiliary Building Pressure Differential Indicator VAS-033 Fuel Handling Area Pressure Differential Indicator VAS-030 Auxiliary Building Pressure Differential Indicator VAS-034 CVS Pump Room Unit Coolers VAS-MS-05A/B 2.7.02.03a (703)
ITAAC #703 Includes a test that measures the chilled water supplied to the CVS and RNS pumps Unit Coolers. The location and function of the CVS and RNS Unit Coolers are verified through this ITAAC; no additional Information Is verified by completion of the functional arrangement ITAAC.
RNS Pump Room Unit Coolers VAS-MS-06A/B Fuel Handling Area Exhaust Fans VAS-MA-06A/B As the functional arrangement of the VAS Is verified by other ITAAC, the functional arrangement ITAAC Itself does not provide any additional Information and Is proposed to be removed.
Page 75 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.31.
Containment Air Filtration System (VPS)
COL Appendix 0 (and plant-specific Tier 1) Table 2.7.6-2 includes ITAAC No. 723 (ITAAC 2.7.06.01), the VPS functional arrangement ITAAC:
Inspections, 1 Table 2.7.6-2 rests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VPS is as described in the Design Description of this Section 2.7.6.
Inspection of the as-built system will be performed.
The as-built VPS conforms with the functional arrangement as described in the Design Description of this Section 2.7.6.
The Design Description for VPS includes the following key attributes:
The VPS provides intermittent flow of outdoor air to purge and filter the containment atmosphere of airborne radioactivity during normal plant operation, and continuous flow during hot or cold plant shutdown conditions to reduce airborne radioactivity levels for personnel access.
The VPS is as shown in Figure 2.7.6-1 and the component locations of the VPS are as shown in Table 2.7.6-3.
The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with VPS components in Figure 2.7.6-1 and Table 2.7.6-3 that demonstrate the design commitment of the VPS functional arrangement ITAAC (Index No. 723, ITAAC 2.7.06.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Containment Vacuum Relief Isolation Motor-Operated Valves VPS-PL-V800A/B 2.2.01.07.11 (108)
ITAAC #108 tests remotely operated containment isolation valves to ensure they close within the required response times, specifically within 10 seconds for the containment purge isolation valves and within 30 seconds for the containment vacuum relief isolations: no additional information is verified by completion of the functional arrangement ITAAC.
Containment Purge Isolation Valves VPS-PL-V003, V004, V009 &
V010 Page 76 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Containment Vacuum Relief Isolation Motor-Operated Valves VFS-PL -
V800A/B 2.7.06.02.11 (725)
\\
IT/V\\C #725 performs tests to demonstrate that the remotely operated containment vacuum relief Isolation valves open within 30 seconds: no additional Information Is verified by completion of the functional arrangement ITAAC.
Containment Air Filtration Supply AHUs VFS-MS-01A/B 2.7.06.03.1 (726)
ITAAC #726, parts 3.1) and 3.11) test the flow rate of the AHUs when operated with their respective exhaust units; no additional Information Is verified by completion of the functional arrangement ITAAC.
Containment Air Filtration Exhaust Units VFS-MS-02A/B Containment Purge Discharge Line VFS-L204 2.7.06.03.1 (726)
IT/\\AC #726, part 3.III) performs an Inspection of the containment purge discharge line penetrating the containment to ensure the nominal line size Is > 36 In.; no additional Information Is verified by completion of the functional arrangement ITAAC.
Containment Air Handling Unit (AMU)
Supply Fans A/B VFS-MA-01A/B 2.7.06.03.1 (726)
ITAAC #726, part 4 performs testing on the components In Table 2.7.6-1 using MCR Controls, part 5 performs an Inspection to confirm the retrlevablllty of the displays In the Table In the MCR; no additional Information Is verified by completion of the functional arrangement IT/\\AC.
Containment AMU Supply Fan Flow Sensors VFS-012A/B Containment Exhaust Fans A/B VFS-MA-02A/B Containment Exhaust Fan Flow Sensors VFS-011A/B As the functional arrangement of the VPS Is verified by other ITAAC, the functional arrangement ITAAC Itself does not provide any additional Information and Is proposed to be removed.
Page 77 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 2.32.
Containment Recirculatlon Cooling System (VCS)
COL Appendix 0 (and plant-specific Tier 1) Table 2.7.7-2 includes ITAAC No. 731 (ITAAC 2.7.07.01), the VCS functional arrangement ITAAC:
Table 2.7.7-2 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria
- 1. The functional arrangement of the VCS is as described in the Design Description of this Section 2.7.7.
Inspection of the as-built system will be performed.
The as-built VCS conforms with the functional arrangement as described in the Design Description of this Section 2.7.7.
The Design Description for VCS includes the following key attributes:
The containment recirculatlon cooling system (VCS) controls the containment air temperature and humidity during normal operation, refueling and shutdown.
The locations of the VCS are as shown in Table 2.7.7-3.
simplified figure.
Note, the VCS has no The DC for this ITAAC is demonstrated through the ITA and AC of other ITAAC. See below for a list of the functional ITAAC associated with VCS components in Table 2.7.7-3. that demonstrate the design commitment of the VCS functional arrangement ITAAC (Index No.
731, ITAAC 2.7.07.01).
Equipment Name Tag No.
Functional ITAAC Number (Index Number)
Logic for Functional ITAAC Coverage of FA Reactor Containment Recirculation Fan Coil Unit Assemblies VCS-MS-01A/B/C/D 2.7.07.02 (732)
ITAAC #732 inspects for the retrievability of displays in the MCR of parameters identified in Table 2.7.7-1; no additional information is verified by completion of the functional arrangement ITAAC.
As the functional arrangement of the VCS is verified by other ITAAC, the functional arrangement ITAAC itself does not provide any additional information and is proposed to be removed.
Page 78 of 85
ND-19-0764 Request for License Amendment; Functional Arrangement ITAAC Optimization (LAR-19-002)
Licensino Basis Chance PescrlDtions The following functional arrangement ITAAC are proposed to be removed from the associated ITAAC table:
Fuel Handling and Refueling System (FHS) -
ITAAC 2.1.01.01, Index No. 1 Component Cooling Water System (CCS) -
ITAAC 2.3.01.01, Index No. 278 Chemical and Volume Control System (CVS) -
ITAAC 2.3.02.01, Index No. 284 Standby Diesel Fuel ON System (DOS) -
ITAAC 2.3.03.01, Index No. 318 Fire Protection System (FPS) -
ITAAC 2.3.04.01, Index No. 326 Mechanical Handling System (MHS) -
ITAAC 2.3.05.01, Index No. 339 Normal Residual Heat Removal System (RNS) -
ITAAC 2.3.06.01, Index No. 354 Spent Fuel Pool Cooling System (SFS) -
ITAAC 2.3.07.01, Index No. 391 Service Water System (SWS) -
ITAAC 2.3.08.01, Index No. 414 Containment Hydrogen Control System (VLS) -
ITAAC 2.3.09.01, Index No. 420 Liquid Radwaste System (WLS) -
ITAAC 2.3.10.01, Index No. 430 Gaseous Radwaste System (WGS) -
ITAAC 2.3.11.01, Index No. 449 Solid Radwaste System (WSS) -
ITAAC 2.3.12.01, Index No. 456 Primary Sampling System (PSS) -
ITAAC 2.3.13.01, Index No. 458 Demlnerallzed Water Transfer and Storage System (DWS) -
ITAAC 2.3.14.01, Index No. 477 Compressed and Instrumentation Air System (CAS) -
ITAAC 2.3.15.01, Index No.
481 Radioactive Waste Drain System (WRS) -
ITAAC 2.3.29.01, Index No. 488 Main and Startup Feedwater System (FWS) -
ITAAC 2.4.01.01, Index No. 492 Main Turbine System (MTS) -
ITAAC 2.4.02.01, Index No. 496 Condensate System (CDS) -
ITAAC 2.4.06.01, Index No. 503 In-Core Instrumentation System (IIS) -
ITAAC 2.5.05.01, Index No. 564 Special Monitoring System (SMS) -
ITAAC 2.5.06.01, Index No. 573 Page 79 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Seismic Monitoring System (SJS) -
ITAAC 2.5.09.01, Index No. 575 Main ac Power System (ECS) -
ITAAC 2.6.01.01, Index No. 578 Onsite Standby Power System (ZDS) -
ITAAC 2.6.04.01, Index No. 621 Nuclear Island Nonradioactive Ventilation System (VBS) -
ITAAC 2.7.01.01, Index No. 677 Central Chilled Water System (VWS) -
ITAAC 2.7.02.01, Index No. 701 Annex / Auxiliary Buildings Nonradioactive Ventilation System (VXS) -
ITAAC 2.7.03.01, Index No. 707 Diesel Generator Building Ventilation System (VZS) -
ITAAC 2.7.04.01, Index No.
712 Radiologically Controlled Area Ventilation System (VAS) -
ITAAC 2.7.05.01, Index No. 718 Containment Air Filtration System (VFS) -
ITAAC 2.7.06.01, Index No. 723 Containment Recirculation Cooling System (VCS) -
ITAAC 2.7.07.01, Index No. 731 Supportino Technical Details:
The functional arrangement ITAAC described above are proposed to be removed because other ITA and AC cover the DC for each functional arrangement ITAAC or the DC is otherwise verified by other means. Submittal of ICNs based upon the current COL Appendix C (and piant-specific Tier 1) information creates reguiatory inefficiencies for the Licensee and the NRC staff, as the conclusions drawn in the functionai arrangement iCN, i.e. that the system is buiit to conform with the design description, is verified by the ITAAC which test the functionality of the system and / or by other means.
The proposed ITAAC optimization continue to meet 10 CFR Part 52 Appendix D and the COL Appendix C (and plant-specific Tier 1) design descriptions, tables and figures and 10 CFR 52.99 for ITAAC closure notification and completion. The ITAAC optimization does not make technical changes to the COL Appendix C (and plant-specific Tier 1) design descriptions, tabies, and figures, because no SSC design function or analysis described in the UFSAR is being affected.
COL Appendix C (and plant-specific Tier 1) information is comprised of the design information and functions subject to verification by the ITAAC closure process. The proposed changes neither affect the ability to meet design criteria or functions nor invoive a decrease in the safety provided by the associated systems. COL Appendix C (and plant-specific Tier 1) ITAAC information would continue to adequately validate their corresponding UFSAR (Tier 2) design commitments. The proposed changes do not impact an SSC, function, or feature used in the prevention or mitigation of accidents or their safety/design analyses. The changes do not affect any SSC accident initiator or initiating sequence of events or involve any safety-related SSC or function used to mitigate an accident.
Page 80 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
The proposed changes do not involve a change to a fission product barrier. The changes do not result in a new failure mode, malfunction, or sequence of events that could affect safety.
The changes would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.
The proposed changes do not affect any safety-related equipment, design code limit, safety-related function, safety-related design analysis, safety analysis input or result, or design or safety margin. No safety analysis or design basis acceptance limit or criterion would be challenged or exceeded.
The proposed changes do not involve a technical (design, analysis, function or qualification) change, e.g., there is no change to an associated calculation, design parameter or design requirement. Therefore, the changes would not result in a decrease in plant safety. The proposed changes associated with this license amendment request do not affect the containment, control, channeling, monitoring, processing or releasing of radioactive and non-radioactive materials. No effluent release path is involved. The types and quantities of expected effluents are not changed; therefore, radioactive or non-radioactive material effluents should not be affected. Plant radiation zones (as described in UFSAR Section 12.3),
controls under 10 CFR 20, and expected amounts and types of radioactive materials are not affected by the proposed changes. Therefore, individual and cumulative radiation exposures will not change.
UFSAR Chapter 14, Section 14.3, and NUREG-0800, Standard Review Plan (SRP), Section 14.3, define and describe requirements for ITAAC. Specifically, they identify that the purpose of the ITAAC is to verify that an as-built facility conforms to the approved plant design and applicable regulations. UFSAR Subsection 14.3.2.1 describes the selection criteria for certified design descriptions and ITAAC. The changes proposed by this request do not lessen the degree of conformity nor reduce the scope of the ITAAC as required by the UFSAR or the SRP, because the ITAAC that bound the functional arrangement ITAAC continue to meet the ITAAC selection criteria and provide verification that the as-built facility conforms to the approved plant design and applicable regulations.
Summarv The change proposes removal of functional arrangement ITAAC in COL Appendix C (and plant-specific Tier 1). For each of these functional arrangement ITAAC proposed to be removed, the Tier 1 Design Description (including tables and figures) and associated UFSAR design information is not proposed to be changed and remains consistent with the current plant design. Therefore, no structure, system, or component (SSC), design function, or analysis, as described in the UFSAR, is affected by the proposed changes and as such, the margin of safety is not reduced.
- 3. TECHNICAL EVALUATION (Included in Section 2)
- 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Page 81 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) 10 CFR 52.98(c) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. This activity involves a departure from COL Appendix C information, and a corresponding change to plant-specific Tier 1 information; therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.
10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. This activity involves a departure from COL Appendix C information, and a corresponding change to plant-specific Tier 1 information; therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.
10 CFR 52.97(b) requires that the Commission shall identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Based on the technical evaluations provided in Section 2 above, the proposed changes to delete ITAAC continue to meet the requirements of 10 CFR 52.97(b).
4.2 Precedent No precedent is identified.
4.3 No Significant Hazards Consideration Determination The proposed changes would require non-technical changes to COL Appendix C information. These changes remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process.
An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed non-technical change to COL Appendix C will remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process. No structure, system, or component (SSC) design or function is affected. No design or safety analysis is affected. The proposed changes do not affect any accident initiating event or component failure, thus the probabilities of the accidents previously evaluated are not affected. No function used to mitigate Page 82 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002) a radioactive material release and no radioactive material release source term is involved, thus the radiological releases in the accident analyses are not affected.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed changes to COL Appendix C do not affect the design or function of any SSC but will remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process. The proposed changes would not introduce a new failure mode, fault or sequence of events that could result in a radioactive material release.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed changes to COL Appendix C will remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process, and would not affect any design parameter, function or analysis. There would be no change to an existing design basis, design function, regulatory criterion, or analysis. No safety analysis or design basis acceptance limit or criterion is involved.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, it is concluded that the proposed amendment does not Involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Pursuant to 10 CFR 50.92, the requested change does not involve a Significant Hazards Consideration Determination.
Page 83 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
- 5. ENVIRONMENTAL CONSIDERATIONS The proposed changes would require non-technical changes to COL Appendix C information.
The changes remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process.
A review has determined that the anticipated construction and operational effects of the proposed amendment meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:
(i) There is no significant hazards consideration.
As documented in Section 4.3, Significant Hazards Consideration Determination, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment." The Significant Hazards Consideration Determination determined that (1) the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the proposed amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.
(ii)
There is no significant change in the types or significant increase in the amounts of any effluents that may be released off site.
The proposed change to COL Appendix C to is remove a number of functional arrangement ITAAC to create a more efficient process for the ITAAC Closure Notification submittals. The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents), or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.
(Hi) There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed change to COL Appendix C is to remove a number of functional arrangement ITAAC to create a more efficient process for the ITAAC Closure Notification submittals. Plant radiation zones (addressed in UFSAR Section 12.3) are not affected, and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.
Page 84 of 85
ND-19-0764 Request for License Amendment: Functional Arrangement ITAAC Optimization (LAR-19-002)
Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational impacts of the proposed amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (ill) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed exemption is not required.
- 6. REFERENCES
- 1. Regulatory Guide 1.206, Revision 0, "Combined License Applications for Nuclear Power Plants"
- 2. NEI 08-01, Revision 5
- Corrected, "Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52" Page 85 of 85