ND-20-0337, ITAAC Closure Notification on Completion of ITAAC 2.2.03.12a.iv (Index Number 216)

ITAAC Closure Notification on Completion of ITAAC 2.2.03.12a.iv (Index Number 216)

ML20287A408
Person / Time
Site:	Vogtle
Issue date:	10/13/2020
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-0337
Download: ML20287A408 (9)

Text

^ ^ ,1 j. I I MichaelJ. Yox 7825 River Road

^OUtnSrn iNUClOdr Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel Docket No.: 52-025 OCT ULI 1I 1J ?n?n Lm 10 CFRND-20-0337 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 ITAAC Closure Notification on Completion of ITAAC 2.2.03.12a.iv (Index Number 2161 Ladies and Gentlemen:

In accordance with 10 CFR 52.99(c)(1), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) of the completion of Vogtle Electric Generating Plant(VEGP) Unit 3 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.03.12a.iv [Index Number 216], for verifying each check valve changes position as indicated in Table 2.2.3-1. The closure process for this ITAAC is based on the guidance described in NEI 08-01, "Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52", which is endorsed by the NRC in Regulatory Guide 1.215.

This letter contains no new NRC regulatory commitments. Southern Nuclear Operating Company (SNC) requests NRC staff confirmation of this determination and publication of the required notice in the Federal Register per 10 CFR 52.99.

If there are any questions, please contact Tom Petrak at 706-848-1575.

Respectfully submitted.

% /J Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 2.2.03.12a.iv [Index Number 216]

MJY/CWM/sfr

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III (w/o enclosures)

Mr. D. L. McKinney (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. C. T. Defnall Mr. C. E. Morrow Mr. R. L. Beiike Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reoulatorv Commission M C. P. Patel M G. J. Khouri M N. D. Karlovich M A. Lerch M C. J. Even M B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Mr. M. Webb Mr. T. Fredette Mr. S. Smith Mr. C. Santos Mrs. M. Bailey Mr. S. Rose Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Ms. K. Carrington Mr. M. King Mr. E. Davidson Mr. T. Fanelli

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 3 of 3 Oqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. Orlani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Mr. Z. 8. Harper Mr. J. L. Coward Other Mr. 8. W. Kline, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. 8. Roetger, Georgia Public Service Commission Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-20-0337 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 2.2.03.12a.lv [Index Number 216]

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 2 of 6 ITAAC Statement Design Commitment 12.a) The squib valves and check valves identified in Table 2.2.3-1 perform an active safety-related function to change position as indicated in the table.

Inspections/Tests/Analvses iv) Exercise testing of the check valves with active safety functions identified in Table 2.2.3-1 will be performed under preoperational test pressure, temperature, and fluid flow conditions.

Acceptance Criteria iv) Each check valve changes position as indicated in Table 2.2.3-1 ITAAC Determination Basis Multiple ITAAC are performed to verify that the squib valves and check valves identified in Table 2.2.3-1 perform an active safety-related function to change position as indicated in the table.

This ITAAC performs testing of check valves in accordance with preoperational test procedures 3-PXS-ITPP-502 (Reference 1), 3-PXS-ITPP-503(Reference 5), 3-PXS-ITPP-506 (Reference 8), and 3-PXS-ITPP-507(Reference 11) to demonstrate each check valve with active safety functions changes position as indicated in VEGP Combined License (COL) Appendix C Table 2.2.3-1 (Attachment A) under preoperational test pressure, temperature, and fluid flow conditions. A methodology enhancement was performed using Work Orders 1195648 (Reference 14) and 1195655 (Reference 15) to perform a disassembly inspection of PXS-PL-V122A,-V122B, -V124A, and -V124B.

References 1 and 2 performed the transfer open testing of the Accumulator Discharge Check Valves(PXS-PL-V028A and -V029A, -V028B and -V029B). The test established the initial conditions of the Accumulator Tank (PXS-MT-01 A)filled and pressurized to greater than 70 pounds per square inch gage (psig) and less than 80 psig, the reactor pressure vessel(RPV) was at atmospheric pressure with the head off and the accumulator outlet valves were closed.

During the flow resistance determination testing of the line from the accumulator discharge to the direct vessel injection (DVI) nozzle, the "A" accumulator outlet valves were opened and the "A" accumulator discharges into the RPV through the DVI line. During this testing, the peak flow rate value was calculated based on volume change,from the change in measured tank level, per time interval. Based on the calculated flow rate, the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A) were verified to transfer open when flow rate exceeded 1614 gallons per minute (gpm). This test was repeated for the Accumulator Discharge Check Valves (PXS-PL-V028B and -V029B) during the flow resistance determination testing of the "B" Accumulator discharge through the "B" DVI line. This was documented in ITAAC Technical Report SV3-PXS-ITR-800216 (Reference 3). These test flow paths are depicted on drawing SV3-PXS-M6-001, Piping and Instrumentation Diagram (P&ID) Passive Core Cooling System.

References 1 and 2 performed the transfer closed testing of the Nitrogen Supply Containment Isolation Check Valve (PXS-PL-V043). The test established the initial conditions of closing the nitrogen supply isolation valve to containment and closing a manual valve downstream of PXS-

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 3 of 6 PL-V043. Temporary air lines were connected to test connections on either side of the PXS-PL-V043 check valve. With the downstream test connection open, the upstream test connection was pressurized with air and PXS-PL-V043 was determined to be open by verifying air exits the downstream test connection. The upstream connection was then closed and the air supply was connected to the downstream test connection. The downstream line was then pressurized through the downstream test connection and the test connection upstream of PXS-PL-V043 was opened and the differential pressure caused the PXS-PL-V043 check valve to transfer closed.

The upstream test connection was checked for leakage to verify the check valve had transferred closed. This was documented in ITAAC Technical Report SV3-PXS-ITR-801216 (Reference 4).

These test flow paths are depicted on drawing SV3-PXS-M6-001, P&ID Passive Core Cooling System.

References 5 and 6 performed the closed testing of the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A, -V028B and -V029B). The test ensured the "A" accumulator discharge lines were filled with water and the accumulator level was at 55% to 56% full, the "A" accumulator discharge isolation valves were closed, and one train of Normal Residual Heat Removal System (RNS) was in service recirculating the Reactor Coolant System (RCS) with the RCS Hot Leg level between 48% and 50%. The Passive Core Cooling System (PXS)test panel was utilized to sequentially place RNS pressure on the downstream side of each Accumulator "A" Discharge Check Valve (PXS-PL-V028A and -V029A). When the upstream side of the check valves were depressurized by opening their respective upstream test connection, each check valve was demonstrated to have transferred closed. This test was repeated for the Accumulator "B" Discharge Check Valves(PXS-PL-V028B and -V029B). This was documented in ITAAC Technical Report SV3-PXS-ITR-802216 (Reference 7). These test flow paths are depicted on drawing SV3-PXS-M6-001, P&ID Passive Core Cooling System. Testing the transfer open function during pre-operational testing (Reference 1) along with testing the closed function during pre-operational testing (References 5) provided assurance that the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A, -V028B and -V029B) were adequately cycled to demonstrate they transferred open and closed.

References 8 and 9 performed the transfer open function of the Core Makeup Tank(CMT)

Discharge Check Valves(PXS-PL-V016A and -V017A, -V016B and -V017B) during the flow resistance determination testing of the CMT injection line. VEGP Updated Final Safety Analysis Report(UFSAR)subsection 6.3.2.1.3 states that these check valves are normally open with or without flow in the line (i.e., flow out of the CMT and into the DVI injection line). This test established the "A" CMT was at approximately 85% level, the RPV was at atmospheric pressure with the head off and the "A" CMT isolation valves were verified to be closed. The "A" CMT isolation valves were then opened and a level rise in the RPV demonstrated by operation of the sump pump to maintain water level within the hot leg confirmed that the "A" CMT Discharge Check Valves (PXS-PL-V016A and -V017A) were open. This testing was repeated on the "B" CMT Discharge Check Valves(PXS-PL-V016B and -V017B). This was documented in ITAAC Technical Report SV3-PXS-ITR-803216 (Reference 10).

References 5 and 6 performed the transfer closed function of the CMT Discharge Check Valves (PXS-PL-V016A and -V017A, -V016B and -V017B). This test established the "A" CMT approximately 75% full with the RPV at atmospheric pressure and the head installed. A demineralized water source, with a flow meter and pressure gauge, was connected to a downstream test connection. PXS-PL-V016A was tested by closing the upstream and downstream "A" CMT isolation valves, an upstream test connection was opened and the downstream demineralized water source established. A rise in the demineralized water supply

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 4 of 6 pressure and a decrease in flow rate demonstrated that the PXS-PL-V016A Discharge Check Valve transferred closed. This testing was repeated for each of the remaining CMT Discharge Check Valves (PXS-PL-V016B,-V017A and -V017B). This was documented in ITAAC Technical Report SV3-PXS-ITR-802216 (Reference 7). These test flow paths are depicted on drawing SV3-PXS-M6-001, P&ID Passive Core Cooling System. Testing the open function during pre-operational testing (Reference 8) along with testing the transfer closed function during pre-operational testing (References 5) provided assurance that the CMT Discharge Check Valves(PXS-PL-V016A and -V017A, -V016B and -V017B) were adequately cycled to demonstrate they transferred both open and closed.

References 11 and 12 performed the transfer open and transfer closed function of the In-containment Refueling Water Storage Tank (IRWST) Injection Check Valves(PXS-PL-V122A and -V124A, -V122B and -V124B) during the IRWST flow resistance determination testing of the IRWST injection lines. This test established the IRWST upper narrow range level between 0 to 15 inches, the reactor vessel was full to the flange with the head off and venturi flow meter test spools were installed in place of downstream squib valves. The IRWST injection line "A" motor-operated valve(MOV) was opened and the flow obtained through each check valve confirmed the IRWST Injection Check Valves PXS-PL-V122A and -V124A had transferred open (Note, full open did not occur as noted in LAR 17-009). After check valves PXS-PL-V122A and -V124A were confirmed to be open, IRWST Injection Line "A" MOV was closed and the check valves PXS-PL-V122A and -V124A were confirmed to transfer closed by Main Control Room (MCR) indication. This test was repeated for the "B" IRWST Injection Check Valves (PXS-PL-V122B and -V124B). NOTE: PXS-PL-V122B did not indicate open so the transfer closed function could not be verified in Reference 11. References 14 and 15 performed a methodology enhancement on all IRWST Injection Check Valves using a disassembly inspection to verify the valves all transferred closed. This was documented in ITAAC Technical Report SV3-PXS-ITR-804216 (Reference 13). These test flow paths are depicted on drawing SV3-PXS-M6-002, P&ID Passive Core Cooling System. Performance of pre-operational testing (Reference 11) and the methodology enhancement(References 14 and 15) provided assurance the IRWST Injection Check Valves(PXS-PL-V122A and -V124A, -V122B and -V124B) were adequately cycled to demonstrate they transferred both open and closed.

References 11 and 12 performed the transfer open and transfer closed function of the Containment Recirculation Check Valves (PXS-PL-V119A and -VI19B) during the IRWST Screen "A" to Containment Recirculation Sump "A" flow resistance determination testing. This test established the IRWST upper narrow range level at 0 to 15 inches, the reactor vessel was full to the flange with the head off, IRWST sumps were fitted with temporary removable valves, temporary pipe spools were installed in place of downstream squib valves and a temporary pipe with a venturi flow meter was installed to cross-connect the containment recirculation sump "A" to "B". The containment recirculation "A" MOV was opened and IRWST injection line "B" isolation valve was opened and check valve PXS-PL-V119A was confirmed to be closed by MCR indication while PXS-PL-V119B was confirmed to be open by system flow. This test was repeated by opening containment recirculation "B" MOV and IRWST injection line "A" isolation valve and confirmed PXS-PL-V119B was closed by MCR indication and PXS-PL-V119A was confirmed to be open by system flow. This was documented in ITAAC Technical Report SV3-PXS-ITR-804216 (Reference 13). These test flow paths are depicted on drawing SV3-PXS-M6-002, P&ID Passive Core Cooling System. Performance of pre-operational testing (Reference

11) provided assurance that Containment Recirculation Check Valves(PXS-PL-V119A and -VI19B) were adequately cycled to demonstrate they transferred both open and closed.

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 5 of 6 References 1 through 15 are available for NRG inspection as well as Unit 3 ITAAC 2.2.03.12a.iv Completion Package (Reference 16).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company(SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there were no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.2.03.12a.iv (Reference 16) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.2.03.12a.iv was performed for VEGP Unit 3 and that the prescribed acceptance criteria were met.

Systems, structures, and components verified as part of this ITAAC are being maintained in their as-designed, ITAAC compliant condition in accordance with approved plant programs and procedures.

References(available for NRC inspection)

1. 3-PXS-ITPP-502, Rev. 3,"PXS Accumulator Mapping and Line Resistance Tesf

2. Work Order 1071717,"(ITAAC) Perform Preop Test 3-PXS-ITPP-502"

3. SV3-PXS-ITR-800216, Rev. 0,"Unit 3 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITAAC 2.2.03.12a.iv"

4. SV3-PXS-ITR-801216, Rev. 0,"Unit 3 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITAAC 2.2.03.12a.iv"

5. 3-PXS-ITPP-503, Rev. 2.1 and Rev. 3,"Passive Core Cooling System Pre-Core Flow Testing with RV Head Installed Preoperational Test Procedure"

6. Work Order 1071718,"(ITAAC) Perform Acceptance Test 3-PXS-ITPP-503"

7. SV3-PXS-ITR-802216, Rev. 0,"Unit 3 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITAAC 2.2.03.12a.iv"

8. 3-PXS-ITPP-506, Rev. 3,"PXS CMT Mapping and Line Resistance Test"

9. Work Order 1071721,"(ITAAC) Perform Preop Test 3-PXS-ITPP-506"

10. SV3-PXS-ITR-803216, Rev. 0,"Unit 3 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITAAC 2.2.03.12a.iv" 11.3-PXS-ITPP-507, Rev. 3,"IRWST Flow Tests"

12. Work Order 1071722,"(ITAAC) Perform Preop Test 3-PXS-ITPP-507"

13. SV3-PXS-ITR-804216, Rev. 0,"Unit 3 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITAAC 2.2.03.12a.iv"

14. Work Order 1195648,"Perform Setup and Testing of SV3-PXS-PL-V122A & SV3-PXS-PL-VI228 Position Switches"

15. Work Order 1195655,"Perform Setup and Testing of SV3-PXS-PL-V124A Position Switches"

16. 2.2.03.12a.iv-U3-CP-RevO, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-20-0337 Enclosure Page 6 of 6 Attachment A

'Excerpt from COL Appendix C Table 2.2.3-1 Equipment Name

• Tag No.

• Active Function*

Transfer Open/Transfer CMT A Discharge Check Valve PXS-PL-V016A Closed Transfer Open/Transfer CMT B Discharge Check Valve PXS-PL-V016B Closed Transfer Open/Transfer CMT A Discharge Check Valve PXS-PL-V017A Closed Transfer Open/Transfer CMT B Discharge Check Valve PXS-PL-V017B Closed Accumulator A Discharge Check Valve PXS-PL-V028A Transfer Open/Close Accumulator B Discharge Check Valve PXS-PL-V028B Transfer Open/Close Accumulator A Discharge Check Valve PXS-PL-V029A Transfer Open/Close Accumulator B Discharge Check Valve PXS-PL-V029B Transfer Open/Close Transfer Closed Nitrogen Supply Containment Isolation Check Valve PXS-PL-V043 Transfer Open/Transfer Containment Recirculation A Check Valve PXS-PL-V119A Closed Transfer Open/Transfer Containment Recirculation B Check Valve PXS-PL-V119B Closed Transfer Open/Transfer IRWST Injection A Check Valve PXS-PL-V122A Closed Transfer Open/Transfer IRWST Injection B Check Valve PXS-PL-V122B Closed Transfer Open/Transfer IRWST Injection A Check Valve PXS-PL-V124A Closed Transfer Open/Transfer IRWST Injection B Check Valve PXS-PL-V124B Closed