ND-20-0952, ITAAC Closure Notification on Completion of ITAAC 2.2.01.11a.i (Index Number 114)

ITAAC Closure Notification on Completion of ITAAC 2.2.01.11a.i (Index Number 114)

ML20329A417
Person / Time
Site:	Vogtle
Issue date:	11/24/2020
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-0952
Download: ML20329A417 (8)

Text

^ ,1 >> I I MichaelJ. Vox 7825 River Road jOUTriOrn lNUCl03r Regulatory Affairs Director Waynesboro, GA 30830 Vogtle3& 4 706-848-6459 tel NOV 2 h 2020 Docket Nos.: 52-025 ND-2G-0952 10CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washiington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 ITAAC Closure Notification on Completion of ITAAC 2.2.01.1 la.i [Index Number 1141 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 2.2.01.1 la.i [Index Number 114]. This ITAAC confirms that the Containment System motor-operated valves are qualified in accordance with the provisions of American Society of Mechanical Engineers(ASME)QME-1-2007 to perform their active safety-related function under design conditions. The closure process for this ITAAC is based on the guidance described in Nuclear Energy Institute (NEI) 08-01,"Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52," which was endorsed by the NRC in Regulatory Guide 1.215.

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.

Michael J. Vox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 2.2.01.1 la.i [Index Number 114]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-20-0952 Page 2 of 3 To:

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

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

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

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

Nuclear Requlatorv Commission Ms. M. Bailey (w/o enclosures)

M M. King M H. K. Nieh M C. P. Patel M G. J. Khouri M C. J. Even M B. J. Kemker Ms. N. C. Coovert M C. Welch M J. Gaslevic M O. Lopez-Santiago M G. Armstrong M M. Webb M T. Fredette M C. Santos M s. M. Bailey M B. Davis M J. Vasquez M J. Eargle M E. Davidson M T. Fanelli M S. Rose Ms. K. McCurry Qqiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-20-0952 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Daiton Utiiities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

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

Mr. M. M. Corletti Mr. Z. S. 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-20-0952 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-20-0952 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 Compietion of ITAAC 2.2.01.11a.i [Index Number 114]

U.S. Nuclear Regulatory Commission ND-20-0952 Enclosure Page 2 of 5 ITAAC Statennent Design Commitment 11.a) The motor-operated and check valves identified in Table 2.2.1-1 perform an active safety-related function to change position as indicated in the table.

Inspections/Tests/Analvses i) Tests or type tests of motor-operated valves will be performed to demonstrate the capability of each valve to operate under design conditions.

ii) Inspection will be performed for the existence of a report verifying that the as-built motor-operated valves are bounded by the tests or type tests.

Acceptance Criteria i) A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.2.1-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

ITAAC Determination Basis Multiple Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) were performed to demonstrate that the Containment System (CNS) motor-operated valves identified in the Combined License (COL) Appendix C, Table 2.2.1-1 perform an active safety-related function to change position as indicated in the table.

i) A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.2.1-1 under design conditions.

This portion of the subject ITAAC required tests or type tests of motor-operated valves to be performed to demonstrate the capability of the valve to operate under its design conditions.

The motor-operated valves identified in COL Appendix C, Table 2.2.1-1 were qualified in accordance with the provisions of American Society of Mechanical Engineers(ASME)QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants (Reference 1).

Functional qualification was performed under the design conditions identified in the design specification for the valves (Reference 2)to demonstrate that each motor-operated valve is qualified to perform its designated function when used in its intended service. In accordance with ASME QME 2007, qualification was substantiated by demonstrating the relationship between the service requirements and the type testing and analysis that was conducted as part of this qualification program.

Type testing was performed, including natural frequency determination, side load static deflection testing, final static seat and stem leakage testing, steam testing, and water testing, for the ranges of the pressure, temperature and flow for each valve and the maximum seat-sealing differential pressure.

In accordance with ASME QME-1-2007, the functional qualification process for these motor-operated valve assemblies also included valve and actuator internal inspections and measurement, orientation requirements, seat and stem leakage limitations, diagnostic data collection and analysis methods.

U.S. Nuclear Regulatory Commission ND-20-0952 Enclosure Page 3 of 5 static and dynamic flow diagnostic testing, and pressure locking and thermal binding evaluations. The qualification also followed the provisions of ASME QME-1-2007 for the extrapolation of functional qualification to another valve assembly, and demonstration of functional capability of production valve assemblies.

The results of the qualification are documented in the Equipment Qualification (EG) Reports (Reference 3) which are identified in Attachment A for each applicable valve. These reports summarize the test methodology and ASME QME-1-2007 functional qualification that demonstrate that each motor-operated valve changes position as indicated in COL Appendix C, Table 2.2.1-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded bv the tests or tvpe tests.

This portion of the subject ITAAC required that an inspection be performed for the existence of a report verifying that the as-built motor-operated valves are bounded by tests or type tests.

The motor-operated valves in CQL Appendix C, Table 2.2.1-1 were verified by type tests in accordance with section i) above, to demonstrate the capability of the valves to operate under their design conditions. The EQ Reports in Attachment A identify the equipment mounting employed for the testing and the specific conditions tested.

In accordance with the EQ ITAAC As-built Walkdown Guideline (Reference 4)and the EQ ITAAC As-built Installation Documentation Guideline (Reference 5), an inspection was conducted of the CNS to confirm the satisfactory installation of the motor-operated valves. The inspection included verification of equipment make/model/serial number, verification of equipment mounting and location, and verification that the mechanical and electrical connections are bounded by the tested conditions.

The documentation of installed configuration of the motor-operated valves includes photographs and/or sketches of equipment mounting and connections. The verification of installed equipment configuration is documented in As-Built EQ Reconciliation Reports(EQRRs)(Reference 6).

Attachment A identifies the EQRRs which verify that the installed configuration of the motor-operated valves identified in COL Appendix 0, Table 2.2.1-1 are bounded by the tests or type tests.

Together, these EQ Reports and EQRRs(References 3 and 6), provide evidence that the ITAAC Acceptance Criteria requirements are met; A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.2.1-1 under design conditions; and A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

References 3 and 6 are available for NRC Inspection as part of the Unit 3 ITAAC 2.2.01.1 la.i Completion Package (Reference 7).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion. Southern Nuclear Qperating Company (SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there was one relevant ITAAC finding associated with this ITAAC.

U.S. Nuclear Regulatory Commission ND-20-0952 Enclosure Page 4 of 5 Unresolved Item (URI)05200025/2017002-02.(closed)

The corrective actions for this finding have been completed and the finding is closed. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.2.01.Ila.i (Reference 7) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.2.01.1 la.i 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. American Society of Mechanical Engineers(ASME)QME-1-2007,"Qualification of Active Mechanical Equipment Used in Nuclear Power Plants"

2. SV3-PV11-Z0-001, Revision 9,"Design Specification for Butterfly Valves, ASME Boiler and Pressure Vessel Code Section III, Class 2 and 3"

3. Equipment Qualification (EQ) Reports as Identified in Attachment A

4. ND-RA-001-014, EQ ITAAC As-built Walkdown Guideline, Version 3.1

5. ND-RA-001-016, EQ ITAAC As-built Installation Documentation Guideline, Version 1.0

6. As-Built Equipment Qualification Reconciiiation Reports(EQRRs)as Identified In Attachment A

7. 2.2.01.11a.i-U3-CP-RevO, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-20-0952 Enclosure Page 5 of 5 Attachment A System: Containment System (CMS)

Active EQ Reports As-Buiit EQRR Equipment Name ^ Tag No. +

Function + (Reference 3) (Reference 6)

Component Cooling Water CCS-PL-V200 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-System (CCS) Containment Closed SV3-PV11-VBR-006 EQRR-PCD001 Isolation Motor-operated Valve(MOV)- Inlet Line Outside Reactor Containment(ORC)

CCS Containment Isolation CCS-PL-V207 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-MOV-Outlet Line IRC Closed SV3-PV11-VBR-006 EQRR-PCD001 CCS Containment Isolation CCS-PL-V208 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-MOV - Outlet Line ORC Closed SV3-PV11-VBR-006 EQRR-PCD001 SFS Discharge Line SFS-PL-V038 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-Containment Isolation MOV Closed SV3-PV11-VBR-006 EQRR-PCD003

-ORC SFS Suction Line SFS-PL-V034 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-Containment Isolation MOV Closed SV3-PV11-VBR-006 EQRR-PCD002

-IRC SFS Suction Line SFS-PL-V035 Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-Containment Isolation MOV Closed SV3-PV11-VBR-006 EQRR-PCD003

-ORC Vacuum Relief Containment VFS-PL-V800A Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-Isolation A MOV - ORC Closed / SV3-PV11-VBR-006 EQRR-PCD002 Transfer Open Vacuum Relief Containment VFS-PL-V800B Transfer SV3-PV11-VBR-005/ 2.2.01.11a.l-U3-Isolation B MOV - ORC Closed / SV3-PV11-VBR-006 EQRR-PCD002 Transfer Open Notes:

Excerpt from COL Appendix C Table 2.2.1-1