ND-22-0182, ITAAC Closure Notification on Completion of ITAAC 2.3.10.07a.ii (Index Number 444)

ITAAC Closure Notification on Completion of ITAAC 2.3.10.07a.ii (Index Number 444)

ML22070B110
Person / Time
Site:	Vogtle
Issue date:	03/11/2022
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-22-0182
Download: ML22070B110 (9)

Text

Michael J. Yo x 7825 Rive r Road

>.. Southern Nuclear Regu latory Affa irs Director Vogtle3&4 Waynesboro, GA 30830 706-848-6459 tel MAR 1 1 2022 Docket No.: 52-025 ND-22-0182 10 CFR 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 2.3.10.07a.ii (Index Number 444]

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) 2.3.10.0?a.ii (Index Number 444], to verify that specified controls and indications are available in the Main Control Room (MCR) , the containment sump level sensitivity is met, specified check valves perform their functions, and that a simulated high radiation signal will close the discharge control isolation valve. The closu re 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 Kelli Roberts at 706-848-6991.

Respectfully submitted ,

14 Michael J. Yox J Regulatory Affairs

Enclosure:

Vogt e Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.3.10.0?a.ii (Index Number 444]

MJY/ JTK/sfr

U.S. Nuclear Regulatory Commission ND-22-0182 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena Ill Mr. D. L. McKinney Mr. H. Nieh Mr. G . Chick Mr. S. Stimac Mr. P. Martino Mr. J.B. Williams Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Ms. J.M. Coleman Mr. C. T. Defnall Mr. C. E. Morrow Mr. K. J. Drudy Mr. J. M. Fishe r Mr. R. L. Beilke Mr. S. Leighty Ms. A . C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND .LI.L06 File AR.01 .02 .06 Nuclear Regulatory Commission Ms. M. Bailey Mr. M . King Mr. G. Bowman Ms. A . Veil Mr. C . P. Patel Mr. G. J. Khouri Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. 0 . Lopez-Santiago Mr. G. Armstrong Mr. M . Webb Mr. T . Fredette Mr. C. Santos Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Mr. T . Fanelli Ms. K. Mccu rry Mr. J. Parent Mr. B. Griman Mr. V . Hall

U.S. Nuclear Regulatory Commission ND-22-0182 Page 3 of 3 Oglethorpe 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 Westinghouse Electric Company, LLC Dr. L. Oriani Mr. D. C. Durham Mr. M. M. Corletti Mr. Z. S. Harper Mr. J. L. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

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

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

U.S . Nuclear Regulatory Commission ND-22-0182 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-22-0182 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.3.10.0?a.ii [Index Number 444]

U.S. Nuclear Regulatory Commission ND-22-0182 Enclosure Page 2 of 6 ITAAC Statement Design Commitment:

7.a) The WLS provides the nonsafety-related function of detecting leaks within containment to the containment sump.

7.b) The WLS provides the nonsafety-related function of controlling releases of radioactive materials in liquid effluents.

8. Controls exist in the MCR to cause the remotely operated valve identified in Table 2.3.10-3 to perform its active function.

9. The check valves identified in Table 2.3.10-1 perform an active safety-related function to change position as indicated in the table.

10. Displays of the parameters identified in Table 2.3.10-3 can be retrieved in the MCR.

Inspection, Tests, Analyses:

i) Inspection will be performed for retrievability of the displays of containment sump level channels WLS-034, WLS-035, and WLS-036 in the MCR.

ii) Testing will be performed by adding water to the sump and observing display of sump level.

Tests will be performed to confirm that a simulated high radiation signal from the discharge radiation monitor, WLS-RE-229, causes the discharge isolation valve WLS-PL-V223 to close.

Stroke testing will be performed on the remotely operated valve listed in Table 2.3.10-3 using controls in the MCR.

Exercise testing of the check valves with active safety functions identified in Table 2.3.10-1 will be performed under pre-operational test pressure, temperature and flow conditions.

Inspection will be performed for retrievability of the displays identified in Table 2.3.10-3 in the MCR.

Acceptance Criteria:

i) Nonsafety-related displays of WLS containment sump level channels WLS-034, WLS-035, and WLS-036 can be retrieved in the MCR.

ii) A report exists and concludes that sump level channels WLS-034 , WLS-035, and WLS-036 can detect a change of 1.34 +/- 0.5 inches.

A simulated high radiation signal causes the discharge control isolation valve WLS-PL-V223 to close.

Controls in the MCR operate to cause the remotely operated valve to perform its active function.

U.S. Nuclear Regulatory Commission ND-22-0182 Enclosure Page 3 of 6 Each check valve changes position as indicated on Table 2.3.10-1 .

Displays identified in Table 2.3.10-3 can be retrieved in the MCR.

ITAAC Determination Basis Multiple ITAAC were performed to verify the Liquid Radwaste System (WLS) provides the non-safety related function of detecting leaks within containment to the containment sump by inspecting for the retrievability of the containment sump level channels in the MCR and testing to demonstrate that the containment sump level instruments can detect and display a sump level change of 1.34 +/-0.5 inches. This ITAAC also confirms that the WLS provides the nonsafety-related function of controlling the release of radioactive materials in liquid effluents by testing to ensure the discharge control valve WLS-PL-V223 closes when a high radiation signal is simulated. This ITAAC ensures controls exist and operate in the Main Control Room (MCR) to cause the remotely operated valves in Combined License (COL) Appendix C Table 2.3.10-3 (Attachment C) to perform the active function and that the check valves in COL Table 2.3.10-1 (Attachment A) perform their active function to change position as listed in the table.

Additionally, an inspection is performed to ensure the displays of the parameters identified in COL Table 2.3.10-3 (Attachment B) can be retrieved in the MCR.

i) Nonsafety-related displays of WLS containment sump level channels WLS-034, WLS-035, and WLS-036 can be retrieved in the MCR.

An inspection was performed for Unit 3 in accordance with component test package listed in Reference 1. The test procedure verified the non-safety related displays of WLS containment sump level channels WLS-034, WLS-035 , and WLS-036 are retrievable in the MCR.

Reference 1 documents the retrieval of the containment sump level indicating channels (WLS-034, WLS-035, and WLS-036) from a MCR console and verifies and documents the indication is displayed.

The results of this inspection as documented in Reference 1 confirm that for Unit 3 the nonsafety-related displays of WLS containment sump level channels WLS-034, WLS-035, and WLS-036 can be retrieved in the MCR.

ii) A report exists and concludes that sump level channels WLS-034, WLS-035, and WLS-036 can detect a change of 1.34 +/- 0.5 inches.

Testing was performed for Unit 3 in accordance with component test package listed in Reference 3 to verify that sump level channels WLS-034, WLS-035, and WLS-036 can detect a change of 1.34 +/- 0.5 inches.

Reference 3 documented testing of sump level channels which commenced by recording the initial sump level measurement locally and using WLS-034 indication in the MCR. A demineralized water source is used to increase the containment sump level by 1.34 inches as measured locally. The local level is compared to WLS-034 indication in the MCR and the difference was verified to be :,; 0.5 inches. This verified WLS-034 can detect a change in containment sump level of 1.34 inches +/- 0.5 inches. This testing was repeated for the remaining containment sump level channels WLS-035 and WLS-036.

U.S. Nuclear Regulatory Commission ND-22-0182 Enclosure Page 4 of 6 The completed test results as documented in Reference 3 demonstrates that for Unit 3, a report exists and concludes sump level channels WLS-034, WLS-035, and WLS-036 can detect a change of 1.34 +/- 0.5 inches.

A simulated high radiation signal causes the discharge control isolation valve WLS-PL-V223 to close.

Testing was performed for Unit 3 in accordance with component test package listed in Reference 2 to verify that a simulated high radiation signal causes the discharge control isolation valve WLS-PL-V223 to close.

Testing was performed as documented in Reference 2 by verifying WGS-PL-V223 is initially open. The test simulated a high radiation signal from the discharge radiation monitor.

WGS-PL-V223 was verified to close on the Plant Control System (PLS) monitor in the Main Control Room and verification is documented in the component test package.

This testing as documented in Reference 2 verified that for Unit 3 a simulated high radiation signal causes the discharge control isolation valve WGS-PL-V223 to close.

Controls in the MCR operate to cause the remotely operated valve to perform its active function.

Testing was performed for Unit 3 in accordance with component test package listed in Reference 1 to verify that controls in the MCR operate to cause the remotely operated valve (Attachment C) to perform its active function.

Testing commenced as documented in Reference 1 at one of the MCR consoles. WLS-PL-V223 was opened using Plant Control System (PLS) controls , verified to be open locally, closed using PLS controls and verified to be closed locally.

The results of this testing as documented in Reference 1 confirmed that for Unit 3, the controls in the MCR operate to cause the remotely operated valve to perform its active function Each check valve changes position as indicated on Table 2.3.10-1.

Testing was performed for Unit 3 in accordance with component test package listed in Reference 3 to verify each check valve changes position as indicated on Attachment A.

Testing documented in Reference 3 verified that the check valve testing began by pouring water into the Chemical and Volume Control System (CVS) compartment floor drain and verifying the proper level rise in the containment sump. This verified that the drain line check valves (WLS-V071A and V072A) partially opened. Then a blank flange is installed downstream of both check valves, test connection caps are removed, and a water hose with an inline flowmeter and pressure gauge is connected to the test connection between the blank flange and WLS-V072A.

The line is pressurized and when flowrate has stabilized , the pressure and leakage are recorded. The flow rate is verified to be< 2 gpm and this verifies that check valve WLS-V072A has closed . The water hose is then moved to the test connection between the two check valves and pressurized. When the pressure and flowrate stabilize, pressure and flowrate are recorded.

The flow rate is verified to be< 2 gpm and this verifies that check valve WLS-V071A has closed .

This methodology was repeated for the two remaining drain lines and associated check valves.

This system is depicted in Piping and Instrumentation Diagram, Liquid Radwaste System WLS-M6-001.

U.S. Nuclear Regulatory Commission ND-22-0182 Enclosure Page 5 of 6 The completed test results as documented in Reference 3 verified for Unit 3 that each check valve changes position as indicated on Table 2.3.10-1.

Displays identified in Table 2.3.10-3 can be retrieved in the MCR.

An inspection was performed for Unit 3 in accordance with component test package listed in Reference 1. This component test package verified the displays identified in Attachment B can be retrieved in the MCR.

Reference 1 documents the retrieval of the displays identified in Attachment B from an MCR console, verifies and documents the indication is displayed.

The completed Unit 3 component test results as documented in Reference 1 confirmed that the displays identified in Table 2.3.10-3 can be retrieved in the MCR.

References 1 through 3 are available for NRC inspection as part of the ITAAC 2.3.10.0?a.ii Completion Package (reference 4).

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 are no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.10.0?a.ii (Reference 4) and is available for NRC review.

IT AAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.10.0?a.ii 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. SV3-WLS-ITR-800444, "Unit 3 Liquid Radwaste System WLS Items ?a, and 10:

ITAAC 2.3.10.0?a.ii"

2. SV3-WLS-ITR-801444, "Unit 3 Liquid Radwaste System WLS Release Isolation:

ITAAC 2.3.10.0?a.ii , Item 7b"

3. SV3-WLS-ITR-802444, "Unit 3 Liquid Radwaste System WLS Leak Detection and Check Valve Function : ITAAC 2.3.10.07a.ii , Items ?.a.ii and 9"

4. 2.3.10.07a.ii-U3-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-22-0182 Enclosure Page 6 of 6 Attachment A

• Excerpt of COL Appendix C Table 2.3.10-1

• Equipment Name *Tag No. *Active Function WLS Drain from Passive Core Cooling System (PXS) WLS-PL-V071 B Transfer Compartment A (Room "1"1206) Check Valve Closed WLS Drain from PXS Compartment A (Room 11206) WLS-PL-V072B Transfer Check Valve Closed WLS Drain from PXS Compartment B (Room 11207) WLS-PL-V071 C Transfer Check Valve Closed WLS Drain from PXS Compartment B (Room 11207) WLS-PL-V072C Transfer Check Valve Closed WLS Drain from Chemical and Volume Control System WLS-PL-V071A Transfer (CVS) Compartment (Room 11209) Check Valve Closed WLS Drain from CVS Compartment (Room 11209) WLS-PL-V072A Transfer Check Valve Closed Attachment B

• Excerpt of COL Appendix C Table 2.3.10-3

• Equipment Name *Tag No. *Displav Reactor Coolant Drain Tank Level WLS-JE-L T002 Yes Letdown Flow from CVS to WLS WLS-JE-FT020 Yes WLS Auxiliary Building RCA WLS-400A Yes Floodup Level Sensor WLS Auxiliary Building RCA WLS-400B Yes Floodup Level Sensor Attachment C

• Excerpt of COL Appendix C Table 2.3.10-3

• Equipment Name *Tag No. *Active Function WLS Effluent Discharge Isolation WLS-PL-V223 Close Valve