ND-22-0200, ITAAC Closure Notification on Completion of ITAAC 2.3.10.02a (Index Number 431)

ITAAC Closure Notification on Completion of ITAAC 2.3.10.02a (Index Number 431)

ML22175A117
Person / Time
Site:	Vogtle
Issue date:	06/24/2022
From:	Coleman J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ITAAC 2.3.10.02a, ND-22-0200
Download: ML22175A117 (12)

Text

>-,, Southern Nuclear Jami e M. Coleman Regulatory Affairs Directo r Vogtl e 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel JUN 2 4 2022 Docket No.: 52-026 ND-22-0200 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 4 ITAAC Closure Notification on Completion of ITAAC 2.3.10.02a [Index Number 4311 Ladies and Gentlemen:

In accordance with 10 CFR 52.99{c)(1 ), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRG) of the completion of Vogtle Electric Generating Plant (VEGP) Unit 4 Inspections, Tests, Analyses , and Acceptance Criteria {ITAAC) Item 2.3.10.02a [Index Number 431 J for verifying the components and piping identified in VEGP Combined License (COL) Appendix C Tables 2.3.10-1 and 2.3.10-2 are designed and constructed in accordance with American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PVC) Section Ill and functional capability requirements for the Liquid Radwaste System (WLS). 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 was endorsed by the NRG in Regulatory Guide 1.215.

This letter contains no new NRG regulatory commitments. Southern Nuclear Operating Company (SNC) requests NRG 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 A. Roberts at 706-848-6991 .

Respectfully submitted, Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.10.02a [Index Number 4311 JMC/GES/sfr

U.S. Nuclear Regulatory Commission ND-22-0200 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. D. Pitts Mr. J.B. Williams 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. Fisher 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 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 Ms. K. Mccurry Mr. J. Parent Mr. B. Griman Mr. V. Hall

U.S . Nuclear Regulatory Commission ND-22-0200 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 Ms. S.L. Zwack 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. Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton , Balch Bingham

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-22-0200 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.10.02a [Index Number 431)

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 2 of 9 IT AAC Statement Design Commitment:

2.a) The components identified in Table 2.3.10-1 as ASME Code Section Ill are designed and constructed in accordance with ASME Code Section Ill requirements .

2.b) The piping identified in Table 2.3.10-2 as ASME Code Section Ill is designed and constructed in accordance with ASME Code Section Ill requirements.

3.a) Pressure boundary welds in components identified in Table 2.3.10-1 as ASME Code Section Ill meet ASME Code Section Ill requirements.

3.b) Pressure boundary welds in piping identified in Table 2.3.10-2 as ASME Code Section Ill meet ASME Code Section Ill requirements.

4.a) The components identified in Table 2.3.10-1 as ASME Code Section Ill retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.3.10-2 as ASME Code Section Ill retains its pressure boundary integrity at its design pressure.

5.b) Each of the lines identified in Table 2.3.10-2 for which functional capability is required is designed to withstand combined normal and seismic design basis loads without a loss of its functional capability.

Inspections, Tests, Analyses:

Inspection will be conducted of the as-built components and piping as documented in the ASME design reports.

Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section Ill.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section Ill to be hydrostatically tested .

Inspection will be performed for the existence of a report verifying that the as-built piping meets the requirements for functional capability.

Acceptance Criteria:

The ASME Code Section Ill design reports exist for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section Ill.

A report exists and concludes that the ASME Code Section Ill requirements are met for non-destructive examination of pressure boundary welds.

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 3 of 9 A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section Ill conform with the requirements of the ASME Code Section Ill.

A report exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional capability is required meets the requirements for functional capability.

IT AAC Determination Basis This ITAAC requires inspections, tests, and analyses be performed and documented to ensure the Liquid Radwaste System (WLS) components and piping listed in the Combined License (COL) Appendix C, Table 2.3.10-1 (Attachment A) and Table 2.3.10-2 (Attachment B) that are identified as American Society of Mechanical Engineers (ASME) Code Section Ill or Functional Capability Required were designed and constructed in accordance with applicable requirements.

2.a and 2.b) The ASME Code Section Ill design reports exist for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section Ill.

Each component listed in Table 2.3.10-1 as ASME Code Section 111 was fabricated in accordance with the VEGP Updated Final Safety Analysis Report (UFSAR) and the ASME Code Section Ill requirements. An ASME Code Section Ill certified Design Report for these components exists and documents that the as-built components conform to the approved design details (Reference 1). This ASME Section Ill certified Design Report is documented on the ASME Section Ill certified Design Report for the applicable piping system (Reference 2).

The as-built piping listed in Table 2.3.10-2 including the components listed in Table 2.3.10-1 as ASME Code Section Ill, were subjected to a reconciliation process (Reference 3) , which verifies that the as-built piping was analyzed for applicable loads (e.g., stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-built system, including installed components, validates that construction completion , including field changes and any nonconforming condition dispositions, were consistent with and bounded by the approved design . All applicable fabrication, installation and testing records , as well as, those for the related Quality Assurance (QA) verification/inspection activities, which confirm adequate construction in compliance with the ASME Code Section Ill and design provisions, were recorded in Supplement 1 (i.e ., Installation N-5 Code Date Report) (Reference 4) of the AP1000 ASME Section Ill System Code Data Report for the Liquid Radwaste System-A (WLS-A), (i.e., System N-5 Code Data Report) (Reference 5).

Certified Design Reports for the components listed in Table 2.3-10-1 (Attachment A) and piping listed in Table 2.3.10-2 (Attachment B) as ASME Code Section Ill , exist and conclude that these installed components and piping were designed and constructed (including the component installation within the applicable as-built piping system) in accordance with the ASME Code (1998 Edition, 2000 Addenda) , Section Ill requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference 6).

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 4 of 9 3.a and 3.b) A report exists and concludes that the ASME Code Section Ill requirements are met for non-destructive examination of pressure boundary welds.

Inspections were performed of each component's as-built drawing which identified and demonstrate that these components contain no pressure boundary welds and therefore non-destructive examination (NOE) of pressure boundary welds in accordance with ASME Code Section Ill requirements were not required (Reference 1).

An inspection was performed in accordance with Reference 3 to demonstrate that the as-built pressure boundary welds in piping identified in Table 2.3.10-2 (Attachment B) as ASME Code Section Ill met ASME Code Section Ill requirements (i.e., no unacceptable indications). This portion of the ITAAC was completed when the piping identified in Table 2.3.10-2, which is encompassed within the respective piping system Code Symbol N-Stamp and the corresponding piping system Installation N-5 Code Data Report Form (Reference 4), were completed. The NDEs (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section Ill) of the piping pressure boundary welds were documented either in the NOE Report(s) within the piping system's supporting data packages or the field weld reports, which support completion of the respective Code Stamping and Installation N-5 Code Data Report (Reference 4). The completion of stamping the respective piping system along with the corresponding Installation N-5 Code Data Report (certified by the Authorized Nuclear Inspector) ensure that the piping was constructed in accordance with the design specifications and the ASME Code Section Ill and that the satisfactory completion of the NDEs of piping pressure boundary welds for the pipe lines identified in Table 2.3.10-2 meet ASME Code Section Ill requirements and were documented in the NOE Reports within the supporting data packages.

4.a and 4.b) A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section 111 conform with the requirements of the ASME Code Section Ill.

Hydrostatic tests were performed both by the vendor in their manufacturing facility and in-situ once installed in the plant to demonstrate that the components identified in Table 2.3.10-1 (Attachment A) as ASME Code Section Ill retain their pressure boundary integrity at their design pressure . The completion of the vendor's N-5 Code Data Report is governed by Reference 3. The completion of in-situ testing is documented in Reference 4.

This portion of the ITAAC was completed once each component identified in Table 2.3.10-1 had their individual Code Symbol N-Stamp applied and the components were installed into the respective Code Symbol N-Stamped piping system and documented on the Installation N-5 Code Data Report (Reference 4) confirming that in-situ hydrostatic test(s) were successfully performed (no leaks at the pressure boundary) and corresponding N-5 Code Data Report completed .

The completion of stamping the individual components and the respective piping system along with the corresponding Installation N-5 Code Data Report (certified by the Authorized Nuclear Inspector) ensures that the components were constructed in accordance with the Design Specification and meets the ASME Code Section Ill requirements for hydrostatic pressure testing.

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 5 of 9 This ITAAC also verified that the piping identified in Table 2.3.10-2 (Attachment B) fully meets all applicable ASME Code , Section Ill requirements and retains its pressure boundary integrity at its design pressure.

Hydrostatic tests were performed (as applicable) that comply with the ASME Code (1998 Edition , 2000 Addenda), Section Ill requirements to demonstrate that the ASME Code Section Ill piping identified in Table 2.3.10-2 retains its pressure boundary integrity at its design pressure (Reference 4).

A hydrostatic test verified there were no leaks at welds or piping, and that the pressure boundary integrity is retained at its design pressure. The hydrostatic testing results of the pipe lines are documented in the Hydrostatic Testing Reports. The Hydrostatic Testing Reports support completion of the Installation N-5 Code Data Report for the applicable piping system (i.e., WLS) (Reference 4) .

The applicable Installation N-5 Code Data Report (Reference 4) identified in Attachments A and B documents that the results of the hydrostatic testing of the components and piping identified in Table 2.3.10-1 and Table 2.3.10-2 respectively conform with the requirements of the Code (1998 Edition , 2000 Addenda) , Section Ill.

5.b) A report exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional capability is required meets the requirements for functional capability.

An inspection was performed of the ASME Section Ill as-built piping design report (Reference 2) to verify that the report demonstrates that each of the WLS piping lines identified in ITAAC Table 2.3.10-2 that requires functional capability was designed to withstand combined normal and seismic design basis loads without a loss of its functional capability. "Functional capability,"

in this context, refe rs to the capability of the piping to withstand the effects of earthquakes, without a loss of safety function (to convey fluids from one location to another). Specific functional capability requirements are defined in the VEGP UFSAR Table 3.9-11 (Reference 6).

Piping functional capability is not a specific ASME Code requirement but it is a requirement in the VEGP UFSAR (Reference 6). As such, information demonstrating that UFSAR functional capability requirements were met is included in the ASME Section Ill As-Built Design Reports for safety class piping prepared in accordance with ASME Section Ill NCA-3550 under the ASME Boiler & Pressure Vessel Code (1998 Edition , 2000 Addenda) Section Ill requirements.

The as-built piping system was subjected to a reconciliation process (Reference 3) , which verified that the as-built piping system was analyzed for functional capability and for compliance with the design specification and ASME Code provisions. Design reconciliation of the as-built system validated that construction completion , including field changes and any nonconforming condition dispositions, were consistent with and bounded by the approved design. As required by ASME Code , the As-Built Design Report includes the results of physical inspection of the piping and reconciliation to the design pipe stress report.

Inspections of the ASME Code Section Ill As-Built Piping Design Report (Reference 2) for the WLS piping lines identified in Table 2.3.10-2 were completed and conclude that each of the as-built WLS piping lines for which functional capability is required met the requirements for

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 6 of 9 functional capability. The ASME Section Ill As-Built Piping Design Report for each of the as-built WLS piping lines in Table 2.3.10-2 are identified in Attachment B.

References 1, 2, 4 and 5 provide the evidence that the ITAAC Acceptance Criteria requirements are met:

• The ASME Code Section Ill design reports exists for the as-built components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section Ill;

• A report exists and concludes that the ASME Code Section Ill requirements were met for non-destructive examination of pressure boundary welds;

• A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section Ill conform with the requirements of the ASME Code Section Ill; and

• A report exists and concludes that each of the as-built lines identified in Table 2.3.10-2 for which functional capability is required meets the requirements for functional capability.

References 1, 2, 4 and 5 are available for NRC inspection as part of the Unit 4 ITAAC 2.3.10.02a Completion Package (References 7).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This review found that there are no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.10.02a (Reference 7) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.10.2a was performed for VEGP Unit 4 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.

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 7 of 9 References (available fo r NRC inspection)

1. SV0-PV03-VDR-175, Rev. 3, "Compliation of Design Reports for the as-built PV03 Datasheet 175 valves" 2 . SV4-WLS-S3R-001 , Rev. 0, "Vogtle Unit 4 Liquid Radwaste System A (WLS-A) ASME Section Ill Piping System Design Report"

3. APP-GW-GAP-139, Rev . 8 "Westinghouse/Stone & Webster ASME Code Data Report and As-Built Documentation Interface Procedure"

4. SV4-WLS-MJR-002, Rev. 0, "Liquid Radwaste System N-5 SV4-WLS-002"

5. SV4-WLS-MUR-001 , Rev. 0, "AP1000 Vogtle Unit 4 ASME Section Ill System Code Data Report for the Liquid Radwaste System (WLS-A)"

6. VEGP 3&4 Updated Final Safety Analysis Report, Rev. 11 .0

a. Subsection 5.2 .1 Compliance with Codes and Code Cases

b. Table 3.9 Piping Functional Capability- ASME Class 1, 2, and 3

7. 2.3.10.02a-U4-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 8 of 9 Attachment A SYSTEM: Liquid Radwaste System (WLS)

ASME Code ASME Ill as-built ASME Ill N-5 Code Equipment Name

• Tag No.*

Section Ill* Design Report Data Report WLS Drain from Passive Core Cooling System (PXS) WLS-PL-V071 B Yes SV4-WLS-S3R-001 Compartment A (Room 11206) SV4-WLS-MUR-001 Check Valve WLS Drain from PXS Compartment A (Room 11206) WLS-PL-V0728 Yes SV 4-WLS-S3R-00 1 SV4-WLS-MUR-001 Check Valve WLS Drain from PXS Compartment B (Room 11207) WLS-PL-V071 C Yes SV4-WLS-S3R-001 SV4-WLS-MUR-001 Check Valve WLS Drain from PXS Compartment B (Room 11207) WLS-PL-V072C Yes SV 4-WLS-S3R-00 1 SV4-WLS-MUR-001 Check Valve WLS Drain from Chemical and Volume Control System (CVS) SV4-WLS-S3R-001 SV4-WLS-MUR-001 WLS-PL-V071 A Yes Compartment (Room 11209)

Check Valve WLS Drain from CVS Compartment (Room 11209) WLS-PL-V072A Yes SV4-WLS-S3R-001 SV4-WLS-MUR-001 Check Valve

• Excerpts from COL Appendix C Table 2.3.10-1

U.S. Nuclear Regulatory Commission ND-22-0200 Enclosure Page 9 of 9 Attachment B SYSTEM: Liquid Radwaste System (WLS)

ASME Functional Line Code ASME Ill As-Built ASME Ill N-5 Line Name* Capability Number* Section Design Report Code Data Required*

Ill* Reports WLS Drain from SV4-WLS-S3R- SV4-WLS-MUR-PXS Compartment WLS-PL-L062 Yes Yes 001 001 A

WLS Drain from PXS Compartment WLS-PL-L063 Yes Yes SV4-WLS-S3R- SV4-WLS-MUR-B 001 001 WLS Drain from WLS-PL-L061 Yes Yes SV4-WLS-S3R- SV4-WLS-MUR-CVS Compartment 001 001

• Excerpts from COL Appendix C, Table 2.3.10-2