ND-22-0649, ITAAC Closure Notification on Completion of ITAAC 2.1.02.12a.iv (Index Number 56)

ITAAC Closure Notification on Completion of ITAAC 2.1.02.12a.iv (Index Number 56)

ML23013A303
Person / Time
Site:	Vogtle
Issue date:	01/13/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0649
Download: ML23013A303 (1)

Text

A Southern Nuclear Jamie M. Coleman Regulatory Affairs Director Vogtle 3 &4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel January 13, 2023 Docket No.: 52-026 ND-22-0649 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 ITMC Closure Notification on Completion of ITMC 2.1.02.12a.iv [Index Number 56]

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 4 Inspections, Tests, Analyses, and Acceptance Criteria (ITMC) Item 2.1.02.12a.iv [Index Number 56]. This ITMC confirms that the Reactor Coolant System squib valves identified in the VEGP Unit 4 Combined License (COL) Appendix C, Table 2.1.2-1 can perform an active safety-related function.

The closure process for this ITMC is based on the guidance described in Nuclear Energy Institute (NEI) 08-01, "Industry Guideline for the ITMC 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 N RC 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, (oOJfwJ ~

Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITMC 2.1.02.12a.iv [Index Number 56]

JMC/PAW/sfr

U.S. Nuclear Regulatory Commission ND-22-0649 Page 2 of 2 cc: Regional Administrator, Region II Director, Office of Nuclear Reactor Regulation (NRR)

Director, Vogtle Project Office NRR Senior Resident Inspector- Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-22-0649 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-22-0649 Enclosure Vogtle Electric Generating Plant (VEGP} Unit 4 Completion of ITAAC 2.1.02.12a.iv [Index Number 56]

U.S. Nuclear Regulatory Commission ND-22-0649 Enclosure Page 2 of 5 ITAAC Statement Design Commitment 12.a) The automatic depressurization valves identified in Table 2.1.2-1 perform an active safety-related function to change position as indicated in the table.

Inspections, Tests, Analyses iv) Tests or type tests of squib valves will be performed that demonstrate the capability of the valve to operate under its design conditions.

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

Acceptance Criteria iv) A test report exists and concludes that each squib valve changes position as indicated in Table 2.1 .2-1 under design conditions.

v) A report exists and concludes that the as-built squib 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 Reactor Coolant System (RCS) automatic depressurization (squib) valves identified in the Combined License (COL) Appendix C, Table 2.1.2-1 perform an active safety-related function to change position as indicated in the table.

iv) A test report exists and concludes that each squib valve changes position as indicated in Table 2.1.2-1 under design conditions.

This acceptance criteria requires tests or type tests of squib valves to be performed to demonstrate the capability of the valve to operate under its design conditions.

The functional qualification program for the AP1000 squib valves is developed based on American Society of Mechanical Engineers (ASME) QME-1-2007, "Qualification of Active Mechanical Equipment Used in Nuclear Power Plants" (Reference 1). The qualification was based on the ASME QME-1-2007 requirements for power operated valve assemblies.

Functional qualification was performed under the design conditions identified in the design specification for the valves (Reference 2) to demonstrate that each squib valve is qualified to perform its designated function when used in its intended service. In accordance with ASME QME-1-2007, qualification is 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, sealing capability testing, functional operation, and flow characteristics, for the ranges of the pressure,

U.S. Nuclear Regulatory Commission ND-22-0649 Enclosure Page 3 of 5 temperature and flow for each valve. In accordance with ASME QME-1-2007, the functional qualification process for these valves also included valve internal inspections, actuator inspection and testing, orientation requirements, leakage limitations, diagnostic data collection and analysis methods, static and dynamic flow diagnostic testing, and thermal binding evaluations.

The results of the qualification are documented in the Equipment Qualification (EQ) 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 squib valve changes position as indicated in VEGP Unit 4 COL Appendix C Table 2.1.2-1 under design conditions.

v) A report exists and concludes that the as-built squib valves are bounded by the tests or type tests.

This acceptance criteria requires that an inspection is performed for the existence of a report verifying that the as-built squib valves are bounded by tests or type tests.

The squib valves in VEGP Unit 4 COL Appendix C Table 2.1.2-1 are verified by the type tests in accordance with ITAAC 2.1.02.12a.iv (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 and the EQ ITAAC As-built Installation Documentation Guideline (References 4 & 5), an inspection was conducted of the RCS to confirm the satisfactory installation of the squib valves. The inspection includes 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 squib valves includes photographs and/or sketches of equipment mounting and connections. The verification of installed component configuration is documented in the EQ As-Built Reconciliation Report (EQRR) (Reference 6).

Attachment A identifies the EQRR which verify that the installed configuration of the squib valves identified in VEGP Unit 4 COL Appendix C Table 2.1.2-1 are bounded by the tests or type tests.

Together, these EQ Reports and EQRR (References 3 and 6), provide evidence that the ITAAC Acceptance Criteria requirements are met:

• A test report exists and concludes that each squib valve changes position as indicated in Table 2.1.2-1 under design conditions; and

• A report exists and concludes that the as-built squib valves are bounded by the tests or type tests.

References 3 and 6 are available for NRC inspection as part of the Unit 4 ITAAC 2.1.02.12a.iv Completion Package (Reference 7).

U.S. Nuclear Regulatory Commission ND-22-0649 Enclosure Page 4 of 5 ITAAC Finding Review In accordance with plant procedures for ITMC completion, Southern Nuclear Operating Company (SNC) performed a review of all ITMC findings pertaining to the subject ITMC and associated corrective actions. This finding review, which included now-consolidated ITMC Index 57, found the following relevant ITMC findings associated with this ITMC:

• Notice of Nonconformance 99900080/2013-201-01 (Closed - ML18152B785)

• Notice of Nonconformance 99900080/2013-201-02 (Closed - ML18152B785)

• Notice of Nonconformance 99900080/2012-201-01 (Closed - ML18152B785)

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITMC 2.1.02.12a.iv was performed for VEGP Unit 4 and that the prescribed acceptance criteria are met.

Systems, structures, and components verified as part of this ITMC are being maintained in their as-designed, ITMC compliant condition in accordance with the 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. APP-PV70-Z0-001 Revision 7, "Squib (Pyrotechnic Actuated) Valves, ASME Boiler and Pressure Vessel Code, Section Ill Class 1"

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

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

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

6. As-Built Equipment Qualification Reconciliation Reports (EQRR) as identified in Attachment A for Unit 4

7. 2.1.02.12a.iv-U4-CP-Rev0, ITMC Completion Package

U.S. Nuclear Regulatory Comm ission ND-22-0649 Enclosure Page 5 of 5 Attachment A System: Reactor Coolant System (RCS)

Active Equipment Name + Tag No.+ Function EQ Reports {Reference 3) As-Built EQRR {Reference 6)

+

Fourth-stage ADS Transfer SV4-PV70-VBR-005 / 2.1.02.12a.iv-U4-EQRR-RCS-PL-V004A Squib Valve Ooen SV4-PV70-VBR-004 PCD001 Fourth-stage ADS Transfer SV4-PV70-VBR-005 / 2.1.02.12a.iv-U4-EQRR-RCS-PL-V004B Squib Valve Ooen SV4-PV70-VBR-004 PCD001 Fourth-stage ADS Transfer SV4-PV70-VBR-005 / 2.1.02.12a.iv-U4-EQRR-RCS-PL-V004C Squib Valve Ooen SV4-PV70-VBR-004 PCD001 Fourth-stage ADS Transfer SV4-PV70-VBR-005 / 2.1.02.12a.iv-U4-EQRR-RCS-PL-V004D Squib Valve Ooen SV4-PV70-VBR-004 PCD001 Notes:

+ Excerpt from COL Appendix C Table 2.1 .2-1