ND-23-0079, ITAAC Closure Notification on Completion of ITAAC 2.3.02.02a (Index Number 285)

ITAAC Closure Notification on Completion of ITAAC 2.3.02.02a (Index Number 285)

ML23033A575
Person / Time
Site:	Vogtle
Issue date:	02/02/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0079
Download: ML23033A575 (1)

Text

Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel

February 2, 2023

Docket No.: 52-026

ND-23-0079 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 2.3.02.02a [Index Number 285]

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 (ITAAC) Item 2.3.02.02a [Index Number 285]. This ITAAC verifies that the Chemical and Volume Control System components and piping listed in the Combined License Appendix C, Table 2.3.2-1 and Table 2.3.2-2, that are identified as American Society of Mechanical Engineers C ode Section III, were designed and constructed in accordance with applicable requirements. The closure process for this ITAAC is based on the guidance described in Nuclear Energ y 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 Kelli 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 2.3.02.02a [Index Number 285]

JMC/TL/sfr U.S. Nuclear Regulatory Commission ND-23-0079 Page 2 of 2

cc: Regional Administrator, Region ll Director, Office of Nuclear Reactor Regulation (NRR)

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

U.S. Nuclear Regulatory Commission ND-23-0079 Enclosure Page 1 of 9

Southern Nuclear Operating Company ND-23-0079 Enclosure

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.02.02a [Index Number 285]

U.S. Nuclear Regulatory Commission ND-23-0079 Enclosure Page 2 of 9

ITAAC Statement

Design Commitment:

2.a) The components identified in Table 2.3.2-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

2.b) The piping identified in Table 2.3.2-2 as ASME Code Section III is designed and constructed in accordance with ASME Code Section III requirements.

3.a) Pressure boundary welds in components identified in Table 2.3.2-1 as ASME Code Section III meet ASME Code Section III requirements.

3.b) Pressure boundary welds in piping identified in Table 2.3.2-2 as ASME Code Section III meet ASME Code Section III requirements.

4.a) The components identified in Table 2.3.2-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.3.2-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure.

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 III.

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

Acceptance Criteria:

The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.2-1 and 2.3.2-2 as ASME Code Section III.

A report exists and concludes that the ASME Code Section III requirements are 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 2.3.2-1 and 2.3.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

ITAAC Determination Basis

This ITAAC required inspections, tests, and analyses be performed and documented to ensure the Chemical and Volume Control System (CVS) components and piping listed in the Combined U.S. Nuclear Regulatory Commission ND-23-0079 Enclosure Page 3 of 9

License (COL) Appendix C, Table 2.3.2-1 (Attachment A) and Table 2.3.2-2 (Attachment B) that are identified as American Society of Mechanical Engineers (ASME) Code Section III, are designed and constructed in accordance with applicable requirements.

2.a and 2.b) The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.2-1 and 2.3.2-2 as ASME Code Section III.

Each component listed in Table 2.3.21 as ASME Code Section III was fabricated in accordance with the VEGP Updated Final Safety Analysis Report (UFSAR) and the ASME Code Section III requirements. The ASME Code Section III certified Design Reports, for these components exist and document that the as-built components conform to the approved design details. The ASME Section III Design Report for each component is documented in the components completed ASME Section III Code Data Report. The individual component ASME Section III Code Data Reports are documented on the ASME Section III N -5 Code Data Report for the applicable piping system (Reference 1).

The as-built piping listed in Table 2.3.2-2 including the components listed in Table 2.3.2-1 as ASME Code Section III, were subjected to a reconciliation process (Reference 2), which verified 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 systems, including installed components, validated 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 confirmed adequate construction in compliance with the ASME Code Section III and design provisions, are referenced in the N-5 Data Report and/or its sub-tier references.

The applicable ASME Section III N-5 Code Data Reports, which include the location of the certified Design Reports, for all the components listed in Table 2.3.2-1 (Attachment A) and piping listed in Table 2.3.2-2 (Attachment B) as ASME Code Section III, exist and conclude that these installed components were designed and constructed (including their installation within the applicable as-built piping system) in accordance with the ASME Code (1998 Edition, 2000 Addenda and 1989 Edition, 1989 Addenda),Section III requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference 3). The N-5 Code Data Reports for the piping system containing the components listed in the Table 2.3.2-1 and Table 2.3.2-2 are identified in Attachments A and B, respectively.

3.a and 3.b) A report exists and concludes that the ASME Code Section III requirements are met for non-destructive examination of pressure boundary welds.

Inspections were performed in accordance with ASME Code Section III (1998 Edition, 2000 Addenda) to demonstrate that as-built pressure boundary welds in components identified in Table 2.3.2-1 as ASME Code Section III meet ASME Code Section III requirements (i.e., no unacceptable indications).

The applicable non-destructive examinations (including liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the components pressure boundary welds are documented in the Non-destructive Examination Report(s), which support completion of the respective ASME Section III N-5 Code Data Report certified by the Authorized Nuclear Inspector, as listed in Attachment A.

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Per ASME Code Section III, Subarticle NCA-8300, Code Symbol Stamps, the N-5 Code Data Report (Reference 1), documented satisfactory completion of the required examination and testing of the item, which includes non-destructive examinations of pressure boundary welds.

Satisfactory completion of the non-destructive examination of pressure boundary welds ensures that the pressure boundary welds in components identified in Table 2.3.2-1 as ASME Code Section III met ASME Code Section III requirements.

An inspection was performed in accordance with Reference 2 to demonstrate that the as-built pressure boundary welds in piping identified in Table 2.3.2-2 (Attachment B) as ASME Code Section III met ASME Code Section III requirements (i.e., no unacceptable indications). This portion of the ITAAC was completed when the piping identified in Table 2.3.2-2, which is encompassed within the respective piping system Code Symbol N-Stamp and the corresponding piping system Code N-5 Data Report (Reference 1), was completed. The non-destructive examinations (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section III) of the piping pressure boundary welds were documented in the Non-destructive Examination Report(s) within the piping systems supporting data package, which support completion of the respective Code Stamping and Code N-5 Data Report. The completion of stamping the respective piping system along with the corresponding ASME Code N-5 Data Reports (certified by the Authorized Nuclear Inspector) ensured that the piping was constructed in accordance with the design specifications and the ASME Code Section III and that the satisfactory completion of the non-destructive examinations of piping pressure boundary welds for the pipe lines identified in Table 2.3.2-2 met ASME Code Section III requirements and were documented in the Non-destructive Examination Report(s) 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 2.3.2-1 and 2.3.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

Hydrostatic tests were performed by the vendor to demonstrate that the components identified in Table 2.3.2-1 (Attachment A) as ASME Code Section III retain their pressure boundary integrity at their design pressure. The completion of the N-5 Data Reports is governed by Reference 2.

This portion of the ITAAC was completed once each component identified in Table 2.3.2-1 had their individual Code Symbol N-Stamp and corresponding Code Data Report completed, and the components installed into the respective Code Symbol N-Stamped piping system and documented on the corresponding N-5 Code Data Report (Reference 1). The hydrostatic testing results of the components pressure boundary were documented in the Hydrostatic Testing Report(s) within the supporting components data package, which support completion of the respective Code Stamping and Code Data Report(s).

The completion of stamping the individual components and the respective piping system along with the corresponding ASME Code Data Reports (certified by the Authorized Nuclear Inspector) ensures that the components were constructed in accordance with the Design Specifications and the ASME Code Section III and that the satisfactory completion of the hydrostatic testing of each component identified in Table 2.3.2-1 as ASME Code Section III were documented in the Hydrostatic Testing Report(s) within the supporting data packages and met ASME Code Section III requirements.

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This ITAAC also verified that the piping identified in Table 2.3.2-2 (Attachment B) fully met all applicable ASME Code,Section III requirements and retains its pressure boundary integrity at its design pressure.

Hydrostatic tests were performed in accordance with procedures identified in Reference 1 (as applicable) that comply with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements to demonstrate that the ASME Code Section III piping identified in Table 2.3.2-2 retains its pressure boundary integrity at its design pressure.

The hydrostatic tests verified that there were no leaks at welds or piping, and that the pressure boundary integrity was retained at its design pressure. The hydrostatic testing results of the pipe lines are documented in the Hydrostatic Testing Report(s). The Hydrostatic Testing Report(s) supports completion of the ASME Section III N-5 Code Data Reports for the applicable piping system (i.e., CVS) (Reference 1).

The applicable ASME Section III N-5 Code Data Report(s) (Reference 1) identified in Attachments A and B documents that the results of the hydrostatic testing of the components and piping identified in Table 2.3.2-1 and Table 2.3.2-2 respectively conform with the requirements of the Code (1998 Edition, 2000 Addenda),Section III.

Reference 1 provides the evidence that the ITAAC Acceptance Criteria requirements were met:

• The ASME Code Section III design reports exist for the as-built components and piping identified in Tables 2.3.2-1 and 2.3.2-2 as ASME Code Section III;

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

• A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.2-1 and 2.3.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

This ITAAC also verified that Preservice Inspection (PSI) for the applicable portions of the Class 1, 2, and 3 Chemical and Control Volume System (CVS) components and piping identified in Tables 2.3.2-1 and 2.3.2-2 were completed (Reference 7), in accordance with the Unit 4 PSI program plan (Reference 5), and that the results of the PSI conforms with the requirements of the ASME Boiler and Pressure Vessel (B&PV) Code.

References 1 and 4 are available for NRC inspection as part of the Unit 4 ITAAC 2.3.02.02a Completion Package (Reference 6).

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, which included now consolidated ITAAC Indexes 286, 287, 288, 289 and 290, found no relevant ITAAC findings associated with this ITAAC. The U.S. Nuclear Regulatory Commission ND-23-0079 Enclosure Page 6 of 9

ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.02.02a (Reference 6) and is available for NRC review.

ITAAC Completion Statement

Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.02.02a 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.

References (available for NRC inspection)

1. SV4-CVS-MUR-001, Rev. 0, AP1000 Vogtle Unit 4 ASME Section III System Code Data Report for the Chemical and Volume Control System (CVS)

2. APP-GW-GAP-139, Rev. 9, Westinghouse/Stone & Webster ASME Code Data Report and As-Built Documentation Interface Procedure

3. VEGP 3&4 Updated Final Safety Analysis Report, Rev. 11.1, Subsection 5.2.1, Compliance with Codes and Code Cases

4. SV4-CVS-S3R-001, Rev. 0, Vogtle Unit 4 Chemical Volume and Control System (CVS)

ASME Section III As-Built Piping System Design Report

5. SV4-GW-GEI-100, Rev. 2, AP1000 Preservice Inspection Program Plan for Vogtle Unit 4

6. 2.3.02.02a-U4-CP-Rev0, ITAAC Completion Package

7. APE-10-00025, SNC Interoffice Memo, dated 1/27/2023, From Ken Baity to Kelli Roberts; Completion of Preservice Inspection for the Vogtle Unit 4 CVS Class 1, 2, and 3 Portions of Systems

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Attachment A

SYSTEM: Chemical and Volume Control System (CVS)

Equipment Name

• Tag No.

• ASME Code ASME III As-Built N-5 Report Section III* Design Report RCS Purification Motor-operated CVS-PL-V001 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Isolation Valve RCS Purification Motor-operated CVS-PL-V002 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Isolation Valve RCS Purification Motor-operated CVS-PL-V003 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Isolation Valve CVS Resin Flush Line CVS-PL-V040 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Valve CVS Resin Flush Line CVS-PL-V041 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Valve CVS Demineralizer Resin Flush Line CVS-PL-V042 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Thermal Relief Valve CVS Letdown CVS-PL-V045 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Valve CVS Letdown CVS-PL-V047 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Valve CVS Letdown Line Containment Isolation CVS-PL-V058 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Thermal Relief Valve CVS Makeup Return Line Bypass Check CVS-PL-V067 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Valve CVS Purification Return Line Pressure CVS-PL-V080 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Boundary Check Valve

CVS Purification Return Line Pressure Boundary Isolation CVS-PL-V081 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Check Valve

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Attachment A

SYSTEM: Chemical and Volume Control System (CVS)

Equipment Name

• Tag No.

• ASME Code ASME III As-Built N-5 Report Section III* Design Report CVS Purification Return Line Pressure CVS-PL-V082 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Boundary Check Valve CVS Auxiliary Pressurizer Spray CVS-PL-V084 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line Pressure Boundary Valve CVS Auxiliary Pressurizer Spray CVS-PL-V085 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line Pressure Boundary Check Valve CVS Makeup Line CVS-PL-V090 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Motor-operated Valve CVS Makeup Line CVS-PL-V091 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Isolation Motor-operated Valve CVS Zinc Injection Containment Isolation CVS-PL-V092 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Valve ORC CVS Zinc Injection Containment Isolation CVS-PL-V094 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Valve IRC CVS Zinc Addition Line Ctmt Isol Thermal CVS-PL-V098 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Relief Valve CVS Makeup Line Containment Isolation CVS-PL-V100 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Thermal Relief Valve CVS Demineralized CVS-PL-V136A Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Water Isolation Valve CVS Demineralized CVS-PL-V136B Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Water Isolation Valve CVS Hydrogen Injection Containment CVS-PL-V217 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Isolation Check Valve IRC CVS Hydrogen Injection Containment CVS-PL-V219 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Isolation Valve ORC

• Excerpts from COL Appendix C Table 2.3.2-1 U.S. Nuclear Regulatory Commission ND-23-0079 Enclosure Page 9 of 9

Attachment B

SYSTEM: Chemical and Volume Control System (CVS)

ASME Code ASME III As-Built Line Name* Line Number* Section III* Design Report N-5 Report

CVS Purification Line L001 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 L040 Yes CVS Resin Flush Containment Penetration L026+ Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line CVS Purification Line L038 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Return CVS Pressurizer Auxiliary L070+ Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Spray Connection L071+ Yes CVS Letdown Containment Penetration L051+ Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line CVS Makeup Containment Penetration L053 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line CVS Hydrogen Injection L213+ Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Containment Penetration L214+

Line L217+

CVS Zinc Injection Containment Penetration L061+ Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Line CVS Return Line from L036 Yes SV4-CVS-S3R-001 SV4-CVS-MUR-001 Regenerative Heat Exchanger

• Excerpts from COL Appendix C, Table 2.3.2-2

+ For girth fillet welds between piping and socket welded fittings, valves and flanges, refer to VEGP UFSAR Section 5.2.1.1 (Reference 3).