ND-23-0382, ITAAC Closure Notification on Completion of ITAAC 2.3.07.02a (Index Number 392)

ITAAC Closure Notification on Completion of ITAAC 2.3.07.02a (Index Number 392)

ML23131A177
Person / Time
Site:	Vogtle
Issue date:	05/11/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0382, ITAAC 2.3.07.02a
Download: ML23131A177 (1)

Text

Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel May 11, 2023 Docket No.: 52-026 ND-23-0382 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 2.3.07.02a [Index Number 392]

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 2.3.07.02a [Index Number 392]. This ITAAC verifies that the Spent Fuel Pool Cooling System (SFS) components listed in the Combined License (COL) Appendix C, Tables 2.3.7-1 and 2.3.7-2 that are identified as American Society of Mechanical Engineers (ASME) Code 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 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 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 2.3.07.02a [Index Number 392]

JMC/TL/sfr

U.S. Nuclear Regulatory Commission ND-23-0382 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-23-0382 Enclosure Page 1 of 7 Southern Nuclear Operating Company ND-23-0382 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.07.02a [Index Number 392]

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 2 of 7 ITAAC Statement Design Commitment:

2.a) The components identified in Table 2.3.7-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

2.b) The piping lines identified in Table 2.3.7-2 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

3. Pressure boundary welds in piping lines identified in Table 2.3.7-2 as ASME Code Section III meet ASME Code Section III requirements.

4. The piping lines identified in Table 2.3.7-2 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

Inspections, Tests, Analyses:

Inspection will be conducted of the ASME as-built components and piping lines 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 piping lines 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 lines identified in Tables 2.3.7-1 and 2.3.7-2 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 piping lines identified in Table 2.3.7-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

ITAAC Determination Basis This ITAAC requires inspections, tests, and analyses be performed and documented to ensure the Spent Fuel Pool Cooling System (SFS) components and piping lines listed in the Combined License (COL) Appendix C, Table 2.3.7-1 (Attachment A) and Table 2.3.7-2 (Attachment B) that are identified as American Society of Mechanical Engineers (ASME) Code Section III, are designed and constructed in accordance with applicable requirements.

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 3 of 7 2.a and 2.b) The ASME Code Section III design reports exist for the as-built components and piping lines identified in Tables 2.3.7-1 and 2.3.7-2 as ASME Code Section III.

Each component listed in Table 2.3.71 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 was 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(s) for the applicable piping system (Reference 1).

The as-built piping lines listed in Table 2.3.7-2 including the components listed in Table 2.3.7-1 as ASME Code Section III, were subjected to a reconciliation process (Reference 2), which verified that the as-built piping lines were 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, validates that construction completion, including field changes and any nonconforming condition dispositions, was 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 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 Report(s), which include the location of the certified Design Reports for all the components listed in Table 2.3.7-1 (Attachment A) and piping lines listed in Table 2.3.7-2 (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(s) containing the components listed in the Table 2.3.7-1 and Table 2.3.7-2 are identified in Attachments A and B, respectively.

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

An inspection was performed in accordance with Reference 2 to demonstrate that the as-built pressure boundary welds in piping lines identified in Table 2.3.7-2 (Attachment B) as ASME Code Section III met ASME Code Section III requirements (i.e., no unacceptable indications).

This portion of the ITAAC was complete when the piping lines identified in Table 2.3.7-2, which is encompassed within the respective piping system Code Symbol N-Stamp and the corresponding piping system Code N-5 Data Report Form(s) (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 lines pressure boundary welds are 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(s).

The completion of stamping the respective piping system along with the corresponding ASME Code N-5 Data Report Form(s) (certified by the Authorized Nuclear Inspector) ensured that the piping lines were constructed in accordance with the design specification(s) and the ASME

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 4 of 7 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 2.3.7-2 meet ASME Code Section III requirements and were documented in the Non-destructive Examination Report(s) within the supporting data packages.

4. A report exists and concludes that the results of the hydrostatic test of the piping lines identified in Table 2.3.7-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

This ITAAC verifies that the piping lines identified in Table 2.3.7-2 (Attachment B) fully met all applicable ASME Code,Section III requirements and retains its pressure boundary integrity at its design pressure.

A hydrostatic test was performed (as applicable) that comply with the ASME Code (1998 Edition, 2000 Addenda),Section III requirements to demonstrate that the ASME Code Section III piping lines identified in Table 2.3.7-2 retains its pressure boundary integrity at its design pressure.

A hydrostatic test verified that there are no leaks at welds or piping lines, 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 Report(s) for the applicable piping system (i.e., SFS) (Reference 1).

The applicable ASME Section III N-5 Code Data Report(s) (Reference 1) identified in Attachment B documents that the results of the hydrostatic testing of the piping lines identified in Table 2.3.7-2 conform with the requirements of the Code (1998 Edition, 2000 Addenda),Section III.

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

• The ASME Code Section III design reports exist for the as-built components and piping lines identified in Tables 2.3.7-1 and 2.3.7-2 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; and

• A report exists and concludes that the results of the hydrostatic test of piping lines identified in Table 2.3.7-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

This ITAAC also verifies that Preservice Inspection (PSI) for the applicable portions of Class 2 and 3 Spent Fuel Pool Cooling System (SFS) components and piping identified in Tables 2.3.7.1 and 2.3.7-2 were completed (Reference 7), in accordance with the Unit 4 PSI program plan, (Reference 5), and 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 2.3.07.02a Completion Package (Reference 6).

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 5 of 7 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, which included now consolidated ITAAC Indexes 393, 394 and 395 found no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.07.02a (Reference 6) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.07.02a 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-SFS-MUR-001, Rev. 0, AP 1000 Vogtle Unit 4 ASME Section III System Code Data Report for the Spent Fuel Pool Cooling System (SFS)

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. 11.2, Subsection 5.2.1, Compliance with Codes and Code Cases

4. SV4-SFS-S3R-001, Rev. 0, Vogtle Unit 4 Spent Fuel Pool Cooling System (SFS) ASME Section III As-Built Piping System Design Report

5. SV4-GW-GEI-100, Rev. 1, AP1000 Preservice Inspection Program Plan for Vogtle Unit 4

6. 2.3.07.02a-U4-CP-Rev0, ITAAC Completion Package

7. APE-10-00026, SNC Interoffice Memo, dated 3/31/2023, Completion of Preservice Inspection for the Vogtle Unit 4 PCS and SFS Class 1, Class 2, and 3 Portions of Systems

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 6 of 7 Attachment A SYSTEM: Spent Fuel Pool Cooling System (SFS)

ASME Code System Design Component Name

• Tag No.

• Report N-5 Report Section III*

Refueling Cavity Drain to SGS Compartment SFS-PL-V031 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Isolation Valve Refueling Cavity to SFS Pump Suction Isolation SFS-PL-V032 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Valve Refueling Cavity Drain to Containment Sump SFS-PL-V033 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Isolation Valve IRWST to SFS Pump SFS-PL-V039 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Suction Line Isolation Valve Fuel Transfer Canal to SFS SFS-PL-V040 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Pump Suction Iso. Valve Cask Loading Pit to SFS Pump Suction Isolation SFS-PL-V041 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Valve Cask Loading Pit to SFS Pump Suction Isolation SFS-PL-V042 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Valve SFS Pump Discharge Line to Cask Loading Pit SFS-PL-V045 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Isolation Valve Cask Loading Pit to SFS-PL-V049 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 WLS Isolation Valve Spent Fuel Pool to Cask Washdown Pit Isolation SFS-PL-V066 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Valve Cask Washdown Pit Drain SFS-PL-V068 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Isolation Valve Refueling Cavity Drain Line SFS-PL-V071 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Check Valve Refueling Cavity Drain Line SFS-PL-V072 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Check Valve SFS Containment Floodup SFS-PL-V075 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Isolation Valve

• Excerpts from COL Appendix C Table 2.3.7-1

U.S. Nuclear Regulatory Commission ND-23-0382 Enclosure Page 7 of 7 Attachment B SYSTEM: Spent Fuel Pool Cooling System (SFS)

Line ASME Code System Design Piping Line Name* Report N-5 Report Number* Section III*

Spent Fuel Pool to RNS L014 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Pump Suction Cask Loading Pit to RNS L115 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Pump Suction Refueling Cavity Drain L033+ Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 PXS IRWST to SFS L035 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Pump Suction Refueling Cavity Skimmer to SFS Pump L036 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Suction Refueling Cavity Drain L037 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Refueling Cavity Drain L044+ Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Fuel Transfer Canal L047 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Drain Cask Washdown Pit L068 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Drain Cask Loading Pit Drain L043 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Cask Pit Transfer Branch L045 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Line Spent Fuel Pool Containment Isolation L052+ Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Thermal Relief Line Refueling Cavity Drain L030 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Upender Pit Drain/Fill L121 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Line Spent Fuel Pool Drain L066+ Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Cask Loading Pit to WLS L067+ Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 RNS Return to Spent L100 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Fuel Pool SFS Containment L120 Yes SV4-SFS-S3R-001 SV4-SFS-MUR-001 Floodup Line

• Excerpts from COL Appendix C, Table 2.3.7-2

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