ND-22-0736, ITAAC Closure Notification on Completion of ITAAC 2.5.02.02.i (Index Number 522)

ITAAC Closure Notification on Completion of ITAAC 2.5.02.02.i (Index Number 522)

ML23133A017
Person / Time
Site:	Vogtle
Issue date:	05/13/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0736, ITAAC 2.5.02.02.i
Download: ML23133A017 (1)

Text

Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel May 13, 2023

Docket No.: 52-026

ND-22-0736 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 2.5.02.02.i [Index Number 522]

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 2.5.02.02.i [Index Number 522] to demonstrate that the Protection and Safety Monitoring System (PMS) equipment identified as seismic Category I or Class 1E in the Combined License (COL)

Appendix C, Table 2.5.2-1 is designed and constructed in accordance with applicable requirements.

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 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 2.5.02.02.i [Index Number 522]

JMC/JRB/sfr

U.S. Nuclear Regulatory Commission ND-22-0736 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

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Southern Nuclear Operating Company ND-22-0736 Enclosure

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.5.02.02.i [Index Number 522]

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ITAAC Statement

Design Commitment

2. The seismic Category I equipment, identified in Table 2.5.2-1, can withstand seismic design basis loads without loss of safety function.

3. The Class 1E equipment, identified in Table 2.5.2-1, has electrical surge withstand capability (SWC), and can withstand the electromagnetic interference (EMI), radio frequency interference (RFI), and electrostatic discharge (ESD) conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

4. The Class 1E equipment, identified in Table 2.5.2-1, can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

Inspections, Tests, Analyses

i) Inspection will be performed to verify that the seismic Category I equipment identified in Table 2.5.2-1 is located on the Nuclear Island.

ii) Type tests, analyses, or a combination of type tests and analyses of seismic Category I equipment will be performed.

iii) Inspection will be performed for the existence of a report verifying that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions.

Type tests, analyses, or a combination of type tests and analyses will be performed on the equipment.

Type tests, analyses, or a combination of type tests and analyses will be performed on the Class 1E equipment identified in Table 2.5.2-1.

Acceptance Criteria

i) The seismic Category I equipment identified in Table 2.5.2-1 is located on the Nuclear Island.

ii) A report exists and concludes that the seismic Category I equipment can withstand seismic design basis loads without loss of safety function.

iii) A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions.

A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the SWC, EMI, RFI, and ESD conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

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A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

ITAAC Determination Basis

This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Protection and Safety Monitoring System (PMS) equipment identified as seismic Category I or Class 1E in the Combined License (COL) Appendix C, Table 2.5.2-1 (the Table) is designed and constructed in accordance with applicable requirements.

i) The seismic Category I equipment identified in Table 2.5.2-1 is located on the Nuclear Island.

To assure that seismic Category I equipment can withstand seismic design basis loads without loss of safety function, all the equipment in the Table is designed to be located on the seismic Category I Nuclear Island. In accordance with Equipment Qualification (EQ) Walkdown ITAAC Guideline and the EQ ITAAC As-Built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the PMS to confirm the satisfactory installation of the seismically qualified equipment. The inspection includes verification of equipment make/model/serial number and verification of equipment location (Building, Elevation, Room).

The EQ As-Built Reconciliation Report (EQRR) (Reference 3) identified in Attachment A document the results of the inspection and conclude that the seismic Category I equipment is located on the Nuclear Island.

ii) A report exists and concludes that the seismic Category I equipment can withstand seismic design basis loads without loss of safety function.

Seismic Category I equipment in the Table requires type tests and/or analyses to demonstrate structural integrity and operability. Safety-related (Class 1E) electrical equipment in the Table was seismically qualified by type testing combined with analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference 4). The specific qualification method (i.e., type testing, analysis, or combination) used for each piece of equipment in the Table is identified in Attachment A. Additional information about the methods used to qualify AP1000 safety-related equipment is provided in the Updated Final Safety Analysis Report (UFSAR) Appendix 3D (Reference 5). The EQ Reports (Reference 6) identified in Attachment A contain applicable test reports and associated documentation and conclud e that the seismic Category I equipment can withstand seismic design basis loads without loss of safety function.

iii) A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions.

An inspection (Reference s 1 & 2) was conducted to confirm the satisfactory installation of the seismically qualified equipment in the Table. The inspection verified the equipment make/model/serial number, as-designed equipment mounting orientation, anc horage and clearances, and electrical and other interfaces. The documentation of installed configuration of seismically qualified equipment includes photographs and/or sketches/drawings of equipment/mounting/interfaces.

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As part of the seismic qualification program, consideration is given to the definition of the clearances needed around the equipment mounted in the plant to permit the equipment to move during a postulated seismic event without causing impact between adjacent pieces of safety-related equipment. When required, seismic testing by measuring the maximum dynamic relative displacement of the top and bottom of the equipment was performed. EQ Reports (Reference 6) identify the equipment mounting employed for qualification and establish interface requirements for assuring that subsequent in-plant installation does not degrade the established qualification.

Interface requirements are defined based on the test configuration and other design requirements.

Attachment A identifies the EQRR (Reference 3) completed to verify that the as-built seismic Category I equipment listed in the Table, including anchorage, are seismically bounded by the tested or analyzed conditions, IEEE Standard 344-1987 (Reference 4) and NRC Regulatory Guide (RG) 1.100 (Reference 7).

A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the SWC, EMI, RFI, and ESD conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

The Class 1E equipment in the Table was qualified by a combination of type testing and analysis in accordance with RG 1.180 (Reference 8) and industry standards. The specific qualification method (i.e., type testing, analysis, or combination) used for each piece of equipment in the Table is identified in Attachment A. The baseline Military Standard (MIL-STD) program is used in its entirety for emissions testing as described in Attachment B, and shows the Electromagnetic Compatibility (EMC) type test and category ( SWC, EMI, RFI or ESD), the test standard, and the application. The alternate International Electrotechnical Commission (IEC) program is used in its entirety for susceptibility testing as described in similar fashion in Attachment C. The testing described in the attachments is a complete set for this ITAAC in accordance with RG 1.180 and the ESD test requirement, and compliant results of th ese tests combined with the location analysis indicate that the ITAAC acceptance criteria was met.

The results of the tests and analysis are documented in the EQ Reports (Reference 6) identified in Attachment A and conclude that the Class 1E equipment ide ntified in the Table has SWC and can withstand the EMI, RFI, and ESD conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

The Class IE equipment identified in the Table was qualified by a combination of type testing and analysis in accordance with IEEE Standard 323-1974 (Reference 9) and RG 1.89 (Reference 10) to meet the requirements of 10 CFR 50.49. This demonstrates that the equipment can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function. Additional information about the methods used to qualify AP1000 safety-related equipment is provided in UFSAR Appendix 3D (Reference 5).

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EQ Reports (Reference 6) identified in Attachment A contain applicable test reports and associated documentation and conclude the equipment identified in the Table can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

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

• The seismic Category I equipment identified in Table 2.5.2-1 is located on the Nuclear Island;

• A report exists and concludes that the seismic Category I equipment can withstand seismic design basis loads without loss of safety function;

• A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions;

• A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the SWC, EMI, RFI, and ESD conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function; and

• A report exists and concludes that the Class 1E equipment identified in Table 2.5.2-1 can withstand the room ambient temperature, humidity, pressure, and mechanical vibration conditions that would exist before, during, and following a design basis accident without loss of safety function for the time required to perform the safety function.

References 3 and 6 are available for NRC inspection as part of the Unit 4 ITAAC 2.5.02.02.i Completion Package (Reference 11).

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 finding review, which included now-consolidated ITAAC Indexes 523, 524, 525, and 526, found the following Notices of Nonconformance (NON) associated with this ITAAC:

1) 99900404/2015-204-02 (closed - ML18152B785)

2) 99900404/2015-204-03 (closed - ML18152B785)

The corrective actions for these findings have been completed and the findings are closed. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.5.02.02.i (Reference 11) and is available for NRC review.

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ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.5.02.02.i was performed for VEGP Unit 4 and that the prescribed acceptance criteria are 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. ND-RA-001-014, EQ ITAAC As-built Walkdown Guideline, Version 3.1

2. ND-RA-001-016, EQ ITAAC As-built Installation Documentation Guideline, Version 1.0

3. EQ As-Built Reconciliation Report (EQRR) as identified in Attachment A for Unit 4

4. IEEE Standard 344-1987, IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations

5. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, Methodology for Qualifying AP1000 Safety-Related Electrical and Mechanical Equipment, Revision 11.1

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

7. Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"

8. Regulatory Guide 1.180, Rev. 1, Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems

9. IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations

10. Regulatory Guide 1.89, Rev. 1, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants

11. 2.5.02.02.i-U4-CP-Rev0, Completion Package for Unit 4 ITAAC 2.5.02.02.i [Index Number 522]

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Attachment A

System: Protection and Safety Monitoring System (PMS)

Seismic Qual. For Type of Equipment Name+ Class 1E+ Harsh EQ Reports As-Built EQRR Cat. I+ Envir.+ Qual.

SV4-PMS-VBR-2.5.02.02.i-U4-PMS Cabinets, Yes Yes No Type Test & 002 EQRR-PCD001 Division A Analysis SV4-PMS-VBR-Rev. 0 003 SV4-PMS-VBR-2.5.02.02.i-U4-PMS Cabinets, Yes Yes No Type Test & 002 EQRR-PCD001 Division B Analysis SV4-PMS-VBR-Rev. 0 003 SV4-PMS-VBR-2.5.02.02.i-U4-PMS Cabinets, Yes Yes No Type Test & 002 EQRR-PCD001 Division C Analysis SV4-PMS-VBR-Rev. 0 003 SV4-PMS-VBR-2.5.02.02.i-U4-PMS Cabinets, Yes Yes No Type Test & 002 EQRR-PCD001 Division D Analysis SV4-PMS-VBR-Rev. 0 003 Reactor Trip SV4-JY50-VBR-2.5.02.02.i-U4-Switchgear, Yes Yes No Type Test & 002 EQRR-PCD001 Division A Analysis SV4-JY50-VBR-Rev. 0 003 Reactor Trip SV4-JY50-VBR-2.5.02.02.i-U4-Switchgear, Yes Yes No Type Test & 002 EQRR-PCD001 Division B Analysis SV4-JY50-VBR-Rev. 0 003 Reactor Trip SV4-JY50-VBR-2.5.02.02.i-U4-Switchgear, Yes Yes No Type Test & 002 EQRR-PCD001 Division C Analysis SV4-JY50-VBR-Rev. 0 003 Reactor Trip SV4-JY50-VBR-2.5.02.02.i-U4-Switchgear, Yes Yes No Type Test & 002 EQRR-PCD001 Division D Analysis SV4-JY50-VBR-Rev. 0 003 SV4-JW03-VBR-2.5.02.02.i-U4-MCR/RSW Transfer Yes Yes No Type Test & 001 EQRR-PCD001 Panels Analysis SV4-JW03-VBR-Rev. 0 002 SV4-OCS-VBR-2.5.02.02.i-U4-MCR Safety-related Yes Yes No Type Test & 006 EQRR-PCD001 Display, Division A Analysis SV4-OCS-VBR-Rev. 0 008 SV4-OCS-VBR-2.5.02.02.i-U4-MCR Safety-related Yes Yes No Type Test & 006 EQRR-PCD001 Display, Division B Analysis SV4-OCS-VBR-Rev. 0 008

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Seismic Qual. For Type of Equipment Name+ Cat. I+ Class 1E+ Harsh Qual. EQ Reports As-Built EQRR Envir.+

SV4-OCS-VBR-2.5.02.02.i-U4-MCR Safety-related Yes Yes No Type Test & 006 EQRR-PCD001 Display, Division C Analysis SV4-OCS-VBR-Rev. 0 008 SV4-OCS-VBR-2.5.02.02.i-U4-MCR Safety-related Yes Yes No Type Test & 006 EQRR-PCD001 Display, Division D Analysis SV4-OCS-VBR-Rev. 0 008 SV4-OCS-VBR-2.5.02.02.i-U4-MCR Safety-related Yes Yes No Type Test & 006 EQRR-PCD001 Controls Analysis SV4-OCS-VBR-Rev. 0 008 Notes:

+ Excerpt from COL Appendix C Table 2.5.2-1

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Attachment B

PMS Applicable SWC Test Standards, Baseline (MIL -STD) Emissions Testing Program

EMC Type Test Test Standard Application Conducted MIL-STD-461E (CE101) Requirements Emissions, for the Control of Electromagnetic Reactor Trip Switchgear Low Frequency Interference Characteristics of Power Leads (Note 1)

(EMI/ RFI) Subsystems and Equipment, U.S.

Department of Defense, August 1999.

PMS Cabinet Power Leads MIL-STD-461E (CE102), Requirements Conducted for the Control of Electromagnetic Reactor Trip Switchgear Emissions, High Interference Characteristics of Power Leads Frequency Subsystems and Equipment, U.S.

(EMI/ RFI) Department of Defense, August 1999. Main Control Room (MCR)

Safety-related (SR) Display &

Control Power Leads Radiated MIL-STD-461E (RE101), Requirements PMS Cabinet Emissions, for the Control of Electromagnetic Reactor Trip Switchgear Magnetic Field Interference Characteristics of (EMI/ RFI) Subsystems and Equipment, U.S. MCR SR Display & Control Department of Defense, August 1999.

Radiated MIL-STD-461E (RE102), Requirements PMS Cabinet Emissions, for the Control of Electromagnetic Reactor Trip Switchgear Electric Field Interference Characteristics of (EMI/ RFI) Subsystems and Equipment, U.S. MCR SR Display & Control Department of Defense, August 1999.

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Attachment C

PMS Applicable SWC Test Standards, Alternate (IEC) Susceptibility Testing Program

EMC Type Test Test Standard Application PMS Cabinet Power & Signal Leads

IEC 61000-4-16, Electromagnetic Reactor Trip Switchgear Power &

Conducted Compatibility (EMC), Part 4: Testing and Signal Leads Susceptibility, Measurement Techniques, Section 16: Test Low Frequency, for Immunity to Conducted, Common Mode Main Control Room/Remote (EMI/ RFI) Disturbances in the Frequency Range of 0 Shutdown Workstation (MCR/RSW)

Hz to 150 kHz, 1998. Transfer Panel Signal Leads

MCR SR Display & Control Power &

Signal Leads IEC 61000-4-13, Electromagnetic Conducted Compatibility (EMC), Part 4: Testing and PMS Cabinet Power Leads Susceptibility, Measurement Techniques, Section 13:

Low Frequency, Harmonics and Interharmonics Including MCR SR Display & Control Power (EMI/ RFI) Mains Signaling at AC Power Port, Low Leads Frequency Immunity Tests, 2002.

PMS Cabinet Power & Signal Leads

IEC 61000-4-6, Electromagnetic Reactor Trip Switchgear Power &

Conducted Compatibility (EMC), Part 4: Testing and Signal Leads Susceptibility, Measurement Techniques, Section 6:

High Frequency Immunity to Conducted Disturbances, MCR/RSW Transfer Panel Signal (EMI/ RFI) Induced by Radio-Frequency Fields, 1996. Leads

MCR SR Display & Control Power &

Signal Leads Radiated IEC 61000-4-8, Electromagnetic PMS Cabinet Susceptibility, Compatibility (EMC), Part 4: Testing and Magnetic Field, Measurement Techniques, Section 8: Reactor Trip Switchgear (EMI/ RFI) Power Frequency Magnetic Field Immunity Test, 1993. (Note 2) MCR SR Display & Control Radiated IEC 61000-4-9, Electromagnetic PMS Cabinet Susceptibility, Compatibility (EMC), Part 4: Testing and Magnetic Field, Measurement Techniques, Section 9: Reactor Trip Switchgear (EMI/ RFI) Power Frequency Magnetic Field Immunity Test, 1993. MCR SR Display & Control Radiated IEC 61000-4-10, Electromagnetic PMS Cabinet Susceptibility, Compatibility (EMC), Part 4: Testing and Magnetic Field, Measurement Techniques, Section 10: Reactor Trip Switchgear (EMI/ RFI) Damped Oscillatory Magnetic Field Immunity Test, 1993. MCR SR Display & Control

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EMC Type Test Test Standard Application IEC 61000-4-3, Electromagnetic PMS Cabinet Radiated Compatibility (EMC), Part 4: Testing and Susceptibility, Measurement Techniques, Section 3: Reactor Trip Switchgear Electrical Field, Radiated, Radio-Frequency, (EMI/ RFI) Electromagnetic Field Immunity Test, MCR/RSW Transfer Panel 1995.

MCR SR Dis play & Control PMS Cabinet Radiated MIL-STD-461E (RS103), Requirements for Susceptibility, the Control of Electromagnetic Interference Reactor Trip Switchgear Electrical Field, Characteristics of Subsystems and (EMI/ RFI) Equipment, U.S. Department of Defense, MCR/RSW Transfer Panel (Note 2) August 1999.

MCR SR Display & Control PMS Cabinet Power & Signal Leads

IEC 61000-4-4, Electromagnetic Reactor Trip Switchgear Power &

Electrical Fast Compatibility (EMC), Part 4: Testing and Signal Leads Transient Measurement Techniques, Section 4:

(SWC) Electrical Fast Transient/Burst Immunity MCR/RSW Transfer Panel Signal Test, 1995. Leads

MCR SR Display & Control Power &

Signal Leads PMS Cabinet Power & Signal Leads

Reactor Trip Switchgear Power &

Surge, IEC 61000-4-5, Electromagnetic Signal Leads Combination Compatibility (EMC), Part 4: Testing and Wave Measurement Techniques, Section 5: MCR/RSW Transfer Panel Signal (SWC) Surge Immunity Test, 1995 & 2005. Leads

MCR SR Display & Control Power &

Signal Leads PMS Cabinet Power & Signal Leads

IEC 61000-4-12, Electromagnetic Reactor Trip Switchgear Power &

Surge, Ring Compatibility (EMC), Part 4: Testing and Signal Leads Wave Measurement Techniques, Section 12:

(EMI/ RFI) Oscillatory Waves Immunity Test, 1995 & MCR/RSW Transfer Panel Signal 2006. Leads

MCR SR Display & Control Power &

Signal Leads

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EMC Type Test Test Standard Application PMS Cabinet Electrostatic IEC 61000-4-2, Electromagnetic Discharge Compatibility (EMC), Part 4: Testing and Reactor Trip Switchgear Immunity (ESD) Measurement Techniques, Section 2:

(Note 3) Electrostatic Discharge Immunity Test, MCR/RSW Transfer Panel 2008.

MCR SR Display & Control

Notes:

1. Voltage Total Harmonic Distortion (VTHD) tests were performed to support exemption of the following equipment from CE101 tests under Regulatory Guide 1.180 Position 3.1.

a. PMS Cabinet Power Leads

b. MCR SR Display & Control Power Leads

2. MIL-STD-461E RS103 (Radiated susceptibility, electric field) test is used to extend the alternative susceptibility test range of the radiated electrical fields susceptibility above 1 GHz, as indicated in RG 1.180 Position 6.

3. Testing for electrostatic discharge (ESD) is performed consistent with the RG 1.180 reference to IEC 61000-4-2, Electromagnetic Compatibility (EMC) - Part 4-2: Testing and Measurement Techniques - Electrostatic Discharge Immunity Test.