ND-23-0465, ITAAC Closure Notification on Completion of ITAAC 2.2.01.08 (Index Number 109)

ITAAC Closure Notification on Completion of ITAAC 2.2.01.08 (Index Number 109)

ML23164A224
Person / Time
Site:	Vogtle
Issue date:	06/13/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0465
Download: ML23164A224 (1)

Text

Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel June 13, 2023 Docket No.: 52-026 ND-23-0465 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 2.2.01.08 [Index Number 109]

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 2.2.01.08 [Index Number 109]. This ITAAC verifies that containment electrical penetration assemblies are protected against currents that are greater than the continuous ratings.

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 2.2.01.08 [Index Number 109]

JMC/MKO/sfr

U.S. Nuclear Regulatory Commission ND-23-0465 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-23-0465 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-23-0465 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.2.01.08 [Index Number 109]

U.S. Nuclear Regulatory Commission ND-23-0465 Enclosure Page 2 of 4 ITAAC Statement Design Commitment

8. Containment electrical penetration assemblies are protected against currents that are greater than the continuous ratings.

Inspections, Tests, Analyses An analysis for the as-built containment electrical penetration assemblies will be performed to demonstrate (1) that the maximum current of the circuits does not exceed the continuous rating of the containment electrical penetration assembly, or (2) that the circuits have redundant protection devices in series and that the redundant current protection devices are coordinated with the containment electrical penetration assembly's rated short circuit thermal capacity data and prevent current from exceeding the continuous current rating of the containment electrical penetration assembly.

Acceptance Criteria Analysis exists for the as-built containment electrical penetration assemblies and concludes that the penetrations are protected against currents which are greater than their continuous ratings.

ITAAC Determination Basis An analysis for the as-built containment electrical penetration assemblies is performed to demonstrate (1) that the maximum current of the circuits does not exceed the continuous rating of the containment electrical penetration assembly, or (2) that the circuits have redundant protection devices in series and that the redundant current protection devices are coordinated with the containment electrical penetration assembly's rated short circuit thermal capacity data and prevent current from exceeding the continuous current rating of the containment electrical penetration assembly.

Most low voltage instrumentation and communication circuits are self-limiting in that circuit resistance limits the fault current to a level that does not damage the penetration. The energy levels in the instrumentation and communication systems are such that damage cannot occur to the containment penetration. For circuits that are not self-limiting, an analysis is performed to verify the as-built containment electrical penetration assemblies are protected against currents that are greater than the manufacturer's continuous ratings. The analysis demonstrates that the maximum current of the circuits does not exceed the continuous rating of the containment electrical penetration assembly, or in circuits with high short circuit current, that each circuit has redundant protection devices in series, and that the redundant current protection devices are coordinated with the containment electrical penetration assembly rated short circuit thermal capacity curves, and the fault current does not exceed the penetration assembly rated short circuit thermal capacity curve in the continuous current time range. Each circuit that requires redundant protective devices is identified in the applicable protection coordination calculations.

The containment electrical penetration assemblies analyzed are listed in Attachment A. Spare penetrations or penetrations containing low voltage instrumentation and communication circuits which are excluded from the analysis are noted in Attachment A.

U.S. Nuclear Regulatory Commission ND-23-0465 Enclosure Page 3 of 4 The electrical penetrations are designed in accordance with IEEE Standard 317(Reference 1).

Qualification testing of the electrical penetrations is performed in accordance with IEEE Standard 317 and IEEE Standard 323(Reference 2). The analysis of the as-built containment electrical penetration assemblies is performed in accordance with section 5.4 of IEEE Standard 741(Reference 3). Analysis of Class 1E circuits is documented in APP-IDS-E0C-014 (Reference 4). Analysis of Non-Class 1E circuits is documented in APP-ECS-E0C-016 (Reference 5). The analysis results are summarized in SV4-CNS-Z0R-001 (Reference 6). The analysis results exist for the as-built containment electrical penetration assemblies and conclude that the penetrations are protected against fault currents which are greater than their continuous current ratings.

The Electrical Penetration Assemblies (EPA) Protection Analysis is available for NRC inspection as part of the ITAAC Completion Package (Reference 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.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.2.01.08 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. IEEE Standard 317-1983, "IEEE Standard for Electrical Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations"

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

3. IEEE Standard 741-1997, "IEEE Standard Criteria for the Protection of Class 1E Power Systems and Equipment in Nuclear Power Generating Stations

4. APP-IDS-EOC-014, Rev. 4, "Verification of IDS Low Voltage Class 1E-Safety Related Electrical Penetrations"

5. APP-ECS-EOC-016, Rev. 4, "Verification of Primary and Backup Electrical Protection of the Low Voltage and Medium Voltage Non-Safety Related Power and Control Containment Electrical Penetrations."

6. SV4-CNS-ZOR-001, Rev. 0, Vogtle Unit 4 Containment Electrical Penetration Assemblies ITAAC 109 As-built Analysis Report

7. 2.2.01.08-U4-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-23-0465 Enclosure Page 4 of 4 Attachment A Containment System Electrical Penetration Assemblies (EPAs)*

Tag No. EPA Description - Equipment Name DAS-EY-P03Z ** Electrical Penetration P03 ECS-EY-P01X Electrical Penetration P01 ECS-EY-P02X Electrical Penetration P02 ECS-EY-P06Y Electrical Penetration P06 ECS-EY-P07X Electrical Penetration P07 ECS-EY-P09W Electrical Penetration P09 ECS-EY-P10W Electrical Penetration P10 IDSA-EY-P11Z** Electrical Penetration P11 IDSA-EY-P12Y Electrical Penetration P12 IDSA-EY-P13Y Electrical Penetration P13 IDSD-EY-P14Z ** Electrical Penetration P14 IDSD-EY-P15Y Electrical Penetration P15 IDSD-EY-P16Y Electrical Penetration P16 ECS-EY-P17X Electrical Penetration P17 ECS-EY-P18X Electrical Penetration P18 ECS-EY-P19Z ** Electrical Penetration P19 ECS-EY-P20Z ** Electrical Penetration P20 EDS-EY-P21Z ** Electrical Penetration P21 ECS-EY-P22X Electrical Penetration P22 ECS-EY-P23X Electrical Penetration P23 ECS-EY-P24 (Spare) ** Electrical Penetration P24 ECS-EY-P25W Electrical Penetration P25 ECS-EY-P26W Electrical Penetration P26 IDSC-EY-27Z ** Electrical Penetration P27 IDSC-EY-28Y Electrical Penetration P28 IDSC-EY-29Y Electrical Penetration P29 IDSB-EY-30Z ** Electrical Penetration P30 IDSB-EY-31Y Electrical Penetration P31 IDSB-EY-32Y Electrical Penetration P32

• Excerpt from COL Table 2.2.1-1

• • Denotes a spare or a penetration containing low voltage instrumentation/communication circuits which are excluded from analysis