ND-17-2100, Vogtie Electric Generating Plant Unit 4 - ITAAC Closure Notification on Completion of ITAAC 2.3.11.02.1 (Index Number 450)

Vogtie Electric Generating Plant Unit 4 - ITAAC Closure Notification on Completion of ITAAC 2.3.11.02.1 (Index Number 450)

ML17355A310
Person / Time
Site:	Vogtle
Issue date:	12/18/2017
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC 2.3.11.02.1, ND-17-2100
Download: ML17355A310 (8)

Text

Michael J. Vox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtie 3 & 4 706-848-6459 tei 410-474-8587 ceii myox@soutfiernco.com DEC I 8 2017 Docket No.: 52-026 ND-17-2100 10CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtie Electric Generating Plant Unit 4 ITAAC Closure Notification on Completion of ITAAC 2.3.11.02.1 findex Number 4501 Ladles 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 Vogtie Electric Generating Plant (VEGP)

Unit 4 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.11.02.1 [Index Number 450] which confirms Gaseous Radwaste System (WGS) activated carbon delay bed location and seismic analysis. 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 Tom Petrak at 706-848-1575.

Respectfully submitted.

Michael J. Vox Regulatory Affairs Director Vogtie 3 & 4

Enclosure:

Vogtie Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.11.02.1 [Index Number 450]

MJY/LBP/amw

U.S. Nuclear Regulatory Commission ND-17-2100 Page 2 of 3 To:

Southern Nuclear Operating Company I Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. M. D. Rauckhorst (w/o enclosures)

Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKinney Mr. M. J. Yox Mr. D. L. Fulton Mr. J. D. Williams Mr. F. H. Willis Ms. A. L. Pugh Mr. A. S. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. 0. Chamberlain Mr. D. R. Culver Mr. R. L. Belike Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reaulatorv Commission Mr. W. Jones (w/o enclosures)

Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. T. C. Brimfield Mr. A. J. Lerch Mr. C. J. Even Ms. V. L. Ordaz Mr. B. J. Kemker Ms. A. E. Rivera-Varona Oqiethoroe Power Corporation Mr. K. T. Haynes Mr. R. B. Brinkman Municipai Eiectric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-17-2100 Page 3 of 3 Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Mr. D. Hawkins Ms. 8. DITommaso Mr. J. L. Coward Ms. N. E. Deangells Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., CDS Associates, inc.

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-17-2100 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-17-2100 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.11.02.1 [Index Number 450]

U.S. Nuclear Regulatory Commission ND-17-2100 Enclosure Page 2 of 5 ITAAC Statement Design Commitment:

2. The equipment identified as having seismic design requirements in Table 2.3.11-1 can withstand seismic design basis loads without loss of its structural integrity function.

Inspections. Tests. Analvses:

i) Inspection will be performed to verify that the equipment identified as having seismic design requirements in Table 2.3.11-1 is located on the Nuclear Island.

ii) Typetests, analyses, or a combination oftype tests and analyses of seismically designed equipment will be performed.

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

Acceptance Criteria:

i) Theequipment identified as having seismic design requirements in Table 2.3.11-1 is located on the Nuclear Island.

ii) Areport exists andconcludes that the seismically designed equipment can withstand appropriate seismic design basis loads without loss of its structural integrity function.

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

ITAAC Determination Basis This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Gaseous Radwaste System (WGS) equipment identified as having seismic design requirements in the Combined License (COL) Appendix CTable 2.3.11-1 (Table) can withstand seismic design basis loads without the loss of its structural integrity function. The subject ITAAC required;

• An inspection be performed to verify thatthe WGS Activated Carbon Delay Beds are located on the Nuclear Island.

• Type tests, analyses, ora combination of type tests and analyses be performed on the WGS Activated Carbon Delay Beds.

• An Inspection be performed for the existence of a report that concludes that the as-built equipment, the WGS Activated Carbon Delay Beds, including anchorage isseismically bounded by the tested or analyzed conditions.

To assure thatthe equipment identified in the Table can withstand the appropriate seismic design basis loads without loss of its structural integrity function, an inspection was conducted of the WGS to confirm the satisfactory installation of the equipment with seismic design requirements identified in Attachment A. The inspection included verification of equipment

U.S. Nuclear Regulatory Commission ND-17-2100 Enclosure Page 3 of 5 number and location. The inspections to verify instailed component locations are documented in Quality Assurance (OA) inspection reports (References 1 and 2). The results of the inspections conclude that each component identified in Attachment A is located on the Nuclear Island.

Seismic loads for the equipment were established using one-half of the AP1000 Safe Shutdown Earthquake (SSE) floor response spectra. Seismic analyses of the equipment identified in the Table were performed to demonstrate structural integrity in accordance with American Society of Mechanical Engineers (ASME) Code Section VIII, Rules for Construction of Pressure Vessels (Reference 3). The analyses are documented in the WGS delay bed design report (Reference

4) and conclude that the equipment identified in the Table as having seismic design requirements can withstand appropriate seismic design basis loads without loss of its structural integrity function.

In accordance with the fabrication and construction installation work packages, inspections were performed on the WGSActivated Carbon Delay Beds and anchorage to confirm the satisfactory installation of the seismicallydesigned equipment. The inspection included verification of equipment fabrication, equipment mounting, equipment anchorage, and critical attributes from the seismic analyses. In accordance with NEI 08-01, Section 9.5, inspection ofWGS Activated Carbon Delay Bed equipment mounting and verification of critical attributesfrom the seismic analyses were performed at otherthan the final installed location, due to inaccessibility of the equipment after installation. Non-conformances and design changes issued during fabrication and installation against the equipmentand anchorage were analyzed against the seismic analyses to ensure inspection results performed at otherthan the equipment's final location remained valid for supporting ITAAC acceptance criteria. Non-conformances and design changes issued up through installation ofthe equipment including attachment to the seismic Category 1 structure were analyzed against the seismic analysis to verify that the analyzed conditions were still bounding when considering the cumulative effects of any deviating conditions.

The results of the verifications were documented in the as-built seismic reconciliation report (Reference 5). The verifications demonstrated thatthe as-built equipment in COL Appendix C, Table 2.3.11-1, including anchorage, is seismically bounded by the analyzed conditions.

Together, these reports (References 1, 2,4, and 5) provide evidence that the ITAAC Acceptance Criteria requirements are met:

• The equipment identified as having seismic design requirements in Table 2.3.11-1 is located on the Nuclear Island.

• A report exists and concludes that the seismicallydesigned equipment can withstand appropriate seismic design basis loads without loss of its structural integrity function.

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

U.S. Nuclear Regulatory Commission ND-17-2100 Enclosure Page 4 of 5 ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of ITAAC Findings and associated corrective actions. This review which included now-consolidated ITAAC Indexes 450, 451, and 452 found no relevant ITAAC Findings associated with this ITAAC. The ITAAC finding review is referenced in the Vogtle Unit 4 ITAAC Completion Package for ITAAC 2.3.11.02.1 (Reference 6) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.11.02.1 [Index Number450] 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. M315-15-10317 Rev. 0, Quality Assurance Type "A" Inspection Report - Mechanical: Fixed Equipment, Vessels and Tanks

2. SV4-WGS-M6K-881481 Rev. 0, SV4 WGS Module KB04 As-Built Location Sketch

3. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code,Section VIII, Rules for Construction of Pressure Vessels, 2001 Edition with 2003 Addenda

4. APP-MV6H-VDR-001 Rev. 2, API 000 MV6H WGS Delay Bed Design Report

5. SV4-MV6H-VFR-001 Rev. 1, Vogtle Unit 4 ITAAC 2.3.11.02.1 As-Built Seismic Reconciliation Report

6. 2.3.11.02.i-U4-CP-Rev 0, Completion Package for Unit 4 ITAAC 2.3.11.02.1 [COL Index Number450] (WGS Activated Carbon Delay Bed Location and Seismic Analysis)

U.S. Nuclear Regulatory Commission ND-17-2100 Enclosure Page 5 of 5 Attachment A ITAAC Number: 2.3.11.02.1 Excerpt from VEGP Unit 4 COL Appendix 0 Tabie 2.3.11-1 Design As-Buiit Equipment Seismic Type of Report Reconciiiation Tag iD Category 1 Quaiification Name Number Document WGS APP-MV6H- SV4-MV6H-Activated WGS-MV-No Analysis VDR-001 VFR-001 Carbon 02A Rev.1 Rev.2 Delay Bed A WGS APP-MV6H- SV4-MV6H-Activated WGS-MV-No Analysis VDR-001 VFR-001 Carbon 02B Rev.1 Rev.2 Delay Bed B (1) The WGS activated carbon delay beds (WGS-MV-02A and WGS-MV-02B) are designed to one-half Safe Shutdown Earthquake (SSE).