ND-20-1037, ITAAC Closure Notification on Completion of ITAAC 2.3.10.05a.i (Index Number 437)

ITAAC Closure Notification on Completion of ITAAC 2.3.10.05a.i (Index Number 437)

ML21259A142
Person / Time
Site:	Vogtle
Issue date:	09/15/2021
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-1037
Download: ML21259A142 (8)

Text

/.,1., I Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel

SEP 1 5 2021

Docket Nos.: 52-025 ND-20-1037 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 3 ITAAC Closure Notification on Completion of ITAAC 2.3.10.05a.i [Index Number 4371

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 3 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.10.05a.i [Index Number 437]. This ITAAC confirms that the seismic Category I Liquid Radwaste System equipment identified in the VEGP Unit 3 Combined License (COL) Appendix C, Table 2.3.10-1 can withstand seismic design basis loads without loss of safety function. 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.

Aau Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.3.10.05a.i [Index Number 437]

MJY/TST/sfr U.S. Nuclear Regulatory Commission ND-20-1037 Page 2 of 3

To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III Mr. D. L. McKlnney Mr. H. Nieh Mr. M. D. Meier Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Ms. J.M. Coleman Mr. C. T. Defnall Mr. C. E. Morrow Mr. K. J. Drudy Mr. J. M. Fisher Mr. R. L. Beiike Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06

cc:

Nuclear Requlatorv Commission Ms. M. Bailey Mr. M. King Mr. G. Bowman Ms. A. Veil M. C. P. Patel M. G. J. Khouri M. C. J. Even M. B. J. Kemker Ms. N. C. Coovert M C. Welch M J. Gaslevic M O. Lopez-Santiago M G. Armstrong M M. Webb M T. Fredette M C. Santos M B. Davis M. J. Vasquez M J. Eargle M E. Davidson M. T. Fanelli Ms. K. McCurry M. J. Parent M B. Griman U.S. Nuclear Regulatory Commission ND-20-1037 Page 3 of 3

Qqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson

Dalton Utilities Mr. T. Bundros

Westinqhouse Electric Company. LLC Dr. L. Oriani Mr. D. 0. Durham Mr. M. M. Corletti Mr. Z. 8. Harper Mr. J. L. Coward

Other Mr. 8. W. Kline, 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 Mr. R. L. Trokey, Georgia Pubiic Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham U.S. Nuclear Regulatory Commission ND-20-1037 Enclosure Page 1 of 5

Southern Nuclear Operating Company ND-20-1037 Enclosure

Vogtle Electric Generating Plant (VEGP) Unit 3 Compietion of ITAAC 2.3.10.OSa.i [Index Number 437]

U.S. Nuclear Regulatory Commission ND-20-1037 Enclosure Page 2 of 5

ITA AC Statement

Design Commitment

5.a) The seismic Category I equipment identified in Table 2.3.10-1 can withstand seismic design basis loads without loss of safety function.

I nspections/T ests/Analvses

i) Inspection will be performed to verify that the seismic Category I equipment identified in Table 2.3.10-1 is located on the Nuclear Island.

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

ill) 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.

Acceptance Criteria

i) The seismic Category I equipment identified in Table 2.3.10-1 is located on the Nuclear Island.

11) 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.

ITAAC Determination Basis

This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Liquid Radwaste System (WLS) equipment identified as seismic Category I in the Combined License (COL) Appendix C, Table 2.3.10-1 was designed and constructed in accordance with applicable requirements.

i) The seismic Cateoorv I eauipment identified in Table 2.3.10-1 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 Table 2.3.10-1 was designed to be located on the seismic Category I Nuclear Island. In accordance with the Equipment Qualification (EG) ITAAC As-built Walkdown Guideline (Reference 1) and the EG ITAAC As-built Installation Documentation Guideline (Reference 2), inspections were conducted of the WLS to confirm the satisfactory installation of the seismically qualified equipment. The inspection included verification of equipment make/model/serial number and verification of equipment location (Building, Elevation, Room). The As-Built EG Reconciliation Reports (EQRRs) (Reference 3) identified in Attachment A document the results of the inspections and conclude that the seismic Category I equipment is located on the Nuclear Island.

ID A report exists and concludes that the seismic Cateoorv I equipment can withstand seismic design basis loads without loss of safetv function.

Seismic Category I equipment identified in Table 2.3.10-1 required type tests and/or analyses to demonstrate structural integrity and operability. Structural integrity of the seismic Category I valves was demonstrated by analysis in accordance with American Society of Mechanical Engineers (ASME)

U.S. Nuclear Regulatory Commission ND-20-1037 Enclosure Page 3 of 5

Code Section III (Reference 4). Functionality of the active safety-related valves under seismic loads was determined using the guidance of American Society of Mechanical Engineers (ASME) QME 2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants (Reference 5).

Seismic qualification of the level sensors identified in Table 2.3.10-1 was demonstrated by type testing, or through a combination of type tests and analyses.

The safety-related (Class IE) electrical equipment identified in Table 2.3.10-1 was seismically qualified by type testing combined with analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference 6).

The specific qualification method (i.e., type testing, analysis, or combination) used for the equipment listed in Table 2.3.10-1 is identified in Attachment A. Additional information about the methods used to qualify API 000 safety-related equipment is provided in the Updated Final Safety Analysis Report (UFSAR) Appendix 3D (Reference 7). The EQ Reports (Reference 8) identified in Attachment A contain applicable test reports and associated documentation and conclude 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 includina anchorage is seismicallv bounded bv the tested or analvzed conditions.

Inspections (Reference 1 and Reference 2) were conducted to confirm the satisfactory installation of the seismically qualified equipment identified in Table 2.3.10-1. The inspections verified the equipment make/model/serial number, as-designed equipment mounting orientation, anchorage and clearances, and electrical and other interfaces. The documentation of installed configuration of seismically qualified components includes photographs and/or sketches/drawings of equipment/mounting/interfaces.

As part of the seismic qualification program, consideration was 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 measuring the maximum dynamic relative displacement of the top and bottom of the equipment was performed. EQ Reports (Reference 8) 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/or other design requirements.

Attachment A identifies the EQRR (Reference 3) completed to verify that the as-built seismic Category I equipment listed in Table 2.3.10-1, including anchorage, is seismically bounded by the tested or analyzed conditions, IEEE Standard 344-1987 (Reference 6), and NRG Regulatory Guide 1.100 (Reference 9).

Together, these reports (References 3 and 8) provide evidence that the ITAAG Acceptance Criteria requirements are met:

• The seismic Category I equipment identified in Table 2.3.10-1 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; and

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

U.S. Nuclear Regulatory Commission ND-20-1037 Enclosure Page 4 of 5

References 3 and 8 are available for NRG inspection as part of the Unit 3 ITAAC 2.3.10.OSa.i Completion Package (Reference 10).

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 finding review, which included now-consolidated ITAAC Index Numbers 438 and 439, found no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.10.OSa.i (Reference 10) and is available for NRC review.

ITAAC Completion Statement

Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.10.OSa.i was performed for VEGP Unit 3 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 favallable 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. As-Built Equipment Qualification Reconciliation Reports (EQRRs) as identified in Attachment A

4. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section III, Rules for Construction of Nuclear Power Plant Components, 1998 Edition with 2000 Addenda

5. ASME QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, June 2007

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

7. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, Methodology for Qualifying APIOOO Safety-Related Electrical and Mechanical Equipment, Revision 9.1

8. Equipment Qualification (EQ) Reports as Identified in Attachment A

9. Regulatory Guide 1.100, Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants, Revision 2

10. 2.3.10.05a.i-U3-CP-Rev0, ITAAC Completion Package