Text

ITAAC Closure Notification on Completion of ITAAC 2.2.03.05a.i (Index Number 165)
	ML22151A332
Person / Time
Site:	Vogtle
Issue date:	05/31/2022
From:	Coleman J; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ND-21-1034
	Download: ML22151A332 (19)
	v • d • e

.,, Southern Nuclear MAY 3 1 2022 Docket No.:

52-025 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 7825 River Road Waynesboro, GA 30830 706-848-6926 tel ND-21-1034 10 CFR 52.99(c)(1)

ITAAC Closure Notification on Completion of ITAAC 2.2.03.05a.i [Index Number 165)

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 (IT AAC) Item 2.2.03.05a.i [Index Number 165) to demonstrate that the Passive Core Cooling System (PXS) components identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.2.3-1 are 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 1 O 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 1 O CFR 52.99.

If there are any questions, please contact Kelli Roberts at 706-848-6991.

Respectfully submitted,

~em~~

Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

JMC/LBP/sfr Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2.03.05a.i [Index Number 165)

U.S. Nuclear Regulatory Commission ND-21-1034 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena Ill Mr. D. L. McKinney Mr. H. Nieh Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. D. Pitts Mr. J.B. Williams 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. Beilke Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 Nuclear Regulatory Commission Ms. M. Bailey Mr. M. King Mr. G. Bowman Ms. A. Veil Mr. C. P. Patel Mr. G. J. Khouri Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. 0. Lopez-Santiago Mr. G. Armstrong Mr. M. Webb Mr. T. Fredette Mr. C. Santos Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Ms. K. Mccurry Mr. J. Parent Mr. B. Griman Mr. V. Hall

U.S. Nuclear Regulatory Commission ND-21-1034 Page 3 of 3 Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Dr. L. Oriani Mr. D. C. Durham Mr. M. M. Corletti Mr. Z. S. Harper Ms. S.L. Zwack Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GOS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 1 of 16 Southern Nuclear Operating Company ND-21-1034 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2.03.0Sa.i [Index Number 165]

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 2 of 16 IT AAC Statement Design Commitment:

5.a) The seismic Category I equipment identified in Table 2.2.3-1 can withstand seismic design basis loads without loss of safety function.

7.a) The Class 1 E equipment identified in Table 2.2.3-1 as being qualified for a harsh environment can withstand the environmental 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 and valves identified in Table 2.2.3-1 are 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.

i) Type tests, analyses, or a combination of type tests and analyses will be performed on Class 1 E equipment located in a harsh environment.

ii) Inspection will be performed of the as-built Class 1 E equipment and the associated wiring, cables, and terminations located in a harsh environment.

Acceptance Criteria:

i) The seismic Category I equipment identified in Table 2.2.3-1 is located on the Nuclear Island.

ii) A report exists and concludes that the seismic Category I equipment can withstand seismic design basis dynamic loads without loss of safety function. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the screens can withstand seismic dynamic loads and also post-accident operating loads, including head loss and debris weights.

iii) A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the as-built screens including their anchorage are bounded by the seismic loads and also post-accident operating loads, including head loss and debris weights.

i) A report exists and concludes that the Class 1 E equipment identified in Table 2.2.3-1 as being qualified for a harsh environment can withstand the environmental 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.

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 3 of 16 ii) A report exists and concludes that the as-built Class 1 E equipment and the associated wiring, cables, and terminations identified in Table 2.2.3-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

ITAAC Determination Basis This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Passive Core Cooling System (PXS) equipment identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.2.3-1 (the Table) is designed and constructed in accordance with applicable requirements.

i) The seismic Category I equipment identified in Table 2.2.3-1 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) ITAAC As-built Walkdown Guideline and the EO ITAAC As-built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the PXS 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 EO As-Built Reconciliation Reports (EORR) (Reference 3) identified in Attachment A documented the results of the inspection and concluded 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 dynamic loads without loss of safety function. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the screens can withstand seismic dynamic loads and also post-accident operating loads, including head loss and debris weights.

Seismic Category I equipment in the Table requires type tests and/or analyses to demonstrate structural integrity and operability. Structural integrity of the seismic Category I valves, as well as other passive seismic Category I mechanical equipment, is demonstrated by analysis in accordance with American Society of Mechanical Engineers (ASME) Code Section Ill (Reference 4). Functionality of the subset of active safety-related valves under seismic loads was determined using the guidance of ASME OME-1-2007 (Reference 5). Structural integrity of the in-containment refueling water storage tank (IRWST) was demonstrated by analysis in accordance with American Concrete Institute (ACI) Standard 349-01 (Reference 6) and American Institute of Steel Construction (AISC) Specification N690 (Reference 7). Structural integrity of the pH adjustment baskets was demonstrated by analysis in accordance with AISC Specification N690 (Reference 7).

Safety-related (Class 1 E) 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 8). This equipment includes safety-related (Class 1 E) field sensors and the safety-related active valve accessories such as electric actuators, position switches, pilot solenoid valves and electrical connector assemblies. 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

U.S. Nuclear Regulatory Commission N D-21-1034 Enclosure Page 4 of 16 Analysis Report (UFSAR) Appendix 3D (Reference 9). The EQ Reports (Reference 1 0) identified in Attachment A contain applicable test reports and associated documentation and conclude that the seismic Category I equipment can withstand seismic design basis dynamic loads without loss of safety function. For the PXS containment recirculation and IRWST screens, the screens can withstand seismic dynamic loads and also post-accident operating loads, including head loss and debris weights.

iii) A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the as-built screens including their anchorage are bounded by the seismic loads and also post-accident operating loads, including head loss and debris weights.

An inspection (References 1 and 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, anchorage 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.

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 10) identified the equipment mounting employed for qualification and established 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 8), and NRC Regulatory Guide (RG) 1.100 (Reference 11 ). For the PXS containment recirculation and IRWST screens, the as-built screens including their anchorage are bounded by the seismic loads and also post-accident operating loads, including head loss and debris weights.

i) A report exists and concludes that the Class 1 E equipment identified in Table 2.2.3-1 as being qualified for a harsh environment can withstand the environmental 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 harsh environment Class 1 E equipment in the Table is qualified by type testing and/or analyses. Class 1 E electrical equipment type testing was performed in accordance with IEEE Standard 323-197 4 (Reference 12) and RG 1.89 (Reference 13) to meet the requirements of 10 CFR 50.49. Type testing of safety-related equipment meets the requirements of 1 0 CFR Part 50, Appendix A, General Design Criterion 4. Attachment A identifies the EQ program and specific qualification method for each piece of safety-related mechanical or Class 1 E electrical equipment located in a harsh environment. Additional information about the methods used to qualify AP1000 safety-related equipment is provided in the UFSAR Appendix 3D (Reference 9).

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 5 of 16 EQ Reports (Reference 10) identified in Attachment A contain applicable test reports and associated documentation and concluded that the equipment can withstand the environmental 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.

ii) A report exists and concludes that the as-built Class 1 E equipment and the associated wiring, cables, and terminations identified in Table 2.2.3-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

An inspection (Reference 1 and 2) was conducted of the PXS to confirm the satisfactory installation of the Class 1 E equipment in the Table. The inspection verified the equipment location, make/model/serial number, as-designed equipment mounting, wiring, cables, and terminations, and confirmed that the environmental conditions for the zone (Attachment A) in which the equipment is mounted are bounded by the tested and/or analyzed conditions. It also documented the installed configuration with photographs or sketches/drawings of equipment mounting and connections. The EQRR (Reference 3) identified in Attachment A documents this inspection and concluded that the as-built harsh environment Class 1 E equipment and the associated wiring, cables, and terminations are bounded by the qualified configuration and IEEE Standard 323-1974 (Reference 12).

Together, these reports (References 3 and 10) provide evidence that the ITAAC Acceptance Criteria requirements are met:

The seismic Category I equipment identified in Table 2.2.3-1 is located on the Nuclear Island; A report exists and concludes that the seismic Category I equipment can withstand seismic design basis dynamic loads without loss of safety function. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the screens can withstand seismic dynamic loads and also post-accident operating loads, including head loss and debris weights; A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions. For the PXS containment recirculation and IRWST screens, a report exists and concludes that the as-built screens including their anchorage are bounded by the seismic loads and also post-accident operating loads, including head loss and debris weights; A report exists and concludes that the Class 1 E equipment identified in Table 2.2.3-1 as being qualified for a harsh environment can withstand the environmental 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 as-built Class 1 E equipment and the associated wiring, cables, and terminations identified in Table 2.2.3-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 6 of 16 References 3 and 10 are available for NRC inspection as part of the Unit 3 ITAAC 2.2.03.05a.i Completion Package (References 14).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all ITAAC findings and associated corrective actions.

This review, which included now consolidated ITAAC Indexes 166, 167, 170, and 171, found the following closed notice of non-conformance (NON) associated with this ITAAC:

1) NON 99901441 /2014-201-03 (Closed-ML14307A578)

2) NON 99901431 /2013-201-01 (Closed-ML14091A361)

3) NON 99901377/2012-201-02 (Closed - ML16357A724)

4) NON 99901377/2012-201-03 (Closed - ML16357A724)

5) NON 99900404/2012-201-01 (Closed-ML16307A159)

6) NON 99900404/2012-201-02 (Closed - ML12313A461)

7) NON 99900404/2012-201-03 (Closed - ML12313A461)

The corrective actions for these findings have been completed and the findings are closed. The IT AAC completion review is documented in the IT AAC Completion Package for IT AAC 2.2.03.05a.i (Reference 14) and is available for NRC review.

IT AAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.2.03.05a.i was performed for VEGP Unit 3 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 the 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 Reports (EQRR) as identified in Attachment A

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

Code, Section Ill, "Rules for Construction of Nuclear Power Plant Components," 1998 Edition with 2000 Addenda

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 7 of 16

5. ASME QME-1-2007, "Qualification of Active Mechanical Equipment Used in Nuclear Power Plants," The American Society of Mechanical Engineers, June 2007

6. American Concrete Institute (ACI) Standard 349-01, "Code Requirements for Nuclear Safety Related Concrete Structures," 2001.

7. American National Standards Institute (ANSI)/ American Institute of Steel Construction (AISC) N690-1994, "Specification for the Design, Fabrication and Erection of Safety-Related Steel Structures for Nuclear Facilities"

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

9. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 30, "Methodology for Qualifying AP1000 Safety-Related Electrical and Mechanical Equipment"

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

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

12. IEEE Standard 323-197 4, "IEEE Standard for Qualifying Class 1 E Equipment for Nuclear Power Generating Stations"

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

14. 2.2.03.05a.i-U3-CP-Rev0, "Completion Package for Unit 3 ITAAC 2.2.03.05a.i [Index Number 165]"

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 8 of 16 Equipment Name+

Tag No.+

Passive Residual Heat Removal Heat Exchanger PXS-ME-01 PRHR HX)

Accumulator Tank A PXS-MT-01A

~ccumulator Tank B PXS-MT-01 B Core Makeup Tank (CMT)

PXS-MT-02A A

CMTB PXS-MT-02B IRWST PXS-MT-03 I RWST Screen A PXS-MY-Y01A IRWST Screen B PXS-MY-Y01 B I RWST Screen C PXS-MY-Y0 1 C Containment Recirculation PXS-MY-Y02A Screen A Containment Recirculation PXS-MY-Y02B Screen B pH Adjustment Basket 3A PXS-MY-Y03A pH Adjustment Basket 3B PXS-MY-Y03B pH Adjustment Basket 4A PXS-MY-Y04A Seismic Cat. I+ 3 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Attachment A System: Passive Core Cooling System Class 1 E/

Envir. Envir Qual Type of Qual. Harsh EQ Reports As-Built EQRR Envir. + 3 Zone 1 Program 2 Qual.

2.2.03.05a.i-U3-EQRR-

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N/A N/A Analysis SV3-ME02-Z0R-001 PCD003

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N/A N/A Analysis SV3-MT02-Z0R-102 2.2.03.05a.i-U3-EQRR-PCO003

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N/A N/A Analysis SV3-MT02-Z0R-102 2.2.03.05a.i-U3-EQRR-PCD003

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N/A N/A Analysis SV3-MT01-Z0R-101 2.2.03.05a.i-U3-EQRR-PCD003

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N/A N/A Analysis SV3-MT01-Z0R-101 2.2.03.05a.i-U3-EORR-PCD003

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N/A N/A Analysis SV3-11 00-GCR-001 2.2.03.05a.i-U3-EORR-PCD003

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N/A N/A Analysis SV3-MY03-VDR-00 1 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis SV3-MY03-VDR-001 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis SV3-MY03-VDR-001 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis SV3-MY03-VDR-00 1 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis SV3-MY03-VDR-001 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis APP-MY0?-Z0C-002 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis APP-MY0?-Z0C-002 2.2.03.05a.i-U3-EQRR-PCD002

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N/A N/A Analysis APP-MY0?-Z0C-002 2.2.03.05a.i-U3-EQRR-PCD002

U.S. Nuclear Regulatory Commission ND-21-1034 Enclosure Page 9 of 16 Equipment Name +

Tag No.+

pH Adjustment Basket 4B PXS-MY-Y04B Downspout Screen 1 A PXS-MY-Y81 Downspout Screen 1 B PXS-MY-Y82 Downspout Screen 1 C PXS-MY-Y83 Downspout Screen 1 D PXS-MY-Y84 Downspout Screen 2A PXS-MY-Y85 Downspout Screen 2B PXS-MY-Y86 Downspout Screen 2C PXS-MY-Y87 Downspout Screen 2D PXS-MY-Y88 CMT A Inlet Isolation Motor-operated Valve PXS-PL-V002A CMT B Inlet Isolation Motor-operated Valve PXS-PL-V002B CMT A Discharge Isolation Valve PXS-PL-V014A Seismic Cat. I+ 3 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Attachment A System: Passive Core Cooling System Class 1E/

Envir. Envir Qual Type of Qual. Harsh EQ Reports As-Built EQRR Envir. + 3 Zone 1 Program 2 Qual.

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N/A N/A Analysis APP-MY0?-Z0C-002 2.2.03.05a.i-U3-EQRR-PCD002

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