ND-22-0600, ITAAC Closure Notification on Completion of ITAAC 2.3.02.05.i (Index Number 291)
| ML22350A723 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/16/2022 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ND-22-0600, ITAAC 2.3.02.05.i | |
| Download: ML22350A723 (1) | |
Text
Jamie M. Coleman Regulatot7 Affairs Director Voglle 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel
^
Southern Nuclear December 16, 2022 Docket No.:
52-026 ND-22-0600 10 CFR 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 2.3.02.05.i [Index Number 2911 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) ohhe completion of Vogtie Electric Generating Plant (VEGP)
Unit 4 Inspections. Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.3.02.05.1 [Index Number 291] to demonstrate that the Chemical and Volume Control System (CVS) equipment identified as seismic Category I or Class IE in the Combined License (COL) Appendix C, Table 2.3.2-1 is designed and constructed in accordance with applicable requirements.
The closure process for this ITAAC is based on the guidance described in Nuclear Energy Institute (NEl) 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 Jamte M. Coleman Regulatory Affairs Director Vogtie 3 & 4
Enclosure:
Vogtie Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.02.05.i [Index Number 291]
JMC/AD/sfr
U.S. Nuclear Regulatory Commission ND-22-0600 Page 2 of 2 Regional Administrator, Region II Director, Office of Nuclear Reactor Regulation (NRR)
Director. Vogtle Project Office NRR Senior Resident Inspector -
Vogtle 3 & 4 cc:
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-22-0600 Enclosure Vogtie Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.02.05.i [Index Number 291]
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 2 of 9 ITAAC Statement Design Commitment
- 5. The seismic Category I equipment identified in Table 2.3.2-1 can withstand seismic design basis loads without loss of safety function.
6.a) The Class 1E equipment identified in Table 2.3.2-1 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 identified in Table 2.3.2-1 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.
i) Type tests, analyses, or a combination of type tests and analyses will be performed on Class 1E equipment located in a harsh environment.
ii) Inspection will be performed of the as-bullt Class IE equipment and the associated wiring, cables, and terminations located in a harsh environment.
Acceptance Criteria i) The seismic Category I equipment identified in Table 2.3.2-1 is located on the Nuclear Island.
ii) A report exists and concludes that the seismic Category I equipment can withstand seismic design basis dynamic 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.
I) A report exists and concludes that the Class 1E equipment identified in Table 2.3.2-1 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.
ii) A report exists and concludes that the as-built Class 1E equipment and the associated wiring cables, and terminations identified in Table 2.3.2-1 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-22-0600 Enclosure Page 3 of 9 ITAAC Determination Basis This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Chemical and Volume Control System (CVS) equipment identified as seismic Category I or Class 1E in the Combined License (COL) Appendix C, Table 2.3.2-1 (the Table) is designed and constructed in accordance with applicable requirements.
\\) The seismic Category I equipment identified in Table 2.3.2-1 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) ITAAC As-built Walkdown Guideline and the EQ ITAAC As-built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the CVS 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 documents the results of the inspection and concludes 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.
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 is demonstrated by analysis in accordance with American Society of Mechanical Engineers (ASME) Code Section III (Reference 4). Functionality of the subset of active safety-related valves under seismic loads is determined using the guidance of ASME QME-1-2007 (Reference 5).
Safety-related (Class 1E) electrical equipment in the Table is seismically qualified by type testing combined with analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference 6). This equipment includes 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 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, iin A report exists and concludes that the as-built equipment including anchorage is seismically bounded bv the tested or analyzed conditions.
An inspection (References 1 and 2) was conducted to confirm the satisfactory installation of the seismically qualified equipment in the Table. The inspection verifies 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
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 4 of 9 seismically qualified equipment 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 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 6), and NRC Regulatory Guide (RG) 1.100 (Reference 9).
i) A report exists and concludes that the Class 1E equipment identified in Table 2.3.2-1 as being qualified for a harsh environment can withstand the environmental conditions that would exist before, during, and following a desian basis accident without loss of safety function for the time required to perform the safety function.
The harsh environment Class 1E equipment in the Table is qualified by type testing and/or analyses. Class 1E electrical equipment type testing was performed in accordance with IEEE Standard 323-1974 (Reference 10} and RG 1.89 (Reference 11) to meet the requirements of 10 CFR 50.49. Type testing of safety-related equipment meets the requirements of 10 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 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 7). EQ Reports (Reference 8) identified in Attachment A contain applicable test reports and associated documentation and conclude 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 1E equipment and the associated wiring, cables, and terminations identified in Table 2.3.2-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.
An inspection (References 1 and 2) was conducted of the CVS to confirm the satisfactory installation of the Class 1E equipment in the Table. The inspection verifies the equipment location, make/model/serial number, as-designed equipment mounting, wiring, cables, and terminations, and confirms 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 concludes that the as-built harsh environment Class 1E equipment and the associated wiring, cables, and terminations are bounded by the qualified configuration and IEEE Standard 323-1974 (Reference 10).
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 5 of 9 Together, these reports (References 3 and 8) provide evidence that the ITAAC Acceptance Criteria requirements are met:
The seismic Category I equipment identified in Table 2.3.2-1 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 toss 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 2.3.2-1 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.
G A report exists and concludes that the as-built Class 1E equipment and the associated wiring, cables, and terminations identified in Table 2.3.2-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.
References 3 and 8 are available for NRC inspection as part of the Unit 4 ITAAC 2.3.02.05.1 Completion Package (Reference 12).
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 292, 293, 294 and 295, found the following relevant ITAAC finding associated with this ITAAC:
- 1) Notice of Nonconformance (NON) 99901412/2012-201-02 (Closed)
ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.02.05.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 the approved plant programs and procedures.
References (available for NRC inspection)
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 6 of 9 EQ As-Built Reconciliation Report (EQRR) as identified in Attachment A for Unit 4 3.
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 4.
ASME QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, The American Society of Mechanical Engineers, June 2007 5.
IEEE Standard 344-1987, IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations 6.
Vogtie 3&4 Updated Final Safety Analysis Report Appendix 3D, Methodology for Qualifying API 000 Safety-Related Electrical and Mechanical Equipment" 7.
Equipment Qualification (EQ) Reports as identified in Attachment A 8.
Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants" 9.
- 10. IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"
- 11. Regulatory Guide 1.89, Rev 1, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants"
- 12. 2.3.02.05.i-U4-CP-Rev0, ITAAC Completion Package
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 7 of 9 Attachment A System: Chemical and Volume Control System (CVS)
Class 1E/
Qual. for Harsh Envir/^
As-Built EQRR (Reference 3)
Type of Qual.
EQ Reports (Reference 8)
Envir Qual Program^
Envir.
Zone1 Seismic Cat. I ^
Tag No. ^
Equipment Name
- 2.3.02.05.i-U4-EQRR-PCD001-Rev0 2.3.02.05.i-U4-EQRR-PCD001-Rev0 SV4-PV01-VBR-012/
SV4-PV01-VBR-011 Type Testing
& Analysis RCS Purification Motor-operated Isolation Valve RCS Purification Motor-operated Isolation Valve RCS Purification Motor-operated Isolation Valve CVS Resin Flush Line Containment Isolation Valve M
- E S YesA'es 1
CVS-PL-V001 Yes SV4-PV01-VBR-012/
SV4-PV01-VBR-011 Type Testing
& Analysis M*ES YesA^es 1
CVS-PL-V002 Yes SV4-PV01-VBR-014/
SV4-PV01-VBR-013 2.3.02.05J-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis M
- ES 1
Yes YesA'es CVS-PL-V003 SV4-PV10-VBR-008/
SV4-PV10-VBR-007 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis
-/-
NA NA Yes CVS-PL-V040 CVS Resin Flush Line Containment Isolation Valve 2.3.02.05.i-U4-EQRR-PCD001-Rev0 SV4-PV10-VBR-008/
SV4-PV10-VBR-007 Type Testing
& Analysis NA
-/-
NA CVS-PL-V041 Yes CVS Demineralizer Resin Flush Line Containment Isolation Thermal Relief Valve 2.3.02.05.I-U4-EQRR-PCD001-Rev0 SV4-PV16-VBR-002/
SV4-PV16-VBR-001 Type Testing
& Analysis
-/-
NA NA CVS-PL-V042 Yes CVS Letdown Containment Isolation Valve SV4-PV14-VBR-002/
SV4-PV14-VBR-001 2.3.02.05.I-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis M*ES YesA'es 1
CVS-PL-V045 Yes CVS Letdown Containment Isolation Valve SV4-PV14-VBR-002 /
SV4-PV14-VBR-001 2.3.02.05J-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis Yes/No NA NA CVS-PL-V047 Yes CVS Letdown Line Containment Isolation Thermal Relief Valve SV4-PV16-VBR-002/
SV4-PV16-VBR-001 2.3.02.05.I-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis NA NA Yes CVS-PL-V058 SV4-PV02-VBR-012/
SV4-PV02-VBR-011 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis CVS Makeup Return Line Bypass Check Valve
-/-
NA NA CVS-PL-V067 Yes
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 8 of 9 Class 1E/
Qual. for Harsh Envir.+ 3 As-BuMt EQRR (Reference 3)
Type of Qual.
EQ Reports (Reference 8)
Envir.
Zone^
Envir Qual Program^
Seismic Cat. I
- Equipment Name ^
Tag No.
- CVS Purification Return Line Pressure Boundary Check Valve SV4-PV03-VBR-014/
SV4-PV03-VBR-013 2.3.02.05J-U4-EQRR-PCD001-Rev0 Analysis NA NA CVS-PL-V080 Yes
-/-
SV4-PV14-VBR-190002 CVS Purification Return Line Pressure Boundary Isolation Check Valve 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis
/
NA CVS-PL-V081 Yes
-/-
NA SV4-PV14-VBR-190001 CVS Purification Return Line Pressure Boundary Check Valve 2.3.02.05.i-U4-EQRR-PCD001-Rev0 SV4-PV03-VBR-014/
SV4-PV03-VBR-013 NA Analysis CVS-PL-V082 Yes
-/-
NA CVS Auxiliary Pressurizer Spray Line Pressure Boundary Valve CVS Auxiliary Pressurizer Spray Line Pressure Boundary Check Valve SV4-PV14-VBR-002/
SV4-PV14-VBR-001 2.3.02.05J-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis M*ES YesA'es 1
CVS-PL-V084 Yes SV4-PV02-VBR-012/
SV4-PV02-VBR-011 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Analysis
-/-
NA NA CVS-PL-V085 Yes CVS Makeup Line Containment Isolation SV4-PV01-VBR-012/
SV4-PV01-VBR-011 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis Yes/No NA NA CVS-PL-V090 Yes Motor-operated Valve CVS Makeup Line Containment Isolation Motor-operated Valve SV4-PV01-VBR-012/
SV4-PV01-VBR-011 2.3.02.05J-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis M*ES CVS-PL-V091 Yes YesA'es 1
CVS Zinc Injection Containment Isolation Valve ORC SV4-PV14-VBR-002/
SV4-PV14-VBR-001 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis YesA'es 10 M*ES CVS-PL-V092 Yes CVS Zinc Injection Containment Isolation Valve IRC SV4-PV14-VBR-002/
SV4-PV14-VBR-001 2.3.02.05.I-U4-EQRR-PCDOOI-RevO Type Testing
& Analysis M*ES Yes / Yes 1
CVS-PL-V094 Yes CVS Zinc Addition Line Ctmt Isol Thermal Relief Valve SV4-PV16-VBR-002/
SV4-PV16-VBR-001 2.3.02.05.i-U4-EQRR-PCDOOI-RevO Type Testing
& Analysis NA CVS-PL-V098 Yes
-/-
NA
U.S. Nuclear Regulatory Commission ND-22-0600 Enclosure Page 9 of 9 Class 1E/
Qual. for Harsh Envlr.^^
As-Built EQRR (Reference 3)
EQ Reports (Reference 8)
Type of Qual.
Envir.
Zone1 Envir Qual Program^
Seismic Cat. I
- Tag No.
Equipment Name CVS Makeup Line Containment Isolation Thermal Relief Valve SV4-PV02-VBR-012/
SV4-PV02-VBR-011 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Analysis NA NA
-/-
CVS-PL-V100 Yes 2.3.02.05J-U4-EQRR-PCD001-Rev0 SV4-PV11-VBR-004/
SV4-PV11-VBR-003 Type Testing
& Analysis CVS Demineralized Water Isolation Valve NA Yes/No NA CVS-PL-V136A Yes 2.3.02.05.i-U4-EQRR-PCD001-Rev0 SV4-PV11-VBR-004/
SV4-PV11-VBR-003 Type Testing
& Analysis CVS Demineralized Water Isolation Valve NA Yes/No NA Yes CVS-PL-V136B CVS Hydrogen Injection Containment Isolation Check Valve IRC 2.3.02.05.i-U4-EQRR-PCD001-Rev0 SV4-PV02-VBR-017/
SV4-PV02-VBR-018 Analysis NA
-/-
NA CVS-PL-V217 Yes CVS Hydrogen Injection Containment Isolation Valve ORC SV4-PV14-VBR-002/
SV4-PV14-VBR-001 2.3.02.05.i-U4-EQRR-PCD001-Rev0 Type Testing
& Analysis M*ES 10 YesA'es CVS-PL-V219 Yes Notes:
+ Excerpt from COL Appendix C Table 2.3.2-1
- 1. See Table 3D.5-1 of UFSAR E - Electrical Equipment Program (limit switch and the motor operator, squib operator, solenoid operator)
M - Mechanical Equipment Program (valve)
S = Qualified for submergence or operation with spray
- - Harsh Environment 2.
Dash (-) indicates not applicable 3.