ND-22-0689, ITAAC Closure Notification on Completion of ITAAC 2.1.02.12a.i (Index Number 53)

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ITAAC Closure Notification on Completion of ITAAC 2.1.02.12a.i (Index Number 53)
ML22307A325
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 11/03/2022
From: Coleman J
Southern Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0689, ITAAC 2.1.02.12a
Download: ML22307A325 (1)


Text

Jamie M. Coleman 7825 River Road

,3/4, Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848 -6926 tel NOV O 3 2022

Docket No.: 52-026 ND-22-0689 1 O 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 2.1.02.12a.i [Index Number 53]

Ladies and Gentlemen:

In accordance with 1 O 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 2.1.02.12a.i [Index Number 53]. This ITAAC confirms that the Reactor Coolant System motor-operated valves identified in COL Appendix C Table 2.1.2-1 perform an active safety-related function to change position as indicated in the table. 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 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,

~~

Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.1.02. 12a.i [Index Number 53]

JMC/AD/sfr U.S. Nuclear Regulatory Commission ND-22-0689 Page 2 of 2

cc: Regional Administrator, Region II Director, Office of Nuclear Reactor Regulation (NRR)

Director, Vogtle Project Office NRR Senior Resident Inspector - Vogtle 3 & 4 U.S. Nuclear Regulatory Commission ND-22-0689 Enclosure Page 1 of 5

Southern Nuclear Operating Company ND-22-0689 Enclosure

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of IT AAC 2.1.02.12a.i [Index Number 53]

U.S. Nuclear Regulatory Commission ND-22-0689 Enclosure Page 2 of 5

ITAAC Statement

Design Commitment

12.a) The automatic depressurization valves identified in Table 2.1.2-1 perform an active safety related function to change position as indicated in the table.

Inspections/Tests/ Analyses

i) Tests or type tests of motor -operated valves will be performed that demonstrate the capability of the valve to operate under its design conditions.

ii) Inspection will be performed for the existence of a report verifying that the as-built motor-operated valves are bounded by the tests or type tests.

Acceptance Criteria

i) A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2. 1.2-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

ITAAC Determination Basis

Multiple Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) were performed to demonstrate that the Reactor Coolant System (RCS) motor-operated valves identified in the Combined License (COL) Appendix C, Table 2.1.2-1 perform an active safety-related function to change position as indicated in the table.

i) A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.1.2-1 under design cond itions.

This portion of the subject ITAAC required tests or type tests of motor-operated valves to be performed to demonstrate the capability of the valve to operate under its design conditions.

The motor-operated valves identified in COL Appendix C, Table 2.1.2-1 were qualified in accordance with the provisions of American Society of Mechanical Engineers (ASME) QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants (Reference 1 ).

Functional qualification was performed under the design conditions identified in the design specification for the valves (Reference 2) to demonstrate that each motor-operated valve is qualified to perform its designated function when used in its intended service. In accordance with ASME OME 2007, qualification was substantiated by demonstrating the relationship between the service requirements and the type testing and analysis that was conducted as part of this qualification program.

Type testing was performed, including natural frequency determination, side load static deflection testing, final static seat and stem leakage testing, steam testing, and water testing, for the ranges of the pressure, temperature and flow for each valve and the maximum seat-sealing differential pressure.

In accordance with ASME QME-1-2007, the functional qualification process for these motor-operated valve assemblies also included valve and actuator internal inspections and measurement, orientation requirements, seat and stem leakage limitations, diagnostic data collection and analysis methods, U.S. Nuclear Regulatory Commission ND-22-0689 Enclosure Page 3 of 5

static and dynamic flow diagnostic testing, and pressure locking and thermal binding evaluations. The qualification also followed the provisions of ASME QME-1-2007 for the extrapolation of functional qualification to another valve assembly, and demonstration of functional capability of production valve assemblies.

The results of the qualification are documented in the Equipment Qualification (EQ) Reports (Reference 3) which are identified in Attachment A for each applicable valve. These reports summarize the test methodology and ASME QME-1-2007 functional qualification that demonstrate that each motor-operated valve changes position as indicated in COL Appendix C, Table 2. 1.2-1 under design conditions.

ii) A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

This portion of the subject ITAAC required that an inspection be performed for the existence of a report verifying that the as -built motor-operated valves are bounded by tests or type tests.

The motor-operated valves in COL Appendix C, Table 2.1.2-1 were verified by type tests in accordance with section i) above, to demonstrate the capability of the valves to operate under their design conditions. The EQ Reports in Attachment A identify the equipment mounting employed for the testing and the specific conditions tested.

In accordance with the EQ ITAAC As-built Walkdown Guideline (Reference 4) and the EQ ITAAC As built Installation Documentation Guideline (Reference 5), an inspection was conducted of the RCS to confirm the satisfactory installation of the motor-operated valves. The inspection included verification of equipment make/model/serial number, verification of equipment mounting and location, and verification that the mechanical and electrical connections are bounded by the tested conditions.

The documentation of installed configuration of the motor-operated valves includes photographs and/or sketches of equipment mounting and connections. The verification of installed equipment configuration is documented in As-Built EQ Reconciliation Report (EQRR) (Reference 6).

Attachment A identifies the EORR which verifies that the installed configuration of the motor-operated valves identified in COL Appendix C, Table 2.1.2-1 are bounded by the tests or type tests.

Together, these EQ Reports and EQRR (References 3 and 6), provide evidence that the ITAAC Acceptance Criteria requirements are met:

  • A test report exists and concludes that each motor-operated valve changes position as indicated in Table 2.1.2-1 under design conditions; and
  • A report exists and concludes that the as-built motor-operated valves are bounded by the tests or type tests.

References 3 and 6 are available for NRC Inspection as part of the Unit 4 ITAAC 2.1.02.12a.i 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 findings pertaining to the subject ITAAC and associated corrective actions. This review found there were two relevant ITAAC findings associated with this ITAAC.

U.S. Nuclear Regulatory Commission ND-22-0689 Enclosure Page 4 of 5

  • Notice of Nonconformance 99900905/2012-201-01 (closed)
  • Notice of Nonconformance 99900905/2012-201-04 (closed)

The corrective actions for these findings have been completed and the findings are closed. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2. 1.02. 12a.i (Reference 7) and is available for NRC review.

ITAAC Comp letion Statement

Based on the above information, SNC hereby notifies the NRC that ITAAC 2.1.02.12a.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 a re being maintained in their as designed, ITAAC compliant condition in accordance with approved plant programs and procedures.

References (available for NRC inspection)

1. American Society of Mechanical Engineers (ASME) QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants
2. SV4-PV01-Z0-001, "3" and Larger Motor Operated Gate and Globe Valves, ASME Boiler and Pressure Vessel Code Section Ill, Class 1, 2, and 3", Revision 4 3. Equipment Qualification (EQ) Reports as Identified in Attachment A 4. ND-RA-001-014, EQ ITAAC As-built Walkdown Guideline, Version 3.1
5. ND-RA-001-016, EQ ITAAC As-built Installation Documentation Guideline, Version 1.0 6. As-Built Equipment Qualification Reconciliation Report (EQRR) as Identified In Attachment A
7. 2.1.02.12a.i-U 4-CP-Rev0, ITAAC Completion Package U.S. Nuclear Regulatory Commission ND-22-0689 Enclosure Page 5 of 5

Attachment A

System : Reactor Coolant System (RCS)

Equipment Name+ Tag No.+ Function+ (Reference 3) Active EQ Reports As-Built EQRR (Reference 6)

First-stage ADS SV4-PV01-VBR - 013 / 2.1.02.12a.i-U4-Motor-operated Valve RCS-PL-V001 A Transfer Open SV4-PV01-VBR-014 EQRR-PCD001

'MOV)

First-stage ADS MOV RCS-PL-V001 B Transfer Open SV4-PV01-VBR-014 SV4-PV01-VBR-013 / 2.1.02.12a.i-U4-EQRR-PCD001 Second-stage ADS RCS-PL-V002A Transfer Open SV4-PV01-VBR-014 SV4-PV01-VBR-013 / 2.1.02.12a.i-U4-MOV EQRR-PCD001 Second-stage ADS RCS-PL-V002B Transfer Open SV4 - PV01-VBR-014 SV4-PV01-VBR-013 / 2.1.02.12a.i-U4-MOV EQRR-PCD001

[Third-stage ADS MOV RCS-PL-V003A Transfer Open SV4-PV01-VBR-014 SV4-PV01-VBR-013 / 2.1.02.12a.i-U4-EQRR-PCD001 Third-stage ADS MOV RCS-PL-V003B Transfer Open SV4-PV01-VBR-014 SV4-PV01-VBR-013 / 2.1.02.12a.i-U4-EQRR-PCD001 First-stage ADS RCS-PL-V011A Transfer Open SV4-PV01 - VBR-012 SV4-PV01-VBR - 011 / 2.1.02. 12a.i-U4-Isolation MOV EQRR-PCD001 First-stage ADS RCS - PL-V011 B Transfer Open SV4-PV01-VBR-012 SV4-PV01-VBR-011 / 2.1.02.12a.i-U4-Isolation MOV EQRR-PCD001 Second-stage ADS RCS-PL-V012A Transfer Open SV4-PV01-VBR-012 SV4-PV01-VBR-011 / 2.1.02.12a.i-U4-Isolation MOV EQRR-PCD001 Second-stage ADS RCS-PL-V012B Transfer Open SV4-PV01-VBR-012 SV4-PV01-VBR-011 / 2.1.02.12a.i-U4-Isolation MOV EQRR-PCD001

[Third-stage ADS RCS-PL-V013A Transfer Open SV4-PV01 -VBR-012 SV4-PV01-VBR-011 / 2.1.02.12a.i - U4-Isolation MOV EQRR-PCD001 Third-stage ADS RCS-PL-V013B Transfer Open SV4-PV01 -VBR-012 SV4-PV01-VBR-011 / 2.1.02. 12a.i-U4-Isolation MOV EQRR-PCD001

Notes:

+ Excerpt from COL Appendix C Table 2.1.2-1