ND-22-0710, ITAAC Closure Notification on Completion of ITAAC 2.3.06.05a.i (Index Number 361)
| ML22322A207 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/18/2022 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ND-22-0710, ITAAC 2.3.06.05a.i | |
| Download: ML22322A207 (1) | |
Text
A Southern Nuclear November 18, 2022 Docket No.:
52-026 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 4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel ND-22-0710 10 CFR 52.99(c)(1)
ITMC Closure Notification on Completion of ITMC 2.3.06.05a.i [Index Number 361]
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 4 Inspections, Tests, Analyses, and Acceptance Criteria (ITMC) Item 2.3.06.05a.i [Index Number 361] to demonstrate that the Normal Residual Heat Removal System (RNS) equipment identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.3.6-1 is designed and constructed in accordance with applicable requirements.
The closure process for this ITMC is based on the guidance described in NEI 08-01, "Industry Guideline for the ITMC 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,
~ma~
Regulatory Affairs Director Vogtle 3 & 4
Enclosure:
JMC/AD/sfr Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITMC 2.3.06.05a.i [Index Number 361]
U.S. Nuclear Regulatory Commission ND-22-0710 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-22-0710 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-22-0710 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.06.0Sa.i [Index Number 361]
U.S. Nuclear Regulatory Commission N D-22-0710 Enclosure Page 2 of 9 IT AAC Statement Design Commitment 5.a) The seismic Category I equipment identified in Table 2.3.6-1 can withstand seismic design basis loads without loss of safety function.
7.a) The Class 1 E equipment identified in Table 2.3.6-1 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 2.3.6-1 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 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 2.3.6-1 is located on the Nuclear Island.
ii) 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.
i) A report exists and concludes that the Class 1 E equipment identified in Table 2.3.6-1 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 1 E equipment and the associated wiring, cables, and terminations identified in Table 2.3.6-1 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-22-0710 Enclosure Page 3 of 9 ITAAC Determination Basis This ITAAC requires that inspections, tests, and analyses were performed and documented to ensure the Normal Residual Heat Removal System (RNS) equipment identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.3.6-1 (the Table) is designed and constructed in accordance with applicable requirements.
i) The seismic Category I equipment identified in Table 2.3.6-1 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) Walkdown ITAAC Guideline and the EQ ITAAC As-built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the RNS 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 Reports (EQRR) (Reference 3) identified in Attachment A document the results of the inspection and conclude 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 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, 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 is determined using the guidance of ASME QME-1-2007 (Reference 5).
Safety-related (Class 1 E) 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.
iii) A report exists and concludes that the as-built equipment including anchorage is seismically bounded by the tested or analyzed conditions.
An inspection (Reference 1 and 2) is 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
U.S. Nuclear Regulatory Commission ND-22-0710 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, is 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 1 E equipment identified in Table 2.3.6-1 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 was qualified by type testing and/or analyses. Class 1 E equipment type testing was performed in accordance with IEEE Standard 323-197 4 (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 1 E equipment and the associated wiring, cables, and terminations identified in Table 2.3.6-1 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 RNS 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 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 documents the installed configuration with photographs or sketches/drawings of equipment mounting and connections. The EQRR (Reference 3) identified in Attachment A document this inspection and conclude that the as-built harsh environment Class 1 E equipment and the
U.S. Nuclear Regulatory Commission ND-22-0710 Enclosure Page 5 of 9 associated wiring, cables, and terminations are bounded by the qualified configuration and IEEE Standard 323-197 4 (Reference 10).
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 2.3.6-1 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; 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 1 E equipment identified in Table 2.3.6-1 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 2.3.6-1 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 2.3.06.05a.i Completion Package (Reference 12).
IT AAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all lTAAC findings pertaining to the subject ITAAC and associated corrective actions. This finding review, which included now-consolidated ITAAC Indexes 362, 363, 366, and 367, found no relevant ITAAC findings associated with this ITAAC.
The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.3.06.05a.i (Reference 12) and is available for NRC review.
IT AAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.3.06.05a.i was performed for VEGP Unit 4 and that the prescribed acceptance criteria are met.
Systems, structures, and components verified as part of this IT AAC are being maintained in their as-designed, ITAAC compliant condition in accordance with approved plant programs and procedures.
U.S. Nuclear Regulatory Commission N D-22-0710 Enclosure Page 6 of 9 References (available for NRC inspection)
- 1. ND-RA-001-014, EQ ITMC As-built Walkdown Guideline, Version 3.1
- 2. ND-RA-001-016, EQ ITMC As-built Installation Documentation Guideline, Version 1.0
- 3. EQ As-Built Reconciliation Reports (EQRR) as identified in Attachment A for Unit 4
Code, Section Ill, "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," The American Society of Mechanical Engineers, June 2007
- 6. IEEE Standard 344-1987, "IEEE Recommended Practices for Seismic Qualification of Class 1 E Equipment for Nuclear Power Generating Stations"
- 7. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, "Methodology for Qualifying AP1000 Safety-Related Electrical and Mechanical Equipment"
- 8. Equipment Qualification (EQ) Reports as identified in Attachment A
- 9. Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"
- 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. 2.3.06.05a.i-U4-CP-Rev0, "Completion Package for Unit 4 ITMC 2.3.06.05a.i [Index Number 361]"
U.S. Nuclear Regulatory Commission ND-22-0710 Enclosure Page 7 of 9 Equipment Name +
Tag No.+
RNS Pump A (Pressure RNS-MP-01A Boundary}
RNS Pump B (Pressure RNS-MP-01B Boundary}
RNS Heat Exchanger A RNS-ME-01A Tube Side}
RNS Heat Exchanger B RNS-ME-01B
'Tube Side)
RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001A Isolation Valve RCS Inner Hot Leg Suction Motor-operated RNS-PL-V001 B Isolation Valve RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002A Isolation Valve RCS Outer Hot Leg Suction Motor-operated RNS-PL-V002B Isolation Valve RCS Pressure Boundary Thermal Relief Check RNS-PL-V003A Valve RCS Pressure Boundary Thermal Relief Check RNS-PL-V003B 1/alve RNS Discharge Motor-operated Containment RNS-PL-V011 Isolation Valve Attachment A System: Normal Residual Heat Removal System (RNS)
Class 1E/
Seismic Qual. For Envir. Envir Qual Type of EQ Reports (Reference 8)
As-Built EQRR Cat. I +
Harsh Zone 1 Program 2 Qual.
(Reference 3)
Envir.+ 3 Yes
-/-
NA NA Analysis SV4-MP08-VBR-001 / SV4-2.3.06.05a.i-U4-MP08-VBR-002 EQRR-PCD001 Yes
-/-
NA NA Analysis SV4-MP08-VBR-001 / SV4-2.3.06.05a.i-U4-MP08-VBR-002 EQRR-PCD001 Yes
-/-
NA NA Analysis SV4-ME1C-VDR-001 2.3.06.05a.i-U4-EQRR-PCD002 Yes
-/-
NA NA Analysis SV4-ME1C-VDR-001 2.3.06.05a.i-U4-EQRR-PCD002 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes Yes/Yes 1
EMS*
Analysis SV4-PV01-VBR-011 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes Yes/Yes 1
EMS*
Analysis SV4-PV01-VBR-011 EQRR-PCD003 Type Test &
SV4-PV01 -VBR-012 /
2.3.06.05a.i-U4-Yes Yes/Yes 1
EMS
- Analysis SV4-PV01 -VBR-011 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes Yes/Yes 1
EMS*
Analysis SV4-PV01-VBR-011 EQRR-PCD003 SV4-PV02-VBR-012 /
2.3.06.05a.i-U4-Yes
-/-
NA NA Analysis SV4-PV02-VBR-011 EQRR-PCD003 SV4-PV02-VBR-012 /
2.3.06.05a.i-U4-Yes
-/-
NA NA Analysis SV4-PV02-VBR-011 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes Yes/No NA NA Analysis SV4-PV01-VBR-011 EQRR-PCD003
U.S. Nuclear Regulatory Commission ND-22-0710 Enclosure Page 8 of 9 Equipment Name +
Tag No.+
RNS Discharge Containment Isolation RNS-PL-V012 rTest Connection RNS Discharge Header Containment Isolation RNS-PL-V01 3 Check Valve RNS Discharge RCS Pressure Boundary RNS-PL-V015A Check Valve RNS Discharge RCS Pressure Boundary RNS-PL-V015B Check Valve RNS Discharge RCS Pressure Boundary RNS-PL-V017A Check Valve RNS Discharge RCS Pressure Boundary RNS-PL-V017B Check Valve RNS Hot Leg Suction RNS-PL-V020 Pressure Relief Valve RNS Hot Leg Suction RNS-PL-V021 Pressure Relief Valve RNS Suction Header Motor-operated RNS-PL-V022 Containment Isolation
!Valve RNS Suction from IRWST Motor-operated RNS-PL-V023 Isolation Valve RNS Discharge to IRWST Motor-operated RNS-PL-V024 Isolation Valve Seismic Cat. I+
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Class 1E/
As-Built EQRR Qual. For Envir.
Envir Qual Type of EQ Reports (Reference 8)
Harsh Zone 1 Program 2 Qual.
(Reference 3)
Envir.+ 3 Type Test &
SV4-PV02-VBR-010 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV02-VBR-009 EQRR-PCD003 Analysis SV4-PV03-VBR-014 /
2.3.06.05a.i-U4-
-/-
NA NA SV4-PV03-VBR-013 EQRR-PCD003 Type Test &
SV4-PV03-VBR-012 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV03-VBR-011 EQRR-PCD003 Type Test &
SV4-PV03-VBR-012 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV03-VBR-011 EQRR-PCD003 Analysis SV4-PV03-VBR-014 /
2.3.06.05a.i-U4-
-/-
NA NA SV4-PV03-VBR-013 EQRR-PCD003 Analysis SV4-PV03-VBR-014 /
2.3.06.05a.i-U4-
-/-
NA NA SV4-PV03-VBR-013 EQRR-PCD003 Type Test &
SV4-PV16-VBR-002 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV16-VBR-001 EQRR-PCD003 Type Test &
SV4-PV16-VBR-002 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV16-VBR-001 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes/No NA NA Analysis SV4-PV01-VBR-011 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-Yes/Yes 1
EMS
- Analysis SV4-PV01-VBR-011 EQRR-PCD003 Type Test &
SV4-PV01-VBR-012 /
2.3.06.05a.i-U4-
-/-
NA NA Analysis SV4-PV01-VBR-011 EQRR-PCD003
U.S. Nuclear Regulatory Commission N D-22-0710 Enclosure Page 9 of 9 Equipment Name +
Tag No.+
RNS Pump Discharge RNS-PL-V045 Relief RNS Suction from Cask Loading Pit Motor-RNS-PL-V055 pperated Isolation Valve RNS Suction from Cask RNS-PL-V056 Loading Pit Check Valve RNS Pump Miniflow Air-RNS-PL-V057A Operated Isolation Valve RNS Pump Miniflow Air-RNS-PL-V057B Operated Isolation Valve RNS Return from Chemical and Volume Control System (CVS)
RNS-PL-V061 Containment Isolation
~alve Notes:
Seismic Cat. I+
Yes Yes Yes Yes Yes Yes
+ Excerpt from COL Appendix C Table 2.3.6-1
- 1. See Table 3D.5-1 of UFSAR Class 1E/
Qual. For Envir.
Envir Qual Type of EQ Reports (Reference 8)
Harsh Zone 1 Program 2 Qual.
Envir.+ 3
-/-
NA NA Type Test &
SV4-PV16-VBR-002 /
Analysis SV4-PV16-VBR-001 Type Test &
SV4-PV01 -VBR-012 /
No/No NA NA Analysis SV4-PV01-VBR-011
-/-
NA NA Analysis SV4-PV03-VBR-014 /
SV4-PV03-VBR-013 No/No NA NA Type Test &
SV4-PV14-VBR-002 /
Analysis SV4-PV14-VBR-001 No/No NA NA Type Test &
SV4-PV14-VBR-002 /
Analysis SV4-PV14-VBR-001 Type Test &
SV4-PV14-VBR-002 /
Yes/Yes 1
EMS*
Analysis SV4-PV14-VBR-001
- 2. 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
- 3. Dash(-) indicates not applicable As-Built EQRR (Reference 3) 2.3.06.05a.i-U4-EQRR-PCD003 2.3.06.05a.i-U4-EQRR-PCD003 2.3.06.05a.i-U4-EQRR-PCD003 2.3.06.05a.i-U4-EQRR-PCD003 2.3.06.05a.i-U4-EQRR-PCD003 2.3.06.05a.i-U4-EQRR-PCD003