ND-22-0920, ITAAC Closure Notification on Completion of ITAAC 2.7.01 .02a (Index Number 678)

ITAAC Closure Notification on Completion of ITAAC 2.7.01 .02a (Index Number 678)

ML22341A607
Person / Time
Site:	Vogtle
Issue date:	12/07/2022
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0920
Download: ML22341A607 (1)

Text

~ Southern Nuclear Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel December 7, 2022 Docket No.: 52-026 ND-22-0920 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 4 ITAAC Closure Notification on Completion of ITAAC 2.7.01 .02a [Index Number 678)

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 (ITAAC) Item 2.7.01 .02a (Index Number 678]. This ITAAC verifies that the Nuclear Island Nonradioactive Ventilation System components and piping listed in the Combined License Appendix C, Table 2.7.1-1 and Table 2.7.1-2, that are identified as American Society of Mechanical Engineers Code Section 111, were designed and constructed in accordance with applicable requirements. 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,

~~m~~~N Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.7.01 .02a [Index Number 678]

JMC/TUsfr

U.S. Nuclear Regulatory Commission ND-22-0920 Page 2 of 2 cc: Regional Administrator, Region II Director, Office of Nuclear Reactor Regulation (NRA)

Director, Vogtle Project Office NRA Senior Resident Inspector - Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-22-0920 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.7.01.02a [Index Number 678]

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 2 of 8 ITAAC Statement Design Commitment:

2.a) The components identified in Table 2.7.1-1 as ASME Code Section Ill are designed and constructed in accordance with ASME Code Section Ill requirements.

2.b) The piping identified in Table 2.7.1-2 as ASME Code Section Ill is designed and constructed in accordance with ASME Code Section Ill requirements.

3.a) Pressure boundary welds in components identified in Table 2.7.1-1 as ASME Code Section Ill meet ASME Code Section Ill requirements.

3.b) Pressure boundary welds in piping identified in Table 2.7.1-2 as ASME Code Section Ill meet ASME Code Section Ill requirements.

4.a) The components identified in Table 2.7.1-1 as ASME Code Section Ill retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.7.1-2 as ASME Code Section Ill retains its pressure boundary integrity at its design pressure.

Inspections, Tests, Analyses:

Inspection will be conducted of the as-built components and piping as documented in the ASME design reports.

Inspection of the as-built pressure boundary welds will be performed in accordance with the ASME Code Section Ill.

A pressure test will be performed on the components and piping required by the ASME Code Section Ill to be pressure tested.

Acceptance Criteria:

The ASME Code Section Ill design reports exist for the as-built components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Ill.

A report exists and concludes that the ASME Code Section Ill requirements are met for nondestructive examination of pressure boundary welds.

A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Ill conform with the requirements of the ASME Code Section Ill.

ITAAC Determination Basis This ITAAC requires inspections, tests, and analyses be performed and documented to ensure the Nuclear Island Nonradioactive Ventilation System (VBS } components and piping listed in the Combined License (COL) Appendix C, Table 2.7.1-1 (Attachment A) and Table 2.7.1-2

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 3 of 8 (Attachment 8) that are identified as American Society of Mechanical Engineers (ASME) Code Section 111, were designed and constructed in accordance with applicable requirements.

2.a and 2.b) The ASME Code Section Ill design reports exist for the as-built components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Ill.

Each component listed in Table 2.7.1-1 as ASME Code Section Ill was fabricated in accordance with the VEGP Updated Final Safety Analysis Report (UFSAR) and the ASME Code Section Ill requirements. The ASME Code Section Ill certified Design Reports for these components exist and document that the as-built components conform to the approved design details. The ASME Section Ill Design Report for each component was documented in the component's completed ASME Section Ill Code Data Report. The individual component ASME Section Ill Code Data Reports are documented on the ASME Section Ill N-5 Code Data Report for the applicable piping system (References 1, 2, 3 & 4).

The as-built piping listed in Table 2.7.1-2 including the components listed in Table 2.7.1-1 as ASME Code Section 111, were subjected to a reconciliation process (Reference 5), which verified that the as-built piping was analyzed for applicable loads (e.g. stress reports) and for compliance with all design specification and Code provisions. Design reconciliation of the as-built systems, including installed components, validated that construction completion, including field changes and any nonconforming condition dispositions, were consistent with and bounded by the approved design. All applicable fabrication, installation and testing records, as well as, those for the related Quality Assurance (QA) verification/inspection activities, which confirmed adequate construction in compliance with the ASME Code Section Ill and design provisions, are referenced in the N-5 Data Report and/or its sub-tier references.

The applicable ASME Section Ill N-5 Code Data Report (Reference 1, 2, 3 & 4), which include the location of the certified Design Reports for all the components listed in Table 2. 7 .1-1 (Attachment A) and piping listed in Table 2.7.1-2 (Attachment B) as ASME Code Section Ill, exist and conclude that these installed components were designed and constructed (including their installation within the applicable as-built piping system) in accordance with the ASME Code (1998 Edition, 2000 Addenda and 1989 Edition, 1989 Addenda), Section Ill requirements as applicable, as described in UFSAR Subsection 5.2.1 (Reference 6). The N-5 Code Data Reports for the piping systems containing the components listed in the Table 2.7.1-1 and Table 2.7.1-2 are identified in Attachments A and B, respectively.

3.a and 3.b) A report exists and concludes that the ASME Code Section Ill requirements are met for nondestructive examination of pressure boundary welds.

Inspections were performed in accordance with ASME Code Section Ill (1998 Edition, 2000 Addenda) to demonstrate that as-built pressure boundary welds in components identified in Table 2. 7 .1-1 as ASM E Code Section 111 meet ASME Code Section Ill requirements (i.e., no unacceptable indications).

The applicable nondestructive examinations (including liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section Ill) of the components' pressure boundary welds are documented in the Non-destructive Examination Report{s), which support completion of the respective ASME Section Ill N-5 Code Data Report certified by the Authorized Nuclear Inspector, as listed in Attachment A.

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 4 of 8 Per ASME Code Section Ill, Subarticle NCA-8300, "Code Symbol Stamps," the N-5 Code Data Reports (References 1, 2, 3 & 4), document satisfactory completion of the required examination and testing of the item, which includes non-destructive examinations of pressure boundary welds. Satisfactory completion of the non-destructive examination of pressure boundary welds ensured that the pressure boundary welds in components identified in Table 2.7.1-1 as ASME Code Section Ill met ASME Code Section Ill requirements.

An inspection was performed in accordance with Reference 5 to demonstrate that the as-built pressure boundary welds in piping identified in Table 2. 7.1-2 (Attachment 8) as ASME Code Section Ill met ASME Code Section Ill requirements (i.e., no unacceptable indications). This portion of the ITAAC was completed when the piping identified in Table 2.7.1-2, which is encompassed within the respective piping system Code Symbol N-Stamp and the corresponding piping system N-5 Code Data Report (References 1, 2, 3 & 4), was completed.

The non-destructive examinations (including visual inspection, liquid penetrant, magnetic particle, radiographic, and ultrasonic testing, as required by ASME Code Section Ill) of the piping pressure boundary welds were documented in the Non-destructive Examination Report(s) within the piping system's supporting data package, which support completion of the respective Code Stamping and N-5 Code Data Report.

The completion of stamping the respective piping system along with the corresponding ASME N-5 Code Data Reports (certified by the Authorized Nuclear Inspector) ensured that the piping was constructed in accordance with the design specifications and the ASME Code Section Ill and that the satisfactory completion of the non-destructive examinations of piping pressure boundary welds for the pipe lines identified in Table 2.7.1-2 met ASME Code Section Ill requirements and were documented in the Non-destructive Examination Report(s) within the supporting data packages.

4.a and 4.b) A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Ill conform with the requirements of the ASME Code Section Ill.

Pressure tests were performed by the vendor to demonstrate that the components identified in Table 2.7.1-1 (Attachment A) as ASME Code Section Ill retain their pressure boundary integrity at their design pressure. The completion of the N-5 Data Reports was governed by Reference 5.

This portion of the ITAAC was completed once each component identified in Table 2. 7 .1-1 had their individual Code Symbol N-Stamp and corresponding Code Data Report completed, and the components installed into the respective Code Symbol N-Stamped piping system and documented on the corresponding N-5 Code Data Report (References 1, 2, 3 & 4). The pressure testing results of the component's pressure boundary were documented in the Pressure (i.e., hydrostatic) Testing Report(s) within the supporting component's data package, which support completion of the respective Code Stamping and Code Data Report.

The completion of stamping the individual components and the respective piping system along with the corresponding ASME Code Data Reports (certified by the Authorized Nuclear Inspector) ensured that the components were constructed in accordance with the Design Specifications and the ASME Code Section 111 and that the satisfactory completion of the pressure testing of each component identified in Table 2.7.1-1 as ASME Code Section Ill were

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 5 of 8 documented in the Pressure (i.e. hydrostatic) Testing Report(s) within the supporting data packages and met ASME Code Section Ill requirements.

This ITAAC also verified that the piping identified in Table 2. 7. 1-2 (Attachment B) fully meets all applicable ASME Code, Section Ill requirements and retains its pressure boundary integrity at its design pressure.

Pressure tests were performed (as applicable) that comply with the ASME Code (1998 Edition, 2000 Addenda), Section Ill requirements to demonstrate that the ASME Code Section Ill piping identified in Table 2.7.1-2 retains its pressure boundary integrity at its design pressure.

The pressure tests verified that there were no leaks at welds or piping, and that the pressure boundary integrity was retained at its design pressure. The pressure testing results of the pipe lines are documented in Pressure Testing Reports. The Pressure Testing Reports are documented in the ASME Section Ill N-5 Code Data Reports and support completion of the ASME Section Ill N-5 Code Data Reports for the applicable piping system (References 1, 2, 3 &

4).

The ASME Section Ill N-5 Code Data Reports (References 1, 2, 3 & 4) identified in Attachments A and B document that the results of the pressure testing of the components and piping identified in Table 2.7.1-1 and Table 2.7.1-2 respectively conform with the requirements of the Code (1998 Edition, 2000 Addenda), Section Ill.

References (1, 2, 3 & 4) and the supporting as-built design reports (References 7, 8, 9 & 10) provide the evidence that the ITAAC Acceptance Criteria requirements were met:

• The ASME Code Section Ill design reports exist for the as-built components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section Ill ;

• A report exists and concludes that the ASME Code Section Ill requirements are met for nondestructive examination of pressure boundary welds; and

• A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.7.1-1 and 2. 7.1-2 as ASME Code Section Ill conform with the requirements of the ASME Code Section Ill.

This ITAAC required no Preservice Inspections (PSI) examinations for the VBS, Potable Water System (PWS), Sanitary Drainage System (SDS), and Waste Water System (WWS) per the Unit 4 Preservice Inspection Program Plan (Reference 11 ).

References 1 through 5, and 7 through 11, are available for NRC inspection as part of the Unit 4 ITAAC 2.7.01 .02a Completion Package (Reference 12).

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 6 of 8 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 no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.7.01.02a (Reference 12) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.7.01.02a was performed for VEGP Unit 4 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 (available for NRC inspection)

1. SV4-VBS-MUR-001, Rev. 0, "AP1000 Vogtle Unit 4 ASME Section Ill System Code Data Report for the Nuclear Island Nonradioactive Ventilation System (VBS)"

2. SV4-PWS-MUR-001, Rev. 0, "AP1000 Vogtle Unit 4 ASME Section 111 System Code Data Report for the Potable Water System (PWS)"

3. SV4-SDS-MUR-001, Rev. 0, "AP1000 Vogtle Unit 4 ASME Section Ill System Code Data Report for the Sanitary Drainage System (SOS)"

4. SV4-WWS-MUR-001, Rev. 0, "AP1000 Vogtle Unit 4 ASME Section 111 System Code Data Report for the Waste Water System (WWS)"

5. APP-GW-GAP-139, Rev. 8, 'Westinghouse/Stone & Webster ASME Code Data Report As-Built Documentation Interface Procedure"

6. VEGP 3&4 Updated Final Safety Analysis Report, Rev. 11.1, Subsection 5.2.1, Compliance with Codes and Code Cases

7. SV4-VBS-S3R-001, Rev. 0, "Vogtle Unit 4 Nuclear Island Nonradioactive Ventilation System (VBS) ASME 111 As-Built Piping System Design Report"

8. SV4-PWS-S3R-001, Rev. 0, "Vogtle Unit 4 Potable Water System (PWS) ASME Ill As-Built Piping System Design Report"

9. SV4-SDS-S3R-001, Rev. 0, "Vogtle Unit 4 Sanitary Drainage System (SOS) ASME Ill As-Built Piping System Design Report"

10. SV4-WWS-S3R-001, Rev. 0, "Vogtle Unit 4 Waste Water System (WWS) ASME Ill Piping System Design Report"

11. SV4-GW-GEl-100, Rev. 1, "AP1000 Preservice Inspection Program Plan for Vogtle Unit 4"

12. 2.7.01.02a-U4-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 7 of 8 Attachment A SYSTEM: Nuclear Island Nonradioactive Ventilation System (VBS)

ASME Code ASME Ill As-Built Equipment Name

• Tag No.* N-5 Report Section Ill* Design Report MCA Supply Air VBS-PL-V186 Yes SV4-VBS-S3A-00 1 SV4-VBS-MUR-001 Isolation Valve MCA Supply Air VBS-PL-V187 Yes SV4-VBS-S3R-001 SV4-VBS-MUR-001 Isolation Valve MCA Return Air VBS-PL-V188 Yes SV4-VBS-S3A-001 SV4-VBS-MUA-001 Isolation Valve MCA Return Air VBS-PL-V189 Yes SV4-VBS-S3A-001 SV4-VBS-MUR-001 Isolation Valve MCA Exhaust Air VBS-PL-V190 Yes SV4-VBS-S3R-00 1 SV4-VBS-MUA-001

~solation Valve MCA Exhaust Air VBS-PL-V191 Yes SV4-VBS-S3A-001 SV4-VBS-MUR-001 Isolation Valve PWS MCA Isolation PWS-PL-V418 Yes SV4-PWS-S3R-00 1 SV4-PWS-MUR-001

!Valve PWS MCA Isolation PWS-PL-V420 Yes SV4-PWS-S3A-001 SV4-PWS-MUR-001

!Valve PWS MCA Vacuum PWS-PL-V498 Yes SV4-PWS-S3A-001 SV4-PWS-MUR-001 Relief MCA SOS (Vent) SDS-PL-V001 Yes SV4-SDS-S3A-001 SV4-SDS-MUA-001 Isolation Valve MCA SDS (Vent) SDS-PL-V002 Yes SV4-SDS-S3A-001 SV4-SDS-MUA-001 Isolation Valve MCA WWS Isolation WWS-PL-V506 Yes SV4-WWS-S3R-001 SV4-WWS-MUA-001 Valve

• Excerpts from COL Appendix C Table 2.7.1-1

U.S. Nuclear Regulatory Commission ND-22-0920 Enclosure Page 8 of 8 Attachment B SYSTEM: Nuclear Island Nonradioactive Ventilation System (VBS)

ASME ASME Ill As-Built Line Name* Line Number* Code Design Report N-5 Report Section Ill*

Main Control Room VBS-L311 Yes SV4-VBS-S3R-001 SV4-VBS-MUR-001 Supply Main Control Room VBS-L312 Yes SV4-VBS-S3R-001 SV4-VBS-MUR-001 Exhaust Main Control Room VBS-L313 Yes SV4-VBS-S3R-001 SV4-VBS-MUR-001 Toilet Exhaust Main Control Room SDS-PL-L016 Yes SV4-SDS-S3R-001 SV4-SDS-MUR-001 Sanitary Vent Line Main Control Room SDS-PL-L 179 Yes SV4-SDS-S3R-001 SV4-SDS-MUR-001 Sanitary Drain Line Main Control Room SDS-PL-L 182 Yes SV4-SDS-S3R-00 1 SV4-SDS-MUR-001 Sanitary Drain Line Main Control Room PWS-PL-L31 g+ Yes SV4-PWS-S3R-001 SV4-PWS-MUR-001 Water Line Main Control Room PWS-PL-L320+ Yes SV4-PWS-S3R-001 SV4-PWS-MUR-001 Water Line Main Control Room WWS-PL-L808 Yes SV4-WWS-S3R-001 SV4-WWS-MUR-001 Waste Water Line Main Control Room WWS-PL-L851 Yes SV4-WWS-S3R-001 SV4-WWS-MUR-001 Waste Water Line

• Excerpts from COL Appendix C, Table 2. 7.1-2

+ For girth fillet welds between piping and socket welded fittings, valves and flanges, refer to VEGP UFSAR Section 5.2.1.1 (Reference 6)