ND-23-0026, ITAAC Closure Notification on Completion of ITAAC 2.2.03.12a.iv (Index Number 216)

ITAAC Closure Notification on Completion of ITAAC 2.2.03.12a.iv (Index Number 216)

ML23013A222
Person / Time
Site:	Vogtle
Issue date:	01/13/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0026
Download: ML23013A222 (1)

Text

~ Southern Nuclear Jamie M. Coleman 7825 River Road Regulatory Affa irs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel January 13, 2023 Docket No.: 52-026 ND-23-0026 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 2.2.03.12a.iv [Index Number 216]

Ladies and Gentlemen:

In accordance with 10 CFR 52.99(c)(1 ), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRG) of the completion of Vogtle Electric Generating Plant (VEGP) Unit 4 Inspections, Tests, Analyses, and Acceptance Criteria {ITAAC) Item 2.2.03.12a.iv [Index Number 216], for verifying each check valve changes position as indicated in Table 2.2.3-1. The closure process for this ITAAC is based on the guidance described in NEI 08-01, "Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52", which is 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,

~a~

Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.2.03.12a.iv [Index Number 216]

JMC/DLW/sfr

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure 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-23-0026 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-23-0026 Enclosure Vogtle Electric Generating Plant {VEGP) Unit 4 Completion of ITAAC 2.2.03.12a.iv [Index Number 216]

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure Page 2 of 6 ITAAC Statement Design Commitment 12.a) The squib valves and check valves identified in Table 2.2.3-1 perform an active safety-related function to change position as indicated in the table.

Inspections/Tests/Analyses iv) Exercise testing of the check valves with active safety functions identified in Table 2.2.3-1 will be performed under preoperational test pressure, temperature, and fluid flow conditions.

Acceptance Criteria iv) Each check valve changes position as indicated in Table 2.2.3-1 ITAAC Determination Basis Multiple ITAAC are performed to verify that the squib valves and check valves identified in Table 2.2.3-1 perform an active safety-related function to change position as indicated in the table.

This ITAAC performs testing of check valves in accordance with preoperational test procedures 4-PXS-ITPP-502 (Reference 1), 4-PXS-ITPP-503 (Reference 3), 4-PXS-ITPP-506 (Reference 5), and 4-PXS-ITPP-507 (Reference 7) to demonstrate each check valve with active safety functions changes position as indicated in VEGP Combined License (COL) Appendix C Table 2.2.3-1 (Attachment A) under preoperational test pressure, temperature, and fluid flow conditions.

References 1 and 2 performed the transfer open testing of the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A, -V028B and -V029B). The test established the initial conditions of the Accumulator Tank (PXS-MT-01A) filled and pressurized to greater than 70 pounds per square inch gage (psig) and less than 80 psig, the reactor pressure vessel (RPV) was at atmospheric pressure with the head off and the accumulator outlet valves were closed.

During the flow resistance determination testing of the line from the accumulator discharge to the direct vessel injection (DVI) nozzle, the "A" accumulator outlet valves were opened and the "A" accumulator discharges into the RPV through the DVI line. During this testing, the peak flow rate value was calculated based on volume change, from the change in measured tank level, per time interval. Based on the calculated flow rate, the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A) were verified to transfer open when flow rate exceeded 1614 gallons per minute (gpm). This test was repeated for the Accumulator Discharge Check Valves (PXS-PL-V028B and -V029B) during the flow resistance determination testing of the "B" Accumulator discharge through the "B" DVI line. This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9). These test flow paths are depicted on drawing SV4-PXS-M6-001, Piping and Instrumentation Diagram (P&ID) Passive Core Cooling System.

References 1 and 2 performed the transfer closed testing of the Nitrogen Supply Containment Isolation Check Valve (PXS-PL-V043). The test established the initial conditions of closing the nitrogen supply isolation valve to containment and closing a manual valve downstream of PXS-PL-V043. Temporary air lines were connected to test connections on either side of the PXS-PL-V043 check valve. With the downstream test connection open , the upstream test connection

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure Page 3 of 6 was pressurized with air and PXS-PL-V043 was determined to be open by verifying air exits the downstream test connection . The upstream connection was then closed and the air supply was connected to the downstream test connection . The downstream line was then pressurized through the downstream test connection and the test connection upstream of PXS-PL-V043 was opened and the differential pressure caused the PXS-PL-V043 check valve to transfer closed.

The upstream test connection was checked for leakage to verify the check valve had transferred closed. This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9).

These test flow paths are depicted on drawing SV4-PXS-M6-001 , P&ID Passive Core Cooling System.

References 3 and 4 performed the closed testing of the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A, -V028B and -V029B). The test ensured the "A" accumulator discharge lines were filled with water and the accumulator level was at 55% to 56% full, the "A" accumulator discharge isolation valves were closed, and one train of Normal Residual Heat Removal System (RNS) was in service recirculating the Reactor Coolant System (RCS) with the RCS Hot Leg level between 48% and 50%. The Passive Core Cooling System (PXS) test panel was utilized to sequentially place RNS pressure on the downstream side of each Accumulator "A" Discharge Check Valve (PXS-PL-V028A and -V029A). When the upstream side of the check valves were depressurized by opening their respective upstream test connection, each check valve was demonstrated to have transferred closed . This test was repeated for the Accumulator "B" Discharge Check Valves (PXS-PL-V028B and -V029B). This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9). These test flow paths are depicted on drawing SV4-PXS-M6-001, P&ID Passive Core Cooling System. Testing the transfer open function during pre-operational testing (Reference 1) along with testing the closed function during pre-operational testing (Reference 3) provided assurance that the Accumulator Discharge Check Valves (PXS-PL-V028A and -V029A, -V028B and -V029B) were adequately cycled to demonstrate they transferred open and closed .

References 5 and 6 performed the transfer open function of the Core Makeup Tank (CMT)

Discharge Check Valves (PXS-PL-V016A and -V017A, -V016B and -V017B) during the flow resistance determination testing of the CMT injection line. VEGP Updated Final Safety Analysis Report (UFSAR) subsection 6.3.2.1.3 states that these check valves are normally open with or without flow in the line (i.e., flow out of the CMT and into the DVI injection line). This test established the "A" CMT was at approximately 85% level, the RPV was at atmospheric pressure with the head off and the "A" CMT isolation valves were verified to be closed . The "A" CMT isolation valves were then opened and a level rise in the RPV demonstrated by operation of the sump pump to maintain water level within the hot leg confirmed that the "A" CMT Discharge Check Valves (PXS-PL-V016A and -V017A) were open. This testing was repeated on the "B" CMT Discharge Check Valves (PXS-PL-V016B and -V017B). This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9).

References 3 and 4 performed the transfer closed function of the CMT Discharge Check Valves (PXS-PL-V016A and -V017A, -V016B and -V017B). This test established the RPV at atmospheric pressure with the head installed. PXS-PL-V016A was tested by closing upstream and downstream CMT isolation valves, connecting one end of a test rig with a flow meter and pressure gauge to Accumulator Tank (PXS-MT-01A) Drain Valve, and the other end to a PXS-PL-V016A upstream vent test connection. With Accumulator Tank (PXS-MT-01A) pressurized to - 700 psig, zero leakage was observed at a downstream PXS-PL-V016A test connection which demonstrated that the PXS-PL-V016A Discharge Check Valve transferred closed. This testing was repeated for each of the remaining CMT Discharge Check Valves (PXS-PL-V016B,

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure Page 4 of 6

-V017A, and -V017B). This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9). These test flow paths are depicted on drawing SV4-PXS-M6-001, P&ID Passive Core Cooling System. Testing the open function during pre-operational testing (Reference 5) along with testing the transfer closed function during pre-operational testing (References 3) provided assurance that the CMT Discharge Check Valves (PXS-PL-V016A and -V017A, -

V0168 and -V0178) were adequately cycled to demonstrate they transferred both open and closed.

References 7 and 8 performed the transfer open and transfer closed function of the In-containment Refueling Water Storage Tank (IRWST) Injection Check Valves (PXS-PL-V122A and -V124A, -V1228 and -V1248) during the IRWST flow resistance determination testing of the IRWST injection lines. This test established the IRWST upper narrow range level between Oto 15 inches, the reactor vessel was full to the flange with the head off and venturi flow meter test spools were installed in place of downstream squib valves. The IRWST injection line "A" motor-operated valve (MOV) was opened and the flow obtained through each check valve confirmed the IRWST Injection Check Valves PXS-PL-V122A and -V124A had transferred open . After check valves PXS-PL-V122A and -V124A were confirmed to be open, IRWST Injection Line "A" MOV was closed and the check valves PXS-PL-V122A and -V124A were confirmed to transfer closed by use of non-intrusive equipment. This test was repeated for the "B" IRWST Injection Check Valves (PXS-PL-V1228 and -V1248). This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9). These test flow paths are depicted on drawing SV4-PXS-M6-002, P&ID Passive Core Cooling System. Performance of pre-operational testing (Reference 7) provided assurance the IRWST Injection Check Valves (PXS-PL-V122A and -

V124A, -V122B and -V1248) were adequately cycled to demonstrate they transferred both open and closed.

References 7 and 8 performed the transfer open and transfer closed function of the Containment Recirculation Check Valves (PXS-PL-V119A and -V1198) during the IRWST Screen "A" to Containment Recirculation Sump "A" flow resistance determination testing. This test established the IRWST upper narrow range level at 0 to 15 inches, the reactor vessel was full to the flange with the head off, IRWST sumps were fitted with temporary removable valves, temporary pipe spools were installed in place of downstream squib valves and a temporary pipe with a venturi flow meter was installed to cross-connect the containment recirculation sump "A" to "B". The containment recirculation "A" MOV was opened and IRWST injection line "B" isolation valve was opened and check valve PXS-PL-V119A was confirmed to be closed by use of non-intrusive equipment while PXS-PL-V119B was confirmed to be open by system flow.

This test was repeated by opening containment recirculation "B" MOV and IRWST injection line "A" isolation valve and confirmed PXS-PL-V1198 was closed by use of non-intrusive equipment and PXS-PL-V119A was confirmed to be open by system flow. This was documented in ITAAC Technical Report SV4-PXS-ITR-800216 (Reference 9). These test flow paths are depicted on drawing SV4-PXS-M6-002, P&ID Passive Core Cooling System. Performance of pre-operational testing (Reference 7) provided assurance that Containment Recirculation Check Valves (PXS-PL-V119A and -V1198) were adequately cycled to demonstrate they transferred both open and closed.

References 1 through 9 are available for NRC inspection as part of the Unit 4 ITAAC 2.2.03.12a.iv Completion Package (Reference 10).

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure Page 5 of 6 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 no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITMC Completion Package for ITAAC 2.2.03.12a.iv (Reference 10) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITMC 2.2.03.12a.iv was performed for VEGP Unit 4 and that the prescribed acceptance criteria were met.

Systems, structures, and components verified as part of this ITMC are being maintained in their as-designed, ITAAC compliant condition in accordance with approved plant programs and procedures.

References (available for NRC inspection)

1. 4-PXS-ITPP-502, Rev. 1.0, "PXS Accumulator Mapping and Line Resistance Test"

2. SV4-PXS-T0W-1191256, "Perform Preop Test 4-PXS-ITPP-502"

3. 4-PXS-ITPP-503, Rev. 1.0, "TPC for Passive Core Cooling System Pre-Core Flow Testing with RV Head Installed Preoperational Test Procedure"

4. SV4-PXS-T0W-1191260, "(ITAAC) Perform Preop Test IAW 4-PXS-ITPP-503"

5. 4-PXS-ITPP-506, Rev. 1.1, "PXS CMT Mapping and Line Resistance Test"

6. SV4-PXS-T0W-1191263, "(ITAAC) Perform Preop Test 4-PXS-ITPP-506"

7. 4-PXS-ITPP-507, Rev. 1.0, "TPC for IRWST Flow Tests"

8. SV4-PXS-TOW-1191264, "(ITMC) Perform Preop Test 4-PXS-ITPP-507"

9. SV4-PXS-ITR-800216, Rev. 0, "Unit 4 Recorded Results of PXS Check Valves Change Position as Indicated in Table 2.2.3-1: ITMC 2.2.03.12a.iv"

10. 2.2.03.12a.iv-U4-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-23-0026 Enclosure Page 6 of 6 Attachment A

• Excerpt from COL Appendix C Table 2.2.3-1 Equipment Name

• Tag No.* Active Function*

rTransfer Open/

CMT A Discharge Check Valve PXS-PL-V016A rTransfer Closed rTransfer Open /

CMT B Discharge Check Valve PXS-PL-V016B rTransfer Closed rTransfer Open /

CMT A Discharge Check Valve PXS-PL-V017A rTransfer Closed rTransfer Open /

CMT B Discharge Check Valve PXS-PL-V017B rTransfer Closed Accumulator A Discharge Check Valve PXS-PL-V028A rrransfer Open/Close Accumulator B Discharge Check Valve PXS-PL-V028B Transfer Open/Close Accumulator A Discharge Check Valve PXS-PL-V029A rTransfer Open/Close PXS-PL-V029B rTransfer Open/Close Accumulator B Discharge Check Valve PXS-PL-V043 Transfer Closed Nitrogen Supply Containment Isolation Check Valve rTransfer Open /

Containment Recirculation A Check Valve PXS-PL-V119A rTransfer Closed rTransfer Open /

Containment Recirculation B Check Valve PXS-PL-V119B rTransfer Closed Transfer Open /

IRWST Injection A Check Valve PXS-PL-V122A Transfer Closed Transfer Open /

IRWST Injection B Check Valve PXS-PL-V1228 rTransfer Closed rTransfer Open /

IRWST Injection A Check Valve PXS-PL-V124A rTransfer Closed rTransfer Open /

IRWST Injection B Check Valve PXS-PL-V124B Transfer Closed