ND-22-0186, ITAAC Closure Notification on Completion of ITAAC 2.2.05.07a.i (Index Number 265)

ITAAC Closure Notification on Completion of ITAAC 2.2.05.07a.i (Index Number 265)

ML22152A217
Person / Time
Site:	Vogtle
Issue date:	06/01/2022
From:	Coleman J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ITAAC 2.2.05.07a.i, ND-22-0186
Download: ML22152A217 (13)

Text

~ Southern Nuclear Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel JUN O1 2022 Docket No.: 52-025 ND-22-0186 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 3 ITAAC Closure Notification on Completion of ITAAC 2.2.05.0?a.i [Index Number 265]

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 3 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.2.05.0?a.i [Index Number 265]. This ITAAC verifies that: The Main Control Room Emergency Habitability System (VES) provides a 72-hour supply of breathable quality air for the occupants of the Main Control Room (MCR), maintains the MCR pressure boundary at a positive pressure with respect to the surrounding areas, provides a passive recirculation flow of MCR air to maintain main control room dose rates below an acceptable level during VES operation , and the background noise level in the MCR does not exceed 65 dB(A) at the operator workstations when VES is operating. This ITAAC also ensures safety-related displays identified in Combined License (COL) Table 2.2.5-1 can be retrieved in the MCR , controls exist in the MCR to cause remotely operated valves identified in COL Table 2.2.5-1 perform their active functions, the valves identified in COL Table 2.2 .5-1 as having PMS control perform their active safety function after receiving a signal from the PMS, and that after loss of motive power, the remotely operated valves identified in COL Table 2.2.5-1 assume the indicated loss of motive power position. Additionally, this ITAAC verifies displays of the parameters identified in COL Table 2.2.5-3 can be retrieved in the MCR. The closure process for this ITAAC was based on the guidance described in 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, C>rit /\AA A11 ~

JaU ~ _' ~:1:: an Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2 .05.0?a.i [Index Number 265]

JMC/JTK/sfr

U.S. Nuclear Regulatory Commission ND-22-0186 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena Ill Mr. D. L. McKinney Mr. H. Nieh Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. D. Pitts Mr. J.B. Williams Mr. A. S. Parton Ms. K. A. Roberts Ms. J.M. Coleman Mr. C. T. Defnall Mr. C. E. Morrow Mr. K. J. Drudy Mr. J. M. Fisher Mr. R. L. Beilke Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01 .02.06 Nuclear Regulatory Commission Ms. M. Bailey Mr. M. King Mr. G. Bowman Ms. A. Veil Mr. C. P. Patel Mr. G. J. Khouri Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. 0. Lopez-Santiago Mr. G. Armstrong Mr. M. Webb Mr. T. Fredette Mr. C. Santos Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Ms. K. Mccurry Mr. J. Parent Mr. B. Griman Mr. V. Hall

U.S. Nuclear Regulatory Commission ND-22-0186 Page 3 of 3 Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Dr. L. Oriani Mr. D. C. Durham Mr. M. M. Corletti Mr. Z. S. Harper Ms. S.L. Zwack Other Mr. S. W. Kline , Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr. , Ph.D., GOS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 1 of 1O Southern Nuclear Operating Company ND-22-0186 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2.05.07a.i [Index Number 265]

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 2 of 10 IT AAC Statement Design Commitment 7.a) The VES provides a 72-hour supply of breathable quality air for the occupants of the MCR.

7.b) The VES maintains the MCR pressure boundary at a positive pressure with respect to the surrounding areas.

7.d) The system provides a passive recirculation flow of MCR air to maintain main control room dose rates below an acceptable level during VES operation .

8. Safety-related displays identified in Table 2.2.5-1 can be retrieved in the MCR.

9.a) Controls exist in the MCR to cause remotely operated valves identified in Table 2.2.5-1 to perform their active functions.

9.b) The valves identified in Table 2.2.5-1 as having PMS control perform their active safety function after receiving a signal from the PMS.

10. After loss of motive power, the remotely operated valves identified in Table 2.2.5-1 assume the indicated loss of motive power position.

11. Displays of the parameters identified in Table 2.2.5-3 can be retrieved in the MCR.

12 The background noise level in the MCR does not exceed 65 dB(A) at the operator workstations when VES is operating.

Inspections, Tests, Analyses i) Testing will be performed to confirm that the required amount of air flow is delivered to the MCR.

iii) MCR air samples will be taken during VES testing and analyzed for quality.

i) Testing will be performed with VES flow rate between 60 and 70 scfm to confirm that the MCR is capable of maintaining the required pressurization of the pressure boundary.

ii) Air leakage into the MCR will be measured during VES testing using a tracer gas.

Testing will be performed to confirm that the required amount of air flow circulates through the MCR passive filtration system, Inspection will be performed for retrievability of the safety-related displays in the MCR.

Stroke testing will be performed on remotely operated valves identified in Table 2.2.5-1 using the controls in the MCR.

Testing will be performed on remotely operated valves listed in Table 2.2.5-1 using real or simulated signals into the PMS.

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 3 of 10 Testing of the remotely operated valves will be performed under the conditions of loss of motive power.

Inspection will be performed for retrievability of the parameters in the MGR.

The as-built VES will be operated, and background noise levels in the MGR will be measured at the operator work stations with the plant not operating.

Acceptance Criteria i) The air flow rate from the VES is at least 60 scfm and not more than 70 scfm.

iii) The MGR air is of breathable quality.

i) The MGR pressure boundary is pressurized to greater than or equal to 1/8-in. water gauge with respect to the surrounding area.

ii) Air leakage into the MGR is less than or equal to 10 cfm.

The air flow rate at the outlet of the MGR passive filtration system is at least 600 cfm greater than the flow measured by VES-003A/B.

Safety-related displays identified in Table 2.2.5-1 can be retrieved in the MGR.

Controls in the MGR operate to cause remotely operated valves identified in Table 2.2.5-1 to perform their active safety functions.

The remotely operated valves identified in Table 2.2.5-1 as having PMS control perform the active safety function identified in the table after receiving a signal from the PMS.

After loss of motive power, each remotely operated valve identified in Table 2.2.5-1 assumes the indicated loss of motive power position.

The displays identified in Table 2.2.5-3 can be retrieved in the MGR.

The background noise level in the MGR does not exceed 65 dB(A) at the operator work stations when the VES is operating.

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 4 of 10 ITAAC Determination Basis Multiple ITAAC were performed to verify that the Main Control Room Emergency Habitability System (VES) provides a 72-hour supply of breathable quality air for the occupants of the Main Control Room (MCR), maintains the MCR pressure boundary at a positive pressure with respect to the surrounding areas, limits air in-leakage to the MCR, provides a passive recirculation flow of MCR air to maintain main control room dose rates below an acceptable level during VES operation , and the background noise level in the MCR does not exceed 65 dB(A) at the operator workstations when VES is operating. This ITAAC also ensures safety-related displays identified in Combined License (COL) Table 2.2.5-1 can be retrieved in the MCR, controls exist in the MCR to cause remotely operated valves identified in COL Table 2.2.5-1 perform their active functions, the valves identified in COL Table 2.2.5-1 as having PMS control perform their active safety function after receiving a signal from the PMS, and that after loss of motive power, the remotely operated valves identified in COL Table 2.2.5-1 assume the indicated loss of motive power position . Additionally, this ITAAC verifies displays of the parameters identified in COL Table 2.2.5-3 can be retrieved in the MCR.

i) The air flow rate from the VES is at least 60 scfm and not more than 70 scfm.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 to confirm that the required amount of air flow is delivered to the MCR .

The test manually actuated a MCR isolation and VES actuation from a normal ventilation alignment, verified proper system alignment and measured the flow rate into the MCR from the VES using VES-FT003A/B (MCR Air Delivery Line A/B Flow rate sensors) . The flow from the Unit 3 VES was 67.82 scfm. This demonstrated that the air flow rate from the VES is at least 60 scfm and not more than 70 scfm.

iii) The MCR air is of breathable quality.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 to confirm that the MCR air is of breathable quality.

The test manually actuated a MCR isolation and VES actuation from a normal ventilation alignment, verified proper system alignment and recorded data from 3 air quality analyzers for a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The VES provided breathable air from the air storage bottles and maintained the breathability of the MCR air by limiting the carbon dioxide concentration below 1/2 percent by volume. The MCR air quality was maintained within the guidelines of Appendix C, Table C-1 of ASHRAE Standard 62.1 - 1989 as documented in Reference 3. The Unit 3 data was analyzed and extrapolated to a 72-hour duration for up to 11 MCR occupants and demonstrated that the Unit 3 MCR air is of breathable quality.

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 5 of 10 i) The MCR pressure boundary is pressurized to greater than or equal to 1/8-in. water gauge with respect to the surrounding area.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 to confirm that the MCR is capable of maintaining the required pressurization of the pressure boundary with VES in service.

During the period when the MCR ventilation systems were in an alignment with VES in service, the atmospheric pressure was measured in an adjacent area outside the MCR and the test meter was zeroed. The MCR was entered, the meter was allowed to stabilize, and a reading was taken . This was repeated for each adjacent area to the MCR until all adjacent areas had been tested. The test results show the Unit 3 MCR minimum boundary differential pressure was 0.16 inch water gauge (WG) which confirmed the MCR pressurization boundary is pressurized to greater than or equal to 1/8-in. water gauge with respect to the surrounding area.

ii) Air leakage into the MCR is less than or equal to 1O cfm.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 to confirm that air leakage into the MCR is less than or equal to 1O cfm.

During the period when the MCR ventilation systems were in an alignment with VES in service ,

a tracer gas was injected into the MCR to establish a known concentration based on MCR volume. Once an equilibrium value was reached, the tracer gas injection was reduced and periodic sampling of the MCR atmosphere was performed. The envelope air leakage into the MCR was calculated and corrected to account for MCR outside air makeup. The results of the test demonstrated the air leakage into the Unit 3 MCR was 5 cfm which confirmed the air leakage into the MCR is less than or equal to 1O cfm .

The air flow rate at the outlet of the MCR passive filtration system is at least 600 cfm greater than the flow measured by VES-003A/B.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 to confirm that the air flow rate at the outlet of the MCR passive filtration system was at least 600 cfm greater than the flow rate measured by VES-003A/B.

During the period when the MCR ventilation systems were in an alignment with VES in service, the MCR air delivery line A/B flow rate (VES-003A/B) and the flow rate at the outlet of the MCR passive filtration system were recorded. The flow differential for Unit 3 was 813 cfm. This verified that the air flow rate at the outlet of the MCR passive filtration system is at least 600 cfm greater than the flow rate measured by VES-003A/B.

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 6 of 10 Safety-related displays identified in Table 2.2.5-1 can be retrieved in the MCR.

An inspection was performed in accordance with Unit 3 component test work packages as documented in Reference 1 and verified the safety-related displays identified in COL Table 2.2.5-1 (Attachment A) can be retrieved in the MCR.

The inspection began at the Primary Dedicated Safety Panel for Division A and verified all of the safety- related displays in Attachment A can be retrieved. This was repeated for each of the 3 remain ing Primary Dedicated Safety Panel Divisions. This confirmed that the safety-related displays identified in Table 2.2.5-1 can be retrieved in the MCR.

Controls in the MCR operate to cause remotely operated valves identified in Table 2.2.5-1 to perform their active safety functions .

Testing was performed in accordance with Unit 3 component test work packages as documented in Reference 2 and verified controls in the MCR operate to cause remotely operated valves identified in COL Table 2.2.5-1 (Attachment B) to perform their active safety functions.

Testing began by ensuring each valve listed in Attachment B was closed . At a MCR operator workstation , each valve was operated to the active function position (open) , the valve position was verified locally, and documented in the test. This demonstrated that controls in Unit 3 MCR operate to cause remotely operated valves identified in Table 2.2.5-1 to perform their active safety functions.

The remotely operated valves identified in Table 2.2.5-1 as having PMS control perform the active safety function identified in the table after receiving a signal from the PMS.

Testing was performed in accordance with Unit 3 component test work packages as documented in Reference 2. These component test packages utilized procedures as outlined in Reference 2 and confirmed that the remotely operated valves identified in COL Table 2.2.5-1 (Attachment C) as having PMS control perform the active safety function identified in the table after receiving a signal from the PMS .

Work packages and procedures in Reference 2 established initial conditions with each valve verified locally and in the MCR to be in the closed position. An actuation signal was generated by PMS using the PMS Maintenance and Test Panel (MTP) to generate a signal to open the valves in Attachment C. Each valve was verified locally and in the MCR to be open. This verified that the remotely operated valves identified in Table 2.2.5-1 as having PMS control perform the active safety function identified in the table after receiving a signal from the PMS.

After loss of motive power, each remotely operated valve identified in Table 2.2.5-1 assumes the indicated loss of motive power position.

Testing was performed in accordance with Unit 3 component test work packages as documented in Reference 2 and demonstrated that after a loss of motive power, each remotely operated valve identified in COL Table 2.2.5-1 (Attachment D) assumes the indicated loss of motive power position .

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 7 of 10 The component test configured and documented the air-operated valves (VES-PL-V022A and V022B) in the closed position and then removed power to the solenoid valve supplying air to the valve operator. The valve was verified to fail to the required position (open) locally. Power was restored , and the valve was positioned as required by plant conditions. The solenoid-operated valves (VES-PL-V005A and V005B) were placed in the closed position, power was removed ,

and the valve was verified to fail to the required position (open) locally. An attempt was made to reposition the valve and it was verified to not change position. Power was restored , and the valves were positioned as required by plant conditions. The test results demonstrated that for Unit 3 after a loss of motive power, each remotely operated valve identified in Table 2.2.5-1 assumes the indicated loss of motive power position.

The displays identified in Table 2.2.5-3 can be retrieved in the MCR.

An inspection was performed in accordance with Unit 3 component test work packages as documented in Reference 1 to confirm that the displays identified in COL Table 2.2.5-3 (Attachment E) can be retrieved in the MCR.

Testing began at an operator work station in Unit 3 MCR and verified all the displays identified in Attachment E can be retrieved . This confirmed that the displays identified in Table 2.2.5-3 can be retrieved in the MCR.

The background noise level in the MCR does not exceed 65 dB(A) at the operator work stations when the VES is operating.

Testing was performed in accordance with Unit 3 preoperational test procedure listed in Reference 3 and verified the background noise level in the MCR did not exceed 65 dB(A) at the operator work stations when the as-built VES is operating.

During the period when the MCR ventilation systems were in an alignment with VES in service, the background noise level was recorded for no less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at the MCR operator work stations. This data was analyzed, recorded and the results show Unit 3 maximum noise level was 61.6 dB(A) at the MCR operator work stations. The test results demonstrated the background noise level in the MCR does not exceed 65 dB(A) at the operator work stations when the VES is operating.

References 1 through 3 are available for NRC inspection as part of ITAAC 2.2.05.0?a.i Unit 3 Completion Package (Reference 4).

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 8 of 10 ITAAC Finding Review In accordance with plant procedures for ITAAC completion , Southern Nuclear Operating Company performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This review found there were no relevant findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package 2.2.05.0?a.i (Reference 4) and is available for NRG review.

ITAAC Completion Statement Based on the above information , SNC hereby notifies the NRG that ITAAC 2.2.05.0?a. i was performed for VEGP Unit 3 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. SV3-VBS-ITR-800265, Rev 0, " Unit 3 Main Control Room Emergency Habitability System Displays: ITAAC 2.2.05.0?a.i Items 8 and 11 "

2. SV3-VES-ITR-801265, Rev 0, "Unit 3 Main Control Room Emergency Habitability System (VES) Valve Control: ITAAC 2.2.05.0?a.i Items 9.a, 9.b and 10"

3. SV3-VES-ITR-802265, Rev 0, "Unit 3 Main Control Room Emergency Habitability System (VES) Pressure, Flow and Noise: ITAAC 2.2.05.0?a.i Items 7.a, 7.b, 7.d and 12"

4. 2.2.05.07a.i-U3-CP-Rev0, ITAAC Completion Package

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 9 of 10 Attachment A

• Excerpt from COL Appendix C Table 2.2.5-1 Table 2.2.5-1

• Equipment Name *TaQ No. *Safety-Related Display MCR Load Shed Panel 1 VES-EP-01 Yes MCR Load Shed Panel 2 VES-EP-02 Yes MCR Air Delivery VES-PL-V005A Yes Isolation Valve A MCR Air Delivery VES-PL-V005B Yes Isolation Valve B MCR Pressure Relief VES-PL-V022A Yes Isolation Valve A MCR Pressure Relief VES-PL-V022B Yes Isolation Valve B MCR Air Delivery Line VES-003A Yes Flow Sensor MCR Air Delivery Line VES-003B Yes Flow Sensor MCR Differential Pressure VES-004A Yes Sensor A MCR Differential Pressure VES-004B Yes Sensor B Attachment B

• Excerpt from COL Appendix C Table 2.2.5-1 Table 2.2.5-1

• Equipment Name *Tag No. *Remotely *Active Function Operated Valve MCR Air Delivery VES-PL-V005A Yes Transfer Open Isolation Valve A MCR Air Delivery VES-PL-V005B Yes Transfer Open Isolation Valve B MCR Pressure VES-PL-V022A Yes Transfer Open Relief Isolation Valve A MCR Pressure VES-PL-V022B Yes Transfer Open Relief Isolation Valve A

U.S. Nuclear Regulatory Commission ND-22-0186 Enclosure Page 1O of 1O Attachment C

• Excerpt from COL Appendix C Table 2.2.5-1 Table 2.2.5-1

• Equipment Name *Tag No. *Remotely *Control *Active Operated Valve PMS Function MCR Air Delivery VES-PL-V005A Yes Yes Transfer Isolation Valve A Open MCR Air Delivery VES-PL-V005B Yes Yes Transfer Isolation Valve B Open MCR Pressure Relief VES-PL-V022A Yes Yes Transfer Isolation Valve A Open MCR Pressure Relief VES-PL-V022B Yes Yes Transfer Isolation Valve B Open Attachment D

• Excerpt from COL Appendix C Table 2.2.5-1 Table 2.2.5-1

• Equipment Name *Tag No. *Remotely *Loss of Motive Operated Power Position Valve MCR Air Delivery Isolation VES-PL-V005A Yes Open Valve A MCR Air Delivery Isolation VES-PL-V005B Yes Open Valve B MCR Pressure Relief Isolation VES-PL-V022A Yes Open Valve A MCR Pressure Relief Isolation VES-PL-V022B Yes Open Valve B Attachment E Excerpt from COL Appendix C Table 2.2.5-3 Table 2.2.5-3 Equipment Tag No. Display Air Storage Tank Pressure VES-001A Yes Air Storage Tank Pressure VES-001B Yes