Text

ITAAC Closure Notification on Completion of Item 2.2.02.05a.i (Index Number 126)
	ML22084A038
Person / Time
Site:	Vogtle
Issue date:	03/25/2022
From:	Yox M; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ND-21-1033
	Download: ML22084A038 (13)
	v • d • e

._ Southern Nuclear MAR 215 2022 Docket No.:

52-025 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 7825 River Road Waynesboro, GA 30830 706-848-6459 tel ND-21-1033 10 CFR 52.99(c)(1)

ITAAC Closure Notification on Completion of Item 2.2.02.05a.i [Index Number 1261 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 2.2.02.05a.i [Index Number 1261 to demonstrate that the Passive Containment Cooling System (PCS) components identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.2.2-1 are designed and constructed in accordance with applicable requirements.

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 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,

~d~

Michael J. Yax Regulatory Affairs Dire tor Vogtle 3 & 4

Enclosure:

MJY/BSZ/sfr Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2.02.05a.i [Index Number 1261

U.S. Nuclear Regulatory Commission ND-21-1033 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. J.B. Williams Mr. M. J. Yox 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 Mr. T. Fanelli Ms. K. Mccurry Mr. J. Parent Mr. B. Griman Mr. V. Hall

U.S. Nuclear Regulatory Commission ND-21-1033 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-21-1033 Enclosure Page 1 of 10 Southern Nuclear Operating Company ND-21-1033 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 2.2.02.0Sa.i [Index Number 126]

U.S. Nuclear Regulatory Commission ND-21-1033 Enclosure Page 2 of 1 O IT AAC Statement Design Commitment:

5.a) The seismic Category I components identified in Table 2.2.2-1 can withstand seismic design basis loads without loss of safety function.

6.a) The Class 1 E components identified in Table 2.2.2-1 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 components and valves identified in Table 2.2.2-1 are located on the Nuclear Island.

ii) Type tests, analyses, or a combination of type tests and analyses of seismic Category I components will be performed.

iii) Inspection will be performed for the existence of a report verifying that the as-built components including anchorage are seismically bounded by the tested or analyzed conditions.

i) Type tests or a combination of type tests and analyses will be performed on Class 1 E components located in a harsh environment.

ii) Inspection will be performed of the as-built Class 1 E components and the associated wiring, cables, and terminations located in a harsh environment.

Acceptance Criteria:

i) The seismic Category I components identified in Table 2.2.2-1 are located on the Nuclear Island.

ii) A report exists and concludes that the seismic Category I components can withstand seismic design basis loads without loss of safety function.

iii) The report exists and concludes that the as-built components including anchorage are seismically bounded by the tested or analyzed conditions.

i) A report exists and concludes that the Class 1 E components identified in Table 2.2.2-1 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 components and the associated wiring, cables, and terminations identified in Table 2.2.2-1 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-21-1033 Enclosure Page 3 of 1 O ITAAC Determination Basis This ITAAC requires that inspections, tests, and analyses be performed and documented to ensure the Passive Containment Cooling System (PCS) components identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.2.2-1 (the Table) are designed and constructed in accordance with applicable requirements.

i) The seismic Category I components identified in Table 2.2.2-1 are located on the Nuclear Island.

To assure that seismic Category I components can withstand seismic design basis loads without loss of safety function, all of the components in the Table are designed to be located on the seismic Category I Nuclear Island. In accordance with Equipment Qualification (EQ) ITAAC As-built Walkdown Guideline and the EQ ITAAC As-built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the PCS to confirm the satisfactory installation of the seismically qualified components. The inspection includes verification of component make/model/serial number and verification of component 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 components are located on the Nuclear Island.

ii) A report exists and concludes that the seismic Category I components can withstand seismic design basis loads without loss of safety function.

Seismic Category I components in the Table require 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 components, 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). Structural integrity of the passive containment cooling water storage tank (PCCWST) is demonstrated by analysis.

Structural integrity of the water distribution bucket and water distribution weirs is demonstrated by analysis in accordance with ANSI/AISC N690-1994 (Reference 6).

Safety-related (Class 1 E) electrical components in the Table are seismically qualified by type testing combined with analysis in accordance with Institute of Electrical and Electronics Engineers (IEEE) Standard 344-1987 (Reference 7). These components include safety-related (Class 1 E) field sensors and the 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 component in the Table is identified in Attachment A. Additional information about the methods used to qualify AP1000 safety-related components is provided in the Updated Final Safety Analysis Report (UFSAR) Appendix 30 (Reference 8). The EQ Reports (Reference 9) identified in Attachment A contain applicable test reports and associated documentation and conclude that the seismic Category I components can withstand seismic design basis loads without loss of safety function.

U.S. Nuclear Regulatory Commission ND-21-1033 Enclosure Page 4 of 1 0 iii) The report exists and concludes that the as-built components including anchorage are seismically bounded by the tested or analyzed conditions.

An inspection (References 1 & 2) was conducted to confirm the satisfactory installation of the seismically qualified components in the Table. The inspection verifies the component make/model/serial number, as-designed component mounting orientation, anchorage and clearances, and electrical and other interfaces. The documentation of installed configuration of seismically qualified components includes photographs and/or sketches/drawings of component/mounting/interfaces.

As part of the seismic qualification program, consideration was given to the definition of the clearances needed around the component mounted in the plant, to permit the component to move during a postulated seismic event without causing impact between adjacent pieces of safety-related components. When required, seismic testing by measuring the maximum dynamic relative displacement of the top and bottom of the components was conducted. EQ Reports (Reference 9) identify the component 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 components listed in the Table, including anchorage, are seismically bounded by the tested or analyzed conditions, IEEE Standard 344-1987 (Reference 7), and NRC Regulatory Guide (RG) 1.100 (Reference 10).

i) A report exists and concludes that the Class 1 E components identified in Table 2.2.2-1 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 components in the Table are qualified by type testing and/or analyses. Class 1 E electrical component type testing is performed in accordance with IEEE Standard 323-197 4 (Reference 11) and RG 1.89 (Reference 12), to meet the requirements of 1 0 CFR 50.49. Type testing of safety-related components meets the requirements of 1 0 CFR Part 50, Appendix A, General Design Criterion 4. Attachment A identifies the EQ program and specific qualification method for each safety-related mechanical or Class 1 E electrical component located in a harsh environment. Additional information about the methods used to qualify AP1000 safety-related components is provided in the UFSAR Appendix 30 (Reference 8). EQ Reports (Reference 9) identified in Attachment A contain applicable test reports and associated documentation and conclude that the components 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 components and the associated wiring, cables, and terminations identified in Table 2.2.2-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

An inspection (References 1 & 2) was conducted of the PCS to confirm the satisfactory installation of the Class 1 E components in the Table. The inspection verified the component

U.S. Nuclear Regulatory Commission ND-21 -1033 Enclosure Page 5 of 1 O location, make/model/serial number, as-designed component mounting, wiring, cables, and terminations, and confirms that the environmental conditions for the zone (Attachment A) in which the component is mounted are bounded by the tested or analyzed conditions. It also documents the installed configuration with photographs and/or sketches/drawings of component 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 component and the associated wiring, cables, and terminations are bounded by the qualified configuration and IEEE Standard 323-197 4 (Reference 11).

Together, these reports (References 3 and 9) provide evidence that the ITAAC Acceptance Criteria requirements are met:

The seismic Category I components identified in Table 2.2.2-1 are located on the Nuclear Island; A report exists and concludes that the seismic Category I components can withstand seismic design basis loads without loss of safety function; The report exists and concludes that the as-built components including anchorage are seismically bounded by the tested or analyzed conditions; A report exists and concludes that the Class 1 E components identified in Table 2.2.2-1 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 components and the associated wiring, cables, and terminations identified in Table 2.2.2-1 as being qualified for a harsh environment are bounded by type tests, analyses, or a combination of type tests and analyses.

References 3 and 9 are available for NRC inspection as part of the Unit 3 ITAAC 2.2.02.05a.i Completion Package (Reference 13).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all lTAAC findings and associated corrective actions.

This review, which included now consolidated ITAAC Indexes 127, 128, 131 and 132, found the following relevant ITAAC findings associated with this ITAAC:

1) Notice of Nonconformance 99900404/2012-201-04 (Closed-ML12313A461)

2) Notice of Nonconformance 99901412/2012-201-02 (Closed - ML18152B785)

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 2.2.02.05a.i (Reference 13) and is available for NRC review.

U.S. Nuclear Regulatory Commission ND-21-1033 Enclosure Page 6 of 10 IT AAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.2.02.05a.i was performed for VEGP Unit 3 and that the prescribed acceptance criteria are met.

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

References (available for NRC inspection)

1. ND-RA-001-014, EQ ITAAC As-built Walkdown Guideline, Version 3.1

2. ND-RA-001-016, EQ ITAAC As-built Installation Documentation Guideline, Version 1.0

3. EQ As-Built Reconciliation Reports (EQRR) as identified in Attachment A for Units 3

4. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code, Section Ill, "Rules for Construction of Nuclear Power Plant Components," 1998 Edition, 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. ANSI/AISC N690-1994, "American National Standard Specification for the Design, Fabrication, and Erection of Steel Safety-Related Structures for Nuclear Facilities"

7. IEEE Standard 344-1987, "IEEE Recommended Practices for Seismic Qualification of Class 1 E Equipment for Nuclear Power Generating Stations"

8. Vogtle 3&4 Updated Final Safety Analysis Report Appendix 3D, "Methodology for Qualifying AP1000 Safety-Related Electrical and Mechanical Equipment"

9. Equipment Qualification (EQ) Reports as identified in Attachment A

10. Regulatory Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants"

11. IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1 E Equipment for Nuclear Power Generating Stations"

12. Regulatory Guide 1.89, Rev 1, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants"

13. 2.2.02.05a.i-U3-CP-Rev 0, "ITAAC Completion Package"

U.S. Nuclear Regulatory Commission N D-21-1033 Enclosure Page 7 of 10 Component Name +

Tag No.+

PCCWST PCS-MT-01 Water Distribution PCS-MT-03 Bucket Water Distribution PCS-MT-04 Wiers (sic)

PCCWST Isolation PCS-PL-V001A Valve PCCWST Isolation PCS-PL-V001 B Valve PCCWST Isolation PCS-PL-V001 C Valve MOV PCCWST Isolation PCS-PL-V002A Block MOV PCCWST Isolation PCS-PL-V002B Block MOV PCCWST Isolation PCS-PL-V002C Block MOV PCS Recirculation Return Isolation PCS-PL-V023 Valve Attachment A System: Passive Containment Cooling System (PCS)

Class 1 E/

Envir Seismic Qual.

Envir.

Qual Type of EQ Reports As-Built EQRR Cat. I+

for Harsh Zone 1 Program 2 Qual.

Envir.+ 3 APP-1278-CCC-007 2.2.02.05a.i-U3-Yes N/A N/A Analysis EQRR-PCD009 APP-MT05-S3C-002 2.2.02.05a.i-U3-Yes N/A N/A Analysis EQRR-PCD009 2.2.02.05a.i-U3-Yes N/A N/A Analysis APP-MT05-S3C-002 EQRR-PCD009 Type APP-PV11-VBR-004 /