ND-22-0869, ITAAC Closure Notification on Completion of Item 2.3.13.05.i (Index Number 462)
| ML23012A245 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/12/2023 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ND-22-0869, ITAAC 2.3.13.05.i | |
| Download: ML23012A245 (1) | |
Text
~ Southern Nuclear January 12, 2023 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 706-848-6459 tel ND-22-0869 10 CFR 52.99(c)(1)
ITMC Closure Notification on Completion of Item 2.3.13.05.i [Index Number 462]
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 2.3.13.05.i [Index Number 462] to demonstrate that the Primary Sampling System (PSS) equipment identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.3.13-1 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 1 O CFR 52.99.
If there are any questions, please contact Kelli Roberts at 706-848-6991.
Respectfully submitted,
~GA~
Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4
Enclosure:
Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITMC 2.3.13.05.i [Index Number 462]
JMC/JRB/sfr
U.S. Nuclear Regulatory Commission ND-22-0869 Page 2 of 2 cc:
Regional Administrator, Region 11 Director, Office of Nuclear Reactor Regulation (NRR)
Director, Vogtle Project Office NRR Senior Resident Inspector - Vogtle 3 & 4
U.S. Nuclear Regulatory Commission ND-22-0869 Enclosure Page 1 of 7 Southern Nuclear Operating Company ND-22-0869 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 2.3.13.05.i [Index Number 462]
U.S. Nuclear Regulatory Commission ND-22-0869 Enclosure Page 2 of 7 IT AAC Statement Design Commitment
- 5. The seismic Category I equipment identified in Table 2.3.13-1 can withstand seismic design basis loads without loss of its safety function.
6.a) The Class 1 E equipment identified in Tables 2.3.13-1 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 their 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 and valves identified in Table 2.3.13-1 are 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 2.3.13-1 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 2.3.13-1 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 its 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 2.3.13-1 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-22-0869 Enclosure Page 3 of 7 IT AAC Determination Basis This IT MC requires that inspections, tests, and analyses were performed and documented to ensure the Primary Sampling System (PSS) equipment identified as seismic Category I or Class 1 E in the Combined License (COL) Appendix C, Table 2.3.13-1 (the Table) is designed and constructed in accordance with applicable requirements.
i) The seismic Category I equipment identified in Table 2.3.13-1 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 ITMC Guideline and the EQ ITMC As-built Installation Documentation Guideline (References 1 and 2), an inspection was conducted of the PSS 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 Report (EQRR) (Reference 3) identified in Attachment A documents the results of the inspection and concludes 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 require type tests and/or analyses to demonstrate structural integrity and operability. Structural integrity of the seismic Category I valves 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) was 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-22-0869 Enclosure Page 4 of 7 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 by 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 NRG Regulatory Guide (RG) 1.100 (Reference 9).
i) A report exists and concludes that the Class 1 E equipment identified in Table 2.3.13-1 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 its 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 electrical 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 or Class 1 E electrical equipment located in a harsh environment. Additional information about the methods used to qualify AP1000 safety-related equipment is provided in the UFSAR Appendix 30 (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 2.3.13-1 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 PSS 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 documents this inspection and concludes that the as-built harsh environment Class 1 E equipment and the associated wiring, cables, and terminations are bounded by the qualified configuration and IEEE Standard 323-197 4 (Reference 10).
U.S. Nuclear Regulatory Commission ND-22-0869 Enclosure Page 5 of 7 Together, these reports (References 3 and 8) provide evidence that the ITMC Acceptance Criteria requirements are met:
The seismic Category I equipment identified in Table 2.3.13-1 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 2.3.13-1 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 its 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 2.3.13-1 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 IT MC 2.3.13.05.i Completion Package (Reference 12).
IT AAC Finding Review In accordance with plant procedures for ITMC completion, Southern Nuclear Operating Company (SNC) performed a review of all IT MC findings pertaining to the subject ITMC and associated corrective actions. This finding review, which included now-consolidated IT MC Indexes 463, 464,465, and 466, found no relevant ITMC finding associated with this ITMC.
The ITMC completion review is documented in the ITMC Completion Package for ITMC 2.3.13.05.i (Reference 12) and is available for NRC review.
IT AAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITMC 2.3.13.05.i was performed for VEGP Unit 4 and that the prescribed acceptance criteria were met.
Systems, structures, and components verified as part of this IT MC are being maintained in their as-designed, ITMC compliant condition in accordance with approved plant programs and procedures.
U.S. Nuclear Regulatory Commission ND-22-0869 Enclosure Page 6 of 7 References {available for NRC inspection)
- 1. ND-RA-001-014, "EQ Walkdown ITMC Guideline", Version 4.0
- 2. ND-RA-001-016, "EQ ITMC As-built Installation Documentation Guideline", Version 1.0
- 3. EQ As-Built Reconciliation Report (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. 2.3.13.05.i-U4-CP-Rev0, "Completion Package for Unit 4 ITMC 2.3.13.05.i [Index Number 462]"
- 13. NEI 08-01. "Industry Guideline for the ITMC Closure Process Under 10 CFR Part 52"
U.S. Nuclear Regulatory Commission ND-22-0869 Enclosure Page 7 of 7 Attachment A System: Primary Sampling System (PSS)
Class 1E/
Equipment Name +
Tag No.+
Seismic Qual. for Envir. EnvirQual Type of Qual.
Cat. I+
Harsh Zone 1 Program 2 Envir.+
Containment Air Sample Type Testing &
Containment Isolation Valve PSS-PL-V008 Yes Yes/Yes 1
ME* S Inside Reactor Containment (IRC Analysis Liquid Sample Line Containment PSS-PL-V010A Yes Yes/Yes 1
ME* S Type Testing &
Isolation Valve IRC Analysis Liquid Sample Line Containment PSS-PL-V01 OB Yes Yes/Yes 1
ME* S Type Testing &
Isolation Valve IRC Analysis Liquid Sample Line Containment Type Testing &
Isolation Valve Outside Reactor PSS-PL-V011A Yes Yes/No N/A N/A Containment (ORC)
Analysis Liquid Sample Line Containment PSS-PL-V011 B Yes Yes/No N/A N/A Type Testing &
Isolation Valve ORC Analysis Sample Return Line Containment PSS-PL-V023 Yes Yes/No N/A N/A Type Testing &
Isolation Valve ORC Analysis Sample Return Containment PSS-PL-V024 Yes Yes/Yes 1
ME* S Type Testing &
Isolation Valve I RC Analysis Air Sample Line Containment PSS-PL-V046 Yes Yes/No N/A N/A Type Testing &
Isolation Valve ORC Analvsis Notes:
+ Excerpt from COL Appendix C Table 2.3.13-1
- 1. See Table 3D.5-1 of UFSAR
- 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 EQ Reports As-Built EQRR (Reference 8)
(Reference 3)
SV4-PV13-VBR-011 /
2.3.13.05.i-U4-SV4-PV13-VBR-012 EQRR-PCD001 SV4-PV13-VBR-011 /
2.3.13.05.i-U4-SV4-PV13-VBR-012 EQRR-PCD001 SV4-PV13-VBR-011 /
2.3.13.05.i-U4-SV4-PV13-VBR-012 EQRR-PCD001 SV4-PV17-VBR-002 /
2.3.13.05.i-U4-SV4-PV17-VBR-001 EQRR-PCD001 SV4-PV17-VBR-002 /
2.3.13.05.i-U4-SV4-PV17-VBR-001 EQRR-PCD001 SV4-PV17-VBR-002 /
2.3.13.05.i-U4-SV4-PV17-VBR-001 EQRR-PCD001 SV4-PV13-VBR-011 /
2.3.13.05.i-U4-SV4-PV13-VBR-012 EQRR-PCD001 SV4-PV17-VBR-002 /
2.3.13.05.i-U4-SV4-PV17-VBR-001 EQRR-PCD001