ND-18-0731, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.05a (Index Number 664)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.05a (Index Number 664)

ML18155A339
Person / Time
Site:	Vogtle
Issue date:	06/04/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC C.2.6.09.05a, ND-18-0731
Download: ML18155A339 (7)

Text

^ Southern Nuclear Michael J. Yox Regulatory Affairs Director 7825 River Road Waynestxtro, GA 30830 Vogtie 3 & 4 706-848-6459 tei 410-474-8587 cell JUN 0 4 2018 myox @southernco.com Docket Nos.: 52-025 52-026 ND-18-0731 10 CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtie Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item C.2.6.09.05a findex Number 6641 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of May 25, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item C.2.6.09.05a [Index Number 664] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing this ITAAC. Southern Nuclear Operating Company will, at a later date, provide additional notifications for ITAAC that have not been completed 225-days prior to initial fuel load.

This notification is informed by 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. In accordance with NEI 08-01, this notification includes ITAAC for which required inspections, tests, or analyses have not been performed or have been only partially completed. All ITAAC will be fully completed and all Section 52.99(c)(1) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding that all acceptance criteria are met prior to plant operation, as required by 10 CFR 52.103(g).

This letter contains no new NRC regulatory commitments.

If there are any questions, please contact Tom Petrak at 706-848-1575.

Respectfully submitted,

/^i Michael J. Yox Regulatory Affairs Direbtor Vogtie 3 &4

Enclosure:

Vogtie Electric Generating Plant (VEGP) Unit 3 & Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.05a Index Number 664]

MJY/RAS/amw

U.S. Nuclear Regulatory Commission ND-18-0731 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. M. D. Rauckhorst (w/o enclosures)

Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKinney Mr. M. J. Yox Mr. D. L. Fulton Mr. J. B. Klecha Mr. G. Chick Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reoulatorv Commission Mr. W. Jones (w/o enclosures)

Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Ms. L. A. Kent Mr. P. B. Donnelly Ms. N. C. Convert OalethorDe Power Corporation Mr. R. B. Brinkman

U.S. Nuclear Regulatory Commission ND-18-0731 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. OrlanI (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. CorlettI Ms. L. G. Iller Mr. D. Hawkins Ms. J. Monahan Mr. J. L. Coward Ms. N. E. Deangelis Other Mr. J. E. Hesier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., CDS Associates, inc.

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-18-0731 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-18-0731 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 & Unit 4 Completlon Plan for Uncompleted ITAAC C.2.6.09.05a Index Number 664]

U.S. Nuclear Regulatory Commission ND-18-0731 Enclosure Page 2 of 4 ITAAC Statement Desion Commitment

5. Access control points are established to:

a) control personnel and vehicle access into the protected area.

b) detect firearms, explosives, and incendiary devices at the protected area personnel access points.

Insoections. Tests. Analvses Tests, inspections, or combination of tests and inspections of installed systems and equipment at the access control points to the protected area will be performed.

Tests, inspections, or combination of tests and inspections of installed systems and equipment at the access control points to the protected area will be performed.

Acceptance Criteria The access control points for the protected area:

a) are configured to control personnel and vehicle access.

b) include detection equipment that is capable of detecting firearms, incendiary devices, and explosives at the protected area personnel access points.

ITAAC Completion Description Tests, inspections or a combination oftests and inspections of installed systems and equipment at the access control points to the protected area are performed to verify the access control points are configured to control personnel and vehicle access, and include detection equipment that is capable of detecting firearms, incendiary devices, and explosives at the protected area personnel access points. The VEGP Unit 3 (Unit 4) Plant Security System ITAACs only cover the Unit 3 (Unit 4) plant security system design commitment scope.

a) The access control ooints for the orotected area are configured to control personnel and vehicle access.

An inspection is performed to confirm that protected area primary personnel and vehicle access control points are installed perapproved construction drawings and to ensurethe access control points are configured to control personnel and vehicle access perthe applicable personnel and vehicle access control requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR Part 73.55(g)(1).

The inspection of the protected area primary personnel access control point confirms that personnel are channeled to the designated access control point where personnel are processed before being granted access to the protected area. The primaiy personnel access control point is confirmed to include: 1) a location where identity and authorization for access can be verified.

U.S. Nuclear Regulatory Commission ND-18-0731 Enclosure Page 3 of 4

2) the ability to search equipment and personnel to verify that unauthorized items are not present prior to entry into the protected area, 3) video surveillance equipment that can be monitored by security personnel, and 4) alarmed entry control devices (e.g., doors, gates, turnstiles, card readers, or biometrics) that prevent or delay unauthorized entry into the protected area before completion of the required processing.

The inspection of the protected area primary vehicle access control point confirms that vehicles are channeled to the designated access control point where vehicles are processed before being granted access to the protected area. The vehicle access control point is confirmed to include: 1) a remotely operated active vehicle barrier both outside and inside the protected area,

2) video surveillance equipment that can be monitored by security personnel, and 3) a vehicle search isolation area between the inner and outer protected area fence to search vehicles for unauthorized items. Vehicle operators are processed via the protected area primary personnel access control point described in the previous paragraph.

The results of the protected area personnel and vehicle access control point inspection are documented in Procedure XXX (References 1 and 2) and confirm that the protected area access control points are configured to control personnel and vehicle access.

b1 The access control points for the protected area include detection eauipment that is capable of detectino firearms, incendiarv devices, and explosives at the protected area personnel access ooints.

Inspection of the primary personnel access point confirms the access point includes a search area containing metal detectors, explosive detectors, and X-Ray devices configuredto prevent unauthorized bypass, and that is capable of detecting firearms, incendiary devices, and explosives, per the applicable personnel access control requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR Part 73.55(h)(3)(i).

Operational testing of the detection equipment is performed following installation to confirm the detection equipment is functioning and performing within design specifications. Walkthrough (portal) metal detectors are used to detect metallic components in weapons; detection of wiring, batteries, and other metallic components of bombs and incendiary devices; and detection of metals used to shield radioactive material. Portal explosive detectors are used to detect trace amounts of explosives. X-Ray imaging equipment is used to inspectthe contents of hand carried items and packages for unauthorized items.

The results of the protected area personnel access point detection equipment inspections and testing are documented in Procedure YYY (References 3 and 4) and confirm that installed equipment at the protected area personnel access point is capable of detecting firearms, incendiary devices, and explosives.

Together, these reports (References 1 through 4) provide evidence that the ITAAC Acceptance Criteria requirements are met:

• The access control points forthe protected area are configured to control personnel and vehicle access; and

U.S. Nuclear Regulatory Commission ND-18-0731 Enclosure Page 4 of 4

• The access control points for the protected area Include detection equipment that Is capable of detecting firearms, Incendiary devices, and explosives at the protected area personnel access points.

References 1 through 4 are available for NRG Inspection as part of the Unit 3 and Unit 4ITAAC Completion Packages (References 5 and 6).

List of ITAAC Findings 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 finding review, which Included now-consolidated ITAAC Index 665, found there are no relevant ITAAC findings associated with this ITAAC.

References (available for NRG inspection)

1. Procedure XXX, Unit 3 Access Control Point Inspection

2. Procedure XXX, Unit 4 Access Control Point Inspection

3. Procedure YYY, Unit 3 Personnel Access Point Detection Equipment Inspection and Testing

4. Procedure YYY, Unit 4 Personnel Access Point Detection Equipment Inspection and Testing

5. C.2.6.09.05a-U3-CP-Rev0, ITAAC Completion Package

6. C.2.6.09.05a-U4-CP-Rev0, ITAAC Completion Package

7. NEI08-01, "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"