ND-18-1013, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.09.13a (Index Number 652)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.09.13a (Index Number 652)

ML18211A632
Person / Time
Site:	Vogtle
Issue date:	07/27/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-18-1013
Download: ML18211A632 (7)

Text

!ik. Southern Nuclear Michael J. Vox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtie 3 & 4 706-848-6459 tei 410-474-8587 ceii JUL 2 7 2018 myox @southernco.com Docket Nos.: 52-025 52-026 ND-18-1013 10CFR 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 2.6.09.13a [Index Number 6521 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of July 18, 2018, Vogtie Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 2.6.09.13a [Index Number 652] 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.

Michael J. Vox Regulatory Affairs Director Vogtie 3 & 4

Enclosure:

Vogtie Electric Generating Plant (VEGP) Unit 3 & Unit 4 Completion Plan for Uncompleted ITAAC 2.6.09.13a [Index Number 652]

MJY/RAS/amw

U.S. Nuclear Regulatory Commission ND-18-1013 Page 2 of 3 To:

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

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

Mr. D. L. McKlnney Mr. M. J. Vox Mr. D. L. Fulton Mr. J. B. Klecha Mr. G. Chick Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Ms. A. C. Chamberlain 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 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 Mr. P. B. Donnelly Ms. N. C. Coovert Oatethoroe Power Corporation Mr. R. B. Brinkman Municipal Electric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-18-1013 Page 3 of 3 Westinahouse Electric Company. LLC Dr. L. Oriani (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. Hosier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

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

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

U.S. Nuclear Regulatory Commission ND-18-1013 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-18-1013 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.6.09.13a [Index Number 652]

U.S. Nuclear Regulatory Commission ND-18-1013 Enclosure Page 2 of 4 ITAAC Statement Design Commitment 13.a) The central and secondary alarm stations have conventional (landline) telephone service with the main control room and local law enforcement authorities.

13.b) The central and secondaryalarm stationsare capable of continuous communication with security personnel.

Inspections. Tests. Analvses Tests, inspections, or a combination of tests and inspections ofthe central and secondary alarm stations' conventional telephone services will be performed.

Tests, inspections, or a combination of tests and inspections ofthe central and secondaryalarm stations' continuous communication capabilities will be performed.

Acceptance Criteria The central and secondary alarm stations are equipped with conventional (landline) telephone service with the main control room and local law enforcement authorities.

The central and secondary alarm stations are equipped with the capability to continuously communicate with security officers, watchmen, armed response individuals, or any security personnel that have responsibilities during a contingency event.

ITAAC Completion Description Tests, inspections, or a combination oftests and inspections of the central and secondary alarm stations' conventional telephone services and continuous communication capabilities are performed to verify the central andsecondary alarm stations are equipped with conventional (landline) telephone service with the main control room and local law enforcement authorities and to verify the central and secondary alarm stations are capable of continuous communication with security personnel. The Vogtle Electric Generating Plant (VEGP) Unit 3 [Unit 4] Plant Security System ITAACs only cover the Unit 3 [Unit 4] plant security system design commitment scope.

13.a) The central and secondarv alarm stations are eouioped with conventional (landline) telephone service with the main control room and local law enforcement authorities.

Testing is performed per Procedure XXX (Reference 1 [2]) to verify that the central alarm station (CAS) and the secondary alarm station (SAS) are equipped with conventional (landline) telephone service with the Unit 3 [Unit 4] main control room and local law enforcement authorities and satisfy the applicable conventional (landline) communications requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 73.55(j)(4).

The communications test between the CAS/SAS and the Unit 3 [Unit 4] main control room is conducted by making a phone call using a conventional (landline) telephone from the CAS/SAS

U.S. Nuclear Regulatory Commission ND-18-1013 Enclosure Page 3 of 4 to the Unit 3 [Unit 4] main control room and confirming verification of voice transmission and reception between the CAS/SAS and the Unit 3 [Unit 4] main control room.

The communications test between the CAS/SAS and the local law enforcement authorities is conducted by making a phone call using a conventional (landline) telephone from the CAS/SAS to the local law enforcement authorities listed in VEGP Procedure 90017-C (Reference 3) and confirming verification of voice transmission and reception between the CAS/SAS and the local law enforcement authorities.

The results of the above testing are documented in Reference 1 [2] and verify the central and secondary alarm stations are equipped with conventional (landline) telephone service with the main control room and local law enforcement authorities.

13.b1 The central and secondarv alarm stations are eauioped with the caoabilitv to continuouslv communicate with securitv officers, watchmen, armed response individuals, or anv securitv personnel that have resoonsibilities durino a continoencv event.

Testing is performed per Procedure YYY (Reference 4 [5]) to verify that the CAS and SAS are equipped with the capabilityto continuously communicate with security personnel (security officers, watchmen, armed response individuals, or any security personnel that have responsibilities during a contingency event) and satisfy the applicable continuous communications requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 73.55(j)(3).

The continuous communications test between the CAS/SAS and security officers, watchmen, armed response individuals, or security personnel that have responsibilities during a contingency event is conducted using continuous communicationstesting methods similarto those identified in Reference 3. The continuous communications methods used at VEGP Unit 3

[Unit 4] include portable primary security radios, portable Very High Frequency (VHF) radios, and intercom communication stations.

Portable security radio testing is conducted between the CAS/SAS and security officers and watchmen performing duties required by the VEGP Unit 3 and Unit 4 Physical Security Plan.

Portable security radio testing and portable VHF radio testing is conducted between the CAS/SAS and armed security officers. Intercom communication station testing is conducted between CAS/SAS and the local intercom communication stations located in VEGP Unit 3

[Unit 4]. The testing contacts and confirms voice transmission and reception between the CAS/SAS and the on-shift security personnel assigned portable security radios, on-shift security personnel assigned VHF radios and each intercom system station located in VEGP Unit 3 [Unit 4]. Armed response individuals and security personnel that would have responsibilities during a contingency event utilize the applicable portable security radios, VHF radios, and intercom communication stations tested above.

The results of the above testing are documented in Reference 4 [5] and verify the central and secondary alarm stations are equipped with the capability to continuously communicate with security officers, watchmen, armed response individuals, or any security personnel that have responsibilities during a contingency event.

Together, the test results contained in References 1 and 4 [2 and 5] provide evidence that the ITAAC Acceptance Criteria requirements are met:

U.S. Nuclear Regulatory Commission ND-18-1013 Enclosure Page 4 of 4

• The central and secondary alarm stations are equipped with conventional (landline) telephone senrice with the main control room and local law enforcement authorities; and

• The central and secondary alarm stations are equipped with the capability to continuously communicate with security officers, watchmen, armed response individuals, or any security personnel that have responsibilities during a contingency event.

References 1 and 4 [2 and 5] are available for NRG inspection as part of the Unit 3 [Unit 4]

ITAAC 2.6.09.13a Completion Package (Reference 6 [7]).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern NuclearOperating Company (SNC) performed a review of allfindings pertaining to the subject ITAAC and associated corrective actions. This finding review, which included now-consolidated ITAAC Index 663, found there are no relevant ITAAC findings associated with this ITAAC.

References favaiiabie for NRC inspection)

1. Procedure XXX, Unit 3 Central Alarm Station and Secondary Alarm Station Conventional (Landline) Telephone Service Test

2. Procedure XXX, Unit 4 Central Alarm Station and Secondary Alarm Station Conventional (Landline) Telephone Service Test

3. Procedure 90017-C, Security Radio and Communications System

4. Procedure YYY, Unit 3 Central Alarm Station and Secondary Alarm Station Security Radio and Intercom Communication System Test

5. Procedure YYY, Unit 4 Central Alarm Station and Secondary Alarm Station Security Radio and Intercom Communication System Test

6. 2.6.09.13a-U3-CP-RevO, ITAAC Completion Package

7. 2.6.09.13a-U4-CP-RevO, ITAAC Completion Package

8. NEI 08-01, "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"