ND-19-0042, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.d (Index Number 763)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.d (Index Number 763)

ML19030B726
Person / Time
Site:	Vogtle
Issue date:	01/28/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0042
Download: ML19030B726 (10)

Text

Michael J. Yox 7825 River Road

,~ Southern Nuclear Regu latory Affairs Director Waynesboro, GA 30830 706-848-6459 tel Vogtle 3 & 4 410-474-8587 cell JAN 2 8 2019 myox @southernco.com Docket Nos.: 52-025 52-026 ND-19-0042 10 CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington , DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.d (Index Number 763]

Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of January 25, 2019, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspection, Test, Analysis, and Acceptance Criteria (ITAAC) Item 3.3.00.02a.i.d

[Index Number 763] has not been completed greater than 225-days prior to initial fuel load . The Enclosure describes the plan for completing ITAAC 3.3.00.02a. i.d [Index Number 763]. 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 NEl-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).

Th is letter contains no new NRC regulatory commitments.

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

Respectfully submitted, Mi~ ~

Regulatory Affairs Director Vogtle 3&4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 3.3.00.02a.i.d [Index Number 763]

MJY/GJUsfr

U.S. Nuclear Regulatory Commission ND-19-0042 Page2of 3 To:

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

Mr. D. L. McKinney (w/o enclosures)

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

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

Mr. J. B. Klecha Mr. G. Chick Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. W. A. Sparkman Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Ms. J.M. Heisserer Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0042 Page3of 3 Dalton Utilities Mr. T. Bundros Westinghouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

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

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hesler, 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 Ms. S. W. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page 1 of 7 Southern Nuclear Operating Company ND-19-0042 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC Item 3.3.00.2a.i.d [Index No. 763]

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page2of 7 ITAAC Statement Design Commitment 2.a) The nuclear island structures, including the critical sections listed in Table 3.3-7, are seismic Category I and are designed and constructed to withstand design basis loads as specified in the Design Description, without loss of structural integrity and the safety-related functions.

lnspections/Tests/Analyses i) An inspection of the nuclear island structures will be performed. Deviations from the design due to as-built conditions will be analyzed for the design basis loads.

Acceptance Criteria i.d) A report exists which reconciles deviations during construction and concludes that the as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections, conform to the approved design and will withstand the design basis loads specified in the Design Description without loss of structural integrity or the safety-related functions.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate that the nuclear island structures, including the critical sections listed in VEGP Unit 3 and Unit 4 Combined License (COL) Appendix C Table 3.3-7 (Attachment A), are seismic Category I and are designed and constructed to withstand design basis loads as specified in the VEGP Unit 3 and Unit 4 COL Appendix C Section 3.3 Design Description, without loss of structural integrity and the safety-related functions. The subject ITAAC verifies inspections of the as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections, and reconciles deviations during construction to the approved design such that the as-built structures will withstand design basis loads without loss of structural integrity or the safety-related functions.

Design bases loads are defined in VEGP Unit 3 and Unit 4 COL Appendix C Section 3.3 as those loads associated with:

• Normal plant operation (including dead loads, live loads, lateral earth pressure loads, and equipment loads, including hydrodynamic loads, temperature and equipment vibration);

• External events (including rain, snow, flood, tornado, tornado-generated missiles and earthquake); and

• Internal events (including flood, pipe rupture, equipment failure, and equipment failure generated missiles).

VEGP 3&4 Updated Final Safety Analysis Report, Section 3.7 "Seismic Design", Section 3.8 "Design of Category I Structures", and Appendix 3H "Auxiliary and Shield Building Critical Sections" describe the analyses for the design basis loads for the Nuclear Island Structures.

Section 3.8 specifies the applicable codes and standards governing the design, materials, fabrication, construction inspection and testing for the Nuclear Island structures. Section 3.8

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page3of 7 also describes the as-built design summary reports which document that the seismic Category I structures meet the specified acceptance criteria.

The structures in the radiologically controlled area of the auxiliary building, including the critical sections, listed in Attachment A, are constructed as designed and specified in the VEGP Unit 3 and Unit 4 COL Appendix C Section 3.3 Design Description to withstand the Design Description design basis loads without loss of structural integrity and the safety-related functions.

The as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections listed in Attachment A, are inspected during construction to verify the as-built structures conform to the specified design, codes, and standards. Identified structural deviations are documented, evaluated, and reconciled by engineering to confirm the structures' ability to withstand design basis loads. The Unit 3 and Unit 4 Auxiliary Building, CA20 Module, and Nuclear Island Basement As-Built Summary Reports (References 1 through 6) exist and document the reconciliation of NI structural deviations identified during construction and conclude that the as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections, will withstand the design basis loads specified in the Design Description without loss of structural integrity or the safety-related functions.

References 1 through 6 are available for NRC inspection as part of Unit 3 and Unit 4 ITAAC 3.3.00.02a.i.d Completion Packages (References 7 and 8, respectively).

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 review found four (4) closed Cited Violations, five (5) closed and two (2) open Non-Cited Violations, one (1) closed Unresolved Item, one (1) closed Licensee Identified Violation, and four (4) closed Notice of Nonconformances associated with this ITAAC.

1 05200025/2012004-01 (Cited Violation, Closed) - Failure to translate CA01 and CA20 design requirements into specifications and drawings. (ML12319A458)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2013-004. (ML13312A316) 2 05200025/2012004-02 (Cited Violation, Closed) As-Built submodule CA20-04, auxiliary building embed plates and nuclear island reinforcement steel not in accordance with procurement documents. (ML12319A458)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2013-005. (ML14024A594) 3 05200025/2012008-01 (Cited Violation, Closed) - Failure to assure design services were accomplished with the appropriate design control measures. (ML12139A192)

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page4 of 7

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2012-004. (ML12319A458}

4 05200025/2013002-01 (Unresolved Item, Closed) - Anchorage and spacing of the headed shear reinforcement. (ML13127A392)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2013-003. (ML13207A241) 5 05200025/2013004-01 (Non-cited Violation, Closed) - Inadequate source and receipt inspections of safety-related embed plates. (ML13312A316}

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2014-008. (ML14087A320) 6 05200025/2014002-001 (Non-cited Violation, Closed) Inadequate anchorage of shear stirrups in precast elements of reinforced concrete slabs. (ML14112A413)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2014-003. (ML14218A213}

7 05200025/2014005-001 (Non-cited Violation, Closed) - Failure to establish qualified welding procedures in accordance with AWSD1 .1 :2000. (ML15037A406)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2015-004. (ML16032A554}

8 05200025/2015002-01 and 05200026/2015002-01 (Non-cited Violation, Closed)-Weld allowable stress calculation not in compliance with current licensing basis.

(ML152238074)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2015004. (ML16032A554}

9 05200025/2015002-02 (Non-cited Violation, Open) - Spent fuel pool wall repair without an approved procedure. (ML152238074) 1O 05200025/2016001-01 and 05200026/2016001-01 (Non-cited Violation, Open) - Failure to perform AISC N690-94 required weld NOE. (ML16132A557}

11.05200025/2012008-02 (Cited Violation, Closed)- Failure to seek NRC approval for Departing from Tier 2* information. (ML12139A192}

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page5of 7

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2012-004. (ML12319A458)

12.05200025/2013003-01 (Licensee Identified Violation, Closed) - Headed shear reinforcement anchorage in auxiliary building basemat and walls. (ML13207A241

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2013-003. (ML13207A241)

13.05200025/2015001-01 (Non-cited Violation, Closed) - Failure to identify nonconforming overlay plates. (ML15124A857)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 05200025/2015001. (ML15124A857)

14. 99901409/2011-201-03 (Notice of Nonconformance, Closed) - Failure to implement the requirements of 10 CFR 50 App B Criterion 111, "Design Control". (ML11286A106)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 99901409/2011-201. (ML18186A573)

15. 99901419/2012-201-03 (Notice of Nonconformance, Closed) - Failed to establish and implement a program for inspection of activities affecting quality to verify conformance with the documented instructions, procedures, and drawings. (ML13042A397)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. N RC closure of this finding is documented in NRC Inspection Report 99901419/2012-201. (ML18131A260)

16. 99901488/2014-201-02 and 99901449/2014-201-02 (Notice of Nonconformance, Closed) - Failing to perform a technical evaluation to justify that the critical characteristics and associated acceptance methods selected for CA20 components to provide reasonable assurance that the CA20 module would perform their intended functions. (ML14308A463)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in NRC Inspection Report 99901448/2017-201. (ML17226A340)

17. 99901425/2014-201-01 (Notice of Nonconformance, Closed)- Failure to correctly identify open nonconformances in the documentation of a sub-module prepared to be shipped. (ML14072A315)

a. The ITAAC completion review determined that all corrective actions associated with this finding are completed and closed. NRC closure of this finding is documented in

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page6of 7 NRC memorandum dated April 12, 2018 (ML18101A168) as documented in NRC memorandum dated October 12, 2018 (ML18152B785).

Before submission of the ICN, corrective actions will be completed for all relevant ITAAC findings identified prior to ICN submission.

References {available for NRC inspection)

1. As-Built Summary Report for Unit 3 Auxiliary Building (SV3-BB-CCC-###)

2. As-Built Summary Report for Unit 4 Auxiliary Building (SV4-BB-CCC-###)

3. As-Built Summary Report for Unit 3 CA20 Module (SV3-EE-FFF-###)

4. As-Built Summary Report for Unit 4 CA20 Module (SV4-EE-FFF-###)

5. As-Built Summary Report for Unit 3 Nuclear Island Basemat (SV3-HH-JJJ-###)

6. As-Built Summary Report for Unit 4 Nuclear Island Basemat (SV4-HH-JJJ-###)

7. 3.3 00.02a.i.d-U3-CP-Rev O, ITAAC Completion Package

8. 3.3 00.02a.i.d-U4-CP-Rev 0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-0042 Enclosure Page 7 of 7 Attachment A: Excerpt from COL Appendix C Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building South wall of auxiliary building (column line 1), elevation 66'-6" to elevation 180'-0" Divider Wall Between the spent fuel pool and the fuel transfer canal.

Nuclear island Basemat Below Auxiliary Building Bay between reference column lines 1 and 2, and K2 and N.