ND-19-0211, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.09 (Index Number 670)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.09 (Index Number 670)

ML19066A212
Person / Time
Site:	Vogtle
Issue date:	03/07/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC C.2.6.09.09, ND-19-0211
Download: ML19066A212 (6)

Text

Michael J. Yox 7825 River Road Regulatory Affairs Director Sk Southern Nuclear Vogtle 3 & 4 Waynestjoro, OA 30830 706-848-6459 tel MAR 0 7 2019 Docket Nos.: 52-025 52-026 ND-19-0211 10CFR 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-davs Prior to Initial Fuel Load Item C.2.6.09.09 findex Number 6701 Ladles and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of March 4, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item C.2.6.09.09 [Index Number 670] 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. Yox /

Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 & Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.09[Index Number 670]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-19-0211 Page 2of 3 To:

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

Mr. D. L. McKlnney(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. 8. 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.G1.02.06 cc:

Nuclear Reoulatorv 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. J. 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 Oaiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipai Eiectric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Daiton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-19-0211 Page 3of 3 Westinqhouse Electric Company. LLC Dr. L. Oriani(w/o enclosures)

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

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hosier, 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. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-19-0211 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-19-0211 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3& Unit 4 Completion Pian for Uncompleted ITAAC C.2.6.09.09[Index Number 670]

U.S. Nuclear Regulatory Commission ND-19-0211 Enclosure Page 2 of 3 ITAAC Statement Design Commitment

9. Emergency exits througti the protected area perimeter are alarmed and secured with locking devices to allow for emergency egress.

9. Emergency exits through the vital area boundaries are locked, alarmed, and equipped with a crash bar to allow for emergency egress.

Inspections/Tests/Analvses Tests, inspections, or a combination of tests and inspections of emergency exits through the protected area perimeter will be performed.

Test, inspection, or a combination of tests and inspections of the emergency exits through the vital area boundaries will be performed.

Acceptance Criteria Emergency exits through the protected area perimeter are alarmed and secured by locking devices that allow prompt egress during an emergency.

The emergency exits through the vital area boundaries are locked, alarmed, and equipped with a crash bar to allow for emergency egress.

ITAAC Compietlon Description Tests of the emergency exits through the protected area perimeter and through the vital area boundaries are performed to verify that each emergency exit through the protected area perimeter is alarmed and secured by a locking device that allows prompt egress during an emergency, and the emergency exits through the vital area boundaries are locked, alarmed, and equipped with a crash bar to allow for emergency egress. The VEGP Unit 3(Unit 4) Plant Security System ITAACs only cover the Unit 3(Unit 4) plant security system design commitment scope.

Emeraencv exits throuoh the protected area perimeter are alarmed and secured bv locking devices that allow prompt earess during an emeroencv.

A test is performed per Procedure XXX (Reference 1)to verify that each emergency exit portal through the protected area perimeter is alarmed and secured by a locking device that allows prompt egress during an emergency and satisfies the applicable protected area perimeter emergency egress requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 73.55(e)(8)(iii).

The test for each protected area perimeter emergency exit portal first verifies the protected area perimeter emergency exit portal is secured by a locking device. The protected area perimeter emergency exit portal is then unlocked, and it is verified that an associated alarm is generated in the central alarm station (CAS)and the secondary alarm station (SAS). Once unlocked it is confirmed that the protected area perimeter emergency exit portal allows prompt egress. The protected area perimeter emergency exit portal is then secured by a locking device, and it is verified that the associated alarm in the CAS and SAS can be reset.

U.S. Nuclear Regulatory Commission ND-19-0211 Enclosure Page 3 of 3 The results of the test are documented in Reference 1 and verify each emergency exit through the protected area perimeter is alarmed and secured by a locking device that allows prompt egress during an emergency.

The emeraencv exits throuoh the vital area boundaries are locked, alarmed, and eouipped with a crash bar to allow for emeroencv egress.

A test is performed per Procedure XXX (Reference 1)to verify that the emergency exits through the vital area boundaries are locked, alarmed, and equipped with a crash bar to allow for emergency egress and satisfy the applicable vital area boundary emergency egress requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 10 CFR 73.55(e)(9)(ii).

The test for each vital area boundary emergency exit portal first verifies the vital area boundary emergency exit portal is locked. The vital area boundary emergency exit portal is then exited using the portal's crash bar, and verification made that an associated alarm is generated in the CAS and SAS. The vital area boundary emergency exit portal is then closed and locked, and verification made that the associated alarm in the CAS and SAS can be reset.

The results of the test are documented in Reference 1 and verify the emergency exits through the vital area boundaries are locked, alarmed, and equipped with a crash bar to allow for emergency egress.

Reference 1 is available for NRC inspection as part of the Unit 3(Unit 4)ITAAC C.2.6.09.09 Completion Package (Reference 2[3]).

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 there are no relevant ITAAC findings associated with this ITAAC.

References favailabie for NRC inspection)

1. Procedure XXX, Unit 3(Unit 4) Protected Area Perimeter and Vital Area Boundary Emergency Exit Test

2. C.2.6.09.09-U3-CP-Rev 0, ITAAC Completion Package

3. C.2.6.09.09-U4-CP-Rev 0, ITAAC Completion Package

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