ND-19-1350, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.c (Index Number 762)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.c (Index Number 762)

ML19326B990
Person / Time
Site:	Vogtle
Issue date:	11/22/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ITAAC 3.3.00.02a.i.c, ND-19-1350
Download: ML19326B990 (13)

Text

Michael J. Yox 7825 River Road

^Southern NucIear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel NOV 2 2 2019 Docket Nos.: 52-025 52-026 ND-19-1350 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-davs Prior to Initial Fuel Load Item 3.3.00.02a.i.c [Index Number 7621 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of November 15, 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.c

[Index Number 762] 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.c [Index Number 762]. 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.

Southern Nuclear Operating Company(SNC) previously submitted Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load for Item 3.3.00.02a.i.c [Index Number 762] ND 1885 [ML16274A279], dated Sept. 29, 2016. This resubmittal supersedes ND-16-1885 in its entirety.

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

U.S. Nuclear Regulatory Commission ND-19-1350 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 3.3.00.02a.i.c [Index Number 762]

MJY/GJL/sfr

U.S. Nuclear Regulatory Commission ND-19-1350 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III (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. G. Chick Mr. M. Page Mr. P. Martino Mr. M. J. Vox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Mr. C. P. Patel Mr. G. J. Khourl 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. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Ms. T. Lamb Mr. M. Webb Mr. T. Fredette Mr. C. Weber Mr. S. Smith Mr. C. Santos Oqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-1350 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros 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 Mr. Z. 8. Harper Mr. J. L. Coward Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NU8, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GD8 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, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-1350 Enciosure Page 1 of 10 Southern Nuclear Operating Company ND-19-1350 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC Item 3.3.00.02a.l.c [Index No. 762]

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 2 of 10 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.

3.) Walls and floors of the nuclear island structures as defined on Table 3.3-1 except for designed openings or penetrations, provide shielding during normal operations.

I nspections/Tests/Analvses 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, and for radiation shielding.

Acceptance Criteria i.c) A report exists which reconciles deviations during construction, including Table 3.3-1 wall and floor thicknesses, and concludes that the as-built structures in the non-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, and without impacting compliance with the radiation protection licensing basis.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate that the nuclear island (Nl) structures, including the critical sections listed in VEGP Unit 3&4 Combined License (COL) Appendix C (Reference 1 and 2) 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&4 COL Appendix C Section 3.3 Design Description, without loss of structural integrity and the safety-related functions. In addition, multiple ITAAC are performed on walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B) except for designed openings or penetrations, that provide radiation shielding during normal operations.

The subject ITAAC verifies inspection of the as-built structures in the non-radiologically controlled area of the auxiliary building, including the critical sections and Table 3.3-1 wall and floor thicknesses, 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, and without impacting compliance with the radiation protection licensing basis.

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

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 3 of 10

• 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(Reference 3), 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 Nl Structures. Section 3.8 specifies the applicable codes and standards governing the design, materials, fabrication, construction inspection and testing for the Nl structures. Section 3.8 also describes the as-built design summary reports which document that the seismic Category I structures meet the specified acceptance criteria.

Radiation zone and equipment qualification requirements are met in accordance with VEGP 3&4 UFSAR Tier 2 design criteria including UFSAR Subsections 3.11.4 "Estimated Radiation and Chemical Environment," 3D.5.1.2 "Radiation Dose," and 12.3.2.1 "Shielding, Design Objectives".

The structures in the non-radiologically controlled area of the auxiliary building, including the critical sections, listed in Attachment A, and walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B) except for designed openings or penetrations, provide radiation shielding during normal operations are constructed as designed and specified in the VEGP Unit 3 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, and without impacting compliance with the radiation protection licensing basis.

The structures in the non-radiologically controlled area of the auxiliary building, including the critical sections, listed in Attachment A, and walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B) except for designed openings or penetrations, which provide radiation shielding during normal operations are inspected during construction to verify the as-built structures conform to the specified design, codes and standards. Construction identified structural deviations are documented, evaluated, and reconciled by engineering to confirm the structures' ability to withstand design basis loads without impacting compliance with the radiation protection licensing basis. The As-Built Summary Reports (References 4 through 7) exist and document the reconciliation of Nl structural deviations identified during construction and conclude that the as-built structures in the non-radiologically controlled area of the auxiliary building, including the critical sections and walls and floors of the Nl structures as defined on Table 3.3-1 except for designed openings or penetrations, will withstand the design basis loads specified in the Design Description without loss of structural integrity or the safety-related functions, and without impacting compliance with the radiation protection licensing basis.

Unit 3 & 4 Principle Closure Documents(References 4 through 7) are available for NRG inspection as part of the Unit 3 & 4 ITAAC 3.3.00.02a.i.c Completion Packages (References 8 and 9)

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 4 of 10 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 ten (10) NRC findings associated with this ITAAC.

1.05200025/2015002-01 (Closed - ML16032A554)

2.05200026/2015002-01 (Closed - ML16032A554)

3.05200025/2013004-01 (Closed - ML14087A320)

4.05200025/2013003-01 (Closed - ML13207A241)

5.05200025/2013002-01 (Closed - ML13207A241)

6.05200025/2012004-02(Closed - ML14024A594)

7.05200025/2012008-01 (Closed - ML12319A458)

8.05200025/2012008-02 (Closed - ML12319A458)

9. 99901419/2012-201-03(Closed - ML18131A260)

10. 99901409/2011-201-03(Closed - ML18186A573)

The IT/\AC completion review is documented in the ITAAC Completion Packages for ITAAC 3.3.00.02a.i.c Unit 3 and Unit 4(Reference 8 and 9) and are available for NRC review.

References(available for NRC inspection)

1. VEGP Unit 3 COL Appendix C, Amendment 167

2. VEGP Unit 4 COL Appendix C, Amendment 165

3. VEGP 3&4 UFSAR, Revision 8.1

4. As-Built Summary Report for Unit 3 Auxiliary Building (except CA20 and Basemat), SV3-AAA-BBB-###

5. As-Built Summary Report for Unit 4 Auxiliary Building (except CA20 and Basemat), SV4-AAA-BBB-###

6. As-Built Summary Report for Unit 3 Nuclear Island Basemat, SV3-EEE-FFF-###

7. As-Built Summary Report for Unit 4 Nuclear Island Basemat, SV4-EEE-FFF-###

8. 3.3.00.02a.i.c-U3-CP-Rev0, ITAAC Completion Package

9. 3.3.00.02a.i.c-U4-CP-Rev0, ITAAC Completion Package

10. NEI 08-01, "Industry Guideline for the IT/\AC Closure Process Under 10 CFR Part 52"

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 5 of 10 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building Interior wall of auxiliary building (column line 7.3), elevation 66'-" to elevation 160'-6" West wall of main control room in auxiliary building (column line L), elevation 117'-6" to elevation 153'-0" North wall of MSIV east compartment(column line 11 between lines L and M), elevation 117'-6" to elevation 153'-0" Floor slab on metal decking at elevation 135'-3" 2'-0" slab in auxiliary building (tagging room ceiling) at elevation 135'-3" Finned floor in the main control room at elevation 135'-3" Nuclear Island Basemat Below Auxiliary Building Bay between reference column lines 9.1 and 11, and K and L

U.S. Nuclear Regulatory Commission ND-19-1350 Enciosure Page 6 of 9 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^'

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines<^> Elevation Range<^'<) Thickness<2)(3)('*)(5)(9)(i8) (Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically Controlled'^)

Column Line 11 wall From 1 to Q From 66'-6" to lOO'-O" 3'-0" No Column Line 11 wall From 1 to Q From 100'-0"to 117'-6" 2'-0" Yes Column Line 11 wall From 1 to L From 117'-6"to roof 2-0" Yes Column Line 11 wall From L to M From 117'-6"to135'-3" 4'-0" Yes Column Line 11 wall From M to P From 117'-6"to 135'-3" 2'-0" Yes Column Line 11 wall From P to Q From 117'-6"to135'-3" 4'-0" Yes Column Line 11 wall From L to Q From 135-3" to roof 2'-0" Yes Column Line 7.3 wall From 1 to shield building From 66'-6"to100'-0" 3'-0" Yes Column Line 7.3 wall From 1 to shield building From lOO'-O" to roof 2'-0" No Column Line 1 wall From 7.3 to 11 From 66'-6" to lOO'-O" 3'-0" No Column Line 1 wall From 5 to 11 From 10O'-O" to roof 2'-0" No Column Line J wall From 7.3 to 11 From 66'-6"to117'-6" 2'-0" No Column Line K wall From shield building From 66'-6"to135'-3" 2'-0" Yes wall to 11 Column Line L wall From shield building From 66-6" to roof 2'-0" Yes wall to 11 Column Line M wall From shield building From 66'-6" to roof 2'-0" Yes wall to 11 Column Line P wall From shield building From 66'-6" to roof 2'-0" Yes wall to 11 Column Line Q wall From shield building From 66'-6" to lOO'-O" 3'-0" No wall to 11

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 7 of 9 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^^

Applicable Radiation Shieiding Wall or Section Floor Elevation or Concrete Wali Description Column Lines^^) Elevation Range^^'^^^ (Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically Controlled<">

Column Line Q wall From shield building From 100'-0" to roof 2'-0" Yes wall to 11 Column Line 9.2 wall From 1 to J and K to L From117'-6"to135'-3" 2'-0" Yes Labyrinth Wall between JtoK From117'-6"to135'-3" 2-0" Yes Column Line 7.3 and 9.2 and J to K Auxiliary Area Basemat From 7.3-11 and l-Q, From 60'-6" to 66'-6" 6'-0" No excluding shield building Floor From 5 to 10'-6" south lOO'-O" 2'-0" Yes of 7.3 and 1 to shield building wall Floor From 10'-6" south of 100'-0" 3'-0" Yes 7.3 to 7.3 and 1 to shield building wall Floor From K to L and shield 100'-0" 0'-9" Yes building wall to column line 10 Main Control Room Floor From 9.2 to 11 and 1 to 117'-6" 2'-0" Yes L

Floor Bounded by shield 117-6" 2'-0" Yes bidg, 7.3, J, 9.2 and L Floor From shield building to 117'-6" 2'-0" Yes 11 and L to Q

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 8 of 9 Attachment B; Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Waii Thicknesses for Nuciear island Buildings, Turbine Buiiding, and Annex Buiiding^^'

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Llnes^^) Elevation Range<^)<) (Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically <Controlled'^)

Floor From 5 to 7.3 and from 135'-3" 0'-9" Yes 1 to intersection with shield building wall

U.S. Nuclear Regulatory Commission ND-19-1350 Enclosure Page 9 of 9 Attachment B: Excerpt of COL Appendix C Table 3.3-1

1. The column lines and floor elevations are identified and included on Figures 3.3-1 through 3.3-13.

2. These wall (and floor) thicknesses have a construction tolerance of +/- 1 inch, except as noted and for exterior walls below grade where the tolerance is +12 inches, -1 inch. These tolerances are not applicable to the nuclear island basemat.

3. For walls that are part of structural modules, the concrete thickness also includes the steel face plates. Where faceplates with a nominal thickness of 0.5 inches are used in the construction of the wall modules, the wall thicknesses in this column apply. Where faceplates thicker than the nominal 0.5 inches are used in the construction of the structural wall modules, the wall thicknesses in the area of the thicker faceplates are greater than indicated in this column by the amount of faceplate thickness increase over the nominal 0.5 inches. Overlay plates are not considered part of the faceplates, and thus are not considered in the wall thicknesses identified in this column.

4. For floors with steel surface plates, the concrete thickness also includes the plate thickness.

5. Where a wall (or a floor) has openings, the concrete thickness does not apply at the opening.

6. N/A to ITAAC 3.3.00.02a.i.c.

7. The Wall or Section Description, Column Line information, and Floor Elevation or Elevation Ranges are provided as reference points to define the general location. The concrete thickness of an item intersecting other walls, roofs or floors at a designated location (e.g., column line) is not intended to be measured to the stated column line, but only to the point where the intersection occurs.

8. Where applicable, the upper wall portions extend to their associated roofs, which may vary in elevation, e.g., sloped roofs.

9. From one wall/floor section to another, the concrete thickness transitions from one thickness to another, consistent with the configurations in Figures 3.3-1 through 3.3-14.

10. N/A to ITAAC 3.3.00.02a.i.c.

11. N/A to ITAAC 3.3.00.02a.i.c.

12. N/A to \TAAC 3.3.00.02a.i.c.

13. N/A to ITAAC 3.3.00.02a.i.c.

14. N/A to ITAAC 3.3.00.02a.i.c.

15. Reconciliation of construction deviations in the nuclear island structures from the thickness and tolerances specified in this table is included in the reconciliation reports, and demonstrate that the as-built structures will withstand design basis loads without loss of structural integrity or safety functions and without impacting compliance with the radiation protection licensing basis, such as GDC 19, established radiological zoning and equipment qualification in accordance with ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.c, 3.3.00.02a.i.c, or 3.3.00.02a.i.d.

16. N/A to ITAAC 3.3.00.02a.i.c.

17. N/A to ITAAC 3.3.00.02a.i.c.

18. Nonconformances from the thicknesses and tolerances specified in Table 3.3-1 (i.e. out of tolerance conditions) are addressed under the 10 CFR Part 50, Appendix B process and subsequently are screened in accordance with the 10 CFR Part 52, Appendix D, Section VIII process, to ensure that the licensing basis is adequately maintained. Construction deviations will continue to be assessed against the licensing basis requirements and will be addressed in accordance with licensee procedures and regulatory requirements and, if applicable, a license amendment will be obtained prior to implementation of the change.