ND-19-1349, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.b (Index Number 761)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.b (Index Number 761)

ML19326B992
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
ND-19-1349
Download: ML19326B992 (12)

Text

Michael J. Yox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel NOV 2 2 2019 Docket Nos.: 52-025 52-026 ND-19-1349 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 3.3.00.02a.i.b [Index Number 7611 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.b

[Index Number 761] 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.b [Index Number 761]. 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.b [Index Number 761] ND 1884[ML16278A353], dated Sept. 30, 2016, Item 3.3.00.02a.ii.b [Index Number 765] ND 0184[ML19059A387], dated Feb 28, 2018, and Item 3.3.00.03b [Index Number 778] ND 0185 [ML19059A376], dated Feb 28, 2019. This resubmittal supersedes ND-16-1884, ND 0184 and ND-19-0185 in their entirety.

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 NEl 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-19-1349 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.b [Index Number 761]

MJY/GJL/sfr

U.S. Nuclear Regulatory Commission ND-19-1349 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 enciosures)

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

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. Defnail Mr. C. E. Morrow Mr. J. L. Hughes Mr. S. Leighty Ms. A. C. Chamberiain Mr. J. C. Hasweii Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown 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. 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 Oqiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-1349 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-19-1349 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-19-1349 Enclosure Vogtle Electric Generating Piant(VEGP) Unit 3 and Unit 4 Completion Pian for Uncompleted ITAAC Item 3.3.00.02a.i.b [Index No.761]

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 2 of 9 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 nsoectlons/Tests/Analvses I) An Inspection of the nuclear Island structures will be performed. Deviations from the design due to as-bullt conditions will be analyzed for the design basis loads, and for radiation shielding.

Acceptance Criteria l.b) A report exists which reconciles deviations during construction. Including Table 3.3-1 wall and floor thicknesses, and concludes that the as-bullt shield building structures. 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-bullt shield building structures. 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-bullt 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:

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

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 3 of 9

• 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 shield building structures, 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 shield building structures, 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 shield building structures, 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.b Completion Packages(References 8 and 9)

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

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 4 of 9 associated corrective actions. This review found seven (7) NRG findings associated with this ITAAC.

1.05200025/2015002-01 (Closed - ML16032A554)

2.05200026/2015002-01 (Closed - ML16032A554)

3.05200025/2012008-01 (Closed - ML12319A458)

4.05200026/2012008-02(Closed - ML12319A458)

5.05200025/2016004-02(Open)

6. 99901419/2012-201-03(Closed - ML18131A260)

7. 99901409/2011-201-03(Closed - ML18186A573)

All Open ITAAC NRC findings will be closed prior to ICN submlttal. The ITAAC completion review Is documented In the ITAAC Completion Packages for IT/\AC 3.3.00.02a.l.b 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-Bullt Summary Report for Unit 3 Shield Building, SV3-/VAA-BBB-###

5. As-Bullt Summary Report for Unit 4 Shield Building, SV4-/\AA-BBB-###

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

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

8. 3.3.00.02a.l.b-U3-CP-Rev0, ITAAC Completion Package

9. 3.3.00.02a.l.b-U4-CP-Rev0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 5 of 9 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Shield Buildino Roof slab at elevation 180'-0" adjacent to shield building cylinder Shield building roof, exterior wail of the PCS water storage tank Shield building roof, interior wall of the PCS water storage tank Shield building roof, tension ring and air inlets Shield building SC cylinder Shield building SC to RC connection

U.S. Nuclear Regulatory Commission ND-19-1349 Enciosure Page 6 of 8 Attachment B: Excerpt of COL Appendix C Tabie 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 Wail Description Column Lines^^) Elevation Range^^xs) Thickness'^X3)(4)(5)(9)(i8) (Yes/No)

Shielding Buiidingt^x^^)

Shielding Building Cylinder Not Applicable From 100'-0"to248'-6" 3'-0" (including Yes 3/4 inch thick min. steel plate liner on each face on portion not protected by auxiliary building)

Air Inlet Not Applicable From 248'-6"to251'-6" 3'-0" (including Yes 3/4 inch thick min. steel plate liner on each face)

From 251'-6"to254'-6" 3'-0" to 4'-6" Yes (including 1 inch thick steel plate liner on each face)

From 254'-6" to 266'-4" 4'-6" (including 1 inch thick Yes min. steel plate liner on each face)

Tension Ring Not Applicable From 266'-4"to 271"-6" 4'-6" (including 1-1/2 inch Yes (at top of plate) thick steel plate liner on each face)

Conical Roof Not Applicable From 271'-6"to293'-9" 3'-0"(including Yes 1/2 inch thick min. steel plate liner on bottom face, outside of PCS tank exterior wall)

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 7 of 8 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<^)<) (Yes/No)

Shielding Buildingt^x^^)

PCS Tank External Cylindrical Not Applicable From 293'-9" to 328'-9" 2'-0" Yes Wall PCS Tank Internal Cylindrical Not Applicable From 309'-4" to 329'-0" l'-6" Yes Wall PCS Tank Roof Not Applicable 328'-9"(Lowest) 329'-0" 1'-3" No (Highest)

Nuclear Island Basemat Below shield building From 60'-6" to 6'-0"(i4) to 22'-0" (varies) No containment vessel or 82'-6"

U.S. Nuclear Regulatory Commission ND-19-1349 Enclosure Page 8 of 8 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. The elevation ranges for the shield building Items are rounded to the nearest Inch.

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.l.b.

11. N/A to ITAAC 3.3.00.02a.l.b.

12. N/A to IT/SAC 3.3.00.02a.l.b.

13. N/A to \TAAC 3.3.00.02a.l.b.

14. The 6-foot concrete thickness includes the thickness of the containment vessel bottom head in a local area at the center of containment.

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.b, 3.3.00.02a.i.c, or 3.3.00.02a.l.d.

16. N/A to IT/\AC 3.3.00.02a.i.b.

17. N/A to ITAAC 3.3.00.02a.l.b.

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.