ML20183A090

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Initial Commission Memo Regarding Status of ITAAC Closure, Inspection, and Licensing Activities for Vogtle Electric Generating Plant, Unit 3
ML20183A090
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 09/24/2020
From: Ho Nieh
NRC/NRR/VPOB
To: Jeff Baran, Annie Caputo, Christopher Hanson, Kristine Svinicki, David Wright
NRC/Chairman, NRC/OCM/AXC, NRC/OCM/CTH, NRC/OCM/DAW, NRC/OCM/JMB, NRC/OCM/KLS
Jennivine Rankin EX. 1530
References
Download: ML20183A090 (19)


Text

September 24, 2020 MEMORANDUM TO: Chairman Kristine L. Svinicki Commissioner Jeff Baran Commissioner Annie Caputo Commissioner David A. Wright Commissioner Christopher T. Hanson Digitally signed by Ho K.

FROM: Ho K. Nieh, Director Ho K. Nieh NiehDate: 2020.09.24 Office of Nuclear Reactor Regulation 07:34:15 -04'00'

SUBJECT:

STATUS OF INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA CLOSURE, AND INSPECTION AND LICENSING ACTIVITIES FOR VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 The purpose of this memorandum is to inform the Commission of the status of the following activities related to Vogtle Electric Generating Plant, Unit 3: closure of inspections, tests, analyses, and acceptance criteria (ITAAC), inspections related to ITAAC and operational programs, and current licensing activities and any possible impact these activities might have on the timing of the staffs finding under Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g). This memorandum has been made publicly available in the Agencywide Documents Access and Management System (ADAMS).

Background:

In SECY-13-0033, Allowing Interim Operation under Title 10 of the Code of Federal Regulations Section 52.103, dated April 4, 2013 (ADAMS Accession No. ML12289A928), the staff proposed that the Commission delegate to the staff the 10 CFR 52.103(g) finding that all ITAAC acceptance criteria are met. Further, the staff stated that its 10 CFR 52.103(g) finding would be based on the ITAAC-related inspection activities performed during construction and the staffs independent ITAAC closure verification activities, which would be summarized in a Basis Document to be enclosed with a paper to the Commission. The Commission approved the staffs recommendation in the Staff Requirements Memorandum, dated July 19, 2013, for SECY-13-0033 (ADAMS Accession No. ML13200A115).

In SECY-06-0114, Description of the Construction Inspection Program for Plants Licensed under 10 CFR Part 52, dated May 13, 2006 (ADAMS Accession No. ML060740479), the staff discussed inspecting the development and implementation of testing programs (i.e., the initial test program) and the other operational programs. The staff committed to inform the Commission of the status of those programs before the anticipated date for loading fuel.

CONTACT: Chris Welch, NRR/VPO 301-415-7000

The Commissioners To support the commitments described above, the staff issued Office Instruction LIC-114, Revision 1, Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g) Finding and Communication Process (ADAMS Accession No. ML20055E096). This office instruction describes the steps for informing the Commission of the status of regulatory activities in the final year of construction under a combined license and the actions the staff must take in support of determining whether to make the 10 CFR 52.103(g) finding. Per LIC-114, this document serves as the initial memorandum to the Commission on the status of ITAAC closure, NRC inspection activities for construction and operational programs, and licensing activities.

Status of ITAAC Completion:

Southern Nuclear Operating Company (the licensee) is required, in accordance with 10 CFR 52.99(c)(1), to notify the U.S. Nuclear Regulatory Commission (NRC) that the prescribed inspections, tests, and analyses have been performed and the acceptance criteria are met. The staff reviews each of these ITAAC closure notifications (ICNs) to verify that the acceptance criteria are met. The results are then posted on the NRC public Web site https://www.nrc.gov/reactors/new-reactors/new-licensing-files/vog3-icnsr.pdf. As of August 31, 2020, Appendix C to the combined license NPF-91 for Vogtle Electric Generating Plant Unit 3 contains 399 ITAAC; the current status of the staffs ICN verification review is as follows:

  • ICNs Verified 142
  • ICNs Under Review 3
  • ICNs Not Received 254 The staff has reviewed the Uncompleted ITAAC Notification for each ITAAC not yet completed.

These Uncompleted ITAAC Notifications must provide sufficient information to demonstrate that the uncompleted ITAAC will be completed successfully. For each Uncompleted ITAAC Notification, the staff has determined that the licensees methodologies are acceptable to close the associated ITAAC. If the licensee uses the planned methodologies, the ICNs should not differ significantly from the Uncompleted ITAAC Notifications, thereby streamlining the ICN review. In addition, staff are qualified and ready to process the significant number of ICN submittals anticipated within the last 60 days before scheduled fuel load. The NRC currently maintains six dedicated ICN reviewers with approximately two dozen other qualified reviewers available if needed to ensure timely review of ICNs.

The requirements of 10 CFR 52.99(c)(2) specify that after an ICN is submitted, the licensee shall notify the NRC in a timely manner of new information that materially alters the basis for determining that either the inspections, tests, and analyses were performed as required or that the acceptance criteria are met. These are referred to as ITAAC post-closure notifications. As of August 31, 2020, the NRC had received two ITAAC post-closure notifications and verified them to be acceptable. The ITAAC post-closure notifications were associated with ITAAC index numbers 335 and 336 related to construction design changes to increase the height of the turbine building elevations by three feet at each level, the addition of platforms above the operating deck, and the incorporation of the beyond design basis requirement to provide 800 gallons per minute of fire protection system water to be supplied to the spent fuel pool for cooling, heat removal, and inventory makeup.

On August 28, 2020, the licensee notified the NRC (Event Notification 54864) that due to a required design change to the protection and monitoring system to maintain class 1E

The Commissioners separation, ITAAC post-closure notifications will be required for ITAAC index numbers 534 and 538. The licensee plans to submit the ITAAC post-closure notifications within 30 days of correcting the identified condition.

In accordance with the requirements of 10 CFR 52.99(c)(4), the licensee shall notify the NRC that all ITAAC are complete. Consistent with the timeline in LIC-114, Revision 1, the All ITAAC Complete notification will likely be submitted to the NRC within approximately 17 days before the actual fuel load date.

Status of Inspection Activities:

The staff continues to perform inspections of a sample of ITAAC to independently verify the licensees performance of the inspections, tests, and analyses and that the results meet the acceptance criteria. These inspections also verify that the licensee (1) has quality construction programs, processes, and procedures, (2) provides adequate quality assurance oversight of construction activities, and (3) identifies and corrects conditions adverse to quality. A sample of the ICNs was inspected against the associated closure packages to verify the accuracy of the information reported in the ICNs. A comprehensive ITAAC Status Report provides the public with a hyperlink to each NRC inspection report related to a corresponding ITAAC, as well as the corresponding ICN and staff actions responding to the ICN. This report can be found on the NRC public Web site at https://www.nrc.gov/reactors/new-reactors/new-licensing-files/vog3-icnsr.pdf.

Approximately 85 percent of the planned ITAAC inspection workload has been completed. The NRC has 293 planned ITAAC related inspections remaining, representing approximately 2,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> of direct inspection workload. The NRC staff continues to closely monitor inspection program implementation and adjustments to our estimates will be based upon licensee performance, lessons learned, and inspection results. Additionally, in anticipation of a significant inspection workload near the end of construction, Region II is conducting multiple planning/readiness meetings with the licensee and Westinghouse Electric Company for ICNs that are scheduled to be submitted within the last 60 days before the anticipated 10 CFR 52.103(g) finding. Region IIs efforts are positioning the NRCs inspectors to be prepared to complete all inspections necessary to support a timely 10 CFR 52.103(g) finding.

NRC staff are also focused on resolving outstanding inspection issues. One ITAAC inspection issue is currently open:

  • Noncited Violation 05200025/2016004-02, Failure to Qualify Welding Procedure Specification (WPS) in Accordance with Applicable Code The NRC issued the noncited violation in Inspection Report 2016-004 dated February 13, 2017 (ADAMS Accession No. ML17044A539). Two separate requests for code interpretations were submitted to the American Welding Society code committee related to this noncited violation. The last response by the American Welding Society code committee was issued May 2020. NRC disposition of this issue is in the final stages of concurrence.

The dynamic construction environment and a changing construction schedule pose a challenge for completing ITAAC inspections, especially as the completion of major construction milestones shifts closer to the licensees planned fuel load date. In addition, due to restrictions resulting

The Commissioners from the Federal, state and local response to the COVID-19 public health emergency, the inspection program has been adapted to ensure its effectiveness while helping to protect the health and safety of inspectors. As a result, construction inspectors have primarily conducted inspections remotely during the public health emergency. Inspectors have conducted onsite inspections of ITAAC, the Initial Test Program, and operational programs based on safety significance and the uniqueness or complexity of the construction activity. For example, over the last few months, inspectors have been onsite to inspect portions of the conical roof installation, integrated leak test, and structural integrity test for Unit 3.

To address these challenges, Region II has frequent communications with the licensee to maintain a detailed awareness of their construction schedule to ensure that inspection activities are completed as early as possible and, in many cases, before the ICN submittal. The staff is also leveraging experience in similar inspection areas and is implementing lessons learned to adjust inspection scope and maximize the effectiveness of each inspection. The staffs agility and extensive communications will enable the inspectors to observe enough activities to ensure the licensee is meeting the NRC's regulatory requirements. In addition, Region II management has developed and is maintaining the resources and skill sets needed to complete the planned construction inspections. To mitigate COVID-19s effect on the ITAAC inspection program, Region II formed a Transition Readiness Group to review site and local conditions and determine which onsite inspections are appropriate and the precautionary measures that should be taken to help protect the health and safety of inspectors. These steps support a thorough and robust inspection program that can adapt to changing conditions.

In SECY-05-0197, Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria, dated October 28, 2005, the staff identified operational programs that are required by regulation, reviewed in a combined license application, and inspected to verify program implementation as described in the final safety analysis report. Chapter 13, Table 13.4-201, Operational Programs Required by NRC Regulations, includes a listing of all the operational programs and their implementation milestones.1 Enclosure 1 of this paper includes a table listing the programs in Table 13.4-201, their implementation milestones, and NRC inspections associated with the implementation of these programs as of August 31, 2020. The 10 CFR 52.103(g) finding is based on verification that the ITAAC, including the emergency planning ITAAC, have been successfully completed; it is not dependent on the inspection of any operational program other than the emergency planning program.

Status of Licensing Activities:

As of August 31, 2020, the NRC has five licensing actions under review for Vogtle Electric Generating Plant Unit 3. Enclosure 2 identifies these proposed licensing actions, the licensees requested completion date, and whether the licensing action is necessary to support the 10 CFR 52.103(g) finding. The staff anticipates completing its review of each licensing action on or before the requested date. In addition, there remains the potential for the licensee to identify the need for additional licensing actions up until the 10 CFR 52.103(g) finding. The Office of Nuclear Reactor Regulation through the Vogtle Project Office is in routine communications with the licensees licensing management to remain cognizant of changes that may necessitate additional licensing actions and is maintaining a dedicated team of staff ready to conduct the necessary safety reviews in a timely manner.

1 Table 13-4.201 also includes operational programs implemented during the construction period.

The Commissioners Future Staff Actions:

As stated above, the staff anticipates the licensee will provide the All ITAAC Complete notification approximately 17 days prior to the actual fuel load date. Provided that (1) no ICNs are deficient, (2) no additional inspections are required to address either deficient ICNs or other emergent issues, and (3) there are no other regulatory activities that may prevent the staff from determining that the acceptance criteria are met, the staff will inform the Commission via memorandum of the staffs plan to make the 10 CFR 52.103(g) finding. This memorandum will be sent to the Commission at least three calendar days before the finding is made and will reference a publicly available document summarizing the staffs basis for the finding that all acceptance criteria are met. The staff will also include an updated table describing the current status of operational program inspections.

Once the staff makes the 10 CFR 52.103(g) finding, it will issue a Federal Register notice, as required by 10 CFR 2.106(a)(2), announcing the issuance of the finding and that the licensee is authorized to operate the facility. The staff will also send a letter to the licensee informing it of the finding.

Enclosures:

1. Operational Program Inspection Status Table
2. Licensing Actions Status Table cc: SECY EDO OGC OCA OPA CFO

ML20183A090 *via e-mail NRC-001 OFFICE BC: NRR/VPO BC: RII/DCO/CIB1 BC:RII/DCO/CIB2 LA: NRR/VPO NAME VHall* NCoovert* BDavis* RButler*

DATE 9/3/2020 9/4/2020 9/3/2020 7/13/20 OFFICE Tech Editor BC: NRR/VPO OGC D: RII/DCO NAME J.Dougherty* OLopez-Santiago* SVrahoretis* MBailey*

DATE 7/15/2020 9/3/2020 9/21/2020 9/21/2020 OFFICE D: VPO RII: RA NRR:OD NAME MKing* LDudes* HNieh*

DATE 9/21/2020 9/21/2020 9/24/2020 Vogtle Mailing List (Revised 4/7/2020) cc:

Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 Brian H. Whitley Regulatory Affairs Director Anne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, BIN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael Yox County Commissioner Site Regulatory Affairs Director Office of the County Commissioner Vogtle Units 3 & 4 Burke County Commission 7825 River Road, Building 302 (ESB)

Waynesboro, GA 30830 Bin 6031 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3

Vogtle Mailing List Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) gam@nei.org (Gia Montserrat)

Lindsay@georgiawand.org (Lindsay Harper) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dlfulton@southernco.com (Dale Fulton) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David)

G2NDRMDC@southernco.com (SNC Document Control)

George.Taylor@opc.com (George Taylor) harperzs@westinghouse.com (Zachary S. Harper) james1.beard@ge.com (James Beard)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mphumphr@southernco.com (Mark Humphrey)

MSF@nei.org (Marvin Fertel) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) ppsena@southernco.com (Peter Sena,III) r.joshi15@comcast.net (Ravi Joshi) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett)

Michelle@cleanenergy.org (Michelle Powell)

Page 2 of 3

Vogtle Mailing List sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) vcsummer2n3@gmail.com (Brian McIntyre) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver)

William.Birge@hq.doe.gov (William Birge)

X2edgran@southernco.com (Eddie R. Grant)

X2hagge@southern.com (Neil Haggerty)

X2dwwill@southernco.com (Daniel Williamson)

Page 3 of 3

Operational Program Inspection Status Table Scheduled or Actual Inspection Report Operational Program Inspection Status Implementation Milestone Number(s) (ADAMS Accession No.)

1 Inservice Inspection Not Started (March 2021) Prior to commercial service N/A Program 2 Inservice Testing Not Started (September/October After generator online on N/A Program 2020) nuclear heat(a) 3 Environmental Partially Complete Prior to initial fuel load 2016004 Qualification Program (ML18032A756),

2017001 (ML17132A345),

2017002 (ML17226A034),

2017004 (ML18094A897),

2018002 (ML18226A348) 4 Preservice Inspection Partially Complete Completion prior to initial 2016004 Program plant start-up (ML18032A756),

2017003 (ML17317A527),

2019001 (ML19135A691),

2019003 (ML19309D596),

2019004 (ML20042E292) 2020008 (ML20224A009)

Enclosure 1

5 Reactor Vessel Partially Complete Prior to initial criticality 2017002 Material Surveillance (ML17226A034)

Program 6 Preservice Testing Partially Complete Prior to initial fuel load 2019004 Program (ML20042E292),

2020008 (ML20224A009) 7 Containment Leakage Complete Prior to initial fuel load 2020008 Rate Testing Program (ML20224A009) 8 Fire Protection Partially Complete Prior to receipt of fuel on site 2020009 Program for buildings storing new fuel and adjacent fire areas.

Prior to initial fuel load for other required elements.

Fire Protection Partially Complete Prior to initial receipt of 2020009 Program (portions byproduct, source, or applicable to special nuclear materials radioactive material) (excluding exempt quantities as described in 10 CFR 30.18) 9 Process and Effluent Partially Complete 2017004 Monitoring and (ML18094A897)

Sampling Program: 2020008 (ML20224A009)

Radiological Effluent Not Started (October/November Prior to initial fuel load N/A Technical 2020)

Specifications/Standard Radiological Effluent Controls Offsite Dose Partially Complete Prior to initial fuel load 2017004 Calculation Manual (ML18094A897)

Radiological Complete Prior to initial fuel load 2017004 Environmental (ML18094A897)

Monitoring Program 2020008 (ML20224A009)

Process Control Not Started (October/November Prior to initial fuel load N/A Program 2020) 10 Radiation Protection Complete Prior to initial receipt of 2020008 Program (including as byproduct, source, or (ML20224A009) low as reasonably special nuclear materials achievable principle) (excluding exempt quantities Radioactive Source Complete as described in Control (assignment of 10 CFR 30.18)

Radiation Protection Supervisor)

Assignment of Complete Radiation Protection Supervisor Minimization of Complete Contamination Personnel Dosimetry Complete Prior to receipt of fuel on site 2020008 (ML20224A009)

Radiation Monitoring Complete and Surveys Radiation Work Permits Complete Assignment of Complete Prior to initial fuel load 2020008 Radiation Protection (ML20224A009)

Manager Respiratory Protection Complete Bioassay Complete

Effluents and Complete Environmental Monitoring and Assessment Job Coverage Complete Prior to initial fuel load 2020008 (ML20224A009)

Radioactive Waste Complete Prior to first shipment of 2020008 Shipping radioactive waste (ML20224A009) 11 Non-Licensed Plant Complete 18 months prior to 2016002 Staff Training Program scheduled date of initial fuel (ML16210A448) load (portions applicable to Complete Prior to initial receipt of 2016002 radioactive material) byproduct, source, or (ML16210A448) special nuclear materials (excluding exempt quantities as described in 10 CFR 30.18) 12 Reactor Operator Complete 18 months prior to 2015301 Training Program scheduled date of initial fuel (ML15113A028),

load 2020007 (ML20114E071),

2016002 (ML16210A448) 13 Reactor Operator Complete Within 3 months after the 2016002 Requalification date the Commission makes (ML16210A448)

Program the finding under 10 CFR 52.103(g) 14 Emergency Planning Complete Full-participation exercise 2020008 conducted within 2 years of (ML20224A009) scheduled date for initial loading of fuel

  • Not Started (September 2020) Onsite exercise conducted N/A within 1 year before the scheduled date for initial loading of fuel Complete Applicants detailed 2020007 implementing procedures for (ML20114E071) its emergency plan submitted at least 180 days prior to the scheduled date for initial loading of fuel 15 Security Program Partially Complete 2017001 (ML17132A345),

2018001 (ML18134A348),

2018002 (ML18226A348),

2019002 (ML19220B678),

2019004 (ML20042E292),

2020008 (ML20224A009) 2020009 Physical Protection Not Started (September/October Prior to initial receipt of N/A Program (applicable to 2020) special nuclear material protection of special nuclear material prior to the protected area being declared operational)

Physical Security Partially Complete Prior to receipt of fuel on site 2017001 Program (protected area) (ML17132A345),

2018001 (ML18134A348),

2018002 (ML18226A348),

2019002 (ML19220B678),

2019004 (ML20042E292),

2020008 (ML20224A009)

Safeguards Complete Prior to receipt of fuel on site 2019411 Contingency Program (protected area) (ML20044C867)

Training and Not Started (August/September Prior to receipt of fuel on site N/A Qualification Program 2020) (protected area) 16 Quality Assurance Partially Complete Combined License issuance 2020008 Program - Operation (ML20224A009) 17 Maintenance Rule Complete Prior to fuel load 2020007 authorization per (ML20114E071) 10 CFR 52.103(g) 18 Motor-Operated Valve Not Started (August/September Prior to initial fuel load N/A Testing 2020) 19 Initial Test Program Partially Complete Prior to the first 2019004 preoperational test for the (ML20042E292),

Preoperational Test 2020007 Program (ML20114E071),

2020008 (ML20224A009) 2020009 Prior to initial fuel load for Not Started the Startup Test Program N/A

20 Fitness-for-Duty Partially Complete Prior to initiating 2010003 Program for 10 CFR Part 26 construction (ML102810444),

Construction (workers activities 2011008 and first-line (ML112660577),

supervisors) 2012010 (ML12272A118),

2012011 (ML14290A358),

2014401 (ML14290A358),

2016403 (ML16302A420),

2018411 (ML18225A218),

2018413 (ML19031C931),

2019001 (ML19135A691)

Fitness-for-Duty Complete Prior to initiating 2010003 Program for 10 CFR Part 26 construction (ML102810444),

Construction activities 2011008 (management and (ML112660577),

oversight personnel) 2012010 (ML12272A118),

2012011 (ML14290A358),

2014401 (ML14290A358),

2016403 (ML16302A420),

2018411 (ML18225A218),

2018413

(ML19031C931),

2019001 (ML19135A691)

Fitness-for-Duty Complete Prior to initiating 2019411 Program for Security 10 CFR Part 26 construction (ML20044C867)

Personnel activities (source requirement: 10 CFR 26.4(e)(1)).

Prior to the earlier of (1) licensees receipt of special nuclear material in the form of fuel assemblies, (2) establishment of a protected area, or (3) the 10 CFR 52.103(g) finding (source requirement: 10 CFR 26.4(a)(5) or 26.4(e)(1)).

Fitness-for-Duty Complete Prior to initiating 2019411 Program for Fitness- 10 CFR Part 26 construction (ML20044C867) for-Duty Program activities personnel Fitness-for-Duty Complete Prior to the conduct of the 2019411 Program for Persons first full-participation (ML20044C867)

Required to Physically emergency preparedness Report to the Technical exercise under Support Center or 10 CFR Part 50, Emergency Operations Appendix E, Section F.2.a Facility Fitness-for-Duty Complete Prior to the earlier of 2019411 Program for Operation (1) establishment of a (ML20044C867) protected area or (2) the 10 CFR 52.103(g) finding

21 Cyber Security Not Started (September 2020) Prior to receipt of fuel on site N/A Program (protected area) 22 Special Nuclear Complete Prior to receipt of special 2017401 Material Control and nuclear material (ML17135A132),

Accounting Program 2018410 (ML18129A409),

2019401 (ML19220B358) 23 10 CFR Part 37 Not Started (September/October Prior to possession of N/A Physical Protection 2020) aggregated Category 1 or Program Category 2 quantity of radioactive material (a) The Inservice Testing Program will be fully implemented by generator online on nuclear heat. Appropriate portions of the program are implemented as necessary to support the system operability requirements of the technical specifications.

  • License Amendments 95 and 94 for Vogtle Electric Generating Plant Units 3 and 4, respectively, approved a change such that the Vogtle Electric Generating Plant Units 3 and 4 exercises will be partial-participation exercises. As permitted by 10 CFR Part 50, Appendix E, Section IV.F.2.a(iii), the full-participation exercise requirement will be satisfied by the biennial exercise conducted for Vogtle Electric Generating Plant Units 1 and 2.

Licensing Actions Status Table Required to Support Licensee Type of Licensing Title 10 CFR 52.103(g) Requested Action Finding Completion Date Technical Specifications 3.3.13 for Main Control Room Emergency Habitability System Instrumentation License Amendment 09/30/2020 Applicability Change and Include Undervoltage No Actuation (LAR 20-003)

Core Makeup Tank Boron Concentration Requirements License Amendment 10/23/2020 (LAR 20-004) No Vacuum Relief Valve Technical Specification Changes License Amendment 11/30/2020 (LAR 20-005) No License Amendment Request to Revise the Emergency Plan to Change Staffing and Extend Staff Augmentation Times for Emergency Response Organization Positions (This LAR applies to the the licensees fleet comprised License Amendment No 06/30/2021 of Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; Vogtle Electric Generating Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 3 and 4)

Request for Alternative: Requirements for Preservice Code Alternative Inspection Acceptance of Volumetric Examinations No 09/30/2020 (PSI/ISI-ALT-14)

Enclosure 2