ND-20-1387, ITAAC Closure Notification on Completion of ITAAC E.3.9.08.01.01 Findex Number 870)

ITAAC Closure Notification on Completion of ITAAC E.3.9.08.01.01 Findex Number 870)

ML21019A359
Person / Time
Site:	Vogtle
Issue date:	01/17/2021
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-1387
Download: ML21019A359 (15)

Text

Michael J. Yox 7825 River Road hk. Southern Nuclear Regulatory Affairs Director Vogtle3&4 Waynesboro, GA 30830 706-848-6459 tel JAN 1 7 2021 Docket Nos.: 52-025 ND-20-1387 10CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 ITAAC Closure Notification on Completion of ITAAC E.3.9.08.01.01 findex Number 8701 Ladies and Gentlemen; In accordance with 10 CFR 52.99(c)(1), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRC)of the completion of Vogtle Electric Generating Plant(VEGP) Unit 3 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item E.3.9.08.01.01 [Index Number 870]. This ITAAC confirms that a partial participation exercise (test) was performed within the specified time periods of 10 CFR Part 50, Appendix E and that onsite exercise objectives are either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public are completed. The closure process for this ITAAC is based on the guidance described in Nuclear Energy Institute (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.

This letter contains no new NRC regulatory commitments. Southern Nuclear Operating Company (SNC) requests NRC staff confirmation of this determination and publication of the required notice in the Federal Register per 10 CFR 52.99.

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 Completion of ITAAC E.3.9.08.01.01 [Index Number 870]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-20-1387 Page 2 of 3 To:

Southern Nuclear Operating Companv/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. G. Chick Mr. S. Stimac 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. R. L. Beiike Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reoulatorv Commission Ms. M. Bailey (w/o enclosures)

M M. King M H. K. Nieh M C. P. Patel M G. J. Khouri M C. J. Even M B. J. Kemker Ms. N. C. Coovert M C. Welch M . J. Gaslevic M . O. Lopez-Santiago M G. Armstrong M M. Webb M T. Fredette M C. Santos M B. Davis M J. Vasquez M J. Eargle M E. Davidson M T. Fanelli M S. Rose Ms. K. McCurry Qqiethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-20-1387 Page 3 of 3 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Daiton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

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

Mr. M. M. Corletti Mr. Z. 8. Harper Mr. J. L. Coward Other Mr. 8. W. Kline, 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 Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 1 of 12 Southern Nuclear Operating Company ND-20-1387 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC E.3.9.08.01.01 [Index Number 870]

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 2 of 12 ITAAC Statement Program Commitment 8.1 The licensee conducts a partial participation exercise to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure EPZ that have not been tested in a previous exercise.[N.I]

I nsoections/Tests/Analvses 8.1 A partial participation exercise (test) will be conducted within the specified time periods of 10 CFR Part 50, Appendix E.

Acceptance Criteria 8.1.1 The exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50 and onsite exercise objectives were either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public have been completed. Exercise objectives include:

A. Accident Assessment and Classification

1. Demonstrate the ability to identify initiating conditions, determine emergency action level (EAL) parameters, and correctly classify the emergency throughout the exercise Standard Criteria:

a. Determine the correct highest emergency classification level based on events which were in progress, considering past events and their impact on the current conditions, within 15 minutes from the time the initiating condition(s) or EAL is met.

B. Notifications

1. Demonstrate the ability to alert, notify, and mobilize site emergency response personnel.

Standard Criteria:

a. Complete the designated actions in accordance with Emergency Implementing Procedures(EIPs) and perform the announcement concerning the initial event classification of Alert or higher.

b. Mobilize site emergency responders in accordance with EIPs at the initial event classification for an Alert or higher.

2. Demonstrate the ability to notify responsible State and local government agencies within 15 minutes and notify the NRC immediately after the completion of the notification to the State and local authorities and no later than 60 minutes after declaring an emergency.

Standard Criteria:

a. Transmit information in accordance with approved emergency implementing procedures (EIPs), within 15 minutes of event declaration.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 3 of 12

b. Transmit information in accordance with approved EIPs, within 60 minutes of last transmittal for a follow-up notification to State and local authorities.

c. Transmit information immediately after the completion of the notification to the State and local authorities and no later than 60 minutes of event declaration for an initial notification of the NRG.

3. Demonstrate the ability to warn or advise onsite individuals of emergency conditions.

Standard Criteria:

a. Demonstrate the ability to notify onsite individuals (via plant page or telephone) in accordance with Emergency Plan Implementing Procedures.

4. Demonstrate the capability of the Alert and Notification System (ANS),for the public, to operate properly when required.

Standard Criteria:

a. 90% of the sirens operate properly, as indicated by the feedback system.

C. Emergency Response

1. Demonstrate the capability to direct and control emergency operations.

Standard Criteria:

a. Command and control is demonstrated by the control room (simulator) in the early phase of the emergency and the technical support center(TSC)and the emergency operations facility(EOF) within 75 minutes following the declaration of an Alert or higher classification.

2. Demonstrate the ability to transfer command and control functions from the control room (simulator) to the TSC and EOF.

Standard Criteria:

a. Briefings were conducted prior to turnover responsibility.

3. Demonstrate the ability to prepare for around-the-clock staffing requirements.

Standard Criteria:

a. Complete 24-hour staff assignments.

4. Demonstrate the ability to perform assembly and accountability for all individuals located within the protected area within 30 minutes of the declaration of a Site Area Emergency or higher classification.

Standard Criteria:

a. Protected area personnel assembly and accountability completed within 30 minutes of the Site Area Emergency or higher emergency declaration.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 4 of 12 D. Emergency Response Facilities

1. Demonstrate activation of the operational support center(080), and full functional operation of the TSC and EOF within 75 minutes foiiowing declaration of an Alert or higher ciassification.

Standard Criteria:

a. The TSC, OSC, and EOF care activated within 75 minutes of an initiai declaration of an Aiert or higher ciassification,

2. Demonstrate the adequacy of equipment, security provisions, and habitabiiity precautions for the TSC, OSC, EOF, and joint information center (JIC), as appropriate.

Standard Criteria:

a. Demonstrate the adequacy of the emergency equipment in the emergency response faciiities as specified in the emergency impiementing procedures (EIPs).

b. The security force impiements and foiiows security plan procedures as applicable.

c. On-site Emergency Response Facility(ERF) habitabiiity is estabiished as specified in the emergency impiementing procedures (EIPs).

d. Demonstrate the capability of TSC and EOF equipment and data dispiays to cieariy identify and refiect the affected unit.

3. Demonstrate the adequacy of communications for emergency support resources.

Standard Criteria:

a. Emergency response communications listed in emergency implementing procedures (EIPs) are available and operational.

b. Not used.

c. Emergency response facility personnei are able to operate specified communication systems.

E. Radiologicai Assessment and Controi

1. Demonstrate the ability to obtain onsite radioiogicai surveys and sampies.

Standard Criteria:

a. RP Technicians demonstrate the abiiity to obtain appropriate instruments (range and type) and take surveys.

b. Airborne samples are taken when the conditions indicate the need for the information.

2. Demonstrate the abiiity to continuously monitor and control radiation exposure to emergency workers.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 5 of 12 Standard Criteria:

a. Emergency workers are issued self-reading dosimeters when radiation levels require, and exposures are controlled to 10 CFR Part 20 limits (unless the Emergency Director authorizes emergency limits).

b. Exposure records are available.

3. Demonstrate the ability to assemble and deploy field monitoring teams.

Standard Criteria:

a. Field monitoring teams are briefed, obtain equipment, and are dispatched in accordance with EIPs.

4. Demonstrate the ability to satisfactorily collect and disseminate field team data.

Standard Criteria:

a. Field team data to be collected is dose rate or counts per minute (cpm)from the plume, both open and closed window, and air sample (gross/net cpm)for particulate and iodine, if applicable.

b. Satisfactory data dissemination is from the field team to the EOF in accordance with emergency implementing procedures (EIPs).

5. Demonstrate the ability to develop dose projections.

Standard Criteria:

a. Personnel with dose assessment expertise on-shift and in the EOF perform timely and accurate dose projections, in accordance with emergency implementing procedures (EIPs).

6. Demonstrate the ability to make the decision whether to issue radioprbtective drugs (Kl) to emergency workers.

Standard Criteria:

a. Recommend the use of Kl if the estimated dose to the thyroid will exceed 25 rem committed dose equivalent(CDE).

7. Demonstrate the ability to develop appropriate protective action recommendations(PARs) and notify appropriate authorities within 15 minutes of PAR approval by the Emergency Director.

Standard Criteria:

a. Total effective dose equivalent(TEDE)and CDE dose projections from the dose assessment computer code are developed in accordance with emergency implementing procedures (EIPs).

b. PARs are developed within 15 minutes of data availability.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 6 of 12

c. PARs are transmitted to responsible State and local government agencies within 15 minutes of PAR approval by the Emergency Director.

F. Public Information

1. Demonstrate the capability to develop and disseminate clear, accurate, and timely Information to the news media, in accordance with EIPs.

Standard Criteria:

a. Media information (e.g., press releases, press briefings, electronic media) concerning events, conditions, and actions is made available.

2. Demonstrate the capability to establish and effectively operate rumor control In a coordinated fashion.

Standard Criteria:

a. Corrected or supplemental information should be released In accordance with emergency implementing procedures(EIPs) if rumors, media errors, or misinformation is identified.

G. Evaluation

1. Demonstrate the ability to conduct a post-exercise critique, to determine areas requiring improvement and corrective action.

Standard Criteria:

a. An exercise time line is developed,followed by an evaluation of the objectives.

b. The critique determines if onsite exercise objectives are met or identifies the corrective actions necessary to protect the health and safety of the public.

ITAAC Determination Basis Multiple ITAAC are performed to ensure that a partial participation exercise is conducted to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure Emergency Planning Zone (EPZ)that have not been tested in a previous exercise. This ITAAC performed a partial participation exercise (test) within the specified time periods of 10 CFR Part 50, Appendix E and confirmed that onsite exercise objectives were either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public were completed.

The Vogtle Electric Generating Plant(VEGP) Unit 3 partial participation exercise was completed under the provisions of 10 CFR 50, Appendix E Section IV.F.2.a.(iii). Specifically, the partial participation exercise is conducted within two years of a full participation exercise at VEGP Unit 1 and 2 as required by 10 CFR 50 Appendix E, Sections IV.F.2.b and IV.F.2.C, and within one year of VEGP Unit 3 initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ii).

An exercise scenario, simulating a radiological release to the environment, was developed and conducted using procedure NMP-EP-303(Reference 1). Scenario-specific onsite exercise

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 7 of 12 objectives were used to evaluate the Standard Criteria identified in the ITAAC Acceptance Criteria, using the guidance provided in procedure NMP-EP-303. The ITAAC Acceptance Criteria (Standard Criteria ITAAC Item) and exercise results are summarized in the table below:

Standard Criteria Result ITAAC item Accident Assessment and Classification 8.1.1.A.1.a The correct highest emergency classification level based on events which were in progress, considering past events and their impact on the current conditions, is determined per EIP NMP-EP-141 (Reference 2)and applicable sub-tier document(s) within 15 minutes from the time the initiating condition(s) or EAL is met.

Notifications 8.1.1.B.1.a Designated actions are completed in accordance with EIP NMP-EP-142 (Reference 3) and applicable sub-tier document(s) and an announcement concerning the initial event classification of Alert or higher is performed.

8.1.1.B.1.b Site emergency responders are mobilized in accordance with EIP NMP-EP-142 and applicable sub-tier document(s) at the initial event classification for an Alert or higher.

8.1.1.B.2.a Event notification information is transmitted to the required state and local authorities in accordance with EIP NMP-EP-142 and applicable sub-tier document(s) within 15 minutes of event declaration.

8.1.1.B.2.b Follow-up notification information is transmitted to the required state and local authorities in accordance with EIP NMP-EP-142 and applicable sub-tier document(s) within 60 minutes of last transmittal.

8.1.1.B.2.C Event notification information is transmitted to the NRC in accordance with EIP NMP-EP-142 and applicable sub-tier document(s) immediately after the completion of the notification to the State and local authorities and no later than 60 minutes of event declaration for an initial notification.

8.1.1.B.3.a The ability to notify onsite individuals (via plant page or telephone) within the Protected Area is demonstrated using EIP NMP-EP-142 and applicable sub-tier document(s). Notification of onsite personnel outside the Protected Area, but within the owner controlled area, is performed under ITAAC Acceptance Criteria Item 8.1.1.D.2.b.

8.1.1.B.4.a 90% of the sirens within the 10 mile Emergency Planning Zone operated properly as indicated by the siren feedback system performance test results.

Emergency Response 8.1.1.C.1.a Command and control is demonstrated by the control room (simulator) in the early phase of the emergency, and the TSC and the EOF within 75 minutes following the declaration of an Alert or higher classification, in accordance with EIPs NMP-EP-142 and NMP-EP-143(Reference 4)and applicable sub-tier document(s).

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 8 of 12 Standard Criteria Resuit ITAAC item 8.1.1.C.2.a The TSC and EOF conduct initial briefings prior to the transfer of command and control functions from the Control Room in accordance with EIP NMP-EP-143 and applicable sub-tier document(s).

8.1.1.C.3.a The TSC, Operations Support Center(OSC), and EOF conduct 24-hour staffing assignments in accordance with EIP NMP-EP-143 and applicable sub-tier document(s).

8.1.1.C.4.a Protected area personnel assembly and accountability is conducted in accordance with EIP NMP-EP-144(Reference 5) and is completed within 30 minutes of the Site Area Emergency or higher emergency declaration.

Emergency Response Facilities 8.1.1.D.1.a The TSC, OSC and EOF are activated within 75 minutes following the declaration of an Alert or higher classification, in accordance with EIP NMP-EP-143 and applicable sub-tier document(s).

8.1.1.D.2.a The emergency equipment in the TSC, OSC, EOF and JIC is adequate to support completion of the applicable accident assessment(NMP-EP-140, Reference 6), event classification (NMP-EP-141), emergency notification (NMP-EP-142),facility activation (NMP-EP-143), protective actions(NMP-EP-144), and offsite dose assessment(NMP-EP-147, Reference 7)activities required by the EIPs.

8.1.1.D.2.b The security force implements and follows security plan procedures to support completion of assembly, accountability, dismissal, emergency vehicle access, repair team and vehicle escort, search and rescue operations, security event operations, and coordination of security response with offsite agencies as applicable.

8.1.1.D.2.C On-site ERF(TSC, OSC) habitability is established per NMP-EP-146-F30 (Reference 8) which is a sub-tier document to EIP NMP-EP-146 (Reference 9).

8.1.1.D.2.d The emergency equipment and data displays in the TSC and EOF clearly identify and reflect the affected unit information necessary to support completion of the applicable accident assessment(NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142),

protective actions(NMP-EP-144), and offsite dose assessment(NMP-EP-147) activities.

8.1.1.D.3.a The emergency response communications identified in Table 5 of the SNC Standard Emergency Plan (Reference 10) which are utilized to complete the applicable accident assessment(NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions(NMP-EP-144), and offsite dose assessment(NMP-EP-147) activities are available and operational.

8.1.1.D.3.b Not used.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 9 of 12 Standard Criteria Result ITAAC item 8.1.1.D.3.C Emergency response facility personnel are able to operate the required emergency response communications identified in Table 5 of the SNC Standard Emergency Plan to complete their applicable accident assessment (NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions(NMP-EP-144), and offsite dose assessment(NMP-EP-147) activities.

Radiological Assessment and Control 8.1.1.E.1.a Radiation Protection (RP)Technicians demonstrate the ability to obtain appropriate instruments (range and type) and take surveys of plant radiological conditions during dispatch of In-Plant Repair Teams.

8.1.1.E.1.b Airborne samples are taken to evaluate plant radiological conditions when the conditions indicate the need for the information.

8.1.1.E.2.a Emergency workers assigned to in-plant repair teams are issued self-reading dosimeters when radiation levels require (prior to entering a radiation controlled area per NMP-HP-201, Reference 11), and exposures to these individuals are controlled to 10 CFR Part 20 limits. If required, emergency exposure authorizations in excess of 10 CFR 20 limits are conducted and approved by the Emergency Director per NMP-EP-144 and applicable sub-tier document(s).

8.1.1.E.2.b Personnel radiation exposure records are available and maintained per NMP-HP-201.

8.1.1.E.3.a Radiological Field Monitoring Team(s) are briefed, obtain equipment, and are dispatched per EIP NMP-EP-147-001 (Reference 12) and applicable sub-tier document(s).

8.1.1.E.4.a Radiological Field Monitoring Team radiological survey data is collected per EIP NMP-EP-147-001 and applicable sub-tier documents and includes dose rate or counts per minute (cpm)from the plume, both open and closed window, and air sample (gross/net cpm)for particulate and iodine, if applicable.

8.1.1.E.4.b Radiological Field Monitoring Team radiological survey results are transmitted to the EOF in accordance with EIP NMP-EP-147-001 and applicable sub-tier documents.

8.1.1.E.5.a The On-shift Dose Analyst and the EOF Dose Analyst perform timely and accurate dose projections in accordance with EIPs NMP-EP-144 and NMP-EP-147.

8.1.1.E.6.a The use of Kl is recommended if the estimated dose to the thyroid will exceed 25 rem committed dose equivalent(ODE) in accordance with EIP NMP-EP-144 and applicable sub-tier documents.

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 10 of 12 Standard Criteria Result ITAAC Item 8.1.1.E.7.a Total effective dose equivalent(TEDE)and CDE dose projections from the dose assessment computer code are developed in accordance with EIP NMP-EP-147 and applicable sub-tier documents.

8.1.1.E.7.b Protective Action Recommendations(PARs) are developed within 15 minutes of data availability in accordance with EIP NMP-EP-142.

8.1.1.E.7.C PARS are transmitted to responsible State and local government agencies within 15 minutes of PAR approval by the Emergency Director in accordance with EIP NMP-EP-142.

Public Information 8.1.1.F.1.a Media information (e.g., press releases, press briefings, electronic media) concerning events, conditions, and actions is made available in accordance with EIPs NMP-EP-204(Reference 13), NMP-EP-205(Reference 14) and NMP-EP-206(Reference 15).

8.1.1.F.2.a Corrected or supplemental information is released in accordance with EIP NMP-EP-204 if rumors, media errors, or misinformation is identified.

Evaluation 8.1.1.G.1.a The partial participation exercise timeline and evaluation of the exercise objectives is conducted during the post-exercise controller critique/debrief in accordance with NMP-EP-303 and documented in the Drill/Exercise Report.

8.1.1.G.2.a The partial participation exercise post-exercise controller critique/debrief is conducted in accordance with NMP-EP-303 and determines if onsite exercise objectives are met or identifies the corrective actions necessary to protect the health and safety of the public. The evaluation of exercise objectives and identification of corrective actions necessary to protect the health and safety of the public is documented in the Drill/Exercise Report.

An evaluation of the partial participation exercise performance was conducted per procedure NMP-EP-303 to confirm that the onsite exercise objectives (Results) identified in the table above were either met, or the post-exercise critique corrective actions necessary to protect the health and safety of the public were entered into the Corrective Action Program.

The partial participation exercise performance (test) results are documented in the September 23, 2020 VEGP Unit 3 NRC Graded Exercise Report(Reference 16) per procedure NMP-EP-303. Additional details documenting the exercise evaluation, and completion of the ITAAC E.3.9.08.01.01 Exercise Acceptance Criteria, are contained in ITAAC Technical Reports(ITRs)

SV3-ERO-ITR-800870(Reference 17) and SV3-ERO-ITR-801870(Reference 18).

The VEGP Unit 3 NRC Graded Exercise Report, as supplemented by References 17 and 18, documents and confirms that onsite exercise objectives were either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public were entered into the Corrective Action Program. SV3-ERO-ITR-801870 documents and confirms that the

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 11 of 12 corrective actions identified during the post-exercise critique, that are necessary to protect the health and safety of the public, have been completed.

Performance of the VEGP Unit 3 partial participation exercise on September 23, 2020 meets the requirements that the exercise be conducted within two years of a full participation exercise at VEGP Unit 1 and 2 as required by 10 CFR 50 Appendix E, Sections IV.F.2.b and IV.F.2.C, and within one year of VEGP Unit 3 initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ii). This meets the criteria that the VEGP Unit 3 partial participation exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50.

References 1 through 18 are available for NRC inspection as part of the Unit 3 E.3.9.08.01.01 ITAAC Completion Package (Reference 19).

ITAAC Finding Review 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. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC E.3.9.08.01.01 (Reference 19) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC E.3.9.08.01.01 was performed for VEGP Unit 3 and that the prescribed acceptance criteria were met.

Systems, structures, and components verified as part of this ITAAC are being maintained in their as-designed, ITAAC compliant condition in accordance with approved plant programs and procedures.

References(available for NRC inspection)

1. NMP-EP-303, Drill and Exercise Standards, Version 21.0

2. NMP-EP-141, Event Classification, Version 2.1

3. NMP-EP-142, Emergency Notification, Version 5.0

4. NMP-EP-143, Facility Activation, Version 6.0

5. NMP-EP-144, Protective Actions, Version 6.0

6. NMP-EP-140, Accident Assessment, Version 3.0

7. NMP-EP-147, Offsite Dose Assessment, Version 4.0

8. NMP-EP-146-F30, OSC RP-Chemistry Group Lead, Version 4.0

9. NMP-EP-146, Emergency Response Organization, Version 3.0

10. Southern Nuclear Operating Company Standard Emergency Plan, Version 5

11. NMP-HP-201, Personnel Dosimetry Program, 2.6

12. NMP-EP-147-001, SNC Field Monitoring Teams Radiological Surveys and Sampling, Version 4.0

13. NMP-EP-204, Joint Information Center Operations, Version 9.0

14. NMP-EP-205, Emergency Communications News Releases, Version 9.0

15. NMP-EP-206, Emergency Communications News Briefings, Version 9.0

16. September 23, 2020 VEGP Unit 3 NRC Graded Exercise Report, 10/1/2020

17. SV3-ERO-ITR-800870, Unit 3 ITAAC 870 9-23-2020 Graded Exercise: ITAAC E.3.9.08.01.01, Revision 0

U.S. Nuclear Regulatory Commission ND-20-1387 Enclosure Page 12 of 12

18. SV3-ERO-ITR-801870, Unit 3 ITAAC 870 9-23-2020 Graded Exercise Supplement 1: ITAAC E.3.9.08.01.01, Revision 0

19. E.3.9.08.01.01-U3-CP-Rev0, ITAAC Completion Package