Text

NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002
	ML21133A105
Person / Time
Site:	Vogtle
Issue date:	05/13/2021
From:	Bradley Davis; NRC/RGN-II
To:	Yox M; Southern Nuclear Operating Co
References
	IR 2021002
	Download: ML21133A105 (74)
	v • d • e

May 13, 2021 Mr. Michael Yox Regulatory Affairs Director Southern Nuclear Operating Company 7825 River Road, BIN 63031 Waynesboro, GA 30830

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - NRC INITIAL TEST PROGRAM AND OPERATIONAL PROGRAMS INTEGRATED INSPECTION REPORTS 05200025/2021002, 05200026/2021002

Dear Mr. Yox:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 3 and 4. The enclosed inspection report documents the inspection results, which the inspectors discussed on April 22, 2021 with Mr. G.

Chick, Vogtle 3 & 4 Executive Vice President, and other licensee and contractor staff members.

The inspection examined a sample of construction, testing, and operational programs activities conducted under your Combined License (COL) as it relates to safety and compliance with the Commissions rules and regulations and with the conditions of these documents. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

NRC inspectors documented seven findings of very low safety significance (Green) in this report. All seven of these findings involved a violation of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC resident inspector at the VEGP Units 3 and 4.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the VEGP Units 3 and 4.

M. Yox 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRC's document system ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact us.

Sincerely,

/RA/

Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket Nos.: 5200025, 5200026 License Nos: NPF-91, NPF-92

Enclosure:

NRC Inspection Report (IR) 05200025/2021002, 05200026/2021002 w/attachment: Supplemental Information

M. Yox 3 cc w/ encls:

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 Regulatory Affairs Director Office of the County Commissioner Southern Nuclear Operating Company Burke County Commission 7825 River Road, BIN 63031 Waynesboro, GA 30830 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

M. Yox 4 Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) 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) 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)

M. Yox 5 wayne.marquino@gmail.com (Wayne Marquino)

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

X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)

X2hagge@southern.com (Neil Haggerty)

X2wwill@southernco.com (Daniel Williamson)

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - NRC INITIAL TEST PROGRAM AND OPERATIONAL PROGRAMS INTEGRATED INSPECTION REPORTS 05200025/2021002, 05200026/2021002 DATED: MAY 13, 2021 DISTRIBUTION:

A. Veil, NRR G. Bowman, NRR V. Hall, NRR M. Webb, NRR T. Fredette, NRR G. Armstrong, NRR E. Duncan, NRR L. Dudes, RII J. Munday, RII M. Bailey, RII O. Lopez-Santiago, RII B. Davis, RII R2DCO PUBLIC ADAMS Accession No.: ML21133A105 OFFICE RII: DCO RII: DCO RII: DCO RII: DCO NAME Christopher Jason Theodore Bradley Even Eargle Fanelli Davis DATE 5/6/2021 5/6/2021 5/7/2021 5/13/2021

U.S. NUCLEAR REGULATORY COMMISSION Region II Docket Numbers: 5200025 5200026 License Numbers: NPF-91 NPF-92 Report Numbers: 05200025/2021002 05200026/2021002 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Unit 3 & 4 Combined License Location: Waynesboro, GA Inspection Dates: January 1, 2021 through March 31, 2021 Inspectors: K. Carrington, Resident Inspector, Division of Reactor Projects (DRP)

B. Collins, Senior Reactor Inspector, Division of Reactor Safety (DRS)

S. Downey, Senior Reactor Inspector, DRS J. Eargle, Senior Resident Inspector - Testing, Division of Construction Oversight (DCO)

C. Even, Senior Construction Inspector, DCO T. Fanelli, Senior Construction Inspector, DCO B. Griman, Resident Inspector, DCO N. Hansing, Mechanical Engineer, Nuclear Reactor Regulation B. Kemker, Senior Resident Inspector, DCO A. Lerch, Reactor Inspector, DRS R. Mathis, Construction Inspector, DCO T. Morrissey, Senior Construction Inspector, DCO R. Patterson, Senior Reactor Inspector, DRS

2 T. Scarbrough, Sr. Mechanical Engineer, Nuclear Reactor Regulation J. Viera, Senior Operations Engineer, DRS B. Caballero, Senior Operations Engineer, DRS M. Donithan, Operations Engineer, DRS N. Lacy, Operations Engineer, DRS D. Dumbacher, Senior Operations Engineer, DRS M. Kennard, Senior Operations Engineer, DRS J. Bundy, Operations Engineer, DRS Approved by: Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight

3

SUMMARY

OF FINDINGS Inspection Report (IR) 05200025/2021002, 05200026/2021002; 01/01/2021 through 03/31/2021; Vogtle Unit 3 & 4 Combined License, initial test program and operational programs integrated inspection report.

This report covers a 3-month period of announced Inspections, Tests, Analysis, and Inspection Criteria (ITAAC), preoperational test program, startup test program, and operational program inspections by resident and regional inspectors. Seven findings of very low safety significance (Green) were identified by the inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 2519, Construction Significance Determination Process. Cross-cutting aspects are determined using IMC 0613, Appendix F, Construction Cross-Cutting Areas and Aspects. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy and the temporary enforcement guidance outlined in enforcement guidance memorandum (EGM)11-006. The NRCs program for overseeing the safe construction of commercial nuclear power reactors is described in IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document.

A. NRC-Identified and Self Revealed Findings (Green) The NRC inspectors identified a construction finding of very low safety significance and a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50),

Appendix B, Criterion XVI, "Corrective Action," for the licensee's failure to correct a deficiency in their Class 1E Direct Current (DC) and Uninterruptible Power Supply (UPS) (IDS) preoperational test procedure, 3-IDS-ITPP-501. The licensee entered this finding into their corrective action program as condition reports (CR) 50076165 and 50078235, and corrective action report (CAR) 80004604, to correct the preoperational test procedure.

The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and the cross-cutting aspect of avoiding complacency. The proximate cause was attributed to a failure to use proper human error reduction techniques, namely inadequate verification by personnel. [H.12]

(Section 1P05)

(Green) The NRC inspectors identified a performance deficiency and ITAAC finding of very low safety significance (Green), and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control for the licensees failure to translate the most limiting accident load profiles and load currents that envelope the battery bank design duty cycle into the battery service tests specified by procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. The licensee entered this finding into their corrective action program as CR 50078637 and changed their procedure to test the worst-case load profile with the worst-case load currents for battery divisions IDSA, IDSB, IDSC, and IDSS service tests.

The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety

4 significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of challenge the unknown. Specifically, the licensee failed to adequately investigate which profiles were the most limiting for each division and the spare battery to ensure the test procedure encompassed the requirements. [H.11] (Section 3T03).

(Green) The NRC inspectors identified a construction finding of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to place the IDSB 24-hour battery on float voltage for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsequent to it being on equalize voltage. The licensee entered this finding into their corrective action program as CR 50085270 to reperform the IDSB service test with the appropriate requisite float voltage.

The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of conservative bias. Specifically, the licensee proceeded with testing without questioning whether a 72-hour float was required. [H.14] (Section 3T03)

(Green) The NRC inspectors identified a construction finding with three examples of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensees failure to translate the design requirements and acceptance limits in applicable design documents into preoperational test procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. Specifically, the licensee failed to translate design requirements from NEMA PE 5-1985, Utility Type Battery Chargers, SV3-IDS-T1-503, Class 1E DC and Uninterruptible Power Supply System Preoperational Test Specification, and the UFSAR Section 14.2.9.1.14. The licensee entered this finding into their corrective action program as CRs 50080097, 50079776, and 50089774, respectively, to restore compliance.

The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of consistent process. Specifically, the licensee used an inconsistent approach to ensure that all requirements were translated into the procedure. [H.13] (Section 3T03)

(Green) The NRC inspectors identified a construction finding of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion VII, "Control of Purchased Material, Equipment, and Services," for the licensees failure to control the quality of design requirements and acceptance criteria in calculations used to determine voltage margins after battery discharge. The licensee entered this into their corrective action program as CR 50080010 and CAP IR 2021-2177.

Corrective actions included using a different battery profile that used a higher final cell voltage which ensured at least 210VDC after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discharge following a design basis accident with three cells bypassed.

The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspector

5 concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of documentation. Specifically, the licensee failed to consider all potential scenarios for the battery calculation. [H.7] (Section 3T03)

The NRC inspectors identified a construction finding of very low safety significance (Green) and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activities of achieving initial criticality in a controlled manner, measuring the isothermal temperature coefficient (ITC), and calculating the moderator temperature coefficient (MTC) of reactivity. The licensee entered this finding into its corrective action program as CR 50086434 for evaluation and identification of appropriate corrective actions.

The performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. This finding was associated with an SSC (i.e.

reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure was not implemented. The inspectors concluded this finding affected the cross-cutting area of human performance and the cross-cutting aspect of teamwork. Consistency between the procedures and test specification required a coordinated effort between three organizations. This was not effectively done during initial drafting of the procedures. [H.4] (Section 4OA1)

The NRC inspectors identified a construction finding of very low safety significance (Green) and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activity of initial fuel loading. The licensee entered this finding into its corrective action program as CR 50086035 for evaluation and identification of appropriate corrective actions.

The performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. This finding was associated with an SSC (i.e.

reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure was not implemented. The inspectors concluded this finding affected the cross-cutting area of human performance and the cross-cutting aspect of documentation. The proximate cause of the performance deficiency was primarily attributed to the failure to create accurate documentation. Revision 1 of the test procedure was archived without sufficient development and it was not adequately reviewed prior to approval. [H.7]

(Section 4OA1)

B. Licensee-Identified Violations None

6 Summary of Plant Construction Status During this report period for Unit 3, the licensee completed various activities to satisfy aspects of the Vogtle Unit 3 operational programs and initial test program. The licensee performed preoperational and component tests of various SSCs and their control systems, e.g. PMS and PLS, in preparation for hot functional testing. Additionally, the licensee performed testing of portions of IDS, air operated valves, and motor operated valves; and test calibrations associated with various safety-related and nonsafety-related level transmitters, flow transmitters, pressure transmitters, and temperature elements.

During this report period for Unit 4, the licensee continued with installation of SSCs, and performed preparations for initial energization and flushing of the chemical and volume control system and spent fuel pool cooling system.

REPORT DETAILS

1. CONSTRUCTION REACTOR SAFETY Cornerstones: Design/Engineering, Procurement/Fabrication, Construction/Installation, Inspection/Testing IMC 2503, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) - Related Work Inspections 1A01 (Unit 3) ITAAC Number 2.1.02.11a.ii (47) / Family 10C

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.1.02.11a.ii (47). The inspectors used the following Nuclear Regulatory Commission (NRC) inspection procedures (IPs) /sections to perform this inspection:

65001.C-02.02 - Construction Test Observation The inspectors used appropriate portions of the IP to review the results of the following procedures to determine if the tests satisfied the applicable quality and technical requirements of the Updated Final Safety Analysis Report (UFSAR) and the ITAAC:

B-GEN-ITPCI-039-F118;

B-GEN-ITPCI-039-F119;

B-GEN-ITPCI-039-F120;

B-GEN-ITPCI-039-F122;

B-GEN-ITPCI-039-F158;

B-GEN-ITPCI-039-F159; and

B-GEN-ITPCI-039-F160.

b. Findings No findings were identified.

7 1A02 (Unit 3) ITAAC Number 2.2.01.09 (110) / Family 10A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.09 (110). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.C-02.02 - Construction Test Observation The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures to determine if the tests satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC:

B-GEN-ITPCI-039-F004;

B-GEN-ITPCI-039-F005;

B-GEN-ITPCI-039-F006;

B-GEN-ITPCI-039-F245;

B-GEN-ITPCI-039-F171; and

B-GEN-ITPCI-039-F172.

b. Findings No findings were identified.

1A03 (Unit 3) ITAAC Number 2.2.03.10 (206) / Family 10A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.03.10 (206). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.C-02.02 - Construction Test Observation The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures to determine if the tests satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC:

B-GEN-ITPCI-039-F071; and

B-GEN-ITPCI-039-F072.

b. Findings No findings were identified.

1A04 (Unit 4) ITAAC Number C.2.6.09.08a (668) / Family 17A

a. Inspection Scope

8 The inspectors performed a direct inspection of construction activities associated with ITAAC Number C.2.6.09.08a (668). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.17-02.03 - The Protected Area Barrier The inspectors performed an inspection to determine if the openings in Vogtle Unit 4 vital area (VA) barriers for heating, ventilation, and cooling (HVAC) system vents were secured to prevent exploitation of the openings to satisfy the ITAAC and 10 CFR 73.55(e)(4).

The inspectors reviewed the design specifications and associated drawings to identify designated HVAC system openings through VA barriers and the way they will be secured and monitored. The inspectors examined the physical installation of the barriers at the nuclear island nonradioactive ventilation system (VBS) piping penetrations into the main control room (room 12401) and eight HVAC system openings (SV4-VAS-AS-05, SV4-VBS-AS-02, SV4-VBS-AS04, SV4-VFS-AS-04, SV4-VXS-AS-03, SV4-VXS-AS-04, SV4-VXS-AS-05, and SV4-VXS-AS-06) to the VA during this inspection period. The inspectors performed direct observation inspections of the openings to determine if they were secured in a manner that would delay or prevent exploitation. Specifically, the inspectors directly inspected the barrier, locking mechanisms, welds, and bolts associated with the openings.

b. Findings No findings were identified.

IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs 1P01 Pre-operational Testing

70702-02.03 - Procedure Review

a. Inspection Scope The inspectors used appropriate portions of the IP to review the following procedures to determine whether the procedures complied with the applicable quality and technical requirements of the UFSAR and the ITAAC:

3-GEN-ITPP-507;

3-GEN-ITPP-509;

3-GEN-ITPP-510;

3-GEN-ITPP-511;

3-GEN-ITPP-512;

3-GEN-ITPP-515;

3-GEN-ITPP-517, and

SV3-RCS-T0W-1188608

b. Findings

9 No findings were identified.

1P02 (Unit 3) Preoperational Testing

a. Inspection Scope

70702-02.04 - Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure to determine if the test satisfied the applicable quality and technical requirements of UFSAR Sections 14.2.9.2.4.c and 14.2.9.2.4.d:

3-RNS-ITPP-501

b. Findings No findings were identified.

1P03 Pre-operational Testing

70702-02.05 - Test Results Review

a. Inspection Scope The inspectors used appropriate portions of the IP to review the results of the following procedures to determine if the tests satisfied the applicable quality and technical requirements of the UFSAR:

B-GEN-ITPCE-039-F004;

B-GEN-ITPCE-039-F074; and

B-GEN-ITPCE-039-F176.

b. Findings No findings were identified.

1P04 Pre-operational Test Program

70367 - Part 52, Inspection of Preoperational Test Program

a. Inspection Scope Inspections of the Unit 3 preoperational test program were previously completed and documented in inspection report 05200025/2019003 (ADAMS Accession No. ML19309D596). For Unit 4, the inspectors reviewed program differences developed and employed since completion of the testing program inspections for Vogtle Unit 3.

The following testing program attributes were reviewed for Unit 4:

Test Organization

10

The responsibilities, qualifications, and training of ITP testing staff were specified in writing including test procedure preparation and approval, test performance and documentation, and test results review and approval.

Test Program Administration

Administrative measures were established for jurisdictional control of system, component, or instrumentation status before, during, and after testing including control of system status before testing and return of system components or instrumentation to construction;

Administrative measures were established governing the conduct of testing including:

methods to change (both major and minor) a test procedure during the conduct of testing; and

method for providing the current test procedure and marked-up drawings showing current modification status to the operators before test commencement; and

Evaluation of test results were established including:

test results are checked against design and compared with previously determined performance standards, limits or acceptance criteria;

deficiencies are clearly identified, documented, and appropriate corrective action has been proposed, reviewed, and completed;

retests are performed as necessary after corrective actions or modifications have been completed; and

test result evaluations are reviewed and formally approved by appropriate licensee personnel and/or contractor personnel.

Document Control

Administrative measures were established which control the test procedure processes for review, approval, issuance, and revision; and

Responsibilities were assigned in writing to ensure that the procedure controls will be implemented.

Design Changes and Modifications

Administrative controls were established for controlling temporary modifications, jumpers, and bypasses;

The review process, including assignment of responsibility, provided for ensuring that all proposed temporary modifications, jumpers, and bypasses are reviewed for potential UFSAR impact;

Controls required that a formal log be maintained of the status of temporary modifications; and

Responsibility was assigned for maintaining formal logs.

b. Findings No findings were identified.

1P05 Construction Quality Assurance

11

a. Inspection Scope

35007-A16.04 - Inspection Requirements and Guidance

35007-A16.04.01 - Inspection of QA Implementing Documents

35007-A16.04.02 - Inspection of QA Program Implementation The inspectors conducted daily reviews of issues entered into the licensees CAP to assess issues that might warrant additional follow-up inspection, to assess repetitive or long-term issues, to assess adverse performance trends, and to ensure the CAP appropriately included regulatory required non-safety related SSCs. The inspectors periodically attended the licensees CAP review meetings, held discussions with licensee and contractor personnel, and performed reviews of CAP activities during the conduct of other baseline inspection procedures.

The inspectors reviewed conditions entered into the licensees CAP to determine whether the issues were classified in accordance with the licensees QA program and CAP implementing procedures. The inspectors reviewed corrective actions associated with conditions entered into the CAP to determine whether appropriate actions to correct the issues were identified and implemented effectively, including immediate or short-term corrective actions, in accordance with the applicable QA program requirements and 10 CFR 50, Appendix B, Criterion XVI. Additionally, the inspectors reviewed the corrective actions taken to determine whether they were commensurate with the significance of the associated conditions in accordance with the licensees CAP implementing procedures. The inspectors completed reviews of CAP entry logs to verify issues from all aspects of the project, including equipment, human performance, and program issues, were being identified by the licensee and associated contractors at an appropriate threshold and entered into the CAP as required by licensees CAP implementing procedures.

CRs 50058111 and 50057805

b. Findings Introduction The NRC inspectors identified a construction finding of very low safety significance (Green), and a NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a deficiency in their Class 1E DC and UPS Preoperational Test procedure, 3-IDS-ITPP-501.

Description On January 29, 2021, the inspectors reviewed the updated preoperational test procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test, to verify if the procedure would demonstrate the test method and acceptance criteria prescribed in UFSAR Section 14.2.9.1.14 was satisfied. During their review the inspectors identified that procedure Section 4.3.4 inappropriately required a minimum test duration of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the 72-hour battery performance test.

12 The inspectors reviewed CRs 50058111 and 50057805 and determined that this issue was previously identified and documented as NCV 05200025/2020009-02, Failure to Establish Adequate Procedure for Unit 3 72-hour Battery Performance Test (ADAMS Accession No. ML20315A137). CRs 50058111 and 50057805 were closed and the revised procedure did not include the corrective actions. Subsequent to the NRC identifying this issue, the licensee changed their preoperational test procedure to include the minimum test duration of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for the 72-hour battery performance test. The licensee entered this issue into their corrective action program as CR 50076165, CR 50078235, and CAR 80004604.

Analysis The inspectors determined that the failure to correct the NRC identified deficiency that was documented and closed in CRs 50058111 and 50057805 was contrary to 10 CFR 50, Appendix B, Criterion XVI and was a performance deficiency. Per the guidance in IMC 0613, Appendix E, "Examples of Minor Construction Issues," the inspectors determined the performance deficiency was more than minor and a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the minimum test duration of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in Step 4.3.4 was entered and closed in the corrective action program without being corrected. The performance deficiency did not impact an ITAAC, thus it was determined to be a construction finding.

The inspectors determined the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP1000 Construction Significance Determination Process, Section 4. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined this finding had a cross-cutting aspect of avoiding complacency in the area of human performance. The proximate cause of the performance deficiency was primarily attributed to a failure to properly use human error reduction techniques, namely inadequate verification by personnel changing the procedure. [H12]

Enforcement Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, since January 29, 2021, the licensee failed to correct an identified condition adverse to quality. Specifically, the minimum test duration of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in Step 4.3.4 was entered and closed in the corrective action program without being corrected in the revised procedure. The licensee entered this issue into their corrective action program as CR 50076165, CR 50078235, and CAR 80004604. Corrective actions are planned and does not present an immediate safety concern because the 72-hr battery performance test has not been performed.

13 Because this violation was not repetitive or willful, was of very low safety significance (Green), and was entered into the licensees corrective action program (CAP), this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-01, Failure to Correct NRC Identified Violation).

3. OPERATIONAL READINESS Cornerstones: Operational Programs 3T01 (Unit 3) ITAAC Number 2.2.01.07.i (107) / Family 11D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.07.i (107). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.D-02.03-Test Results Review The inspectors used appropriate portions of the IP to review the results of the following procedures to determine if the tests satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC:

3-CNS-ITPP-501; and

3-CNS-ITPP-502.

b. Findings No findings were identified.

3T02 (Unit 3) ITAAC Number 2.2.01.11b (118) / Family 07D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.11b (118). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.D-02.03-Test Results Review The inspectors used appropriate portions of the IP to review the results of the following procedure to determine if the test satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC:

B-GEN-ITPCM-017

b. Findings

14 No findings were identified.

3T03 (Unit 3) ITAAC Number 2.6.03.04c (603) / Family 08D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.6.03.04c (603). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.D-02.01 - Procedure Review

65001.D-02.02 - Test Witnessing The inspectors used appropriate portions of the IP to review the following procedures to determine whether the procedures complied with the applicable quality and technical requirements of the UFSAR and the ITAAC.

3-IDS-ITPP-501;

B-GEN-ITPCE-008;

B-GEN-ITPCE-006; and

B-GEN-ITPCE-009.

b. Findings NCV 05200025/2021002-02, Failure to Use Worst Case Load Profile for IDS Battery Service Test Introduction The NRC inspectors identified an ITAAC finding of very low safety significance (Green),

and an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the most limiting accident load profiles and load currents that envelopes the battery bank design duty cycle into the battery service testing specified by procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. This testing procedure for IDS batteries Division A, IDSB, IDSC, and IDSS did not meet the required inspection, test, and analysis for ITAAC 2.6.03.04c or the requirements in the licensing basis.

Description In January and February 2021, the licensee performed service tests on the four divisional batteries (A, B, C, and D) for the IDS in accordance with ITAAC 2.6.03.04c, the UFSAR Section 8.3.2, DC Power Systems, and the UFSAR Section 14.2.9.1.14, Class 1E DC Power and Uninterruptible Power Supply Testing. The ITAAC required that the tests use an equivalent load that equals or exceeds the battery bank design duty cycle capacity. The licensing basis established the methods for battery sizing and testing.

15 The inspectors compared the preoperational test procedure used for testing, 3-IDS-ITPP-501, and the design specification, SV3-DB01-Z0-001, Design Specification for Class 1E 250 VDC Batteries and Racks, to the battery sizing calculation, APP-IDS-E0C-001, Class 1E 250 VDC Battery Sizing, Charger Sizing and Available Short Circuit Current, to verify if the ITAAC's acceptance criteria was translated into the test requirements.

The inspectors identified that the accident load profiles used to perform the service tests for battery divisions IDSC and IDSS were not the most limiting specified in the battery sizing calculation for those divisions. In addition, the load step currents that make up the accident load profiles used for the testing of battery divisions IDSA, IDSB, and IDSC were lower than the load currents specified in the battery sizing calculation for those divisons.

By not using the most limiting load profiles or load step currents that envelopes the battery bank design duty cycle, the licensee was not be able to verify that the battery could supply its dc switchboard bus load for a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without recharging.

The licensee entered this issue into its corrective action program as CRs 50078637 and 50080247 and changed their preoperational test procedure to meet the acceptance criteria. Additional planned corrective actions include reperformance of the battery service tests on battery divisions IDSA, IDSB, and IDSC.

Analysis The inspectors determined the failure to translate the most limiting accident load profiles and load currents that envelope the battery bank design duty cycle into the battery divisions IDSA, IDSB, IDSC, and IDSS preoperational test procedure, 3-IDS-ITPP-501, to verify the acceptance criteria of ITAAC 2.6.03.04c and the licensing basis was contrary to 10 CFR 50, Appendix B, Criterion III and was a performance deficiency.

Per the guidance in IMC 0613, Appendix E, "Examples of Minor Construction Issues,"

the inspectors determined the performance deficiency was determined to be more than minor because it represented a substantive failure to establish or implement an adequate program, process, procedure or quality oversight function. Specifically, the licensee failed to use the most limiting accident load profiles and currents for the service tests of IDSA, IDSB, IDSC, and IDSS 24-hour batteries because they were not translated into the preoperational test procedure. This finding is an ITAAC finding because the performance deficiency is material to ITAAC 2.6.03.04c. Specifically, the inspection, tests, and analysis for ITAAC 2.6.03.04c specifies that the test of the 24-hour IDS batteries was required to be performed by applying a simulated or real load, or a combination of simulated or real loads which envelope the battery bank design duty cycle. By not using the worst-case load profile or currents, the licensee was not be able to verify whether the battery could supply its dc switchboard bus load and have a terminal voltage of at least 210VDC after a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The inspectors determined the finding was associated with the Inspection/Testing cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP 1000 Construction Significance Determination Process, Section 4. The inspectors determined the finding was of very low safety significance because the finding did not impair a design function.

16 In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of challenge the unknown in the area of human performance. Specifically, the licensee failed to adequately investigate which profiles were the most limiting for each division and the spare to ensure the test procedure encompassed the requirements. [H.11]

Enforcement Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, since July 22, 2020, the licensee failed to correctly translate the applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to correctly translate the most limiting accident load currents and profiles for IDSA, IDSB, IDSC, and IDSS batteries into the preoperational test procedure. The licensee entered this issue into their corrective action program as CRs 50078637 and 50080247. Corrective actions are planned and do not present an immediate safety concern because the 24-hr battery service tests will be reperformed.

Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees CAP, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-02, Failure to Use Worst Case Load Profile for IDS Battery Service Test).

NCV 05200025/2021002-03, Failure to Place IDSB Battery on Float for 72 hrs. After Being on Equalize Voltage Introduction The NRC inspectors identified a construction finding of very low safety significance (Green), and an NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to place the IDSB 24-hour battery on float voltage for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsequent to it being on equalize voltage.

Description On February 1, 2021, the inspectors observed the 24-hour service test of IDSB battery to verify if the test would satisfy the ITAAC and UFSAR requirements. Upon completion of the 24-hour float voltage, the licensee observed the as-found voltage prior to the start of the test of the battery was at 273.13 volts (V) DC. This voltage was above the maximum allowable float voltage of 271.2VDC specified for the battery. The licensee stopped the test, then placed the IDSB battery on float voltage at 270VDC for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to starting the battery service test again for that division instead of the required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months per procedure.

17 The battery specifications in SV3-DV01-V0D-002, AP1000 Class 1E 250 VDC Battery System Data Sheet: EnerSys S-1156 GN-29 Battery Range Summary, documented the maximum float voltage of the battery at 2.26V per cell, which is 271.2VDC across all 120 battery cells. Any applied voltage above this voltage is specified as an equalizing voltage per Institute of Electrical and Electronic Engineers standard 450-1995 and considered outside of the normal float voltage. The prerequisite conditions in the battery capacity test procedure B-GEN-ITPCE-008, Class 1E and Non-Class 1E Battery Testing, Section 3, Step 5 specified, that Ensure Battery to be tested has been on Normal (Float) for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after an Equalize Charge. Based on this procedure, the inspectors determined that the IDSB battery should have been placed on float voltage for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to starting the battery service test for that division. The licensee entered this issue into its corrective action program as CR 50085270.

Analysis The inspectors determined that the failure to place the IDSB on float charge for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following an equalizing charge as required by B-GEN-ITPCE-008 was contrary to 10 CFR 50, Appendix B, Criterion V, and was a performance deficiency. The performance deficiency was determined to be more than minor and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee failed to follow their procedure and place the IDSB battery on float charge for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after being on equalizing voltage. The performance deficiency did not impact an ITAAC, thus it was determined to be a construction finding.

The inspectors determined the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP1000 Construction Significance Determination Process, Section 4. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of conservative bias in the area of human performance. Specifically, the licensee proceeded with testing without questioning whether a 72-hour float was required. [H.14]

Enforcement Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings.

The licensees battery test procedure B-GEN-ITPCE-008, Section 3.0, Step 5 required that the battery be placed on normal float voltage for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after being on equalize voltage.

Contrary to the above, on February 1, 2021, the licensee failed to follow Step 5 in Section 3.0 of B-GEN-ITPCE-008. Specifically, the licensee failed to place the IDSB battery on float voltage for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after being on an equalize voltage. The licensee

18 entered this issue into their corrective action program as CR 50085270. Corrective actions are planned and do not present an immediate safety concern because the IDSB service test will be reperformed.

Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees CAP, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-03, Failure to Place IDSB Battery on Float for 72 hrs. After Being on Equalize Voltage).

NCV 05200025/2021002-04, Failure to Translate Design Requirements into IDS Test Procedure Introduction The NRC inspectors identified three examples of a construction finding of very low safety significance (Green), and an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the design requirements and acceptance limits in applicable design documents into preoperational test procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. Specifically, the licensee failed to translate design requirements from NEMA PE 5-1985, Utility Type Battery Chargers, SV3-IDS-T1-503, Class 1E DC and Uninterruptible Power Supply System Preoperational Test Specification, and the UFSAR Section 14.2.9.1.14.

Description Example 1: Procedures allowed float tolerance is greater than the design of the system The licensees design specification, APP-IDS-E8-001, Class 1E DC and UPS Specification Document, Rev. 5, specified that the maximum adjustable output float voltage was 270VDC. The design standard for the battery charger, National Electrical Manufacturers Association (NEMA) PE-5, Section 3.7, Voltage deviation (regulation) specified the allowed voltage deviation shall not exceed 0.5% of the charger setpoint. The NEMA PE 5 standard specified that the voltage regulation was only to account for the system deviations described in Sections 2 and 3 of the NEMA standard. These deviations that required voltage regulation were from changes in environmental conditions, changes in incoming power conditions, and changes in charger load conditions. Design Specification APP-DC01-Z0-001, Rev.11, Sections 4.1.1.3.2 and 4.1.1.3.3 specified, in part, that the battery charger output voltage shall be regulated at no more than +0.5% of the nominal float voltage (270V). The normal float voltage plus 0.5% equals a maximum measured float voltage of no greater than 271.35VDC. This upper voltage is specified for the excursions identified in the NEMA standard, otherwise, the maximum float voltage should be 270VDC.

The licensees preoperational test procedure, 3-IDS-ITPP-501, Step 4.1.1.3, specified a maximum float voltage of 272VDC without identifying the circumstances for which this was allowed. This prescribed upper limit in the test procedure is above the voltage deviation allowed for excursions per the NEMA standard and above the 271.2VDC maximum float voltage per the battery design.

19 After identification, the licensee changed their preoperational test procedure to reflect the NEMA PE 5 voltage regulation requirement. The licensee entered this issue into its corrective action program as CR 50080097 and planned corrective actions to revise the procedure.

Example 2: Static transfer switch was not tested under load The inspectors reviewed preoperational test procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test, to verify if the procedure would demonstrate the test method and acceptance criteria prescribed in the UFSAR Section 14.2.9.1.14, Class 1E DC Power and Uninterruptible Power Supply Testing. The UFSAR required that the capability of each of the static transfer switches to automatically transfer the electrical loads supplied by each inverter to its associated regulating transformer to be verified.

To verify this, the static transfer switch would be required to be under an electrical load. The test procedure specified static switch testing without an electrical load connected to it. As a result of the design requirements not being translated into the preoperational test procedure, static transfer switch 3-IDSA-DU-1 was tested without an electrical load and did not verify the switch capability as required. The licensee entered this issue into its corrective action program as CR 50079776 and planned corrective actions to revise the procedure to test the static transfer switches while connected to a load.

Example 3: Battery charger test did not meet UFSAR requirements The UFSAR Section 14.2.9.1.14, Class 1E DC and UPS Testing, required, the capability of each of the seven battery chargers to charge its associated battery at the required rate be verified. This testing includes verification that the individual voltage of each cell is within the specified limits for a charged battery. Preoperational test procedure 3-IDS-ITPP-501 did not require the individual cell voltages to be verified while charging and after charging the batteries at the required rate. The required rate was established by ITAAC 2.6.03.04c and test specification 3-IDS-ITPP-501 as 150A for the 24hr batteries and 125A for the 72hr batteries. The licensee entered this issue into its corrective action program as CR 50079774 and was planning corrective actions.

Analysis The inspectors determined that the failure to translate the requirements of the Class 1E DC and UPS system into testing procedures was contrary to 10 CFR 50, Appendix B, Criterion III, and was a performance deficiency. The performance deficiency was determined to be more than minor and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee failed to translate design requirements from NEMA PE 5, APP-IDS-T1-503, and UFSAR Section 14.2.9.1.14 into their preoperational test procedure, 3-IDS-ITPP-501. The performance deficiency did not impact an ITAAC, and therefore was determined to be a construction finding.

The inspectors determined the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP1000 Construction Significance

20 Determination Process, Section 4. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of consistent process in the area of human performance. Specifically, the licensee used an inconsistent approach to ensure that all requirements were translated into the procedure. [H.13]

Enforcement Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, on February 2, 2021, the licensee failed to translate the design information in NEMA PE 5, APP-IDS-T1-503, and UFSAR Section 14.2.9.1.14 into the Class 1E DC and UPS preoperational test procedure, 3-IDS-ITPP-501. The licensee entered these issues into their corrective action program as CR 50080097, 50079776, and 50079774, respectively. Corrective actions are planned and do not present an immediate safety concern because none of the tests that use this design information have been completed and accepted by the licensee.

Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees CAP, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-04, Failure to Translate Design Requirements into IDS Test Procedure).

NCV 05200025/2021002-05, Failure to Control Design Calculation for Three Battery Cells Bypassed Introduction The NRC inspectors identified a construction finding of very low safety significance (Green), and an NCV of 10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, for the licensees failure to control the quality of design requirements and acceptance criteria in calculations used to determine voltage margins after discharge.

Description The IDS batteries were sized such that 120 cells would provide no less than 210VDC after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discharge following a design basis accident. The inspectors reviewed portions of APP-IDS-E0C-001, Class 1E 250V DC Battery Sizing, Charger Sizing and Available Short Circuit Current, Rev 8, and determined that the calculation allowed for

21 the bypassing of three battery cells with no loss of battery performance. The inspectors noted that at 117 cells the calculation inappropriately used a minimum voltage of 1.75VDC per cell, which would not provide the required minimum battery voltage of 210VDC after a complete discharge in some design basis accident scenarios.

Subsequent to the NRC identifying this concern, the licensee entered this into their corrective action program as CR 50080010 and CAP IR 2021-2177. Corrective actions included using a different battery profile that used a higher final cell voltage that ensured at least 210VDC after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discharge following a design basis accident with three cells bypassed.

Analysis The inspectors determined that the failure to control the quality of the battery sizing calculation was contrary to 10 CFR 50, Appendix B, Criterion VII and was a performance deficiency. The performance deficiency was determined to be more than minor and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function.

Specifically, the licensee failed to have quality oversight of the battery sizing calculation that could affect the safety function of the battery. The performance deficiency did not impact an ITAAC, thus it was determined to be a construction finding.

The inspectors determined the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP1000 Construction Significance Determination Process, Section 4. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of documentation in the area of human performance. Specifically, the licensee failed to consider all potential scenarios for the battery calculation. [H.7]

Enforcement Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services requires, in part, the effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services.

Contrary to the above, on February 24, 2021, the licensee failed to assess the effectiveness of the control of quality by contractors and subcontractors at intervals consistent with the importance, complexity, and quantity of the product or services.

Specifically, calculation APP-IDS-E0C-001 used a battery profile with three cells bypassed that would not provide the minimum required voltage after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discharge following a design basis accident. The licensee and contractor entered this issue into their corrective action programs as CR 50080010 and CAP IR 2021-2177. Corrective actions are planned and do not present an immediate safety concern because the batteries were not be relied upon to perform their safety-related

22 function. Corrective actions are planned and do not present an immediate safety concern because the results of the calculation have not been used to justify the bypassing of any battery cells.

Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees CAP, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-05, Failure to Control Design Calculation for Three Battery Cells Bypassed).

3T04 (Unit 3) ITAAC Number 2.2.01.11a.iii (116) / Family 07D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.11a.iii (116). The inspectors used the following NRC IPs/sections to perform this inspection:

65001.D-02.02 - Test Observation The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure(s) to determine if the test(s) satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

B-GEN-ITPCI-039-F004;

B-GEN-ITPCI-039-F005; and

B-GEN-ITPCI-039-F006.

b. Findings No findings were identified.

IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs 3P01 Inservice Testing

73758-App A.02.02 - Preservice and Inservice Testing (PST) (IST) Program

73758-App B.02.01 - Inspection Requirements

a. Inspection Scope Inservice Testing (IST) Program The inspectors reviewed the Vogtle Units 3 & 4 IST Program Plan, Licensing Document Change Request (LDCR) 2019-079, site procedures, and other documents to determine whether the licensees IST Program was developed in compliance with the applicable regulatory requirements and license conditions, is consistent with the plant-specific UFSAR, and is ready to support the operation of the facility. Specifically, the inspectors reviewed the following:

23

license conditions applicable to IST at Vogtle Units 3 & 4 to verify if they have been incorporated into the IST Program;

the scope of the IST Program to verify if it was consistent with the plant-specific FSAR, and is in compliance with the ASME OM Code as incorporated by reference in 10 CFR 50.55a;

the testing specified in the IST Program Plan and LDCR-2019-079 to verify if they were in accordance with the requirements of 10 CFR 50.55a and the 2012 Edition of the ASME OM Code as incorporated by reference in 10 CFR 50.55a;

alternatives to the requirements of 10 CFR 50.55a or the ASME OM Code identified in the IST Program Plan to verify if they were authorized prior to their use;

ASME OM Code Cases identified in the IST Program Plan to verify if they had been approved for use;

justifications for deferring applicable IST activities to cold shutdown and refueling outages included in the IST Program Plan;

controls in place to ensure that components do not receive unacceptable preconditioning prior to IST activities; and

planned changes to the UFSAR identified in LDCR-2019-079 to verify if they were consistent with the IST provisions of the ASME OM Code as incorporated by reference in 10 CFR 50.55a.

The inspectors also reviewed Southern Nuclear Operating Company (SNC) Document No. ND-LI-013-47-09-15-2020 (dated 9/18/2020), Technical Specification Requirements in accordance with the Inservice Testing Program, which was developed by SNC to determine a method of compliance with the Technical Specification Surveillance Requirements (SRs) that require compliance in accordance with the Inservice Testing Program when they become applicable at the 10 CFR 52.103(g) finding given that the IST Program requirements start at the first generation of electricity by nuclear heat at Vogtle Units 3 & 4. As stated in ND-LI-013-47-09 2020, the licensees position is that the Technical Specification SRs that require compliance in accordance with the Inservice Testing Program during the initial plant startup period, are met by testing to the ASME OM Code requirements as required by 10 CFR 50.55a(f), which encompasses both PST and IST activities. The licensees position provides that this was accomplished by satisfactory performance to the requirements (test procedure and frequency) of preservice testing prior to initial generation of electricity by nuclear heat, and testing to requirements for inservice testing starting at the first generation of electricity by nuclear heat (i.e., the first periodic performance for each inservice test is due after the first generation of electricity by nuclear heat plus the stated frequency with allowed adjustment per ASME OM Code Case OMN-20). During the review, the inspectors obtained information from NRC headquarters staff from the technical branches responsible for IST and Technical Specification requirements. The NRC headquarters staff determined that the licensees position is consistent with the current language of the ASME OM Code that does not include periodic PST activities for a nuclear power plant during its initial startup. In considering the licensees position, the NRC headquarters staff noted that the ASME OM Code includes flexibility in the intervals for IST activities by allowing quarterly IST activities to be extended to refueling outages where testing during plant operation is not practicable. On this basis, the inspectors determined the licensees position in ND-LI-01347-09-15-2020 was acceptable, and noted that the NRC can address the

24 performance of PST activities by a separate process if the startup process for Vogtle Units 3 & 4 becomes extended.

Operational Readiness of Pumps, Valves, and Dynamic Restraints within the Scope of Regulatory Treatment of Non-Safety Systems To determine how the licensee will comply with the requirements of 10 CFR 50.55a(b)(3)(iii)(D), the inspectors reviewed procedures intended to establish the performance criteria and monitoring parameters needed to assess the operational readiness of pumps, valves, and dynamic restraints, that are within the scope of Regulatory Treatment of Non-Safety Systems (RTNSS). Specifically, the inspectors reviewed SNC Procedure NMP-ES-001 (Version 10.1, approved 12/15/2020),

Equipment Reliability Process Description, which provided the strategy and overall process for integrating various equipment reliability processes that are essential to ensure sustained long-term equipment performance. The procedure states that it will be implemented fully by the NRC ITAAC 52.103(g) finding. The inspectors also reviewed SNC Procedure NMP-ES-005 (Version 18.0, approved 02/25/2020), Scoping and Importance Determination for Equipment Reliability, which provided guidance for determining or modifying the criticality classification, duty cycle, and service condition of a component. The procedure applies to systems and components important to support safe power generation, and also applies to components requiring preventive maintenance in order to minimize unanticipated failures that may result in economic impact or radiation exposure.

During the procedure review, the inspectors also asked whether the licensee had completed the scoping and importance determination process, per NMP-ES-005, for the pumps, valves, and dynamic restraints that were subject to the Equipment Reliability Process. The licensee responded that the scoping for these components is currently in process per NMP-ES-005 with completion planned by the second quarter of 2021. In addition, the inspectors asked whether the licensee had established performance criteria/monitoring parameters for the aforementioned pumps, valves, and dynamic restraints. The licensee responded that the maintenance strategies have been drafted for the majority of components and that the preventative maintenance and surveillances are being evaluated in preparation for system transition. The licensee also provided a list with examples of RTNSS equipment that had been scoped and assigned maintenance strategies using the Equipment Reliability Process. The examples of RTNSS equipment and their maintenance strategies included (1) Residual Heat Removal (RHR) System Pump 3-RNS-MP-01A with periodic exercise testing, flow verification, oil analysis, and motor vibration monitoring; and (2) Letdown containment isolation valve 3-CVS-V045 with periodic AOV diagnostic testing, solenoid replacement, airline maintenance, Topworx C7GO Switch replacement, and ASCO solenoid valve replacement. The inspectors determined that the maintenance strategies provided were sufficient to assess the operational readiness of the sampled components.

The inspectors also reviewed Licensing Document Change Request for Vogtle Electric Generating Plant (VEGP) Units 3&4 LDCR-2019-079 (Version 1.0, dated April 30, 2020), Inservice Testing Program Plan, Vogtle Units 3&4. In LDCR-2019-079, the licensee plans to include new Section 3.9.6.4.6, Regulatory Treatment of Non-Safety Systems (RTNSS) component testing, in the next revision to the UFSAR for Vogtle Units 3 & 4. This new UFSAR section will reference 10 CFR 50.55a(b)(3)(iii)(D) for the requirement to assess the operational readiness of pumps, valves, and dynamic

25 restraints within the scope of the RTNSS program. The new UFSAR section will state that the method for assessment of operational readiness for these components is documented in the equipment reliability assessment for the associated components and includes testing of the components performed per Section 16.3 of the UFSAR. The inspectors discussed the planned UFSAR updates with the licensee as well as the plans to use the Equipment Reliability Program to ensure that the testing of RTNSS pumps, valves, and dynamic restraints satisfies the operational readiness requirements of 10 CFR 50.55a(b)(3)(iii)(D).

Based on the review described above, the inspectors determined that the implementation of the Equipment Reliability Program can provide reasonable assurance of the operational readiness of pumps, valves, and snubbers provided the licensee satisfies the requirements of 10 CFR 50.55a(b)(3)(iii)(D). The inspectors also verified that no components classified as RTNSS are within the scope of the PST/IST program.

b. Findings No findings were identified.

3P02 Preservice Testing

73758-App A.02.01 - Functional Design and Qualification

73758-App A.02.02 - Preservice and Inservice Testing Program

73758-App B.02.01 - Inspection Requirements

73758-App C.02.01 - Inspection Requirements

a. Inspection Scope Functional Design and Qualification The inspectors performed the following activities related to the development and implementation of the Functional Design and Qualification Program for pumps, valves, and dynamic restraints that will perform safety-related functions at Vogtle Units 3 & 4:

the inspectors reviewed the licensees disposition of the international operating experience with AP1000 plants on the potential for thermal binding of globe valves in high temperature applications to determine if the licensees actions provided reasonable assurance that the issue identified in the operating experience will not adversely impact the plant during operation;

The inspectors reviewed motor-operated valve (MOV) application reports, and other documents, related to the qualification of Size 3 Class 1890 Flexwedge gate valves with Limitorque SB-1-60 DC motor actuators used at Vogtle Units 3

& 4 to determine if the licensee satisfied the provisions of ASME Standard QME-1-2007 as specified in the Vogtle Units 3 & 4 plant-specific FSAR, and as accepted in Regulatory Guide 1.100 (Revision 3);

The inspectors reviewed design reports, and other documents (including the verification and validation process for incorporating the Boiling Water Reactor

26 Owners Group DC Motor Methodology into the Teledyne MIDAS MOV Calculation Software) related to the qualification of PCS-PL-001C, PCS Actuation Valve C, MOV to verify if the appropriate justifications were provided for assumptions made in the valve set point data sheet (SPDS), including the assumptions of a 0.58 valve coefficient of friction, the Limitorque SB-00 actuator maximum thrust, and the 10% margin tracking method; and

The inspectors reviewed a sample of work packages for post-installation valve testing to determine if the licensee satisfied the provisions of ASME Standard QME-1-2007, as specified in the UFSAR. The sample included the following valves:

o SV3-SFS-PL-V034, Refueling Cavity/IRWST to SFS IC Containment Isolation Valve; o SV3-SFS-PL-V035, Refueling Cavity/IRWST to SFS OC Containment Isolation Valve; o SV3-SFS-PL-V038, SFS to Refueling Cavity/IRWST to SFS OC Containment Isolation Valve; o SV3-PXS-PL-V014A, CMT A Outlet Valve; o SV3-PXS-PL-V014B, CMT B Outlet Valve; o SV3-PXS-PL-V015A, CMT A Outlet Valve; o SV3-PXS-PL-V015B, CMT B Outlet Valve; and o SV3-RNS-PL-V061, CVS Return to RNS Suction/IC Containment Isolation Valve.

PST Program The inspectors performed the following activities related to the development and implementation of the PST Programs for pumps, valves, and dynamic restraints that will perform safety-related functions at Vogtle Units 3 & 4:

The inspectors reviewed PST Program implementing procedures to verify if administrative controls were in place to track the completion of required PST activities prior to the first electrical generation by nuclear heat, as required by the ASME OM Code;

The inspectors reviewed the licensees check valve monitoring program procedure to verify if it was in compliance with the requirements of 10 CFR 50.55a(b)(3)(iv) and the ASME OM Code as incorporated by reference in 10 CFR 50.55a;

The inspectors reviewed PST activities specified for a sample of valves in the PST Program Plan for compliance with the ASME OM Code as incorporated by reference in 10 CFR 50.55a. The sample included the following valves:

o SV3-RCS-PL-V001A, ADS Stage 1 Control Valve (4-inch globe MOV);

o SV3-RCS-PL-V002B, ADS Stage 2 Control Valve (8-inch globe MOV);

o SV3-RCS-PL-V003A, ADS Stage 3 Control Valve (8-inch globe MOV);

o SV3-RCS-PL-V004B, ADS Stage 4 Valve (14-inch squib valve);

o SV3-PXS-PL-V123A, Containment Recirc. Sump A to RCS Actuation Squib Valve (8-inch squib valve);

27 o SV3-SGS-PL-V031B, SG 2 Safety Valve; o SV3-RNS-PL-V061, CVS return to RNS Suction/IC Containment Isolation Valve (3-inch globe AOV); and o SV3-PXS-PL-V016A, CMT A outlet to RCS Check (8-inch check valve);

The inspectors reviewed the preservice examination results for the following sample of dynamic restraints to verify if the requirements of ASME OM Code, Subsection ISTD, paragraph ISTD-4110, as incorporated by reference in 10 CFR 50.55a, had been met:

o SV3-PXS-PH-11Y0020, SV3-PXS-PH-11Y2052; o SV3-RNS-PH-12Y2060; and o SV3-RCS-PH-11Y0039, SV3-RCS-PH-11Y0081, SV3-RCS-PH-11Y0388, SV3-RCS-PH-11Y0528, SV3-RCS-PH-11Y1134, SV3-RCS-PH-11Y2005, SV3-RCS-PH-11Y1130, SV3-RCS-PH-11Y2264; and

The inspectors reviewed corrective actions taken to address the following issues to determine if the licensees actions were appropriate:

o the inability to use magnetic switches to verify the position of check valves PXS-PL-V122B and V124B, IRWST/Containment Recirc Sump injection to RCS check valves; and o unsatisfactory snubber examination results.

b. Findings No findings were identified.

3P03 Quality Assurance (Operations)

35101 - QA Program Implementation Inspection for Operational Programs

42401 - Part 52, Plant Procedures

42453 - Part 52, Operating Procedures Inspection

42454 - Part 52, Emergency Procedures

71303 - Part 52, Technical Specifications Review

a. Inspection Scope IP 35101 The inspectors reviewed licensee controls pertaining to status of inspections and tests of items installed in the plant. Specifically, the inspectors reviewed procedure NMP-GM-006-002, Surveillance Program, to determine if controls were in place for:

responsibilities, administrative controls, and documentation requirements to assure compliance with surveillance requirements of licensing documents;

periodic testing to verify that safety-related structures, systems, and components (SSCs) were in a state of readiness to perform their functions, and to provide assurance that failures or substandard performance do not remain undetected; and

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system level operability program administrative guidance, which provides requirements for performance tests of AP-1000 passive systems.

The inspectors reviewed licensee measures used to identify satisfactory completion of required inspections and tests. Specifically, the inspectors reviewed procedure NMP-GM-006, Work Management, to determine if controls existed for:

a long-range maintenance cycle plan that bundles work to minimize out of service time, aligns with preventive maintenance (PM) strategies, and minimizes Maintenance Rule unavailability of equipment;

planning and performance of post-maintenance testing; and

multi-discipline reviews of the PM program, and generation of PM Change Requests as required.

The inspectors reviewed licensee measures that prevent the inadvertent bypass of required inspections and tests. Specifically, the inspectors reviewed procedure B-ADM-WCO-001-001, Operational Readiness Repetitive Task Management, to determine if controls were in place for:

maintaining the Master List of Surveillance Requirements (MLSR), which is a comprehensive listing of all surveillance requirements in: Technical Specifications (TS), the Technical Requirements Manual (TRM), and the Offsite Dose Calculation Manual (ODCM);

maintaining the surveillance/PM database to ensure work orders are generated and scheduled for all surveillance requirements;

scheduling, performing (by qualified personnel), reviewing surveillance test procedures, and documenting corrective actions as required

ensuring that preventive maintenance change requests were used to add, revise, or change the scope of the surveillance program The inspectors reviewed licensees measures to verify if they were used to indicate the operating status of SSCs, such as tagging valves and switches that prevent inadvertent operation. Specifically, the inspectors reviewed the following procedures:

B-ADM-OPS-001, Operations Configuration Control

B-ADM-OPS-012, Equipment Clearance and Tagging

B-ADM-OPS-016, Plant Status and Configuration Control The inspectors also reviewed the procedures to determine if controls existed for:

maintaining configuration control zones, 2-foot buffer areas in front of switchgear, motor control centers, control panels, and other sensitive equipment;

locking in of required valve positions for components that have particular operational importance, or for other control considerations such as radiological or fire protection;

logging of Ovation computer points that are forced out of scan for longer than one shift;

ensuring that system valve, switch, and breaker lineups for operation were performed after equipment lockout/tagout per OSHA personnel-protection requirements; and

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identifying, preventing, and correcting component mispositioning events.

IP 42401 The inspectors performed a sample of 16 plant procedures pertaining to written instructions and guides from the categories of abnormal operating, conduct of operations and emergency plan procedures to verify if the procedures conformed with the criteria established in IP 42401, Appendix B, Procedure Usability Evaluation Checklist. Specifically, the inspectors reviewed whether the procedures contained equipment identification names, acronyms, continuous action steps, and the current verification and validation resources to capture possible needed enhancements.

The inspectors reviewed the sampled procedures to verify if administrative controls and responsibilities have been established for the review, approval, and periodic updating of plant procedures that conform to license requirements. Specifically, the inspectors reviewed NMP-AP-002, SNC Fleet Procedures Writers Guide.

The inspectors reviewed the sampled procedures to verify if procedural controls had been established and usability of the procedures satisfied quality standards. The inspectors reviewed the usability to determine whether the procedures accomplished their intended purpose, the operating limitations and design criteria were incorporated, and human factors principles were incorporated.

The inspectors reviewed a sample of the current conduct of operations guidance and instructions for standing orders, night orders, and shift logs to verify that these orders were not being used in place of procedures. The inspectors reviewed the administrative controls for the preparation and correction of operating logs, shift turnover activities and log reviews.

The inspectors performed four interviews with facility procedure writer staff to determine awareness and understanding of facility programs established for controlling temporary changes to procedures and procedure quality.

For pandemic related concerns, on-site inspector validation of facility procedure use was not pursued (evaluation of human factor principles to verify procedure usability to include a walk thru or table-top evaluation). Based on subject matter overlap between inspection sampled facility procedures and use of these procedures during NRC evaluation of licensed operator examination applicants, equivalency reviews of administered examination materials and results were conducted. Equivalency credit was appropriate for verifying inspection criteria since the facility staff observed during licensing examinations directly represent the facility population of expected procedure users in the actual plant and human performance principles were directly observed through actual facility implementation of sampled procedures. The performance observed during NRC evaluated licensing examinations ties directly to anticipated performance during actual plant operation.

The inspectors reviewed the results of license operator exams administered in 2016 and 2020 to validate that specific abnormal operating procedures were effective tools for operator mitigation of applicable abnormal events. The inspectors verified the

30 procedural content used and compared scenario performance use with the relevant procedures sampled for this inspection.

IP 42453 The inspectors reviewed a sample of 16 plant procedures from administrative, general plant operating, safety-related system startup, shutdown and operation, and surveillance test procedures to verify if the procedures were in conformance with NMP-AP-002, Procedure Writers Guide.

The inspectors reviewed the procedures to verify if administrative controls and responsibilities have been established for the review, approval, and periodic updating of plant procedures that conform to license requirements. Specifically, the inspector reviewed NMP-AP-001-003, Review and Approval of Site Procedures, to ensure compliance.

The inspectors reviewed the procedure to verify if the following controls existed:

procedure preparation in the desired format and content;

issuing new and revised procedures;

control and disposition of outdated procedures;

control of temporary changes to procedures;

ensuring changes to procedures are approved by the same organization that approved the original unless another qualified organization has been designated; and

ensuring that the training organization is informed of procedure changes.

The inspectors reviewed the procedures to determine whether the procedures accomplished their intended purpose, operating limitations and design criteria were incorporated, human factors principles were incorporated, and procedure quality standards were met.

The inspectors performed one group interview with facility staff to determine awareness and understanding of facility programs established for controlling temporary changes to procedures. Additionally, the inspector discussed the sampled procedures as related to compliance with site guidance, including NMP-AP-001-003.

IP 42454 The inspectors reviewed a sample of 16 emergency operating procedures (EOPs) to determine if the procedures were consistent with the format specified in the facilitys administrative controls procedures. Specifically, the inspectors reviewed NMP-AP-002, Procedure Writers Guide and NMP-AP-002-002, SNC Fleet Procedures Writers Guide. The inspectors reviewed documentation confirming review by a technical authority for use in accordance with D-GEN-ADM-001, Verification and Validation.

The inspectors reviewed the procedures to verify if administrative controls and responsibilities have been established to review, approval, and periodic updating of emergency operating procedures. Specifically, the inspectors reviewed NMP-AP-004, Maintenance of Emergency Operating and Accident Procedures.

31 The inspectors reviewed the procedures to verify whether the following procedure controls existed:

procedure preparation in the desired format and content;

issuing new and revised procedures;

control and disposition of outdated procedures;

control of temporary changes to procedures;

ensuring changes to procedures are approved by the same organization that approved the original unless another qualified organization has been designated; and

ensuring that the training organization is informed of procedure changes.

The inspectors conducted an in-office review of 16 EOPs to:

verify if procedures accomplish their intended purpose, within applicable design characteristics and safety review considerations;

verify if appropriate technical specification, vendor, or design operating limitations, such as heat up/cool down rates, pressure/temperature limits, reactivity limits, safety limits, limiting conditions of operations, and limiting safety system settings, were incorporated;

verify if human factors principles (in accordance with IP 42454, Appendix B, Procedure Usability) were incorporated;

verify if procedures were usable by the personnel intended

evaluate procedures against the writing style and format standards established in NMP-AP-002, SNC Fleet Procedures Writers Guide, and NMP-AP-002-002, SNC Fleet Two Column Procedures Writers Guide; and

verify if quality requirements of NMP-AP-002 and NMP-AP-002-002 were implemented.

For pandemic related concerns, on-site inspector validation of facility procedure use was not pursued to meet inspection evaluation criteria 02.04.c (evaluation of human factor principles to verify procedure usability). Based on subject matter overlap between inspection sampled facility procedures and use of these procedures during NRC evaluation of licensed operator examination applicants, equivalency reviews of administered examination materials and results were conducted. Equivalency credit was appropriate for verifying inspection criteria of 02.04.c since the facility staff observed during licensing examinations directly represent the facility population of expected procedure users in the actual plant and human performance principles were directly observed through actual facility implementation of sampled procedures. The performance observed during NRC evaluated licensing examinations ties directly to anticipated performance during actual plant operation.

The inspectors reviewed the results of the most recent NRC administered operating test, Examination Report 2020301, conducted during the period of March 16-20, 2020.

The scenarios used for this examination included use of seven procedures reviewed for this inspection. The inspectors verified the procedural content used, performance by plant operating staff and compared scenario performance use with the appropriate EOPs sampled for this inspection.

32 The inspectors conducted four telephone interviews with facility operations staff of varying organizational levels to determine awareness and understanding of facility programs established for controlling temporary changes to emergency operating procedures, changes specific to use of emergency operating procedures and facility component labelling in relation to performance of emergency operating procedures (specifically for control and manipulation of field components). All four interviewees received the same set of questions with responses received consistent across the facilitys Operations department.

IP 71303 The inspectors performed a line-by-line check of seven TS-related license amendments enacted since COL issuance, to verify the amendments were incorporated into licensee-controlled copies of TS (and TS Bases), which were in use by plant operations and support staff.

The inspectors verified the acceptability of the licensees operability determination procedures by:

reviewing NMP-AD-012, Operability Determinations, to determine the process for operability determinations on degraded and non-conforming equipment, including criteria for when an operability determination was required, the allowable time frame for completion of the determination, including any extensions to the time frame;

reviewing NMP-OS-027, Recording Limiting Conditions for Operation, to determine the process for implementation of required actions when the limiting condition for operation was not met, and to determine the acceptability of the safety function determination program, which ensures proper actions are taken such that multiple inoperable SSCs do not result in an undetected loss of safety function; and

the inspectors performed three interviews with licensed SROs to assess their knowledge of NMP-AD-012 and the Safety Function Determination Program for two hypothetical operability issues. Specifically, the inspectors conducted the interviews via Teams so the interviewees could share their screen with the inspector to describe the operability determination process for a main control room envelope operability determination and a safety function determination following the loss of an electrical power supply panel.

The inspectors reviewed a sample of 10 surveillance procedures used to implement TS surveillance requirements; these surveillance procedures included reactivity control (TS 3.1), instrumentation (TS 3.3), electrical (TS 3.8), and refueling (TS 3.9). The review was performed to verify that the procedures fulfilled the intent of the associated TS surveillance requirement. The facility licensee was not required to perform the surveillance procedures since no fuel was loaded at the time of the inspection; therefore, completed surveillance procedure documents were not available for inspector review.

The inspectors reviewed the following programs' implementing procedures to verify if the licensee met programmatic requirements in TS Section 5.5:

off-site dose calculation manual (TS 5.5.1);

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safety function determination program (TS 5.5.7);

secondary water chemistry program (TS 5.5.5); and

the main control room envelope habitability program (TS 5.5.12).

The inspectors reviewed the core operating limits report (TS 5.6.3) and the pressure temperature limits report (TS 5.6.4) to verify if the licensee met reporting requirements in TS Section 5.5.

The inspectors reviewed the following procedures that manage Technical Specifications with respect to engineering changes to verify if proper controls were in place:

ND-LI-VNP-002, Applicability Determination and 50.59 Departure Screening, to determine the process for performing applicability determinations and 50.59/Departure Screenings for design, plant procedure, and licensing document change activities;

ND-LI-VNP-003, 50.59 / Departure Evaluations, to determine the process for compliance with the requirements of 10CFR50.59 and 10CFR52 Appendix D Section VIII, and the controls and methods for these processes which enable plant staff to prepare 50.59 / Departure Evaluations needed to support various change activities;

ND-LI-VNP-007, Licensing Document Change Requests, to determine the process for requesting, processing, and approving changes to licensing documents, including the controls and methods for the LDCR process which enable plant staff to prepare LDCRs to support various change activities; and

a sample of six (6) implemented design modifications from the past 24 months.

The inspectors reviewed the following TS Bases documents and processes in use by the licensees operations and support staff to verify if they were controlled in accordance with the TS Bases Control Program (TS 5.5.6):

ND-LI-VNP-015, Technical Specification Bases Control for VEGP Units 3&4, to ensure TS 5.5.6 programmatic requirements were met;

the TS Bases were consistent with the TS-related license amendment sample;

the TS Bases did not require changes for the modifications sample; and

TS Bases changes to ensure consistency with the updated UFSAR.

b. Findings No findings were identified.

3P04 Initial Test Program (Startup)

IP 72401-02.01 - Test Program

a. Inspection Scope Inspections of the Unit 3 startup test program was previously completed and documented in inspection report 05200025/2020008 (ADAMS Accession No. ML20224A009). For the Unit 4 startup test program, the inspectors reviewed program

34 differences developed and employed since completion of the testing program inspections for Vogtle Unit 3. The following testing program attributes were reviewed for Unit 4:

Test Organization

The responsibilities, qualifications, and training of ITP testing staff were specified in writing including test procedure preparation and approval, test performance and documentation, and test results review and approval.

Test Program Administration

Administrative measures were established for jurisdictional control of system, component, or instrumentation status before, during, and after testing including control of system status before testing and return of system components or instrumentation to construction.

Administrative measures were established governing the conduct of testing including:

o methods to change (both major and minor) a test procedure during the conduct of testing; and o method for providing the current test procedure and marked-up drawings showing current modification status to the operators before test commencement.

Evaluation of test results were established including:

o test results were checked against design and compared with previously determined performance standards, limits or acceptance criteria; o deficiencies were clearly identified, documented, and appropriate corrective action has been proposed, reviewed, and completed; o retests were performed as necessary after corrective actions or modifications have been completed; and o test result evaluations were reviewed and formally approved by appropriate licensee personnel and/or contractor personnel.

Document Control

Administrative measures were established which control the test procedure processes for review, approval, issuance, and revision.

Responsibilities were assigned in writing to ensure that the procedure controls will be implemented.

Design Changes and Modifications

Administrative controls were established for controlling temporary modifications, jumpers, and bypasses.

The review process, including assignment of responsibility, provided for ensuring that all proposed temporary modifications, jumpers, and bypasses were reviewed for potential impacts to the UFSAR.

Controls required that a formal log be maintained of the status of temporary modifications.

Responsibility was assigned for maintaining formal logs.

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b. Findings No findings were identified.

4. OTHER INSPECTION RESULTS 4OA1 IMC 2514 - AP 1000 Reactor Inspection Program - Startup Testing Phase

IP 72304-02.01 - Review of Startup Test Procedures

a. Inspection Scope The inspectors used applicable portions of the IP to review the following startup test procedures to verify if they were consistent with the licensees technical and administrative criteria, Combined License (COL) commitments, Design Control Document (DCD), UFSAR, regulatory requirements, and Technical Specifications (TS).

3-GEN-ITPS-601;

3-GEN-ITPS-610;

3-GEN-ITPS-611;

3-GEN-ITPS-633;

3-GEN-ITPS-636;

3-GEN-ITPS-638;

3-GEN-ITPS-640; and

3-PLS-ITPS-605.

b. Findings NCV 05200025/2021002-06, Inadequate Startup Testing Procedures for Establishing Initial Criticality Introduction The inspectors identified a construction finding of very low safety significance (Green), and an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activities of achieving initial criticality in a controlled manner, measuring the ITC, and calculating the MTC of reactivity.

Description On January 20, 2021, the inspectors performed a review of 3-GEN-ITPS-610, Initial Criticality and LPPT Sequence Startup Test Procedure, Version 1.0; 3-GEN-ITPS-611, Initial Criticality and Low Power Physics Tests Startup Test Procedure, Version 2.0; the associated Westinghouse startup test specifications (SV3-GW-T1-693, AP1000 Startup Test Specifications for Initial Criticality Tests, Revision 1 and SV3-GW-T1-694, AP1000 Startup Test Specifications for Low Power Tests, Revision 1); and, the operations and nuclear engineering implementing procedures (3-GOP-302, Reactor

36 Startup Mode 3 To Mode 2, Version K=0.10 and B-GEN-RES-004, Low Power Physics Testing, Version 4.0). The inspectors identified many discrepancies between the Westinghouse test specifications and the licensees test procedures and implementing procedures. The inspectors noted the licensee had not correctly translated all of the test conditions from the test specifications to the test procedures and implementing procedures. The inspectors also noted conflicting conditions for performing testing specified in the test specifications and procedures.

It should be noted 3-GEN-ITPS-610 and 3-GEN-ITPS-611 do not specify many of the test conditions, but instead refer to the implementing procedures. Specifically, 3-GEN-ITPS-611, Step 1.1.2 stated: Initial criticality and low power physics testing is conducted using procedures 3-GOP-302, Reactor Startup Mode 3 to Mode 2, and B-GEN-RES-004, Low Power Physics Testing. The results and data from these procedures are obtained and utilized for the Acceptance Criteria contained in this procedure.

Deficiencies identified with the licensees test procedures and implementing procedures included:

1. 3-GEN-ITPS-610, Step 4.1.3 specified a required RCS temperature band of 557°F +/- 1.5°F; however, APP-GW-T1-693, Step 2.3 Precautions and Limitations Step 4 stated: RCS T-avg shall be maintained within +/-1°F of the initial value [557°F] for the duration of this test. B-GEN-RES-004, Step 3.2.5 and 3-GOP-302, Step 3.2 specified a required RCS temperature band of 555°F to 559°F, which would be 557°F+/-2°F. The criterion to maintain RCS T-avg within +/-1°F of the initial value for the duration of the test was not correctly translated from the startup test specification into the test procedures and implementing procedures.

2. APP-GW-T1-693, Step 2.3 Precautions and Limitations Step 3 stated: The boron concentration sampling of the RCS and PZR [pressurizer] established during the approach to criticality will be continued throughout this test. RCS and PZR boron concentrations should remain within +/-20 ppm (parts per million) of each other. However, B-GEN-RES-004, Step 3.2.7.b specified a delta of 1000 pcm (Per Cent Mille) and 3-GOP-302, Steps 2.23 and 4.12 specified 50 ppm. There were no criteria for maintaining boron concentration between the RCS and PZR specified in 3-GEN-ITPS-610 and 3-GEN-ITPS-611. The criterion to maintain RCS and PZR boron concentrations within +/-20 ppm of each other was not correctly translated from the startup test specification into the test procedures and implementing procedures.

3. SV3-GW-T1-693, Step 2.3, Lessons Learned Step 3 stated: Revision for the criteria for reaching criticality is as follows: Change the startup rate from 0.15 dpm [decades-per-minute] on the Intermediate Range (IR) channels to 0.25 dpm on either Source Range (SR) or IR channels, and the corresponding reactivity change from 35 pcm to 50 pcm. This revision to the criteria was not made in 3-GOP-302 and B-GEN-RES-004. The Note above 3 GOP-302, Att 2 Step 4.6.i stated: A sustained positive startup rate of greater than 0.15 dpm is indication that the reactor is critical. B-GEN-RES-004, Step 4.1.15 stated:

When a consistent positive startup rate (0.05 to 0.1 dpm) is achieved, ensure that operations announces on the plant paging system that the reactor is critical. There were no criteria for reaching criticality specified in 3-GEN-ITPS-

37 610 and 3-GEN-ITPS-611. The revision for the criteria for reaching criticality was not correctly translated from the startup test specification into the test procedures and implementing procedures.

4. 3-GOP-302 and B-GEN-RES-004 had inconsistent and contradictory direction after the reactor becomes critical. 3-GOP-302 secures dilution of the RCS with no criteria provided, adjusts control rods, raises power to 1E-3% and stabilizes power, obtains critical data, and then performs LPPT. B-GEN-RES-004 secures the dilution after establishing a stable 0.25 dpm startup rate or reactor engineer discretion, adjusts control rods, raises power to 2E-4% and stabilizes power, and adjusts rods for 40 to 75 pcm in the core for LPPT. B-GEN-RES-004 did not take into account operators obtaining critical data at 1E-3% since it would have power stabilized before that at 2E-4% for LPPT. Similarly, 3-GOP-302 would not have had operators stabilize power at 2E-4%, but rather proceed to 1E-3% to obtain critical data and then proceed to LPPT. SV3-GW-T1-693, Step 2.3, Test Method Step 18 stated: Use the controlling bank, as required, to attain and stabilize at approximately 1x10-3% RTP [reactor thermal power] on the intermediate range neutron detectors. The inspectors noted there was a guidance statement in the test specification saying operating experience for LPPT is to stabilize the plant at 1E-4% RTP to 1E-3% RTP on the intermediate range; however, SV3-GW-T1-693 did not stabilize power at 2E-4% for LPPT.

The licensee entered these procedure discrepancies into its CAP as CRs 50078446, 50085995, 50085903, 50076122, and 50086434 for evaluation and identification of appropriate corrective actions.

Analysis The inspectors determined the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activities of achieving initial criticality in a controlled manner, measuring the ITC, and calculating the MTC of reactivity was contrary to the requirements of 10 CFR 50, Appendix B, Criterion III, Design Control, and was a performance deficiency. Per the guidance in IMC 0613, Appendix E, "Examples of Minor Construction Issues," the inspectors determined this performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee had not correctly translated all of the test conditions from the test specifications to the test procedures and implementing procedures. Additionally, the inspectors found conflicting conditions for performing testing specified in the test specifications and procedures, requiring changes to the procedures. The inspectors also reviewed the Appendix E examples of minor issues and found one similar example of a "not minor if" performance deficiency. Example 7 was similar, in that the inspectors identified the test procedures and implementing procedures were inadequate because they did not correctly implement applicable technical requirements or conditions for conducting the tests. The inspectors determined this was a construction finding because it was not associated with a specific ITAAC.

The inspectors determined this finding was related to the Inspection/Testing attribute of the Construction Reactor Safety Cornerstone. This finding was not associated with a

38 security program; it was not associated with an IMC 2504 operational/construction program; and it was not associated with a repetitive, NRC-identified omission of a program critical attribute. In accordance with IMC 2519, "Construction Significance Determination Process," Appendix A, "AP 1000 Construction Significance Determination Process," dated December 6, 2017, the inspectors determined this finding was associated with an SSC (i.e. reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure had not been implemented.

In accordance with IMC 0613, Appendix F, "Construction Cross-Cutting Areas and Aspects," the inspectors determined this finding had a cross-cutting aspect of teamwork in the area of human performance. Consistency between the procedures and test specification required a coordinated effort between three organizations. This was not effectively done during initial drafting of the procedures but was later recognized when the three organizations convened to solve the problem. [H4]

Enforcement 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, on or before January 20, 2021, the licensee failed to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activities of achieving initial criticality in a controlled manner, measuring the ITC, and calculating the MTC of reactivity. Specifically, the licensee did not correctly translate all applicable test conditions from Westinghouse startup test specifications SV3-GW-T1-693 and SV3-GW-T1-694 to startup test procedures 3-GEN-ITPS-610 and 3-GEN-ITPS-611 and operations and nuclear engineering implementing procedures 3-GOP-302 and B-GEN-RES-004. Additionally, there were conflicting conditions for performing testing specified in the test specifications and procedures, requiring changes to the procedures. The licensee entered this finding into its CAP for evaluation and identification of appropriate corrective actions (CR 50086434) to restore compliance. Inasmuch as the procedures had not yet been used for the startup testing activities, there was no immediate safety concern.

Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees corrective action program, it is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-06, Inadequate Startup Testing Procedures for Establishing Initial Criticality).

NCV 05200025/2021002-07, Inadequate Startup Testing Procedures for Initial Fuel Loading Introduction

39 The inspectors identified a construction finding of very low safety significance (Green) with an associated NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activity of initial fuel loading.

Description On February 12, 2021, the inspectors performed a review of 3-GEN-ITPS-601, Initial Fuel Loading Startup Test Procedure, Version 1.0; the associated Westinghouse startup test specification (APP-GW-T1-691, AP1000 Startup Test Specifications for Initial Fuel Loading, Revision 1); and, the operations and nuclear engineering implementing procedures (NMP-RE-007, Core Verification, Version 5.0; and B-RFL-FHP-031, Fuel Handling Control Procedure, Version C=0.2). The inspectors identified many discrepancies between the Westinghouse test specification and the licensees test procedure. The inspectors noted the licensee had not correctly translated all of the test conditions from the test specification into the test procedure. The inspectors also noted conflicting conditions for performing testing specified in the test specification and test procedure either due to errors in the test specification or in the test procedure.

Deficiencies identified with the Westinghouse startup test specification included:

1. APP-GW-T1-691, Section 2.3, GEN-601A Reactor Systems Sampling for Fuel Loading, Initial Condition 8, stated: "The fuel transfer canal should be flooded to just above the transfer tracks and the remainder of the refueling cavity is dry." However, 3-GEN-ITPS-601, Step 3.2.11, stated: The fuel transfer canal is flooded to normal refueling level per 3-SFS-SOP-001, Spent Fuel Pool Cooling System, and borated to greater than or equal to 2700 ppm. The criterion for refueling cavity level was not correctly translated from the startup test specification into the test procedure. In response to the inspectors questions, the licensee responded the Unit 3 initial fuel loading was being planned to be conducted with the refueling cavity filled and that a note was being added to the next revision of 3-GEN-ITPS-601, prior to Step 3.2.11, noting that if the initial fuel loading is being performed with the reactor cavity dry, the fuel transfer canal should be flooded to just above the transfer tracks. From this response, the inspectors concluded the startup test specification was deficient since it did not provide an appropriate criterion (i.e.,

an initial condition in this case) for performing the test with the refueling cavity filled. The licensee entered this issue into its CAP as CR 50082530 and initiated ESR 50082534 requesting Westinghouse revise the startup test specification to provide criteria for performing the initial fuel loading with the refueling cavity filled.

2. APP-GW-T1-691, Section 2.4, GEN 601B Fuel Loading Instrumentation and Neutron Source Requirements, Note 5, Monitoring Instrumentation Recommendations, Step c stated: "Operability of all source range detectors is demonstrated through flashing each detector (passing a neutron source near the detector to verify detector and instrumentation circuit response) with a neutron source prior to beginning fuel loading. (A fuel assembly with a primary source can be used, but is not recommended [emphasis added]). Thus, operability of all permanent source range detectors is demonstrated for

40 compliance with TS 3.3.1 and 3.3.2 in other operating modes." This recommendation for demonstrating SR detector operability was not correctly translated from the startup test specification into the test procedure. 3-GEN-ITPS-601, Step 4.2 deviated from this recommendation by using the first two assemblies with primary sources installed to check detector responses. In response to the inspectors questions, the licensee entered this issue into its CAP as CR 50080913 and initiated ESR 50080908 requesting Westinghouse revise the test specification to clarify the use of a portable neutron source or fuel assembly with a primary source to check the ability of a source range detector to respond to neutrons.

Deficiencies identified with the licensees test procedure included:

1. APP-GW-T1-691, Section 2.6, GEN-601D Initial Fuel Loading, Precautions and Limitations Step 8d stated: "If there is indication of boron dilution by an unexplained increase in hot leg or refueling cavity water levels initiate emergency boration until the analyses RCS boron concentration is greater than COLR [Core Operating Limits Report] limit plus margin (e.g., 1662 to 1700 ppm was used for China). This criterion to initiate emergency boration from the startup test specification was not correctly translated into the test procedure. There was no criterion to initiate emergency boration in the startup test procedure.

2. APP-GW-T1-691, Section 2.6, GEN-601D Initial Fuel Loading, Precautions and Limitations Step 7f specified two criteria for changes in count rate during fuel loading that are applicable only after the initial nucleus 8 fuel assemblies have been loaded in front of a responding detector, the fuel assembly containing a primary source is in its final location, and the new reference count rate for inverse count rate ratio (ICRR) has been established. These conditions from the startup test specification were not correctly translated into Steps 2.1.8.h and 2.1.8.i of 3-GEN-ITPS-601.

3. APP-GW-T1-691, Section 2.4, GEN 601B Review Criterion 1 stated: "Equipment used for neutron monitoring during fuel loading is operating correctly and is responsive to changes in neutron flux levels as indicated by a minimum count rate of 0.2 counts per second, attributable to core neutrons, and indicated on at least two of the available pulse-type nuclear channels at all times following installation of the initial nucleus of fuel assemblies and during fuel loading, which provides meaningful inverse count-rate monitoring. Guidance: A minimum count rate is selected for monitoring core reactivity based on the minimum range for the nuclear instrumentation of 0.1 counts per second." The criterion for a minimum count rate of 0.2 counts per second from the startup test specification was not correctly translated into the test procedure. 3-GEN-ITPS-601, Step 4.3.6 stated: IF there is an insufficient count rate(i.e., < 0.1 counts/seconds), halt fuel movement until a resolution is reached.

The licensee entered these procedure discrepancies into its CAP as CRs 50086035, and 50082527 for evaluation and identification of appropriate corrective actions.

Analysis

41 The inspectors determined the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activity of initial fuel loading was contrary to the requirements of 10 CFR 50, Appendix B, Criterion III, Design Control, and was therefore a licensee performance deficiency warranting a significance evaluation. Per the guidance in IMC 0613, Power Reactor Construction Inspection Reports, Appendix B, Issue Screening, dated November 4, 2020, the inspectors determined traditional enforcement or enforcement discretion would not apply to this performance deficiency. Per further guidance in IMC 0613, Appendix E, "Examples of Minor Construction Issues," the inspectors determined this performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee had not correctly translated all of the test conditions from the test specification to the test procedure. Additionally, the inspectors found conflicting conditions for performing testing specified in the test specification and procedure, requiring changes to both. The inspectors also reviewed the Appendix E examples of minor issues and found one similar example of a "not minor if" performance deficiency. Example 7 was similar, in that the inspectors identified the test specifications and test procedures were inadequate because they did not correctly implement applicable technical requirements or conditions for conducting the tests. The inspectors determined this was a construction finding because it was not associated with a specific ITAAC.

The inspectors determined this finding was related to the Inspection/Testing attribute of the Construction Reactor Safety Cornerstone. This finding was not associated with a security program; it was not associated with an IMC 2504 operational/construction program; and it was not associated with a repetitive, NRC-identified omission of a program critical attribute. In accordance with IMC 2519, "Construction Significance Determination Process," Appendix A, "AP 1000 Construction Significance Determination Process," dated December 6, 2017, the inspectors determined this finding was associated with an SSC (i.e. reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure had not been implemented.

In accordance with IMC 0613, Appendix F, "Construction Cross-Cutting Areas and Aspects," the inspectors concluded this finding affected the cross-cutting area of human performance and the cross-cutting aspect of documentation. The proximate cause of the performance deficiency was primarily attributed to the failure to create accurate documentation. Revision 1 of the test procedure was archived without sufficient development and it was not adequately reviewed prior to approval. [H7]

Enforcement 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

42 Contrary to the above, on or before February 12, 2021, the licensee failed to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activity of initial fuel loading. Specifically, the licensee did not correctly translate all applicable test conditions from Westinghouse startup test specification SV3-GW-T1-691 into startup test procedure 3-GEN-ITPS-601. Additionally, there were conflicting conditions for performing testing specified in the test specification and test procedure, requiring changes to both. Because this violation was not repetitive or willful, was of very low safety significance, and was entered into the licensees corrective action program, it is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021002-07, Inadequate Startup Testing Procedures for Initial Fuel Loading). The licensee entered this finding into its CAP for evaluation and identification of appropriate corrective actions (CR 50086035). Inasmuch as the test specification and test procedure had not yet been used for the startup testing activity, there was no actual safety consequence.

4OA6 Meetings, Including Exit

.1 Exit Meeting.

On April 22, 2021, the inspectors presented the inspection results to Mr. G.

Chick, Vogtle 3&4 Executive Vice President, and other licensee and contractor staff members. Proprietary information was reviewed during the inspection period but was not included in the inspection report.

43 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensees and Contractor Personnel E. Riffle, ITP Director A. Nix, NI Manager T. Petrak, ITAAC Manager M. Hickox, Test Support Manager C. Alexander, Milestone Manager S. Boyle, Milestone Manager D. Pagan-Diaz, ITP Turnover. Manager J. Olsen, NI Supervisor S. Leighty, SNC Licensing Supervisor C. Castell, SNC Licensing Engineer N. Patel, SNC Licensing Engineer J. Cole, SNC Licensing Engineer J. Weathersby, SNC Licensing Engineer C. Main, ITAAC Project Manager D. Wade, ITAAC Project Manager B. Macioce, Principle Engineer Digital Testing R. McKay, ITP Test Engineer S. Turner, ITP Test Engineer G. Weaver, ITP Test Engineer R. Nicoletto, ITP Test Engineer W. Pipkins, ITP Test Engineer D. Melton, ITP Test Engineer R. Espara, ITP Test Engineer J. Clark, ITP Test Engineer K. Morgan, ITP Test Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description 05200025/2021002-01 NCV Open/Closed Failure to Correct NRC Identified Violation 05200025/2021002-02 NCV Open Failure to Use Worst Case Load Profile for IDS Battery Service Test 05200025/2021002-03 NCV Open/Closed Failure to Place IDSB Battery on Float for 72 hrs. After Being on Equalize Voltage 05200025/2021002-04 NCV Open/Closed Failure to Translate Design Requirements into IDS Test Procedure

44 05200025/2021002-05 NCV Open/Closed Failure to Control Design Calculation for Three Battery Cells Bypassed 05200025/2021002-06 NCV Open/Closed Inadequate Startup Testing Procedures for Establishing Initial Criticality 05200025/2021002-07 NCV Open/Closed Inadequate Startup Testing Procedures for Initial Fuel Loading LIST OF DOCUMENTS REVIEWED Section 1A01 Work Order 1109868, (ITAAC) Perform ITAAC PMS CIM Component Testing Using 3-RCS-OTS-10-001 (RCS), dated 6/1/2020 B-GEN-ITPCI-039-F118, RCS-PL-V001B COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F119, RCS-PL-V002A COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F120, RCS-PL-V002B COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F122, RCS-PL-V003B COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F158, RCS-PL-V012B COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F159, RCS-PL-V013A COMPONENT TEST, Rev. 3 B-GEN-ITPCI-039-F160, RCS-PL-V013B COMPONENT TEST, Rev. 3 Section 1A02 Work Order SV3-CCS-TOW-1241512, Perform ITAAC PMS CIM Component Retest CCS-PL-V200, dated 3/5/2021 Work Order 1109854, Perform ITAAC PMS CIM Component Testing CCS-PL-V200, CCS-PL-V207, and CCS-PL-V208, dated 1/27/2021 Work Order SV3-WLS-TOW-1109877, PMS CIM Component Test - WLS-V055-S1 & WLS-V067, dated 4/4/2021 Work Order SV3-RNS-TOW-1241549, PMS CIM Component Retest RNS-PL-V002A, dated 4/1/2021 Work Order SV3-RNS-TOW-1241550, PMS CIM Component Retest RNS-PL-V002B, dated 4/1/2021 B-GEN-ITPCI-039-F004, CCS-PL-V200 Component Test, Rev. 1.1 B-GEN-ITPCI-039-F005, CCS-PL-V207 Component Test, Rev. 2 B-GEN-ITPCI-039-F006, CCS-PL-V208 Component Test, Rev. 2 B-GEN-ITPCI-039-F245, WLS-PL-V067 Component Test, Rev. 1.0 B-GEN-ITPCI-039-F171, RNS-PL-V002A Component Test, Rev. 1.2 B-GEN-ITPCI-039-F172, RNS-PL-V002B Component Test, Rev. 1.2 Section 1A03 Work Order SV3-RNS-T0W-1241527, PMS CIM Component Retest PXS-PL-V002B, dated 3/28/2021 B-GEN-ITPCI-039-F071, PXS-PL-V002B-1 Component Test, Rev. 1.1 B-GEN-ITPCI-039-F072, PXS-PL-V002B-2 Component Test, Rev. 1.1 Section 1A04 APP-1261-M0-106, "Auxiliary Building HVAC Duct Penetrations Area 1 Roof Elevation," Rev. 1

45 APP-1261-M0X-106, "Auxiliary Building HVAC Duct Penetrations List Area 1 Roof Elevation,"

Rev. 1 APP-AB01-AB-010, "Blockouts and Barriers (Penetrations, Seals and Fire Stops) Details Sheet 10," Rev. 4 APP-AB01-AB-012, "Blockouts and Barriers (Penetrations, Seals and Fire Stops) Details Sheet 12," Rev. 0 APP-VXS-MD-511, "HVAC Layout VXS Supply Duct Annex Building Area 1 EL 135'-3"," Rev. 3 APP-VXS-MD-512, "HVAC Layout VXS Supply Duct Isometric Annex Building Area 1 EL 135'3"," Rev. 3 APP-VXS-MD-514, "HVAC Layout VXS Exh & Ret Duct Annex Building Area 1 EL 135'-3","

Rev. 3 APP-VAS-MD-500, "HVAC Layout VAS Supply Duct Isometric Annex Building Area 3 EL 135'-

3"," Rev. 1 APP-VAS-MD-532, "HVAC Layout VAS Supply Duct Isometric Annex Building Area 3 EL 135'-

3"," Rev. 1 APP-VBS-MD-620, "VBS Duct Layout Auxiliary Building EL 153'-0" Area 2," Rev. 4 SV0-MD03-GNR-000001, "The Direction of the Cross Bars for the AS21 Specialty Devices Installed in Fire Dampers," Rev. 0 SV4-1333-VFS-MD-840, "Auxiliary Building Area 4 EL. 145'-9" to 282'-8 3/4" VFS Duct Layout,"

Rev. 3E SV40MD-03-V6-850006, "Fire Damper Grating Assembly," Rev. 1 Engineering & Design Coordination Report No. APP-FSAR-GEF-061, "Addition of AS04 Specialty Device Detail to HVAC," Rev. 0 Engineering & Design Coordination Report No. APP-SES-GEF-031, "Updates to Barrier Matrix,"

Rev. 0 Engineering & Design Coordination Report No. APP-MD03-GEF-850014, "Addition of Security Bars due to APP-SES-GEF-031," Rev. 0 Engineering & Design Coordination Report No. APP-VBS-GEF-124, "UL-752 Level 4 Protection for VBS Main Control Room Penetrations," Rev. 0 APP-AS21-Z0D-101, "AS21 HVAC Data Sheet," Rev. 0 APP-AS21-A1-001, "AP1000 Security Barrier Design Requirements," Rev. 1 APP-GW-MD-103, "HVAC Details Sheet 1," Rev. 1 CR 50079248, "HVAC Penetration 12505-ML-H07 Supplied by the Vendor" Section 1P01 Procedures 3-GEN-ITPP-512, Chemical and Volume Control System Dynamic Effects and Vibration Testing, Ver. 1.0 3-GEN-ITPP-515, Steam Generator System Dynamic Effects and Vibration Testing, Ver. 1.0 3-GEN-ITPP-512, Chemical and Volume Control System Dynamic Effects and Vibration Testing, Ver. 1.0 3-GEN-ITPP-515, Steam Generator System Dynamic Effects and Vibration Testing, Ver. 1.0 B-GEN-ITPA-004, Conduct of Testing, Ver. 3.1 NMP-AP-001-003, Review and Approval of Site Procedures, Ver. 17.1 B-GEN-ITPA-011, Initial Test Program Administrative and Test Procedure Development, Ver.

3.0 B-GEN-ITPP-507, Thermal Expansion, Ver. 2 B-GEN-ITPP-509, Reactor Coolant System Dynamic Effects and Vibration Testing, Ver. 2 B-GEN-ITPP-510, Normal Residual Heat Removal System Dynamic Effects and Vibration Testing, Ver. 1

46 B-GEN-ITPP-511, Passive Core Cooling System Dynamic Effects and Vibration Testing, Ver.

1 B-GEN-ITPP-517, Precore Hot Functional Test Procedure, Ver. 3.0 NMP-AP-001-003, Review and Approval of Site Procedures, Ver. 15.1 NRC NUREG-1793, Final Safety Evaluation Report Related to Certification of the AP1000 Standard Plant Design NRC NUREG-2124, Final Safety Evaluation Report Related to the Combined Licenses for Vogtle Electric Generating Plant, Units 3 and 4 Vogtle Electric Generating Plant Unit 3 Combined Operating License, Appendix C, Inspections, Test, Analyses, and Acceptance Criteria Regulatory Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants, Rev. 3 Drawings APP-RNS-M6-001, Piping and Instrumentation Diagram Normal Residual Heat Rem. System, Rev. 13 APP-PXS-M6-001, Piping and Instrumentation Diagram Passive Core Cooling System, Rev. 13 APP-PXS-M6-002, Piping and Instrumentation Diagram Passive Core Cooling System, Rev.1 Miscellaneous ANSI/ASME OM Code-1995 and 1996 Addenda, Code for Operation and Maintenance of Nuclear Power Plants. Part 3 ASME OM Part 7 APP-PXS-M3-001, Passive Core Cooling System, System Specification Document, Rev. 10 APP-RNS-M3-001, Normal Residual Heat Removal System - System Specification Document, Rev. 7 APP-CVS-P2C-001, Chemical and Volume Control System (CVS) Vibration Monitoring Requirements, Rev. 0 WO SV3-RCS-T0W-1188608, Vacuum Breaker Component Test, 10/19/2020 SV3-PV18-VQQ-001, PV18 - Quality Release and Certificate of Conformance, Rev. 0 APP-PV18-Z0-001, Vacuum Breaker Valves, ASME Boiler and Pressure Vessel Code,Section III, Class 3, Rev. 5 APP-PV18-Z0R-001, Vacuum Breaker, Valve Specification Data Sheet Report, Rev. 2 Section 1P02 3-RNS-ITPP-501, Normal Residual Heat Removal System Preoperational Test Procedure rev 2.1 APP-RNS-M6-001, Piping and Instrumentation Diagram Normal Residual Heat Removal System Rev 13 APP-SFS-M6-001, Piping and Instrumentation Diagram Spent Fuel Pool Cooling System Rev 14 APP-SFS-M6-001-CRTT, Piping and Instrumentation Diagram Spent Fuel Pool Cooling System (Combined Release for Test) Rev 13 Work Order SV3-RNS-T0W-1071784, (ITAAC) Perform Preop Test 3-RNS-ITPP-501 Section 1P03 WO SV3-CCS-TOW-1109854, Perform ITAAC PMS CIM Component Test CCS-PL-V200 &

CCS-PL-V207 & CCS-PL-V208, Rev. 0 B-GEN-ITPCl-039-F004, CCS-PL-V200 Component Test, Ver. 1.0

47 26139-SV3-TOP-CCS*2, SV3-CCS*2 Component Cooling Water System I Containment, dated 7/3/2020 WO SV3-PXS-T0W-1109899, Perform ITAAC PMS CIM Component Testing Using 3-GEN-OTS-10-003 (PXS), Rev. 0 3-GEN-OTS-10-003, Division C Quarterly Valve Stroke Test, Ver. A=0.0 B-GEN-ITPCI-039-F074, PXS-PL-V014B-S1 Component Test, Ver. 1.0 WO SV3-RNS-TOW-1109884, PMS CIM Component Testing Using 3-GEN-OTS-I0-002 (RNS)

(ITAAC), Rev. 0 3-GEN-OTS-10-002, Division B Quarterly Valve Stroke Test, Ver. B=0.1 Section 1P04 SNC Procedures B-GEN-ITPA-001, ITP Administration and Organization, Ver. 7.2 B-GEN-ITPA-002, Joint Test Working Group (JTWG), Ver. 8.0 B-GEN-ITPA-003, Initial Test Program Personnel Qualification & Training, Ver. 5.2 B-GEN-ITPA-004, Conduct of Test, Ver. 20.0 B-GEN-ITPA-004-F05, Forced Computer Point Log, Ver. 3.0 B-GEN-ITPA-004-F06, Test Package Closure Page, Ver. 5.0 B-GEN-ITPA-004-F07, Lifted/Landed Lead and Jumper Data Sheet, Ver. 2.3 B-GEN-ITPA-004-F10, Measurement Uncertainty Worksheet, Ver. 4.0 B-GEN-ITPA-004-F11, Pre-Test Checklist, Ver. 6.0 B-GEN-ITPA-004-F12, Post Test Checklist, Ver. 3.0 B-GEN-ITPA-004-F16, Construction Work Authorization, Ver. 5.0 B-GEN-ITPA-004-F17, Construction Work Authorization Extension, Ver. 2.0 B-GEN-ITPA-004-F18, CIM Position Control Log, Ver. 1.0 B-GEN-ITPA-004-F19, Test Support Operating Steps (TSOS), Ver. 1.0 B-GEN-ITPA-007, Jurisdictional Control, Ver. 5.1 B-GEN-ITPA-009, ITP Configuration Control of Digital Information, Ver. 5.3 B-GEN-ITPA-010, Initial Test Program Temporary Modifications, Ver. 11.1 B-GEN-ITPA-010-F01, Temporary Modification Control Form, Ver. 6.2 B-GEN-ITPA-010-F05, TCC Tag List, Ver. 1.1 B-GEN-ITPA-010-F06, TMOD/COM Control Form, Ver. 1.1 B-GEN-ITPA-010-F07, TMOD/COM Log Index, Ver. 1.0 B-GEN-ITPA-011, Initial Test Program Administrative and Test Procedure Development, Ver.

9.0 B-GEN-ITPA-011-F01, ITP Procedure Approval Form, Ver. 5.0 B-GEN-ITPA-011-F02, Component and Preoperational Temporary Procedure Change Prior To 103G, Ver. 1.0 B-GEN-ITPA-014, Flushing and Initial Cleanness Verification, Ver. 4.2 B-GEN-ITPA-019-GL02, PMS CIM Operation Guidance, Ver. 1.0 700015, Procedure Writer/Reviewer Qualification Procedure, Ver. 5.0 26139-000-4MP-T81C-N1307, System and Equipment Safety Lockout/Tagout, Rev. 4 NMP-AD-006, Infrequently Performed Tests and Evolutions, Ver. 13.1 NMP-GM-006-002, Surveillance Program, Ver. 4.1 B-GEN-EIC-002, Software Quality Assurance, Ver. 1.0 Other 3-CVS-ITPP-501, Chemical and Volume Control System Preoperational Test Procedure, Ver

.5.0 NMP-AP-001-F08, Site Approval Form for 3-CVS-ITPP-501 v5.0, Ver. 6.0

48 B-GEN-ITPA-011-F01, ITP Procedure Approval Form for 3-CVS-ITPP-501 v5.0, Ver. 5.0 ND-LI-VNP-002-F01, Applicability Determination for VEGP Units 3&4 CVS-ITPP-501, Ver.

1.0 3-GEN-ITPS-629, Thermal Power Measurement and Statepoint Data Collection Startup Test Procedure, Ver. 2.0 NMP-AP-001-F08, Site Approval Form for 3-GEN-ITPS-629 v2.0, Ver. 6.0 B-GEN-ITPA-011-F01, ITP Procedure Approval Form for 3-GEN-ITPS-629 v2.0, Ver. 5.0 ND-LI-VNP-002-F01, Applicability Determination for VEGP Units 3&4 GEN-ITPS-629, Ver.

1.0 Southern Nuclear Qualification/Curriculum Review, dated 2/12/2021: Khiem Le (ND-ITP-Level II Test Engineer), Lance Keiser (ND-ITP-Level III Test Engineer), Ben Frey (ND-ITP-Level III Test Engineer), Steve Sheahan (ND-ITP-Level III Test Engineer), David Martano (ND-ITP-Level III Test Engineer), Henry Nix (ND-ITP-Level III Test Engineer)

B-GEN-ITPCE-024-V3.0-01, TPC for SEL Relay Commissioning, Ver. 3.0-1 B-GEN-ITA-004-F19, TSOS WO 1124408 3-IDSA Inverter, dated February 3, 2021 B-GEN-ITPA-010-F06, TMOD/COM Control Number SWS-2-1, dated 3/22/2020 CWA-3-21-0305, dated 2/7/2021 CWA-3-21-0102, dated 1/13/2021

3. OPERATIONAL READINESS Section 3T01 VOG3ILRT.20-R200711A, Preoperational Integrated Leakage Test Report, Rev. 0 SV3-CNS-ITR-800107, Unit 3 Recorded Results of Containment Integrated Leak Rate Test:

ITAAC 2.2.01.07.i, Rev. 2 Work Order 1221302, Conduct LLRTs in accordance with 3-CNS-ITPP-502 Attachment 6, dated 12/7/20 3-CNS-ITPP-501, Containment Integrated Leak Rate Test (Type A), dated 12/31/20 3-CNS-ITPP-502, Containment Penetration Leak Rate (Type B) Preoperational Test, dated 12/31/20 Corrective Action Documents CR 50061137, NRC identified Green Non-cited Violation associated with ILRT performance, dated 8/31/20 TE 60017782, Tracking TE for CAR 80003535, dated 12/8/20 CAR 80003535, NRC identified Green Non-cited Violation associated with ILRT performance, dated 8/31/20 Work Packages SV3-CNS-MLW-1124631, ASME III - REMOVE / REINSTALL 1/2" THREADED PLUG'S AT EPA E01, E02, E03, E06, E07, E09 AND E10 THRU E18 TO SUPPORT TESTING SV3-CNS-TH-8001A THRU SV3-CNS-TH-P8015A, Rev. 0 SV3-CNS-M LW -1124634, ASME III - REMOVE / REINSTALL 1/2" THREADED PLUG'S AT EPA E19 THRU E32 TO SUPPORT TESTING SV3-CNS-TH-P8016A THRU SV3-CNS-TH-8029A, Rev. 0 SV3-CNS-THW-1124462, ASME III - PERFORM PNEUMATIC TESTING FOR EPA RING MODIFICATIONS: SV3-CNS-TH-P8016A / P8017A / P8018A / P8019A / P8020A / P8021A /

P8022A / P8023A / P8024A / P8025A / P8026A / P8027A / P8028A / P8029A, Rev. 0 SV3-CNS-THW-1098472, ASME III - PERFORM PNEUMATIC TESTING FOR EPA RING MODIFICATIONS: SV3-CNS-TH-P8001A / P8002A / P8003A / P8004A / P8005A / P8006A

49

/ 8007A / P8008A / P8009A / P8010A / P8011A / P8012A / P8013A / P8014A / P8015A, Rev.

0 Section 3T02 B-GEN-ITPCM-017, Air-Operated Valve Test, version 5.1 ND-18-0666, "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 2.2.01.11b

[Index Number 118]"

SV3-CNS-ITR-802118, Unit 3 Test Results for SFS Containment Isolation Valves - Loss of Motive Power Testing: ITAAC 2.2.01.11 b, Rev. 0 SV3-CNS-ITR-800118, Unit 3 Test Results for CAS Containment Isolation Valve - Loss of Motive Power Testing: ITAAC 2.2.01 .11 b, Rev. 0 SV3-CCS-TOW-1043966, Air-Operated Valve Test for SV3-CAS-V014 SV3-CCS-TOW-1068448, MOV Static Diagnostic Testing for SV3-SFS-PL-V034 SV3-CCS-TOW-1061803, MOV Static Diagnostic Testing for SV3-SFS-PL-V035 SV3-CCS-TOW-1061806, MOV Static Diagnostic Testing for SV3-SFS-PL-V038 Section 3T03 CR 50076165 CR 50078235 CAR 80004604 SV3-DB01-Z0-001, Design Specification for Class 1E 250VDC Batteries and Racks, Rev. 9 SV3-DC01-Z0-001, Design Specification for Class 1E 250 VDC Battery Chargers for System IDS, Rev. 11 SV3-DU01-Z0-001, Design Specification for Class 1E Inverters, Static Transfer Switch, and Manual Bypass Switches for IDS system, Rev. 7 SV3-IDS-E0C-004 IDS Power Cable Sizing and Voltage Drop Analysis Rev. 6 SV3-DC01-VQQ-001, QA Data Package IDS DC01 Rev. 1 SV3-DU01-GCW-001, Field Change Notice for Class 1E IDS Inverter Bypass Frequency Tolerance Setting Rev. 0 SV3-DU01-GCW-003, Field Deviation Notice for Class 1E IDS Inverter Control Board (A070)

Modification Rev. 0 SV3-DU01-V0M-001, Vogtle Units 3&4 Class 1E Inverter Multipurpose Manuals Operating and Maintenance Instructions (DU01) Rev. 0 SV3-DU01-VQQ-001, QA Data Package for IDS DU01 Rev. 1 SV3-IDS-T1-503, Class 1E DC and Uninterruptible Power Supply System Preoperational Test Specification Rev. 0 WO 1124429, Perform Pre-Op Test 3-IDS-ITPP-501 Section 4.5.3, SPARE BATTERY CHARGER CAPACITY TEST FOR 3-IDSS-DC-1, dated 3/5/21 Section 3T04 B-GEN-ITPCI-039-F004 CCS-PL-V200 COMPONENT TEST, Rev. 2 B-GEN-ITPCI-039-F005 CCS-PL-V207 COMPONENT TEST, Rev. 2 B-GEN-ITPCI-039-F006 CCS-PL-V208 COMPONENT TEST, Rev. 2 Work Order 1109854, Perform ITAAC PMS CIM Component Testing CCS-PL-V200, CCS-PL-V207, and CCS-PL-V208, dated 1/27/2021 Section 3P01 Condition Reports CR 50062788, dated 9/15/2020, Testing of PXS-V122A/B and V124A/B

50 CR 50070256, dated 11/30/2020, No established process to verify QME-1-2007, section 7470 testing requirements, as required by UFSAR 3.10.1 CR 50075488, dated 01/22/2021, Snubber SV3-RCS-PH-11Y1140 Unsatisfactory Inspection CR 50075508, dated 01/22/2021, Snubber SV3-RCS-PH-11Y0813 Unsatisfactory Inspection CR 50075511, dated 01/22/2021, Snubber SV3-RCS-PH-11Y0082 Unsatisfactory Inspection CR 50075518, dated 01/22/2021, Snubber SV3-RCS-PH-11Y0067 Unsatisfactory Inspection CR 50075563, dated 01/22/2021, Snubber SV3-RCS-PH-11Y0060 Unsatisfactory Inspection CR 50075571, dated 01/22/2021, Snubber SV3-SGS-PH-11Y0001 Unsatisfactory Inspection CR 50075576, dated 01/22/2021, Snubber SV3-RCS-PH-11Y2017 Unsatisfactory Inspection CR 50075593, dated 01/22/2021, Snubber SV3-PXS-PH-11Y2052 Unsatisfactory Inspection CR 50078890, dated 02/17/2021, Incorrect Reference in SV0-PV01-Z0C-110, Revision 0 CR 50081208, dated 03/03/2021, NRC Inspection Recommendation regarding Equipment Reliability Program explicitly specifying RTNSS components CAR 80004207, dated 11/30/2020, No established process to verify QME-1-2007, section 7470 testing requirements, as required by UFSAR 3.10.1 NDE Reports Visual Examination Record for Snubber SV3-PXS-PH-11Y0020, 01/06/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0039, 01/14/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0081, 02/09/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0388, 02/05/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0528, 01/12/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y1130, 02/10/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y1134, 01/14/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y2005, 01/12/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y2264, 02/10/21 Visual Examination Record for Snubber SV3-RNS-PH-12Y2060, 01/06/21 Program Documents Licensing Document Change Request Package for LDCR-109-079, Version 1.0, dated 4/30/2020, Initial Inservice Testing Program Plan & associated FSAR changes Inservice Testing Program Plan - 1st Interval: Vogtle Electric Generating Plants Units 3&4, Ver.

1.0 ND-19-0747, Preservice Test Plan, Ver. 2.0 ND-20-0645, Preservice Test Plan, Ver. 3.0 ND-LI-013-47-09-15-2020, dated 9/18/2020, Technical Specification Requirements in accordance with the Inservice Testing Program Procedures 3-GEN-ENG-001, Preservice Testing Completion, Ver. 1.0 3-GEN-ITPP-509, Reactor Coolant System Dynamic Effects and Vibration Testing, Ver. 1.0 B-GEN-ENG-036, Snubber Preservice Examination and Testing, Ver. 1.0 NMP-ES-001, Equipment Reliability Process Description, Ver. 10.1 NMP-ES-005, Scoping and Importance Determination for Equipment Reliability, Ver. 18.0 NMP-ES-006, Preventive Maintenance Implementation and Continuing Equipment Reliability Improvement, Ver. 12.0 NMP-ES-013, Inservice Testing Program, Ver. 8.1 NMP-ES-013-003, IST Check Valve Monitoring Program Development and Maintenance, Ver.

6.0 NMP-ES-013-005, IST Implementation, Ver. 8.0 NMP-ES-013-006, IST Ten Year Interval Update, Ver. 2.1

51 NMP-ES-013-010, IST Relief Valve Program Development and Maintenance, Ver. 1.0 NMP-ES-013-GL01, IST Positions, Ver. 6.0 NMP-ES-027, Maintenance Rule Program, Ver. 10.3 QME Application Reports SV0-PV01-VPR-099002, Revision 0, dated 8/3/2020, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-099 SV0-PV01-VPR-131002, dated 7/31/2020, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-131 SV0-PV01-VPR-132002, dated 7/31/2020, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-132 Technical Evaluations TE 60017001, dated 9/15/2020, Test Procedure for PXS-V122A/B and V124A/B and IST Program Revision TE 60018407, dated 11/30/2020, Documentation required to tie ASME QME-1 required valves to the associated ITP work orders that verify QV-7470 compliance TE 60018408, dated 11/30/2020, ITP to identify QME-1, QV-7470 testing requirements for power-operated valves that are not AOVs or MOVs TE 60018410, dated 11/30/2020, Revise procedures NMP-ES-014-003 and NMP-ES-017 needed to address QME-1 requirements for AOVs and MOVs once plant is operational)

TE 60018411, dated 11/30/2020, Verify when developing the program for hydraulic and solenoid valves that QME-1 requirements are included TE 60018822, dated 11/30/2020, Revise NMP-MA-014 to address QME-1 requirements in post-maintenance testing Westinghouse Documents APP-GW-T1R-501, Revision 0, dated 4/8/2019, TEDEV Acceptance Criteria and Instrument Installations Locations Database for WEMMEX APP-PV01-VBR-011, Revision 2, Equipment Qualification Summary Report for Flowserve Flex Wedge Gate Valves with Limitorque Motor Operators for Use in the AP1000 Plant APP-PV01-VDR-000001, Revision 2, dated 6/7/2017, PV01 Motor Actuated Valves Actuator Sizing Calculations (including RAL-1097)

APP-PV01-VDR-000003, dated 3/2/2017, ADS 1, 2 3 Globe Valve Thermal Expansion Report APP-PV01-VDR-000004, dated 3/3/2017, ADS 1, 2, 3 Globe Valve Side Loading Report APP-PV01-VDR-000006, dated 11/7/2019, PV01 Globe Valve Clearance Analysis Report APP-PV01-VPR-010, dated 3/29/2017, Supplemental Functional Test Report for Piston Ring Configuration on a Flowserve Size 8 Figure BD2026(CF3M)JMTY with SMB-0-5 APP-PV01-Z0D-099, Revision 3, dated 5/8/2012, PV01 Datasheet 099 WCAP-18549, dated 7/2020, Minimum Required Thrust for Motor Operated Valves at Vogtle Units 3 and 4 Work Packages SV3-SFS-T0W-1061801, dated 4/25/2020, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V034 SV3-SFS-T0W-1061805, dated 4/25/2020, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V035 SV3-SFS-T0W-1061807, dated 4/25/2020, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V038

52 SV3-PXS-T0W-1100122, dated 5/27/2020, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V014A SV3-PXS-T0W-1100124, dated 4/14/2020, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V014B SV3-PXS-T0W-1100125, dated 4/17/2020, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V015A SV3-PXS-T0W-1100126, dated 4/17/2020, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V015B SV3-RNS-T0W-1100161, Dynamic Diagnostic Testing of AOV SV3-RNS-PL-V061, dated 4/22/2020 SV3-RCS-PHW-1018286, ASME III- Install Snubber SV3-RCS-PH-11Y0067 from ISO RCS-PLW-01L, Rev. 0 SV3-SGS-PHW-1030747, ASME III-Fabricate/Install Snubbers from Isometric SV3-SGS-PLW-020, Rev. 0 SV3-RCS-PHW-1096324, ASME III-Install Snubbers SV3-RCS-PH-11Y1140, SV3-RCS-PH-11Y1127 & SV3-RCS-PH-11Y1130, Rev. 0 Valve Calculations and Set Point Data Sheets SV0-PV01-M3C-110, dated 2/28/2020, Minimum Required Thrust for Valves Built to Datasheet APP-PV01-Z0D-110 Using EPRI PPMc, Rev. 0 SV0-PV01-T9-110, dated 9/10/2020, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-110, Rev. 1 SV0-PV01-T9-099, dated 12/6/2018, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-099, Rev. 0 SV0-PV01-Z0C-099, dated 9/22/2020, Valve Setup Calculation for Datasheet APP-PV01-Z0D-099 to Support Startup of Vogtle 3 and 4, Rev. 0 SV0-PV01-Z0C-110, dated 9/24/2020, Vale Setup Calculations for Datasheet APP-PV01-Z0D-110 to Support Startup of Vogtle 3 and 4, Rev. 0 Teledyne Documents TTS-CC-128, dated 6/26/2015, MOV Software BWROG DC Methodology Module Verification &

Validation Report [for incorporation into MIDAS Calculation Software] , Rev. 4 Section 3P02 Condition Reports CR 50062788, Testing of PXS-V122A/B and V124A/B, dated 9/15/2020 CR 50070256, No established process to verify QME-1-2007, section 7470 testing requirements, as required by UFSAR 3.10.1, dated 11/30/2020 CR 50075488, Snubber SV3-RCS-PH-11Y1140 Unsatisfactory Inspection, dated 01/22/2021 CR 50075508, Snubber SV3-RCS-PH-11Y0813 Unsatisfactory Inspection, dated 01/22/2021 CR 50075511, Snubber SV3-RCS-PH-11Y0082 Unsatisfactory Inspection, dated 01/22/2021 CR 50075518, Snubber SV3-RCS-PH-11Y0067 Unsatisfactory Inspection, dated 01/22/2021 CR 50075563, Snubber SV3-RCS-PH-11Y0060 Unsatisfactory Inspection, dated 01/22/2021 CR 50075571, Snubber SV3-SGS-PH-11Y0001 Unsatisfactory Inspection, dated 01/22/2021 CR 50075576, Snubber SV3-RCS-PH-11Y2017 Unsatisfactory Inspection, dated 01/22/2021 CR 50075593, Snubber SV3-PXS-PH-11Y2052 Unsatisfactory Inspection, dated 01/22/2021 CR 50078890, Incorrect Reference in SV0-PV01-Z0C-110, Rev. 0 CR 50081208, NRC Inspection Recommendation regarding Equipment Reliability Program explicitly specifying RTNSS components, dated 03/03/2021

53 CAR 80004207, No established process to verify QME-1-2007, section 7470 testing requirements, as required by UFSAR 3.10.1, dated 11/30/2020 NDE Reports Visual Examination Record for Snubber SV3-PXS-PH-11Y0020, 01/06/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0039, 01/14/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0081, 02/09/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0388, 02/05/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y0528, 01/12/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y1130, 02/10/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y1134, 01/14/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y2005, 01/12/21 Visual Examination Record for Snubber SV3-RCS-PH-11Y2264, 02/10/21 Visual Examination Record for Snubber SV3-RNS-PH-12Y2060, 01/06/21 Program Documents Licensing Document Change Request Package for LDCR-109-079, Ver. 1.0, dated 4/30/2020, Initial Inservice Testing Program Plan & associated FSAR changes Inservice Testing Program Plan - 1st Interval: Vogtle Electric Generating Plants Units 3&4, Ver.

1.0 ND-19-0747, Preservice Test Plan, Ver. 2.0 ND-20-0645, Preservice Test Plan, Ver. 3.0 ND-LI-013-47-09-15-2020, Technical Specification Requirements in accordance with the Inservice Testing Program, dated 9/18/2020 Procedures 3-GEN-ENG-001, Preservice Testing Completion, Ver. 1.0 3-GEN-ITPP-509, Reactor Coolant System Dynamic Effects and Vibration Testing, Ver. 1.0 B-GEN-ENG-036, Snubber Preservice Examination and Testing, Ver. 1.0 NMP-ES-001, Equipment Reliability Process Description, Ver. 10.1 NMP-ES-005, Scoping and Importance Determination for Equipment Reliability, Ver. 18.0 NMP-ES-006, Preventive Maintenance Implementation and Continuing Equipment Reliability Improvement, Ver. 12.0 NMP-ES-013, Inservice Testing Program, Ver. 8.1 NMP-ES-013-003, IST Check Valve Monitoring Program Development and Maintenance, Ver.

6.0 NMP-ES-013-005, IST Implementation, Ver. 8.0 NMP-ES-013-006, IST Ten Year Interval Update, Ver. 2.1 NMP-ES-013-010, IST Relief Valve Program Development and Maintenance, Ver. 1.0 NMP-ES-013-GL01, IST Positions, Ver. 6.0 NMP-ES-027, Maintenance Rule Program, Ver. 10.3 QME Application Reports SV0-PV01-VPR-099002, dated 8/3/2020, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-099, Rev. 0 SV0-PV01-VPR-131002, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-131, dated 7/31/2020 SV0-PV01-VPR-132002, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-132, dated 7/31/2020

54 Technical Evaluations TE 60017001, Test Procedure for PXS-V122A/B and V124A/B and IST Program, dated 9/15/2020 TE 60018407, Documentation required to tie ASME QME-1 required valves to the associated ITP work orders that verify QV-7470 compliance, dated 11/30/2020 TE 60018408, ITP to identify QME-1, QV-7470 testing requirements for power-operated valves that are not AOVs or MOVs, dated 11/30/2020 TE 60018410, Revise procedures NMP-ES-014-003 and NMP-ES-017 needed to address QME-1 requirements for AOVs and MOVs once plant is operational), dated 11/30/2020 TE 60018411, Verify when developing the program for hydraulic and solenoid valves that QME-1 requirements are included, dated 11/30/2020 TE 60018822, Revise NMP-MA-014 to address QME-1 requirements in post-maintenance testing, dated 11/30/2020 Westinghouse Documents APP-GW-T1R-501, dated 4/8/2019, TEDEV Acceptance Criteria and Instrument Installations Locations Database for WEMMEX, Rev. 0 APP-PV01-VBR-011, Equipment Qualification Summary Report for Flowserve Flex Wedge Gate Valves with Limitorque Motor Operators for Use in the AP1000 Plant, Rev. 2 APP-PV01-VDR-000001, dated 6/7/2017, PV01 Motor Actuated Valves Actuator Sizing Calculations (including RAL-1097), Rev. 2 APP-PV01-VDR-000003, ADS 1, 2 3 Globe Valve Thermal Expansion Report, dated 3/2/2017 APP-PV01-VDR-000004, ADS 1, 2, 3 Globe Valve Side Loading Report, dated 3/3/2017 APP-PV01-VDR-000006, PV01 Globe Valve Clearance Analysis Report, dated 11/7/2019 APP-PV01-VPR-010, Supplemental Functional Test Report for Piston Ring Configuration on a Flowserve Size 8 Figure BD2026(CF3M)JMTY with SMB-0-5, dated 3/29/2017 APP-PV01-Z0D-099, dated 5/8/2012, PV01 Datasheet 099, Rev. 3 WCAP-18549, Minimum Required Thrust for Motor Operated Valves at Vogtle Units 3 and 4, dated 7/2020 Work Packages SV3-SFS-T0W-1061801, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V034, dated 4/25/2020 SV3-SFS-T0W-1061805, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V035, dated 4/25/2020 SV3-SFS-T0W-1061807, Dynamic Diagnostic Testing of MOV SV3-SFS-PL-V038, dated 4/25/2020 SV3-PXS-T0W-1100122, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V014A, dated 5/27/2020 SV3-PXS-T0W-1100124, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V014B, dated 4/14/2020 SV3-PXS-T0W-1100125, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V015A, dated 4/17/2020 SV3-PXS-T0W-1100126, Dynamic Diagnostic Testing of AOV SV3-PXS-PL-V015B, dated 4/17/2020 SV3-RNS-T0W-1100161, Dynamic Diagnostic Testing of AOV SV3-RNS-PL-V061, , dated 4/22/2020 SV3-RCS-PHW-1018286, ASME III- Install Snubber SV3-RCS-PH-11Y0067 from ISO RCS-PLW-01L, Rev. 0

55 SV3-SGS-PHW-1030747, ASME III-Fabricate/Install Snubbers from Isometric SV3-SGS-PLW-020, Rev. 0 SV3-RCS-PHW-1096324, ASME III-Install Snubbers SV3-RCS-PH-11Y1140, SV3-RCS-PH-11Y1127 & SV3-RCS-PH-11Y1130, Rev. 0 Valve Calculations and Set Point Data Sheets SV0-PV01-M3C-110, dated 2/28/2020, Minimum Required Thrust for Valves Built to Datasheet APP-PV01-Z0D-110 Using EPRI PPMc, Rev. 0 SV0-PV01-T9-110, dated 9/10/2020, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-110, Rev. 1 SV0-PV01-T9-099, dated 12/6/2018, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-099, Rev. 0 SV0-PV01-Z0C-099, dated 9/22/2020, Valve Setup Calculation for Datasheet APP-PV01-Z0D-099 to Support Startup of Vogtle 3 and 4, Rev. 0 SV0-PV01-Z0C-110, dated 9/24/2020, Vale Setup Calculations for Datasheet APP-PV01-Z0D-110 to Support Startup of Vogtle 3 and 4, Rev. 0 Teledyne Documents TTS-CC-128, dated 6/26/2015, MOV Software BWROG DC Methodology Module Verification &

Validation Report [for incorporation into MIDAS Calculation Software], Rev. 4 Section 3P03 IP 35101 B-ADM-OPS-001, Operations Configuration Control, Version 8.0 B-ADM-OPS-012, Equipment Clearance and Tagging, Version 8.1 B-ADM-OPS-016, Plant Status and Configuration Control, Version 2.1 B-ADM-WCO-001-001, Operational Readiness Repetitive Task Management, Version 5.0 ND-EN-VNP-008, Preventive Maintenance Change Requests, Version 7.0 NMP-GM-006, Work Management, Version 18.1 NMP-GM-006-002, Surveillance Program, Version 4.1 IP42401 AOP-115, Loss of RHR, Version H 0.7 AOP-116, Loss of SFP Cooling, Version K 0.10 AOP-402, Malfunction of PMS, Version H 0.7 AOP-404, Instrument Failure PMS Division B, Version F 0.5 AOP-501, Loss of Main Control Room Air Conditioning, Version F 0.5 AOP-601, Evacuation of Main Control Room, Version J 0.9 AOP-602, DAS operations at Local Cabinets, Version G 0.6 AOP-704, Loss of Service Water, Version 1 AOP-904, Security Events, Version L 0.11 D-GEN-ADM-001, Verification and Validation, Version 7 NMP-007-003, Plant Operating Orders, Version 3 NMP-AD-012, Operability Determinations, Version 14 NMP-AP-001, Development and Control of Southern Nuclear Procedures, Version 21 NMP-AP-001-001, Review and Approval of Nuclear Management Procedures, Version 16 NMP-AP-001-003, Review and Approval of Site Procedures, Version 15.1 NMP-AP-001-F08, Review and Control of Southern Nuclear Procedures checklist, Version 21 NMP-AP-002, SNC Fleet Procedures Writers Guide, Version 9 NMP-EP-143, Facility Activation (EP), Version 5

56 NMP-GM-005-002, Human Performance Tools Instruction, Version 9.1 NMP-OS-007, Conduct of Operations, Version 16.1 NMP-OS-007-001, Conduct of Operations Standards and Expectations, Version 17 Condition Reports Initiated 50077366, 50077367, 50077368 IP 42453 3-GEN-OTS-17-002, 12 Hour Technical Specification Surveillance, Version C 0.2 3-GEN-OTS-17-003, 24 Hour Technical Specification Surveillance, Version D 0.3 3-GOP-101, Power Operations Above 25% Power, Version N 0.13 3-GOP-102, Draining the Reactor Coolant System (RCS), Version G 0.6 3-GOP-202, Plant Shutdown 25% Power To Mode 3, Version N 0.13 3-GOP-303, Plant Heatup Mode 5 to Normal Operating Temperature, Version P 0.15 3-IDSA-SOP-002, Class 1E AC System - Division A, Version B 0.1 3-PCS-SOP-001, Passive Containment Cooling System, Version F 0.5 3-PMS-OTS-16-002, Incore Detector Comparison to Nuclear Instrument Channel Axial Flux Difference, Version D 0.3 3-PMS-OTS-16-007, Calorimetric Heat Balance Comparison To Nuclear And Delta T Power, Version E 0.4 3-PMS-SOP-001, Protection And Safety Monitoring System, Version G 0.6 3-PXS-SOP-001, Passive Core Cooling System, Version I 0.8 D-GEN-ADM-001, Verification and Validation, Version 7 NMP-AP-001, Development and Control of Southern Nuclear Procedures, Version 21 NMP-AP-001-001, Review and Approval of Nuclear Management Procedures, Version 16 NMP-AP-001-003, Review and Approval of Site Procedures, Version 15.1 NMP-AP-002, SNC Fleet Procedures Writers Guide, Version 9 NMP-AP-002-GL01, SNC Fleet Procedures Writers' Guide Examples, Version 5.1 NMP-GM-005-002, Human Performance Tools Instruction, Version 9.1 NMP-GM-006-002, Surveillance Program, Version 4.1 NMP-OS-007, Conduct of Operations, Version 16.1 NMP-OS-007-001, Conduct of Operations Standards and Expectations, Version 17 NMP-OS-007-007, Rounds, Version 5 NMP-OS-007-008, Logkeeping, Version 1.1 Condition Reports Initiated 50075581 IP 42454 3-EOP-E-0, Reactor Trip or Safeguards Actuation, Version K 0.10 3-EOP-E-1, Loss of Reactor or Secondary Coolant, Version K 0.5 3-EOP-E-2, Faulted Steam Generator Isolation, Version K 0.5 3-EOP-E-3, Steam Generator Tube Rupture, Version K 0.10 3-EOP-ECA-1.1, LOCA Outside Containment, Version E 0.4 3-EOP-ES-0.1, Reactor Trip Response, Version I 0.8 3-EOP-ES-1.3, ADS Stage 1-3 Actuation Response, Version H 0.7 3-EOP-ES-1.4, ADS Stage 4 Actuation Response, Version G 0.6 3-EOP-F-0, Critical Safety Function Status Trees, Version I 0.8 3-EOP-FR-H.1, Response to Loss of Heat Sink, Version G 0.6 3-EOP-FR-H.3, Response to Steam Generator High Level, Version F 0.5 3-EOP-FR-P.1, Response to Imminent Pressurized Thermal Shock Conditions, Version E 0.4

57 3-EOP-FR-S.1, Response to Nuclear Power Generation - ATWS, Version F 0.5 3-EOP-FR-S.2, Response to Loss of Core Shutdown, Version E 0.4 3-EOP-FR-Z.1, Response to High Containment Pressure, Version E 0.4 3-EOP-SDP-4, Response to Rising Nuclear Flux During Shutdown, Version E 0.4 APP-GW-GJR-201, Background Information For E-0, Reactor Trip or Safeguards Actuation, Revision 11 APP-GW-GJR-202, Emergency Operating Procedure E-1, Loss of Reactor or Secondary Coolant, Revision 10 APP-GW-GJR-203, Background Information for E-2, Faulted Steam Generator Isolation, Revision 8 APP-GW-GJR-205, Background Information for ECA-1.1, LOCA Outside Containment, Revision 9

APP-GW-GJR-223, Background Information for FR-S.1, Response to Nuclear Power Generation ATWS, Revision 6 APP-GW-GJR-224, Background Information for FR-S.2, Response to Loss of Core Shutdown, Revision 4 APP-GW-GJR-225, Background Information for FR-Z.1, Response to High Containment Pressure, Revision 5 APP-GW-GJR-234, Background Information for SDP-4, Response to Rising Nuclear Flux During Shutdown, Revision 6 D-GEN-ADM-001, Verification and Validation, Version 7 NMP-AP-001, Development and Control of Southern Nuclear Procedures, Version 21 NMP-AP-001-003, Review and Approval of Site Procedures, Version 15.1 NMP-AP-002, SNC Fleet Procedures Writers Guide, Version 9 NMP-AP-002-002, SNC Fleet Two Column Procedures Writers Guide, Version 2 NMP-AP-004, Maintenance of Emergency Operating and Accident Procedures, Version 3 NMP-AP-005, Transient Response Guidelines, Version 2 VEGP 3&4 - UFSAR, Chapter 15 - Accident Analyses, Revision 6 IP 71303 3-IDSA-OTS-06-001, 7 Day Surveillance Test of Station Batteries, Version D 0.3 3-IDSB-OTS-06-001, 7 Day Surveillance Test of Station Batteries, Version C 0.2 3-IDSB-OTS-06-012, 7 Day Surveillance Test of Station Batteries, Version A 0.0 3-IDSC-OTS-06-001, 7 Day Surveillance Test of Station Batteries, Version C 0.2 3-IDSC-OTS-06-012, 7 Day Surveillance Test of Station Batteries, Version A 0.0 3-IDSD-OTS-06-001, 7 Day Surveillance Test of Station Batteries, Version C 0.2 3-PMS-OTS-16-007, Heat Balance Comparison to Nuclear and Delta T Power, Version E 0.4 3-PMS-OTS-17-001, PAM Instrumentation-Channel Check, Version B 0.1 3-RCS-OTS-16-005, Division B-RCS Hot Leg Level Calibration, Version B 0.1 3-RCS-OTS-16-006, Division C-RCS Hot Leg Level Calibration, Version B 0.1 3-IDS-OTS-20-001, Class 1E DC & AC Voltage & Switch Alignment Mode 1-4, Version B 0.1 3-GEN-OTS-17-002, 12 Hour Technical Specification Surveillance, Version C 0.2 3-GEN-OTS-17-003, 24 Hour Technical Specification Surveillance, Version D 0.3 3-RCS-OTS-17-004, RCS Boron Concentration During Refueling, Version A 0.0 Amendment 13, Tech Spec Upgrade, Table A, Administrative Changes (ML13239A288), and Table M, More Restrictive Changes (ML13239A319)

Amendment 138, Tech Spec Updates for Reactivity Controls & Misc Changes (ML18100A110)

Amendment 53, Core Makup Tank Volume (ML16216A304)

Amendment 65, RTS RCS Flow Signal Density Compensation (ML16348A073)

Amendment 72, PXS and Condensate Return (ML17024A317)

Amendment 81, IRWST Volume Changes (ML17171A137)

58 Amendment 135, Battery Charger Output Amp Value (ML18173A302)

B-ADM-PLMC-012, Periodic Analysis Scheduling Program, Version 0.5 B-GEN-PLMC-045, Chemistry Control of the Condensate Storage Tanks, Version 0.0 B-GEN-PLMC-064, Chemistry Control of the Condensate & FW System, Version 0.0 B-GEN-PLMC-067, Operation of the Secondary Sampling System, Version 0.2 B-GEN-PLMC-077, Chemistry Control of the Steam Generators, Version 0.0 B-GEN-ENG-034, Control Room Habitability Program, Version 1.0 ND-LI-VNP-002, Applicability Determination and 50.59/Departure Screening, Version 18.0 ND-LI-VNP-003, 50.59/Departure Evaluations, Version 8.0 ND-LI-VNP-007, Licensing Document Change Requests, Version 10.0 NMP-CH-008, PWR Secondary Water Chemistry Program, Version 3.1 NMP-CH-008-GL03, Vogtle Units 3-4 Secondary Water Chemistry Strategic Plan, Version 3.1 NMP-EN-001, Management of the Radioactive Effluent Release Reports and the ODCM, Version 8.1 NMP-OS-027, Recording Limiting Conditions for Operation, Version 2.0 LDCR-2018-094, Reactor Coolant System (RCS) Flow Coastdown (LAR-18-025), Version 1.0 LDCR-2019-061, Pressurizer Water Level Control and Pressurizer Pressure Control Systems Design Change, Version 1.0 LDCR-2019-095, ADS and CMT Design Parameters, Results Update of SBLOCA Analysis, Post-LOCA Long-Term Cooling Analysis, and Analyses of LOCA Events in Shutdown Modes, Version 1.0 LDCR-2019-138, Technical Requirements Manual Related Changes, Version 1.0 LDCR-2019-150, NL-1335 non-IST Program Updates LDCR-2020-040, CMT Boron Concentration Requirements (LAR-20-004), Version 1.0 LDCR-2020-046, TS Bases 3.5.4, Required Actions F.2 and F.2 Notes LDCR-2020-057, Main Control Room Emergency Habitability System Pressure Regulating Valve and Source Range Neutron Flux Doubling Surveillance Changes, and Other Miscellaneous Technical Specification Changes (LAR-20-002), Version 1 LDCR-2020-086, UFSAR Corrections Pertaining to Reg Guide 1.52 LDCR-2020-105, Containment Recirc DAS Manual Controls LDCR-2020-106, Trisodium Phosphate Density Change LDCR-2020-107, Conformance with RG 1.52, Regulatory Position C.3.7 Offsite Dose Calculation Manual, Revision 2.0, August 2020 Vogtle Unit 3 Cycle 1 Core Operating Limits Report (COLR), Version 3, December 2020 Condition Reports Initiated 50060599, 50066087/80004052 - TE 60017660, 50069143 - TE 60017510 Section 3P04 SNC Procedures B-GEN-ITPA-001, ITP Administration and Organization, Ver. 7.2 B-GEN-ITPA-002, Joint Test Working Group (JTWG), Ver. 8.0 B-GEN-ITPA-003, Initial Test Program Personnel Qualification & Training, Ver. 5.2 B-GEN-ITPA-004, Conduct of Test, Ver. 20.0 B-GEN-ITPA-004-F05, Forced Computer Point Log, Ver. 3.0 B-GEN-ITPA-004-F06, Test Package Closure Page, Ver. 5.0 B-GEN-ITPA-004-F07, Lifted/Landed Lead and Jumper Data Sheet, Ver. 2.3 B-GEN-ITPA-004-F10, Measurement Uncertainty Worksheet, Ver. 4.0 B-GEN-ITPA-004-F11, Pre-Test Checklist, Ver. 6.0 B-GEN-ITPA-004-F12, Post Test Checklist, Ver. 3.0

59 B-GEN-ITPA-004-F16, Construction Work Authorization, Ver. 5.0 B-GEN-ITPA-004-F17, Construction Work Authorization Extension, Ver. 2.0 B-GEN-ITPA-004-F18, CIM Position Control Log, Ver. 1.0 B-GEN-ITPA-004-F19, Test Support Operating Steps (TSOS), Ver. 1.0 B-GEN-ITPA-007, Jurisdictional Control, Ver. 5.1 B-GEN-ITPA-009, ITP Configuration Control of Digital Information, Ver. 5.3 B-GEN-ITPA-010, Initial Test Program Temporary Modifications, Ver. 11.1 B-GEN-ITPA-010-F01, Temporary Modification Control Form, Ver. 6.2 B-GEN-ITPA-010-F05, TCC Tag List, Ver. 1.1 B-GEN-ITPA-010-F06, TMOD/COM Control Form, Ver. 1.1 B-GEN-ITPA-010-F07, TMOD/COM Log Index, Ver. 1.0 B-GEN-ITPA-011, Initial Test Program Administrative and Test Procedure Development, Ver.

9.0 B-GEN-ITPA-011-F01, ITP Procedure Approval Form, Ver. 5.0 B-GEN-ITPA-011-F02, Component and Preoperational Temporary Procedure Change Prior To 103G, Ver. 1.0 B-GEN-ITPA-014, Flushing and Initial Cleanness Verification, Ver. 4.2 B-GEN-ITPA-019-GL02, PMS CIM Operation Guidance, Ver. 1.0 700015, Procedure Writer/Reviewer Qualification Procedure, Ver. 5.0 26139-000-4MP-T81C-N1307, System and Equipment Safety Lockout/Tagout, Rev. 4 NMP-AD-006, Infrequently Performed Tests and Evolutions, Ver. 13.1 NMP-GM-006-002, Surveillance Program, Ver. 4.1 B-GEN-EIC-002, Software Quality Assurance, Ver. 1.0 Other 3-CVS-ITPP-501, Chemical and Volume Control System Preoperational Test Procedure, Ver.

5.0 NMP-AP-001-F08, Site Approval Form for 3-CVS-ITPP-501 v5.0, Ver. 6.0 B-GEN-ITPA-011-F01, ITP Procedure Approval Form for 3-CVS-ITPP-501 v5.0, Ver. 5.0 ND-LI-VNP-002-F01, Applicability Determination for VEGP Units 3&4 CVS-ITPP-501, Ver.

1.0 3-GEN-ITPS-629, Thermal Power Measurement and Statepoint Data Collection Startup Test Procedure, Ver. 2.0 NMP-AP-001-F08, Site Approval Form for 3-GEN-ITPS-629 v2.0, Ver. 6.0 B-GEN-ITPA-011-F01, ITP Procedure Approval Form for 3-GEN-ITPS-629 v2.0, Ver. 5.0 ND-LI-VNP-002-F01, Applicability Determination for VEGP Units 3&4 GEN-ITPS-629, Ver.

1.0 Southern Nuclear Qualification/Curriculum Review, dated 2/12/2021: Khiem Le (ND-ITP-Level II Test Engineer), Lance Keiser (ND-ITP-Level III Test Engineer), Ben Frey (ND-ITP-Level III Test Engineer), Steve Sheahan (ND-ITP-Level III Test Engineer), David Martano (ND-ITP-Level III Test Engineer), Henry Nix (ND-ITP-Level III Test Engineer)

B-GEN-ITPCE-024-V3.0-01, TPC for SEL Relay Commissioning, Ver. 3.0-1 B-GEN-ITA-004-F19, TSOS WO 1124408 3-IDSA Inverter, dated February 3, 2021 B-GEN-ITPA-010-F06, TMOD/COM Control Number SWS-2-1, dated 3/22/2020 CWA-3-21-0305, dated 2/7/2021 CWA-3-21-0102, dated 1/13/2021 Section 4OA1 3-GEN-ITPS-610, Initial Criticality and LPPT Sequence Startup Test Procedure, Ver. 1 3-GEN-ITPS-611, Initial Criticality and Low Power Physics Test Startup Test Procedure, Ver. 2

60 3-GEN-ITPS-633, 100% Load Rejection Startup Test Procedure, Ver. 2 3-GEN-ITPS-638, Loss of Offsite Power Startup Test Procedure, Ver. 1.1 3-GEN-ITPS-636, Plant Trip from 100% Power Startup Procedure, Ver. 1 3-GEN-ITPS-640, Remote Shutdown Workstation Startup Test Procedure, Ver. 1 3-GEN-ITPS-601, Initial Fuel Loading Startup Test Procedure, Ver. 1.0 3-GOP-302, Reactor Startup Mode 3 To Mode 2, Ver. K=0.10 Vogtle 3 Technical Specifications, Amendment No. 186 Vogtle Electric Generating Plant (VEGP) Updated Final Safety Analysis Report (UFSAR), Rev.

9.1 SV3-GW-T1-693, AP1000 Startup Test Specifications for Initial Criticality Tests, Rev. 1 SV3-GW-T1-694, AP1000 Startup Test Specifications for Low Power Tests, Rev. 1 B-GEN-RES-004, Low Power Physics Testing, Ver. 4.0 B-GEN-REP-001, Physics Testing Equipment Checkout, Ver. 1.0 B-GEN-REP-006, MTC Boron Concentration Limits, Ver. 1.0 SV3-GW-F1-001, Core Operating Limits Report (COLR) for the Vogtle Electric Generating Plant, Unit 3 Cycle 1, Rev. 2, December 2020 CR 50085903, 3-GOP-302 Enhancement for Consistency on RCS Tavg Band CR 50085995, Requesting Evaluation of Stabilizing Power Plateau in 3-PMS-ITPS-603 CR 50076122, 3-GOP-302 and B-GEN-RES-004 Conflict on Startup Criteria CR 50078446, Temperature Band Difference Between3-GEN-ITPS-610 and APP-GW-T1-693 CR 50081927, 3-GOP-302 (Reactor Startup Mode 3 to Mode 2) Enhancement CR 50086434, NCV Green Violation - Failure to Translate Test Criteria Inconsistencies APP-GW-T1-691, AP1000 Startup Test Specifications for Initial Fuel Loading, Rev. 1 SV3-GW-F1-001, Core Operating Limits Report (COLR) for the Vogtle Electric Generating Plant, Unit 3 Cycle 1, Rev. 2, December 2020 Vogtle 3 Technical Specifications, Rev. 9.1 Vogtle Electric Generating Plant (VEGP) Updated Final Safety Analysis Report (UFSAR), Rev.

9.1 NMP-RE-007, Core Verification, Ver. 5.0 B-RFL-FHP-031, Fuel Handling Control Procedure, Ver. C=0.2 CR 50086035, NRC Violation - Start-up Test Procedure 3-GEN-ITPS-601 CR 50082527, NRC Review Comments on 3-GEN-ITPS-601 3-PLS-ITPS-605, Rapid Power Reduction Startup Test Procedure Rev. 1.0 3-PLS-ITPS-606, Post Fuel Load Precritical Test Sequence Startup Test Procedure APP-PLS-J1-034, Rapid Power Reduction Logic - Rod Control System Functional Requirements, Rev. 5 APP-GW-GM-100, AP1000 NSSS Control System Setpoint Study Summary Report - Standard Plant Units, Rev. 3 APP-GW-T1-692, AP1000 Startup Test Specifications For Precritical Tests, Rev. 1

61 LIST OF ACRONYMS 10 CFR 50 Title 10 of the Code of Federal Regulations, Part 50 CAP corrective action program CAR corrective action report COL Combined License CR condition report DC direct current DCD Design Control Document EOP emergency operating procedure IDS Class 1E DC and UPS system IP inspection procedure IST inservice testing LDCR licensing document change request MOV motor operated valve NCV noncited violation NEMA National Electrical Manufacturers Association NRC Nuclear Regulatory Commission PM preventive maintenance PST preservice testing RTNSS Regulatory Treatment of Non-Safety Systems SNC Southern Nuclear Operating Company SSC structures, systems, and components TS Technical Specifications UFSAR Updated Final Safety Analysis Report UPS uninterruptable power supply V volt VBS ventilation system VEGP Vogtle Electric Generating Plant

62 ITAAC INSPECTED No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 47 2.1.02.11a.ii 10. Safety-related Inspection will be Safety-related displays identified in performed for displays identified in Table 2.1.2-1 can be retrievability of the Table 2.1.2-1 can be retrieved in the MCR. safety-related displays retrieved in the MCR.

11.a) Controls exist in in the MCR. ii) Stroke ii) Controls in the the MCR to cause the testing will be MCR operate to remotely operated performed on the other cause the remotely valves identified in remotely operated operated valves Table 2.1.2-1 to valves listed in Table (other than squib perform active 2.1.2-1 using controls valves) to perform functions. 11.b) The in the MCR. ii) Testing active functions. ii) valves identified in will be performed on The other remotely Table 2.1.2-1 as the other remotely operated valves having PMS control operated valves identified in Table perform an active identified in Table 2.1.2-1 as having safety function after 2.1.2-1 using real or PMS control perform receiving a signal from simulated signals into the active function the PMS. 12.b) After the PMS. iii) Testing identified in the table loss of motive power, will be performed to after receiving a the remotely operated demonstrate that signal from PMS. iii) valves identified in remotely operated RCS These valves open Table 2.1.2-1 assume valves RCSV001A/B, within the following the indicated loss of V002A/B, V003A/B, times after receipt of motive power position. V011A/B, V012A/B, an actuation signal:

V013A/B open within V001A/B < 40 sec the required response V002A/B, V003A/B <

times. Testing of the 100 sec V011A/B <

remotely operated 30 sec V012A/B, valves will be V013A/B < 60 sec performed under the Upon loss of motive conditions of loss of power, each motive power. remotely operated valve identified in Table 2.1.2-1 assumes the indicated loss of motive power position.

63 No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 107 2.2.01.07.i 7. The CNS provides i) A containment i) The leakage rate the safety-related integrated leak rate test from containment for function of will be performed. the integrated leak containment isolation rate test is less than for containment La.

boundary integrity and provides a barrier against the release of fission products to the atmosphere.

110 2.2.01.09 9. Safety-related Inspection will be Safety-related displays identified in performed for displays identified in Table 2.2.1-1 can be retrievability of the Table 2.2.1-1 can be retrieved in the MCR. safety-related displays retrieved in the MCR.

10.a) Controls exist in in the MCR. Stroke Controls in the MCR the MCR to cause testing will be operate to cause those remotely performed on remotely remotely operated operated valves operated valves valves identified in identified in Table identified in Table Table 2.2.1-1 to 2.2.1-1 to perform 2.2.1-1 using the perform active safety active functions. 10.b) controls in the MCR. functions. The The valves identified in Testing will be remotely operated Table 2.2.1-1 as performed on remotely valves identified in having PMS control operated valves listed Table 2.2.1-1 as perform an active in Table 2.2.1-1 using having PMS control safety function after real or simulated perform the active receiving a signal from signals into the PMS. function identified in the PMS. the table after receiving a signal from PMS.

116 2.2.01.11a.iii 11.a) The motor- iii) Tests of the motor- iii) Each motor-operated and check operated valves will be operated valve valves identified in performed under changes position as Table 2.2.1-1 perform preoperational flow, indicated in Table an active safety- differential pressure, 2.2.1-1 under pre-related function to and temperature operational test change position as conditions. conditions.

indicated in the table.

118 2.2.01.11b 11.b) After loss of Testing of the remotely After loss of motive motive power, the operated valves will be power, each remotely operated performed under the remotely operated valves identified in conditions of loss of valve identified in Table 2.2.1-1 assume motive power. Table 2.2.1-1 the indicated loss of assumes the motive power position. indicated loss of motive power position.

64 No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 206 2.2.03.10 10. Safety-related Inspection will be Safety-related displays of the performed for the displays identified in parameters identified retrievability of the Table 2.2.3-1 can be in Table 2.2.31 can safety-related displays retrieved in the MCR.

be retrieved in the in the MCR. ii) Stroke ii) Controls in the MCR. 11.a) Controls testing will be MCR operate to exist in the MCR to performed on remotely cause remotely cause the remotely operated valves other operated valves operated valves than squib valves other than squib identified in Table identified in Table valves to perform 2.2.3-1 to perform their 2.2.3-1 using the their active functions.

active function(s). controls in the MCR. ii) ii) Remotely 11.b) The valves Testing will be operated valves identified in Table performed on the other than squib 2.2.3-1 as having PMS remotely operated valves perform the control perform their valves other than squib active function active function after valves identified in identified in the table receiving a signal from Table 2.2.3-1 using after a signal is input the PMS. 12.b) After real or simulated to the PMS. iii) loss of motive power, signals into the PMS. These valves open the remotely operated iii) Testing will be within 20 seconds valves identified in performed to after receipt of an Table 2.2.3-1 assume demonstrate that actuation signal.

the indicated loss of remotely operated PXS After loss of motive motive power position. isolation valves PXS- power, each

13. Displays of the V014A/B, V015A/B, remotely operated parameters identified V108A/B open within valve identified in in Table 2.2.3-3 can the required response Table 2.2.3-1 be retrieved in the times. Testing of the assumes the MCR. remotely operated indicated loss of valves will be motive power performed under the position. Displays conditions of loss of identified in Table motive power. 2.2.3-3 can be Inspection will be retrieved in the MCR.

performed for retrievability of the displays identified in Table 2.2.3-3 in the MCR.

65 No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 379 2.3.06.09c Not used per Not used per Not used per Amendment No. 113 Amendment No. 113 Amendment No. 113 9.c) The RNS Testing will be Each RNS pump provides low pressure performed to confirm provides at least makeup flow from the that the RNS can 1100 gpm net flow to cask loading pit to the provide low pressure the RCS when the RCS for scenarios makeup flow from the water level above the following actuation of cask loading pit to the bottom of the cask the ADS. RCS when the pump loading pit is 1 foot +/-

suction is aligned to the 6 inches.

cask loading pit and the discharge is aligned to both PXS DVI lines with RCS at atmospheric pressure.

66 603 2.6.03.04c 4.c) Each IDS 24-hour Testing of each 24- The battery terminal battery bank supplies hour asbuilt battery voltage is greater a dc switchboard bus bank will be performed than or equal to 210 load for a period of 24 by applying a simulated V after a period of no hours without or real load, or a less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months recharging. 4.d) Each combination of with an equivalent IDS 72-hour battery simulated or real loads load that equals or bank supplies a dc which envelope the exceeds the battery switchboard bus load battery bank design bank design duty for a period of 72 duty cycle. The test cycle capacity. The hours without will be conducted on a battery terminal recharging. 4.e) The battery bank that has voltage is greater IDS spare battery been fully charged and than or equal to 210 bank supplies a dc has been connected to V after a period of no load equal to or a battery charger less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months greater than the most maintained at 270+/-2 V with an equivalent severe switchboard for a period of no less load that equals or bus load for the than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to exceeds the battery required period the test. Testing of bank design duty without recharging. each 72-hour as-built cycle capacity. The 4.f) Each IDS 24-hour battery bank will be battery terminal inverter supplies its ac performed by applying voltage is greater load. 4.g) Each IDS a simulated or real than or equal to 210 72-hour inverter load, or a combination V after a period with supplies its ac load. of simulated or real a load and duration 4.h) Each IDS 24-hour loads which envelope that equals or battery charger the battery bank design exceeds the most provides the PMS with duty cycle. The test will severe battery bank two loss-of-ac input be conducted on a design duty cycle voltage signals. 5.a) battery bank that has capacity. Each 24-Each IDS 24-hour been fully charged and hour inverter battery charger has been connected to supplies a line-to-line supplies a dc a battery charger output voltage of 208 switchboard bus load maintained at 270+/-2 V +/- 2% V at a while maintaining the for a period of no less frequency of 60 +/-

corresponding battery than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to 0.5% Hz. Each 72-charged. 5.b) Each the test. Testing of the hour inverter IDS 72-hour battery as-built spare battery supplies a line-to-line charger supplies a dc bank will be performed output voltage of 208 switchboard bus load by applying a simulated +/- 2% V at a while maintaining the or real load, or a frequency of 60 +/-

corresponding battery combination of 0.5% Hz. Two PMS charged. 5.c) Each simulated or real loads input signals exist IDS regulating which envelope the from each 24-hour transformer supplies most severe of the battery charger an ac load when division batteries indicating loss of ac powered from the 480 design duty cycle. The input voltage when V MCC. 6. Safety- test will be conducted the loss-of-input related displays on a battery bank that voltage condition is identified in Table has been fully charged simulated. Each 24-

67 2.6.3-1 can be and has been hour battery charger retrieved in the MCR. connected to a battery provides an output

11. Displays of the charger maintained at current of at least parameters identified 270+/-2 V for a period of 150 A with an output in Table 2.6.3-2 can no less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months voltage in the range be retrieved in the prior to the test. 210 to 280 V. Each MCR. Testing of each 24- 72-hour battery hour as-built inverter charger provides an will be performed by output current of at applying a simulated or least 125 A with an real load, or a output voltage in the combination of range 210 to 280 V.

simulated or real loads, Each regulating equivalent to a resistive transformer supplies load greater than 12 a line-to-line output kW. The inverter input voltage of 208 +/- 2%

voltage will be no more V. Safety-related than 210 Vdc during displays identified in the test. Testing of Table 2.6.3-1 can be each 72-hour as-built retrieved in the MCR.

inverter will be Displays identified in performed by applying Table 2.6.3-2 can be a simulated or real retrieved in the MCR.

load, or a combination of simulated or real loads, equivalent to a resistive load greater than 7 kW. The inverter input voltage will be no more than 210 Vdc during the test. Testing will be performed by simulating a loss of input voltage to each 24-hour battery charger. Testing of each as-built 24-hour battery charger will be performed by applying a simulated or real load, or a combination of simulated or real loads. Testing of each 72-hour as-built battery charger will be performed by applying a simulated or real load, or a combination of simulated or real loads. Testing of each

68 No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis as-built regulating transformer will be performed by applying a simulated or real load, or a combination of simulated or real loads, equivalent to a resistive load greater than 30 kW when powered from the 480 V MCC. Inspection will be performed for retrievability of the safety-related displays in the MCR. Inspection will be performed for retrievability of the displays identified in Table 2.6.3-2 in the MCR.

668 C.2.6.09.08a 8.a) Penetrations Inspections will be Penetrations and through the protected performed of openings through the area barrier are penetrations through protected area secured and the protected area barrier are secured monitored. 8.b) barrier. Inspections will and monitored.

Unattended openings be performed of Unattended openings (such as underground unattended openings (such as pathways) that that intersect the underground intersect the protected protected area pathways) that area boundary or vital boundary or vital area intersect the area boundary will be boundary. protected area protected by a boundary or vital physical barrier and area boundary are monitored by intrusion protected by a detection equipment physical barrier and or provided monitored by surveillance at a intrusion detection frequency sufficient to equipment or detect exploitation. provided surveillance at a frequency sufficient to detect exploitation.

ML21133A105

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ML21133A105

Text

SUBJECT:

Dear Mr. Yox:

Enclosure:

SUBJECT:

SUMMARY

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