ND-23-0316, ITAAC Closure Notification on Completion of ITAAC 3.2.00.01e (Index Number 744)

ITAAC Closure Notification on Completion of ITAAC 3.2.00.01e (Index Number 744)

ML23117A343
Person / Time
Site:	Vogtle
Issue date:	04/27/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0316
Download: ML23117A343 (1)

Text

Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel April 27, 2023 Docket No.:

52-026 ND-23-0316 10 CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 4 ITAAC Closure Notification on Completion of ITAAC 3.2.00.01e [Index Number 744]

Ladies and Gentlemen:

In accordance with 10 CFR 52.99(c)(1), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) of the completion of Vogtle Electric Generating Plant (VEGP) Unit 4 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 3.2.00.01e [Index Number 744]. This ITAAC confirms that a report exists and concludes that implementation of the plant Human Factors Engineering/Human System Interface (as designed at the time of plant startup) verification was performed in accordance with the Human Factors Engineering verification and validation implementation plan. The closure process for this ITAAC is based on the guidance described in Nuclear Energy Institute (NEI) 08-01, Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52, which was endorsed by the NRC in Regulatory Guide 1.215.

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

If there are any questions, please contact Kelli Roberts at 706-848-6991.

Respectfully submitted, Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 3.2.00.01e [Index Number 744]

JMC/PCM/sfr

U.S. Nuclear Regulatory Commission ND-23-0316 Page 2 of 2 cc:

Regional Administrator, Region ll Director, Office of Nuclear Reactor Regulation (NRR)

Director, Vogtle Project Office NRR Senior Resident Inspector - Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-23-0316 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-23-0316 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 3.2.00.01e [Index Number 744]

U.S. Nuclear Regulatory Commission ND-23-0316 Enclosure Page 2 of 3 ITAAC Statement Design Commitment

1. The HFE verification and validation program is performed in accordance with the HFE verification and validation implementation plan and includes the following activities:

e) Plant HFE/HSI (as designed at the time of plant startup) verification Inspections/Tests/Analyses e) An evaluation of the implementation of the plant HFE/HSI (as designed at the time of plant startup) verification will be performed.

Acceptance Criteria e) A report exists and concludes that: The plant HFE/HSI, as designed at the time of plant startup, is consistent with the HFE/HSI verified in 1.a) through 1.d).

ITAAC Determination Basis Multiple ITAAC are performed to verify that the Human Factors Engineering (HFE) verification and validation program, as described in VEGP 3&4 Updated Final Safety Analysis Report, Section 18.11, Human Factors Engineering Verification and Validation (Reference 1), is performed in accordance with the HFE verification and validation implementation plan. The subject ITAAC requires that an evaluation of the implementation of the plant HFE/Human System Interface (HFE/HSI) (as designed at the time of plant startup) verification be performed which concludes that the plant HFE/HSI, as designed at the time of plant startup, is consistent with the HFE/HSI verified in 1.a) through 1.d) (ITAAC 3.2.00.01a through 3.2.00.01d, References 2-6).

An evaluation was performed in accordance with the AP1000 Plant Startup Human Factors Engineering Design Verification Plan (Reference 7), to demonstrate that the plant HFE/HSI design at the time of plant startup conforms to the human factors principles and guidance as specified in APP-OCS-GBH-001 "AP1000 Human Factors Engineering Program Plan" (Reference 8). The results of the evaluation are documented in the AP1000 Plant Startup Human Factors Engineering Design Verification Report (Reference 9). An evaluation (Reference 10) was performed to confirm that there are no substantial design changes between Unit 3 and Unit 4 and no new significant human factor discrepancies to consider since the issuance of Reference 9.

The AP1000 Plant Startup Human Factors Engineering Design Verification Report exists and concludes that the plant HFE/HSI, as designed at the time of plant startup, is consistent with the HFE/HSI verified in 1.a) through 1.d), (ITAAC 3.2.00.01a through 3.2.00.01d, References 2-6).

References 1 through 10 are available for NRC inspection as part of the ITAAC 3.2.00.01e Completion Package (Reference 11).

ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there were no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 3.2.00.01e (Reference 11) and is available for NRC review.

U.S. Nuclear Regulatory Commission ND-23-0316 Enclosure Page 3 of 3 ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 3.2.00.01e was performed for VEGP Unit 4 and that the prescribed acceptance criteria was met.

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

References (available for NRC inspection)

1. VEGP 3&4 Updated Final Safety Analysis Report, Section 18.11, Human Factors Engineering Verification and Validation, Revision 11.2

2. ND-17-1107, Resubmittal of ITAAC Closure Notification on Completion of ITAAC 3.2.00.01a

[Index Number 739], July 24, 2017, [ML17205A305]

3. ND-17-1108, Resubmittal of ITAAC Closure Notification on Completion of ITAAC 3.2.00.01b

[Index Number 740], July 24, 2017, [ML17205A293]

4. ND-16-2243, ITAAC Closure Notification on Completion of ITAAC 3.2.00.01c.i

[Index Number 741], November 23, 2016, [ML16350A110]

5. ND-18-0830, ITAAC Closure Notification on Completion of ITAAC 3.2.00.01c.ii

[Index Number 742], June 27, 2018, [ML18179A072]

6. ND-18-0831, ITAAC Closure Notification on Completion of ITAAC 3.2.00.01d

[Index Number 743], June 28, 2018, [ML18180A103]

7. APP-OCS-GEH-520, AP1000 Plant Startup Human Factors Engineering Design Verification Plan, Revision 4

8. APP-OCS-GBH-001, AP1000 Human Factors Engineering Program Plan, Revision 2

9. APP-OCS-GER-520, AP1000 Plant Startup Human Factors Engineering Design Verification Report, Revision 0

10. LTR-GIC-WAPP-23-008, Evaluation of Vogtle Unit 3 & 4 Differences for Supporting Unit 4 ITAAC 744 Closure

11. 3.2.00.01e-U4-CP-Rev0, ITAAC Completion Package