ND-23-0116, ITAAC Closure Notification on Completion of ITAAC C.2.6.09.03b (Index Number 661)

ITAAC Closure Notification on Completion of ITAAC C.2.6.09.03b (Index Number 661)

ML23180A273
Person / Time
Site:	Vogtle
Issue date:	06/29/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0116
Download: ML23180A273 (1)

Text

Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel June 29, 2023 Docket No.: 52-026 ND-23-0116 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 C.2.6.09.03b [Index Number 661]

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 C.2.6.09.03b [Index Number 661]. This ITAAC confirms that the protected area perimeter barrier isolation zones are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons and which cause concurrent alarms in both the Central Alarm Station and Secondary Alarm Station. This ITAAC also confirms that the intrusion detection and assessment equipment at the protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power. 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 C.2.6.09.03b [Index Number 661]

JMC/CIP/sfr

U.S. Nuclear Regulatory Commission ND-23-0116 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-23-0116 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-23-0116 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC C.2.6.09.03b [Index Number 661]

U.S. Nuclear Regulatory Commission ND-23-0116 Enclosure Page 2 of 4 ITAAC Statement Design Commitment 3.b) The isolation zones are monitored with intrusion detection equipment that provides the capability to detect and assess unauthorized persons.

4. The intrusion detection and assessment equipment at the protected area perimeter:

a) detects penetration or attempted penetration of the protected area barrier and concurrently alarms in both the Central Alarm Station and Secondary Alarm Station; b) remains operable from an uninterruptible power supply in the event of the loss of normal power.

Inspections/Tests/Analyses Inspections will be performed of the intrusion detection equipment within the isolation zones.

Tests, inspections or a combination of tests and inspections of the intrusion detection and assessment equipment at the protected area perimeter and its uninterruptible power supply will be performed.

Tests, inspections or a combination of tests and inspections of the intrusion detection and assessment equipment at the protected area perimeter and its uninterruptible power supply will be performed.

Acceptance Criteria The isolation zones are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons.

The intrusion detection and assessment equipment at the protected area perimeter:

a) detects penetration or attempted penetration of the protected area barrier and concurrently alarms in the Central Alarm Station and Secondary Alarm Station; b) remains operable from an uninterruptible power supply in the event of the loss of normal power.

ITAAC Determination Basis Inspection of the intrusion detection equipment within the protected area perimeter isolation zones was performed to verify that the isolation zones at the protected area perimeter are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons. Tests, inspections or a combination of tests and inspections of the intrusion detection and assessment equipment at the protected area perimeter and its uninterruptible power supply were also performed to verify the intrusion detection and assessment equipment at the protected area perimeter detects penetration or attempted penetration of the protected area barrier and concurrently alarms in the Central Alarm Station (CAS) and Secondary Alarm Station (SAS), and the intrusion detection and assessment equipment at the protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power. The VEGP Unit 4 Plant Security System ITAACs only cover the Unit 4 plant security system design commitment scope. The CAS and SAS are common to both VEGP Unit 3 and Unit 4.

U.S. Nuclear Regulatory Commission ND-23-0116 Enclosure Page 3 of 4 The isolation zones are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons.

An inspection was performed as described in ITAAC Technical Report SV4-SES-ITR-800661 Reference 1) to verify that the Unit 4 protected area perimeter isolation zones are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons and satisfy the applicable intrusion detection and assessment requirements of the VEGP Units 1-4 Physical Security Plan associated with 10 CFR 73.55(i).

The inspection performed a walkdown of the Unit 4 protected area perimeter isolation zones to confirm that the protected area perimeter isolation zones are equipped with intrusion detection equipment that is installed per approved construction drawings and provides the capability to detect and assess unauthorized persons.

The inspection results are documented in Reference 1 and verify that the Unit 4 protected area perimeter isolation zones are equipped with intrusion detection equipment that provides the capability to detect and assess unauthorized persons.

The intrusion detection and assessment equipment at the protected area perimeter detects penetration or attempted penetration of the protected area barrier and concurrently alarms in the Central Alarm Station and Secondary Alarm Station.

Testing was performed as identified in ITAAC Technical Report SV4-SES-ITR-801661 (Reference 2) to verify that the intrusion detection and assessment equipment at the Unit 4 protected area perimeter detects penetration or attempted penetration of the protected area barrier and concurrently alarms in the CAS and SAS and satisfy the applicable intrusion detection and assessment requirements of the VEGP Units 1-4 Physical Security Plan associated with 10 CFR 73.55(i).

The testing identified in Reference 2 tested each segment of the Unit 4 protected area perimeter intrusion detection system by crossing or disturbing the zone of detection and confirming that concurrent intrusion detection alarms are received in both the CAS and SAS. The tests then confirmed that for each intrusion detection system alarm the security video system could provide video image recording with real-time display of video images and playback of recorded video images for assessment to both CAS and SAS.

The test results are documented in Reference 2 and verify that the intrusion detection and assessment equipment at the Unit 4 protected area perimeter detects penetration or attempted penetration of the protected area barrier and concurrently alarms in the Central Alarm Station and Secondary Alarm Station.

The intrusion detection and assessment equipment at the protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power.

Testing was performed as identified in ITAAC Technical Report SV4-SES-ITR-802661 (Reference 3) to verify that the intrusion detection and assessment equipment at the Unit 4 protected area perimeter remained operable from an uninterruptible power supply in the event of the loss of normal power and satisfy the applicable intrusion detection and assessment power supply requirements of the VEGP Units 1-4 Physical Security Plan associated with 10 CFR 73.55(i).

The testing identified in Reference 3 involved securing the assigned normal power supply to Unit 4 intrusion detection and assessment equipment at the protected area perimeter and verifying that the protected area perimeter intrusion detection and assessment equipment remained powered from the

U.S. Nuclear Regulatory Commission ND-23-0116 Enclosure Page 4 of 4 credited uninterruptible power supply, such that the affected intrusion detection and assessment equipment remained operable.

The test results are documented in Reference 3 and verify that the intrusion detection and assessment equipment at the Unit 4 protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power.

References 1, 2 and 3 are available for NRC inspection as part of the Unit 4 ITAAC C.2.6.09.03b Completion Package (Reference 4).

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 C.2.6.09.03b (Reference 4) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC C.2.6.09.03b was performed for VEGP Unit 4 and that the prescribed acceptance criteria were met.

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

References (available for NRC inspection)

1. SV4-SES-ITR-800661, Unit 4 ITAAC 661 Walkdown Inspection: ITAAC C.2.6.09.03b, Rev 0 (SRI)

2. SV4-SES-ITR-801661, Intrusion Detection/Video Assessment Testing: ITAAC C.2.6.09.03b, Rev 0 (SRI)

3. SV4-SES-ITR-802661, Uninterruptible Power Supply Testing: ITAAC C.2.6.09.03b, Rev 0 (SRI)

4. C.2.6.09.03b-U4-CP-Rev0, ITAAC Completion Package