ND-18-0609, Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item E.3.9.08.01.01 (Index Number 870)

Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item E.3.9.08.01.01 (Index Number 870)

ML18131A232
Person / Time
Site:	Vogtle
Issue date:	05/11/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC E.3.9.08.01.01, ND-18-0609
Download: ML18131A232 (25)

Text

Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel 410-474-8587 cell myox@southernco.com MAY 1 t'ZOtt Docket Nos.: 52-025 52-026 ND-18-0609 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 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 E.3.9.08.01.01 [Index Number 870]

Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of May 1, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item E.3.9.08.01.01 [Index Number 870] has not been completed greater than 225-days prior to initial fuel load. The Enclosures describe the plans for completing this ITAAC. Southern Nuclear Operating Company will, at a later date, provide additional notifications for ITAAC that have not been completed 225-days prior to initial fuel load.

This notification is informed by the guidance described in 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. In accordance with NEI 08-01, this notification includes ITAAC for which required inspections, tests, or analyses have not been performed or have been only partially completed. All ITAAC will be fully completed and all Section 52.99(c)(1) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding that all acceptance criteria are met prior to plant operation, as required by 10 CFR 52.103(g).

This letter contains no new NRC regulatory commitments.

If there are any questions, please contact Tom Petrak at 706-848-1575.

Respectfully submitted.

Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-18-0609 Page 2 of 4 : Vogtle Electric Generating Plant (VEGP) Unit 3 Docket No.52-025 Completion Plan for Uncompleted ITAAC E.3.9.08.01.01 [Index Number 870] : Vogtle Electric Generating Plant (VEGP) Unit 4 Docket No.52-026 Completion Plan for Uncompleted ITAAC E.3.9.08.01.01 [Index Number 870]

MJY/RAS/amw

U.S. Nuclear Regulatory Commission ND-18-0609 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. M. D. Rauckhorst (w/o enclosures)

Mr. M. D. Meier Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKinney Mr. M. J. Vox Mr. D. L. Fulton Mr. J. B. Klecha Mr. G. Chick Mr. F. H. Willis Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Mr. J. P. Redd Ms. A. C. Chamberlain Mr. D. R. Culver Mr. T. G. Petrak Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reaulatorv Commission Mr. W. Jones (w/o enclosures)

Ms. J. M. Heisserer Mr. C. P. Patel Mr. M. E. Ernstes Mr. G. J. Khouri Mr. T. E. Chandler Ms. S. E. Temple Ms. P. Braxton Mr. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. F. D. Brown Mr. B. J. Kemker Ms. A. E. Rivera-Varona Ms. L. A. Kent Mr. P. B. Donnelly Ms. N. C. Coovert Oqiethoroe Power Corporation Mr. R. B. Brinkman

U.S. Nuclear Regulatory Commission ND-18-0609 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Daiton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

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

Mr. M. M. Corletti Ms. L. G. Iller Mr. D. Hawkins Ms. J. Monahan Mr. J. L. Coward Ms. N. E. Deangelis Other Mr. J. E. Hosier, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch BIngham

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 1 of 11 Southern Nuclear Operating Company ND-18-0609 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Unit 3 Docket No.: 52-025 Completion Plan for Uncompleted ITAAC E.3.9.08.01.01 [Index Number 870]

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 2 of 11 ITAAC Statement Program Commitment 8.1 The licensee conducts a partial participation exercise to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure EPZthat have not been tested in a previous exercise. [N.I]

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

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

A. Accident Assessment and Classification

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

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

B. Notifications

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

Standard Criteria:

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

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

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

Standard Criteria:

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 3 of 11

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

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

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

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

Standard Criteria:

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

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

Standard Criteria:

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

C. Emergency Response

1. Demonstrate the capabilityto direct and control emergency operations.

Standard Criteria:

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

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

Standard Criteria:

a. Briefings were conducted priorto turnover responsibility.

3. Demonstrate the ability to prepare for around-the-clockstaffing requirements.

Standard Criteria:

a. Complete 24-hour staff assignments.

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 4 of 11 Standard Criteria:

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

D. Emergency Response Facilities

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

Standard Criteria:

a. The TSC, OSC, and EOF care activated within 75 minutes of an initial declaration of an Alert or higher classification,

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

Standard Criteria:

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

b. The security force implements and follows security plan procedures as applicable.

c. On-site Emergency Response Facility (ERF) habitability is established as specified in the emergency implementing procedures (EIPs).

d. Demonstrate the capability of TSC and EOF equipment and data displays to clearly identify and reflect the affected unit.

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

Standard Criteria:

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

b. Not used.

c. Emergency response facility personnel are able to operate specified communication systems E. Radiologicai Assessment and Control

1. Demonstrate the ability to obtain onsite radiological surveys and samples.

Standard Criteria:

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 5 of 11

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

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

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

Standard Criteria:

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

b. Exposure records are available.

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

Standard Criteria:

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

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

Standard Criteria:

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

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

5. Demonstrate the ability to develop dose projections.

Standard Criteria:

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

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

Standard Criteria:

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 6 of 11

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

Standard Criteria:

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

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

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

F. Public Information

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

Standard Criteria:

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

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

Standard Criteria:

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

G. Evaluation

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

Standard Criteria:

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

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

ITAAC Completion QescrlDtlon Multiple ITAAC are performed to ensure that a partial participation exercise is conducted to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure Emergency Planning Zone (EPZ) that have

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 7 of 11 not been tested In a previous exercise. This ITAAC performs a partial participation exercise (test) within the specified time periods of 10 CFR Part 50, Appendix E and confirms that onslte exercise objectives are either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public are completed.

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

An exercise scenario, simulating a radiological release to the environment. Is developed and conducted using procedure NMP-EP-303 (Reference 1). Scenario-specific onslte exercise objectives are generated to evaluate the Standard Criteria Identified In the ITAAC Acceptance Criteria, using the guidance provided In procedure NMP-EP-303. The ITAAC Acceptance Criteria (Standard Criteria ITAAC Item) and exercise results are summarized In the tables below:

Accident Assessment and Classification 8.1.1.A.1.a The correct highest emergency classification level based on events which were In progress, considering past events and their Impact on the current conditions. Is determined per EIP NMP-EP-141 (Reference 2) and applicable sub-tier document(s) within 15 minutes from the time the Initiating condltlon(s) or EAL Is met.

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

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

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

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

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 8 of 11 ITAAC item 8.1.1.B.3.a The ability to notify onsite individuals (via plant page or telephone) within the Protected Area is demonstrated using EIP NMP-EP-142 and applicable sub-tier document(s). Notification of onsite personnel outside the Protected Area, but within the owner controlled area, is performed under ITAAC Acceptance Criteria Item 8.1.1.D.2.b.

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

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

8.1.1.C.2.a The TSC and EOF conduct initial briefings prior to the transfer of command and control functions from the Control Room in accordance with EIP NMP-EP-143 and applicable sub-tier document(s).

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

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

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

8.1.1.D.2.a The emergency equipment in the TSC, OSC, EOF and JIC is adequate to support completion of the applicable accident assessment (NMP-EP-140),

event classification (NMP-EP-141), emergency notification (NMP-EP-142),

facility activation (NMP-EP-143), protective actions (NMP-EP-144), and offsite dose assessment (NMP-EP-147, Reference 6) activities required by the EIPs.

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

8.1.1.D.2.C On-site ERF (TSC, OSC) habitability is established per NMP-EP-146-F30 (Reference 7) which is a sub-tier document to EIP NMP-EP-146 (Reference 8).

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 9 of 11 ITAACIteni MMV llwlil 8.1.1.D.2.d The emergency equipment and data displays in the JSC and EOF clearly identify and reflect the affected unit information necessary to support completion of the applicable accident assessment (NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142),

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

8.1.1.D.3.a The emergency response communications identified in Table 5 of the SMC Standard Emergency Plan (Reference 9) which are utilized to complete the applicable accident assessment (NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions (NMP-EP-144), and offsite dose assessment (NMP-EP-147) activities are available and operational.

8.1.1.D.3.b Not used.

8.1.1.D.3.C Emergency response facility personnel are able to operate the required emergency response communications identified in Table 5 of the SNC Standard Emergency Plan to complete their applicable accident assessment (NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions (NMP-EP-144), and offsite dose assessment (NMP-EP-147) activities.

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

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

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

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

8.1.1.E.3.a Radiological Field Monitoring Team(s) are briefed, obtain equipment, and are dispatched per EIP NMP-EP-147-00X (Reference 11) and applicable sub-tier document(s).

8.1.1.E.4.a Radiological Field Monitoring Team radiological survey data is collected per EIP NMP-EP-147-00X and applicable sub-tier documents and includes dose rate or counts per minute (cpm) from the plume, both open and closed window, and air sample (gross/net cpm) for particulate and iodine, if applicable.

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 10 of 11 ITAAC Item 8.1.1.E.4.b Radiological Field Monitoring Team radiological survey results are transmitted to the EOF in accordance with EIP NMP-EP-147-00X and applicable sub-tier documents.

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

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

8.1.1.E.7.a Total effective dose equivalent (TEDE) and CDE dose projections from the dose assessment computer code are developed in accordance with EIP NMP-EP-147 and applicable sub-tier documents.

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

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

Public Information 8.1.1.F.1.a Media information (e.g., press releases, press briefings, electronic media) concerning events, conditions, and actions is made available in accordance with EIPs NMP-EP-204 (Reference 12), NMP-EP-205 (Reference 13) and NMP-EP-206 (Reference 14).

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

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

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

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

The partial participation exercise performance (test) results are documented in Drill/Exercise Report XXX (Reference 15) per procedure NMP-EP-303. The Drill/Exercise Report documents

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 1 Page 11 of 11 and confirms that onsite exercise objectives are either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public are entered into the Corrective Action Program.

Completion of the post-exercise critique corrective actions necessary to protect the health and safety of the public (if any identified) is documented in the Partial Participation Exercise CorrectiveAction Completion Report YYY (Reference 16) and confirmsthat the post-exercise critique corrective actions necessary to protect the health and safety of the public are complete.

Documentation that the VEGP Unit 3 partial participation exercise is conducted within two years of a full participation exercise at VEGP Unit 1 and 2 as required by 10 CFR 50 Appendix E, Sections IV.F.2.b and IV.F.2.C, and within one year of VEGP Unit 3 initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ii) is contained in Drill/Exercise Report XXX. This confirmsthat the VEGP Unit 3 partial participation exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50.

References 1 through 16 are available for NRC inspection as part ofthe Unit 3 ITAAC E.3.9.08.01.01 Completion Package (Reference 17).

List of ITAAC Findings In accordance with plantprocedures for ITAAC completion. Southern Nuclear Operating Company performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This finding review found no relevant ITAAC findings associated with this ITAAC.

References {available for NRC inspection)

1. Procedure NMP-EP-303, Drill and Exercise Standards

2. Procedure NMP-EP-141, Event Classification

3. Procedure NMP-EP-142, Emergency Notification

4. Procedure NMP-EP-143, Facility Activation

5. Procedure NMP-EP-144, Protective Actions

6. Procedure NMP-EP-147, Offsite Dose Assessment

7. Form NMP-EP-146-F30, OSC RP-Chemistry Group Lead

8. Procedure NMP-EP-146, Emergency Response Organization

9. Southern Nuclear Operating Company Standard Emergency Plan

10. Procedure NMP-HP-201, Personnel Dosimetry Program

11. Procedure NMP-EP-147-00X, SNC Field Monitoring Teams Radiological Surveys and Sampling

12. Procedure NMP-EP-204, Joint Information Center Operations

13. Procedure NMP-EP-205, Emergency Communications News Releases

14. Procedure NMP-EP-206, Emergency Communications News Briefings

15. Drill/Exercise Report XXX

16. Partial Participation Exercise Corrective Action Completion Report YYY

17. E.3.9.08.01.01-U3-CP-RevO, ITAAC Completion Package

18. NEI 08-01, "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 1 of 10 Southern Nuclear Operating Company ND-18-0609 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Unit 4 Docket No.: 52-026 Completion Plan for Uncompleted ITAAC E.3.9.08.01.01 [Index Number 870]

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 2 of 10 ITAAC Statement Prooram Commitment 8.1 The licensee conducts a partial participation exercise to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure EPZ that have not been tested in a previous exercise. [N.I]

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

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

A. Accident Assessment and Classification

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

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

B. Notifications

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

Standard Criteria:

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

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

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

Standard Criteria:

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 3 of 10

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

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

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

Standard Criteria:

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

C. Emergency Response

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

Standard Criteria:

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

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

Standard Criteria:

a. Briefings were conducted prior to turnover responsibility.

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

Standard Criteria:

a. Complete 24-hour staff assignments.

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

Standard Criteria:

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

D. Emergency Response Facilities

1. Demonstrate timely activation of the operational support center (OSC).

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 4 of 10 Standard Criteria:

a. The OSC is activated within 75 minutes following declaration of an Alert or higher classification.

2. Demonstrate the adequacy of equipment, security provisions, and habitability precautions for the OSC, as appropriate.

Standard Criteria:

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

b. The security force implements and follows security plan procedures as appropriate.

c. On-site Emergency Response Facility (ERF) habitability is established as specified in the emergency implementing procedures (EIPs).

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

Standard Criteria:

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

b. Not used.

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

E. Radiological Assessment and Control

1. Demonstrate the ability to obtain onsite radiological surveys and samples.

Standard Criteria:

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

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

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

Standard Criteria:

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

b. Exposure records are available.

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 5 of 10

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

Standard Criteria:

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

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

Standard Criteria:

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

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

5. Demonstrate the ability to develop dose projections.

Standard Criteria:

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

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

Standard Criteria:

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

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

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

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 6 of 10 The Vogtle Electric Generating Plant (VEGP) Unit 4 partial participation exercise is completed under the provisions of 10 CFR 50, Appendix E Section IV.F.2.a.(iii). Specifically, the partial participation exercise is conducted within two years of a full participation exercise at VEGP Units 1 and 2 as required by 10 CFR 50 Appendix E, Sections IV.F.2.b and IV.F.2.C, and within one year of VEGP Unit 4 initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ii).

An exercise scenario, simulating a radiological release to the environment, is developed and conducted using procedure NMP-EP-303 (Reference 1). Scenario-specific onsite exercise objectives are generated to evaluate the Standard Criteria identified in the ITAAC Acceptance Criteria, using the guidance provided in procedure NMP-EP-303. The ITAAC Acceptance Criteria (Standard Criteria ITAAC Item) and exercise results are summarized in the table below:

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

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

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

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

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

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

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

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 7 of 10 Emergency Response S.i.l.C.l.a Command and control Is demonstrated by the control room (simulator) In the early phase of the emergency, and the by TSC and the EOF within 75 minutes following the declaration of an Alert or higher classification, In accordance with EIPs NMP-EP-142 and NMP-EP-143 (Reference 4) and applicable sub-tier document(s).

8.1.1.C.2.a The TSC and EOF conduct Initial briefings prior to the transfer of command and control functions from the Control Room In accordance with EIP NMP-EP-143 and applicable sub-tier document(s).

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

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

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

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

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

8.1.1.D.2.C On-slte ERF (OSC) habltablllty Is established per NMP-EP-146-F30 (Reference 7) which Is a sub-tier document to EIP NMP-EP-146 (Reference 8).

8.1.1.D.3.a The emergency response communications Identified In Table 5 of the SNC Standard Emergency Plan (Reference 9) which are utilized to complete the applicable accident assessment (NMP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions (NMP-EP-144), and offslte dose assessment (NMP-EP-147) activities are available and operational.

8.1.1.D.3.b Not used.

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 8 of 10 Standard 8.1.1.D.3.C Emergency response facility personnel are able to operate the required emergency response communications identified in Table 5 of the SNC Standard Emergency Plan to complete their applicable accident assessment (NI\/IP-EP-140), event classification (NMP-EP-141), emergency notification (NMP-EP-142), protective actions (NMP-EP-144), and offsite dose assessment (NI\/IP-EP-147) activities.

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

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

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

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

8.1.1.E.3.a Radiological Field Monitoring Team(s) are briefed, obtain equipment, and are dispatched per EIP NMP-EP-147-00X (Reference 11) and applicable sub-tier document(s).

8.1.1.E.4.a Radiological Field Monitoring Team radiological survey data is collected per EIP NMP-EP-147-00X and applicable sub-tier documents and includes dose rate or counts per minute (cpm) from the plume, both open and closed window, and air sample (gross/net cpm) for particulate and iodine, if applicable.

8.1.1.E.4.b Radiological Field Monitoring Team radiological survey results are transmitted to the EOF in accordance with EIP NMP-EP-147-00X and applicable sub-tier documents.

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

8.1.1.E.6.a Total effective dose equivalent (TEDE) and CDE dose projections from the dose assessment computer code are developed in accordance with EIP NMP-EP-147 and applicable sub-tier documents.

8.1.1.E.6.b Protective Action Recommendations (PARs) are developed within 15 minutes of data availability in accordance with EIP NMP-EP-142.

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 9 of 10 Standard

. rrifi>>n2^

vriiiGri9 ITAAC Item 'lIIL 8.1.1.E.6.C PARs are transmitted to responsible State and local government agencies within 15 minutes of PAR approval by the Emergency Director in accordance with EiP NMP-EP-142.

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

The partial participation exercise performance (test) results are documented in Drill/Exercise Report XXX (Reference 12) per procedure NMP-EP-303. The Drill/Exercise Report documents and confirms that onsite exercise objectives are either met or the post-exercise critique corrective actions necessary to protect the health and safety of the public are entered into the Corrective Action Program.

Completion of the post-exercise critique corrective actions necessary to protect the health and safety of the public (if any identified) is documented in the Partial Participation Exercise Corrective Action Completion Report YYY (Reference 13) and confirms that the post-exercise critique corrective actions necessary to protect the health and safety of the public are complete.

Documentation that the VEGP Unit 4 partial participation exercise is conducted within two years of a full participation exercise at VEGP Unit 1 and 2 as required by 10 CFR 50 Appendix E, Sections IV.F.2.b and IV.F.2.C, and within one year of VEGP Unit 4 initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ii) is contained in Drill/Exercise Report XXX. This confirms that the VEGP Unit4 partial participation exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50.

References 1 through 13 are available for NRC inspection as part of the Unit 4 ITAAC E.3.9.08.01.01 Completion Package (Reference 14).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern Nuclear Operating Company performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This finding review found no relevant ITAAC findings associated with this ITAAC.

References favaiiable for NRC inspection)

1. Procedure NMP-EP-303, Drill and Exercise Standards

2. Procedure NMP-EP-141, Event Classification

3. Procedure NMP-EP-142, Emergency Notification

4. Procedure NMP-EP-143, Facility Activation

5. Procedure NMP-EP-144, Protective Actions

6. Procedure NMP-EP-147, Offsite Dose Assessment

7. Form NMP-EP-146-F30, OSC RP-Chemistry Group Lead

8. Procedure NMP-EP-146, Emergency Response Organization

U.S. Nuclear Regulatory Commission ND-18-0609 Enclosure 2 Page 10 of 10

9. Southern Nuclear Operating Company Standard Emergency Plan

10. Procedure NMP-HP-201, Personnel Dosimetry Program

11. Procedure NMP-EP-147-00X, SNC Field Monitoring Teams Radiological Surveys and Sampling

12. Drill/Exercise Report XXX

13. Partial Participation Exercise Corrective Action Completion Report YYY

14. E.3.9.08.01.01-U4-CP-Rev0, ITAAC Completion Package

15. NEI 08-01, "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"