ND-18-0775, Unit 4 - Resubmittal of Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item E.3.9.08.01.03 (Index Number 872)

Unit 4 - Resubmittal of Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item E.3.9.08.01.03 (Index Number 872)

ML18197A135
Person / Time
Site:	Vogtle
Issue date:	07/13/2018
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ITAAC E.3.9.08.01.03, ND-18-0775
Download: ML18197A135 (7)

Text

^ ,1 l. I I Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel 410-474-8587 ceii JUL 1 3 2018 myox@southernco.com Docket Nos.: 52-025 52-026 ND-18-0775 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Wastiington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 and Unit 4 Resubmittal of Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item E.3.9.08.01.03 findex Number 8721 Ladles and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of July 12, 2018, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item E.3.9.08.01.03 [Index Number 872] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan 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.

Southern Nuclear Operating Company (SNC) previously submitted Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load for Item E.3.9.08.01.03 [Index Number 872]

ND-18-0637 [ML18131A244] dated May 11, 2018. This resubmittal supersedes ND-18-0637 in its entirety.

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

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC E.3.9.08.01.03 [Index Number 872]

MJY/LBP/amw

U.S. Nuclear Regulatory Commission ND-18-0775 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (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 Ms. A. L. Pugh Mr. A. 8. Parton Mr. W. A. Sparkman Mr. C. E. Morrow Ms. K. M. Stacy Mr. M. K. Washington Ms. A. C. Chamberlain 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 Mr. P. B. Donnelly Ms. N. C. Coovert Oalethorpe Power Corporation Mr. R. B. Brinkman Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Daiton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-18-0775 Page 3 of 3 Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. 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., CDS 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-18-0775 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-18-0775 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC E.3.9.08.01.03 [Index Number 872]

U.S. Nuclear Regulatory Commission ND-18-0775 Enclosure Page 2 of 4 ITAAC Statement Program Commitment 8.1 The licensee conducts a partial participation exercise to evaluate portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure EPZ that have not been tested in a previous exercise. [N.I]

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 8.1.3 The exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50, offsite exercise objectives have been met, and there are either no uncorrected offsite deficiencies, or a license condition requires offsite deficiencies to be corrected priorto operation above 5% of rated power.

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) to evaluate offsite portions of emergency response capabilities within the plume exposure EPZ that have not been tested in a previous exercise. This Vogtle Electric Generating Plant (VEGP) Unit 3 (Unit 4) partial participation exercise is conducted within the specified time periods of 10CFR Part 50, Appendix Eand confirms that offsite exercise objectives are met and there are either no uncorrected offsite (State and local agency) deficiencies, or a license condition requires offsite deficiencies to be corrected prior to operation above 5% of rated power. Offsite deficiencies as used in this ITAAC are considered to be Level 1 Findings, as defined inthe Federal Emergency Management Agency's (FEMA's) January 2016 Program Manual - Radiological Emergency Preparedness (FEMA P-1028) (Reference 1), and as addressed in FEMA's May 15, 2015, Memorandum, "New Terms to Classify REPP Exercise-Related Observations and Issues" (Reference 2).

The VEGP Unit 3 (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 3 (Unit 4) initial fuel load, as required by 10CFR 50, Appendix E, Section IV.F.2.a.(ii). The VEGP Unit 3 (Unit 4) partial participation exercise scenerio is of sufficient scope to require appropriate offsite authorities to actively take part in the exerciseto test direction and control functions (i.e.,

(a) protective action decision making related to emergency action levels, and (b) communication capabilities among affected State and local authorities and the licensee) that were not previously evaluated by FEMA during the VEGP Units 1 and 2 full participation graded exercise.

The VEGP Unit 3 (Unit 4) exercise scenario, simulating a radiological release to the environment, is developed and conducted using procedure NMP-EP-303 (Reference 3). A

U.S. Nuclear Regulatory Commission ND-18-0775 Enclosure Page 3 of 4 scenario review Is conducted between FEMA, Impacted States and Southern Nuclear Operating Company, as required by NMP-EP-303, to approve State and county (local) objectives for the exercise and define scenario requirements to meet these objectives. The scenario review Is conducted approximately 4-5 months priorto the partial participation exercise and will focus on, but Is not limited to. State and county exercise objectives that were not evaluated by FEMA as part of the VEGP Units 1 and 2 full participation graded exercise. If State and county (local) objectives are Identified as requiring evaluation In the scenario review meeting discussed above, scenerlo-speclfic Unit 3 (Unit 4) offslte exercise objectives supporting these State and county (local) objectives are developed and finalized, using the guidance provided In procedure NMP-EP-303. If no offslte State and county (local) objectives are Identified as requiring evaluation by FEMA In the Unit 3 (Unit 4) scenario review meeting, no offslte exercise objectives will be developed and this ITAAC will credit the results of the VEGP Units 1 and 2 FEMA After Action Report/Improvement Plan (Reference 4) for the VEGP Unit 3 (Unit 4) ITAAC Acceptance Criteria.

The VEGP Units 1 and 2 FEMA After Action Report/Improvement Plan documents State and local agency deficiencies Identified by FEMA during the VEGP Units 1 and 2 full participation graded exercise. Resolution of open deficiencies bythe State and county (local) agencies are tracked In the VEGP Corrective Action Program.

State and county (local) objectives (If any) approved In the scenario review meeting discussed above are evaluated by FEMA and documented In a VEGP Unit 3 (Unit 4) FEMA After Action Report/Improvement Plan (Reference 5). Resolution of open deficiencies by the State and county (local) agencies are tracked In the VEGP Corrective Action Program. If no offslte State and county (local) objectives are Identified as requiring evaluation by FEMA In the Unit 3 (Unit 4) scenario review meeting there will not be a VEGP Unit 3 (Unit 4) FEMA After Action Report/Improvement Plan.

An evaluation of the Unit 3 (Unit 4) partial participation exercise performance Is conducted per procedure NMP-EP-303 to confirm that the offslte exercise objectives necessary to support offslte State and county (local) objectives approved In the scenario review meeting discussed above are met. The exercise performance (test) results are documented In Unit 3 (Unit 4)

DrIII/Exerclse Report XXX (Reference6) per procedure NMP-EP-303. The DrIII/Exerclse Report documents and confirms that VEGP Unit 3 (Unit 4) offslte exercise objectives necessary to support offslte State and county (local) objectives approved In the scenario review meeting are met. If no offslte State and county (local) objectives are Identified as requiring evaluation by FEMA In the Unit 3 (Unit 4) scenario review meeting there will be no VEGP Unit 3 (Unit 4) offslte exercise objective discussion In the partial participation exercise DrIII/Exerclse Report.

Documentation that the VEGP Unit 3 (Unit 4) 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 yearof VEGP Unit 3 (Unit 4) Initial fuel load, as required by 10 CFR 50, Appendix E, Section IV.F.2.a.(ll) Iscontained In the Unit 3 (Unit 4) DrIII/Exerclse Report XXX. This confirms that the VEGP Unit 3 (Unit 4) partial participation exercise Is completed within the specified time periods of Appendix E to 10 CFR Part 50.

Resolution ofthe open State and county (local) deficiencies Identified In the VEGP Units 1 and 2 FEMA After Action Report/Improvement Plan and the VEGP Unit 3 (Unit 4) FEMA After Action

U.S. Nuclear Regulatory Commission ND-18-0775 Enclosure Page 4 of 4 Report/Improvement Plan (if required) are documented in the VEGP Unit 3 (Unit 4) After Action Report/Improvement Plan Closure Report (Reference 7).

If no uncorrected offsite deficiencies remain from the VEGP Units 1 and 2 FEMA After Action Report/Improvement Plan and the VEGP Unit 3 (Unit 4) FEMA After Action Report/Improvement Plan (if required) at the time the Unit 3 (Unit 4) ITAAC E.3.9.08.01.02 02 Principle Closure Documents are prepared, a license condition requiring offsite deficiencies to be corrected prior to operation above 5% of rated power is not required.

If uncorrected offsite deficiencies remain from the VEGP Units 1 and 2 FEMA After Action Report/Improvement Plan and the VEGP Unit 3 (Unit 4) FEMAAfter Action Report/Improvement Plan (if required) at the time the Unit 3 (Unit 4) ITAAC E.3.9.08.01.02 Principle Closure Documents are prepared, a license amendment request will be submitted requesting a license condition requiring the offsite deficiencies be corrected prior to operation above 5% of rated power.

References 1 through 7 are available for NRC inspection as part of the Unit 3 (Unit 4) ITAAC E.3.9.08.01.02 Completion Packages (References 8 and 9).

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

References favailable for NRC inspection^

1. FEMA P-1028, Federal Emergency Management Agency (FEMA) Radiological Emergency Preparedness Program, January 2016

2. A. Mitchell, May 15, 2015, "NewTerms to Classify REPP Exercise-Related Observations and Issues" [Memorandum], FEMA

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

4. VEGP Unitsi and 2 FEMA After Action Report/Improvement Plan

5. VEGP Unit 3 (Unit 4) FEMAAfter Action Report/Improvement Plan

6. Unit 3 (Unit 4) Drill/Exercise Report XXX

7. VEGP Unit 3 (Unit4) After Action Report/Improvement Plan Closure Report

8. E.3.9.08.01.03-U3-CP-Rev0, ITAAC Completion Package

9. E.3.9.08.01.03-U4-CP-Rev0, ITAAC Completion Package

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