ND-19-0333, Vogtie, Unit 3 and Unit 4, Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item C.2.6.09.03a (Index Number 660)

Vogtie, Unit 3 and Unit 4, Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item C.2.6.09.03a (Index Number 660)

ML19095B448
Person / Time
Site:	Vogtle
Issue date:	04/05/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0333
Download: ML19095B448 (6)

Text

Michael J. Yox 7825 River Road Regulatory Affairs Director

^Southern Nuclear Vogtie 3 & 4 Waynesboro, GA 30830 706-848-6459 tel APR 0 5 Z0I9 Docket Nos.: 52-025 52-026 ND-19-0333 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtie Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item C.2.6.09.03a [Index Number 6601 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of April 2, 2019, Vogtie Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item C.2.6.09.03a [Index Number 660] 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.

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. Yo)<<

Regulatory Affairs Director Vogtie 3 & 4

Enclosure:

Vogtie Electric Generating Plant(VEGP) Unit 3 & Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.03a [Index Number 660]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-19-0333 Page 2of 3 To:

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

Mr. D. L. McKinney (w/o enclosures)

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

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

Mr. J. B. Klecha Mr. G. Chick Mr. M. J.,Yox Mr. A. 8. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. W. A. Sparkman Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Ms. J. M. Heisserer Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. J. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oaiethoroe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Eiectric Authoritv of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Daiton Utilities Mr. T. Bundros

U.S. Nuclear Regulatory Commission ND-19-0333 Page 3 ol 3 Westinqhouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

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

Mr. S. 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-19-0333 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-19-0333 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3& Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.03a [Index Number 660]

U.S. Nuclear Regulatory Commission ND-19-0333 Enclosure Page 2 of 4 ITAAC Statement Desion Commitment 3.a) Isolation zones exist in outdoor areas adjacent to the physical barrier at the perimeter of the protected area that allows 20 feet of observation on either side of the barrier. Where permanent buildings do not allow a 20-foot observation distance on the inside of the protected area, the building walls are immediately adjacent to, or an integral part of, the protected area barrier.

Insoections/Tests/Analvses Inspections will be performed of the isolation zones in outdoor areas adjacent to the physical barrier at the perimeter of the protected area.

Acceptance Criteria Isolation zones exist in outdoor areas adjacent to the physical barrier at the perimeter of the protected area and allow 20 feet of observation and assessment of the activities of people on either side of the barrier. Where permanent buildings do not allow a 20-foot observation and assessment distance on the inside of the protected area, the building walls are immediately adjacent to, or an integral part of, the protected area barrier and the 20-foot observation and assessment distance does not apply.

ITAAC Completion Description An inspection of the isolation zones in outdoor areas adjacent to the physical barrier at the perimeter of the protected area is performed to verify that isolation zones exist in outdoor areas adjacent to the physical barrier at the perimeter of the protected area and allow 20 feet of observation and assessment of the activities of people on either side of the barrier and satisfy the applicable protected area perimeter physical barrier isolation zone requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 73.55(e)(7)(i)(A). The VEGP Unit 3(Unit 4) Plant Security System ITAACs only cover the Unit 3(Unit 4) plant security system design commitment scope.

Where permanent buildings do not allow a 20-foot observation and assessment distance on the inside of the protected area, the building walls are immediately adjacent to, or an integral part of, the protected area barrier and the 20-foot observation and assessment distance does not apply. In the case of VEGP Unit 3(Unit 4), a point on both the Personnel Access Point (Building 304)east and west exterior walls intersects and is immediately adjacent to the protected area perimeter physical barrier. The protected area perimeter physical boundary continues through the inside of Building 304 between the building's east and west exterior walls and is monitored with intrusion detection. The Building 304 roof is monitored by a perimeter intrusion detection system and security cameras and is only accessible from inside the protected area. The interior of Building 304 is monitored by security cameras and a continuously manned Bullet Resisting Enclosure. Building 304 is the common personnel access control portal to both the VEGP Unit 3 and Unit 4 protected area. There are no other permanent buildings at VEGP Unit 3(Unit 4)that are immediately adjacent to, or an integral part of, the VEGP Unit 3(Unit 4) protected area perimeter physical barrier.

The inspection is performed per Procedure XXX (Reference 1) and measures, using a commercially available measuring device, the isolation zone observation and assessment distance in outdoor areas that are adjacent to either side of protected area perimeter physical

U.S. Nuclear Regulatory Commission ND-19-0333 Enclosure Page 3of 4 barrier. The measurements verify that a minimum 20-foot observation and assessment distance exists on either side of the protected area perimeter physical barrier. The inspection also visually confirms that the isolation zone observation and assessment distance measured above is clear of objects which could conceal or shield the activities of people on either side of the protected area perimeter physical barrier. Lastly, the inspection visually verifies that the Building 304 east and west exterior walls intersect, and are immediately adjacent to, the protected area perimeter physical barrier.

The results of the inspection are documented in Reference 1 and verify that isolation zones exist in outdoor areas adjacent to the physical barrier at the perimeter of the protected area and allow 20 feet of observation and assessment of the activities of people on either side of the barrier. Where permanent buildings do not allow a 20-foot observation and assessment distance on the inside of the protected area the inspection results verify that the building walls are immediately adjacent to, or an integral part of, the protected area barrier.

Reference 1 is available for NRC inspection as part of the Unit 3(Unit 4)ITAAC C.2.6.09.03a Completion Package (Reference 2[3]).

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 favaiiabie for NRC inspection)

1. Procedure XXX, Unit 3(Unit 4) Protected Area Perimeter Physical Barrier Outdoor Isolation Zone Inspection

2. C.2.6.09.03a -U3-CP-Rev 0, ITAAC Completion Package

3. C.2.6.09.03a -U4-CP-Rev 0, ITAAC Completion Package

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