ND-19-1351, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.d (Index Number 763)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 3.3.00.02a.i.d (Index Number 763)

ML19326B963
Person / Time
Site:	Vogtle
Issue date:	11/22/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-19-1351
Download: ML19326B963 (17)

Text

Michael J. Yox 7825 River Road

^Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel NOV 2 2 2019 Docket Nos.: 52-025 52-026 ND-19-1351 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 3.3.00.02a.i.d [Index Number 7631 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of November 15, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspection, Test, Analysis, and Acceptance Criteria (ITAAC) Item 3.3.00.02a.i.d

[Index Number 763] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 3.3.00.02a.i.d [Index Number 763]. 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 3.3.00.02a.i.d [Index Number 763] ND 0042[ML19030B726], dated Jan. 28, 2019. This resubmittal supersedes ND-19-0042 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, I

Michael J. Yox Regulatory Affairs Director Vogtle 3&4

U.S. Nuclear Regulatory Commission ND-19-1351 Page 2 of 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 3.3.00.02a.i.d [Index Number 763]

MJY/GJL/sfr

U.S. Nuclear Regulatory Commission ND-19-1351 Page 3 of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III (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. G. Chick Mr. M. Page Mr. P. Martino Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

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

Mr. F. D. Brown Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Ms. T. Lamb Mr. M. Webb Mr. T. Fredette Mr. C. Weber Mr. S. Smith Mr. C. Santos Qqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen

U.S. Nuclear Regulatory Commission ND-19-1351 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. Orlani (w/o enclosures)

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

Mr. M. M. Corletti Ms. L. G. Iller Mr. Z. S. Harper Mr. J. L. Coward Other Mr. J. E. Hosier, Bechtel Power Corporation Ms. L. Matis, TetraTech NUS, Inc.

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

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

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 1 of 14 Southern Nuclear Operating Company ND-19-1351 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC Item 3.3.00.02a.i.d [Index No. 763]

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 2 of 14 ITAAC Statement Design Commitment 2.a) The nuclear island structures, including the critical sections listed in Table 3.3-7, are seismic Category i and are designed and constructed to withstand design basis loads as specified in the Design Description, without loss of structural integrity and the safety-related functions.

3.) Walls and floors of the nuclear island structures as defined on Table 3.3-1 except for designed openings or penetrations, provide shielding during normal operations.

I nspections/Tests/Analvses i) An inspection of the nuclear island structures will be performed. Deviations from the design due to as-built conditions will be analyzed for the design basis loads, and for radiation shielding.

Acceptance Criteria i.d) A report exists which reconciles deviations during construction, including Table 3.3-1 wall and floor thicknesses, and concludes that the as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections, conform to the approved design and will withstand the design basis loads specified in the Design Description without loss of structural integrity or the safety-related functions, and without impacting compliance with the radiation protection licensing basis.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate that the nuclear island (Nl) structures, including the critical sections listed in VEGP Unit 3&4 Combined License(COL) Appendix C (Reference 1 and 2) Table 3.3-7(Attachment A), are seismic Category I and are designed and constructed to withstand design basis loads as specified in the VEGP Unit 3&4 COL Appendix C Section 3.3 Design Description, without loss of structural integrity and the safety-related functions. In addition, multiple ITAAC are performed on walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B) except for designed openings or penetrations, that provide radiation shielding during normal operations.

The subject ITAAC verifies inspection of the as-built structures in the radiologically controlled area of the auxiliary building, including the critical sections and Table 3.3-1 wall and floor thicknesses, and reconciles deviations during construction to the approved design such that the as-built structures will withstand design basis loads without loss of structural integrity or the safety-related functions, and without impacting compliance with the radiation protection licensing basis.

Design bases loads are defined in VEGP Unit 3 COL Appendix C Section 3.3 as those loads associated with:

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 3 of 14

• Normal plant operation (including dead loads, live loads, lateral earth pressure loads, and equipment loads, including hydrodynamic loads, temperature and equipment vibration);

• External events (Including rain, snow,flood, tornado, tornado generated missiles and earthquake); and

• Internal events (Including flood, pipe rupture, equipment failure, and equipment failure generated missiles).

VEGP 3&4 Updated Final Safety Analysis Report(Reference 3), Section 3.7 "Seismic Design",

Section 3.8 "Design of Category I Structures", and Appendix 3H "Auxiliary and Shield Building Critical Sections" describe the analyses for the design basis loads for the Nl Structures. Section 3.8 specifies the applicable codes and standards governing the design, materials, fabrication, construction Inspection and testing for the Nl structures. Section 3.8 also describes the as-bullt design summary reports which document that the seismic Category I structures meet the specified acceptance criteria.

Radiation zone and equipment qualification requirements are met In accordance with VEGP 3&4 UFSAR Tier 2 design criteria Including UFSAR Subsections 3.11.4 "Estimated Radiation and Chemical Environment," 3D.5.1.2 "Radiation Dose," and 12.3.2.1 "Shielding, Design Objectives".

The structures In the radlologlcally controlled area of the auxiliary building. Including the critical sections, listed In Attachment A, and walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B)except for designed openings or penetrations, provide radiation shielding during normal operations are constructed as designed and specified In the VEGP Unit 3 COL Appendix C Section 3.3 Design Description to withstand the Design Description design basis loads without loss of structural Integrity and the safety-related functions, and without Impacting compliance with the radiation protection licensing basis.

The structures In the radlologlcally controlled area of the auxiliary building. Including the critical sections, listed In Attachment A, and walls and floors of the Nl structures as defined on Table 3.3-1 (Attachment B),except for designed openings or penetrations, which provide radiation shielding during normal operations are Inspected during construction to verify the as-bullt structures conform to the specified design, codes and standards. Construction Identified structural deviations are documented, evaluated, and reconciled by engineering to confirm the structures' ability to withstand design basis loads without Impacting compliance with the radiation protection licensing basis. The As-Bullt Summary Reports (References 4 through 9) exist and document the reconciliation of Nl structural deviations Identified during construction and conclude that the as-bullt structures In the radlologlcally controlled area of the auxiliary building. Including the critical sections and walls and floors of the Nl structures as defined on Table 3.3-1 except for designed openings or penetrations, will withstand the design basis loads specified In the Design Description without loss of structural Integrity or the safety-related functions, and without Impacting compliance with the radiation protection licensing basis.

Unit 3 & 4 Principle Closure Documents (References 4 through 9) are available for NRG Inspection as part of the Unit 3 & 4 ITAAC 3.3.00.02a.l.d Completion Packages (References 10 and 11)

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 4 of 14 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 twenty (20) NRC findings associated with this ITAAC.

1. 05200025/2016001 -01 (Closed - ML19135A691)

2. 05200026/2016001 -01 (Closed - ML19135A691)

3.05200025/2015002-02 (Closed - ML19045A614)

4.05200025/2015002-01 (Closed - ML16032A554)

5.05200026/2015002-01 (Closed - ML16032A554)

6.05200025/2015001-01 (Closed - ML15124A857)

7.05200025/2014005-01 (Closed - ML16032A554)

8.05200025/2014002-01 (Closed - ML14218A213)

9.05200025/2013004-01 (Closed - ML14087A320)

10.05200025/2013003-01 (Closed - ML13207A241)

11.05200025/2013002-01 (Closed - ML13207A241)

12.05200025/2012004-01 (Closed - ML13312A316)

13.05200025/2012004-02(Closed - ML14024A594)

14.05200025/2012008-01 (Closed - ML12319A458)

15.05200025/2012008-02(Closed - ML12319A458)

16. 99901448/2014-201-02(Closed - ML17226A340)

17. 99901449/2014-201-02 (Closed - ML17226A340)

18. 99901425/2014-201-01 (Closed - ML18101A168)

19. 99901419/2012-201-03(Closed - ML18131A260)

20. 99901409/2011-201-03(Closed - ML18186A573)

The ITAAC completion review is documented in the IT/\AC Completion Packages for IT/\AC 3.3.00.02a.i.d Unit 3 and Unit 4(Reference 10 and 11) and are available for NRC review.

References(available for NRC inspection)

1. VEGP Unit 3 COL Appendix C, Amendment 167

2. VEGP Unit 4 COL Appendix C, Amendment 165

3. VEGP 3&4 UFSAR, Revision 8.1

4. As-Built Summary Report for Unit 3 Auxiliary Building (except CA20 and Basemat), SV3-AAA-BBB-###

5. As-Built Summary Report for Unit 4 Auxiliary Building (except CA20 and Basemat), SV4-AAA-BBB-###

6. As-Built Summary Report for Unit 3 CA20, SV3-CCC-DDD-###

7. As-Built Summary Report for Unit 4 CA20, SV4-CCC-DDD-###

8. As-Built Summary Report for Unit 3 Nuclear Island Basemat, SV3-EEE-FFF-###

9. As-Built Summary Report for Unit 4 Nuclear Island Basemat, SV4-EEE-FFF-###

10. 3.3.00.02a.i.d-U3-CP-Rev0, ITAAC Completion Package

11. 3.3.00.02a.i.d-U4-CP-Rev0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 5 of 14 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building South wall of auxiliary Building (column line 1), elevation 66'-6" to elevation 180'-0" Divider Wall Between the spent fuel pool and the fuel transfer canal.

Nuclear Island Basemat Below Auxiliary Building Bay between reference column lines 1 and 2, and K2 and N

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 6 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^^

Appiicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines^^) Elevation Range^^^^^ (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlled^^^^

Column Line 1 wall From 1 to N From66'-6"to100'-0" 3'-0" No 2.-3" Yes Column Line 1 wall From 1 to 5'-7" west of From lOO'-O" to 109'-3" K-2 Column Line 1 wall From 5'-7" west of K-2 From lOO'-O" to 109'-3" 3'-0" Yes to N Column Line 1 wall From 1 to 5'-6" east of L- From 109-3" to IBO'-O" 2'-3" Yes 2

Column Line 1 wall From 5'-6" east of L-2 to From 109'-3" to 125'-0" 3'-0" Yes N

2.-3" Yes Column Line 1 wall From 5'-6" east of L-2 to From 125'-0"to180'-0" N

Column Line 2 wall From 1 to K-2 From 66'-6"to135'-3" 2'-6" Yes Column Line 2 wall From K-2 to L-2 From 66'-6"to135'-3" 5'-0" Yes Column Line 2 wall From L-2 to N From 82'-6" to 135'-3" 2'-6" Yes Column Line 2 wall From 1 to J-1 From135'-3"to153'-0" 2'-0" Yes Column Line 3 wall From J-1 to J-2 From 66'-6" to 82'-6" 2'-6" Yes Column Line 3 wall From J-1 to J-2 From lOO'-O" to 135'-3" 2'-6" Yes Column Line 3 wall From J-2 to K-2 From 66'-6" to 135'-3" 2'-6" Yes Column Line 3 wall From K-2 to L-2 From 66'-6" to 92'-8 1/2" 2'-6" Yes Column Line 4 wall From 1 to J-1 From 66'-6"to 135'-3" 2'-6" Yes Column Line 4 wall From J-1 to J-2 From 66'-6" to 92'-6" 2'-6" Yes

U.S. Nuclear Regulatory Commission ND-19-1351 Enciosure Page 7 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wail Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Buiiding^^)

Applicable Radiation Shielding Wall or Section Fioor Elevation or Concrete Wail Description Coiumn Lines^^) Elevation Range<^)<^ (Yes/No)

Auxiliary Building Walls/Floors Radiologicaily Controlled<^^>

Column Line 4 wall From J-1 to J-2 From107'-2"to135'-3" 2'-6" Yes Column Line 4 wall From J-2 to K-2 From 66'-6"to135'-3" 2'-6" Yes Column Line 4 wall From 1 to Intersection From 135'-3"to IBO'-O" 2'-0" Yes with shield building wall Column Line 5 wall From 1 to shield From 66'-6"to160'-6" 2'-0" Yes building; with opening east of J-1 (below 107'-

2" floor).

Wall, 17'-3" north of Column From 1 to 8' east of J-1 From 66'-6" to 82'-6" 2'-0" Yes Line 7 Wall, 10'-6" south of Column From 1 to 5'-6"east of J- From 66'-6" to 82'-6" 2'-0" Yes Line 7.3 1 Wall, 10'-6" south of Column From 1 to just east of J From 82'-6"to100'-0" 2'-0" Yes Line 7.3 Column Line 1 wall From 1 to 4 From 66'-6"to100'-0" 3'-0" No Column Line 1 wall From 4 to 16'-0" south From66'-6"to107'-2" 3'-0" No of 5 Column Line 1 wall From 16'-0" south of 5 From 66'-6"to105'-0" 3'-0" No to 5 Column Line 1 wall From 5 to 7.3 From 66'-6"to lOO'-O" 3'-0" No Column Line 1 wall From 1 to 3 From lOO'-O" to roof 2'-0" Yes Column Line 1 wall From 3 to 4 From lOO'-O" to roof 2'-0" Yes

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 8 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wail Thicknesses for Nuciear Island Buildings, Turbine Buiiding, and Annex Buiiding^^)

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Llnes^^) Elevation Range<^><) Th1c (Yes/No)

Auxiliary Building Walls/Floors Radlologlcally Controlled^^^^

Column Line 1 wall From 4 to 16'-0" south From 107'-2"to roof 2'-0" No of 5 Column Line 1 wall From 16'-0" south of 5 From 105'-0"to roof 2'-0" No to 5 Column Line J-1 wall From 1 to 2 From 82'-6" to 100'-0" 2'-0" Yes Column Line J-1 wall From 2 to 4 From 66'-6" to 135'-3" 2'-6" Yes Column Line J-1 wall From 2 to 4 From135'-3"to153'-0" 2'-0" Yes Column Line J-1 wall From 4 to shield From 66'-6"to107'-2" 2'-0" Yes building Column Line J-2 wall From 2 to 4 From 66'-6" to 135'-3" 2'-6" Yes Column Line J-2 wall From 4 to intersection From 66'-6" to 135'-3" 2'-0" Yes with shield building wall Column Line K-2 wall From 2 to 4 From 66'-6" to 135'-3" 4'-9" Yes Column Line L-2 wall From 2 to 4 From 66'-6" to 135'-3" 4'-0" Yes Column Line N wall From 1 to 2 From 66'-6" to lOO'-O" 3'-0" No Column Line N wall From 1 to 12'-9" north of From100'-0"to125'-0" 3'-9" Yes 1

Column Line N wall From 1 to 12'-9" north of From 125'-0" to 135'-3" 2'-0" Yes 1

Column Line N wall From 12'-9" north of 1 to From100'-0"to118'-2 3'-0" Yes 2 1/2" Column Line N wall From 12'-9" north of 1 to From 118'-2 1/2" to 135'- 2'-0" Yes 2 3"

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 9 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^)

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines^^) Elevation Range<^><> (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlled^^^)

Column Line N wall From 2 to 4(or to shield From 66'-6" to 98'-1" 5'-6" No building)

Column Line N wall From 2 to 4(or to shield From 98'-1"to135'-3" 5'-6"(") Yes building)

Column Line N wall From 1 to 4(or to shield From135'-3"to180'-0" 2'-0" Yes building)

Labyrinth Wall between Col. Not Applicable From 82'-6" to 92'-6" 2'-6" Yes Line 3 and 4 and J-1 to 5'-2" from J-2 N-S Shield Wall (low wall) 5'-7" west of column line From 100'-0"to IIO'-O" 2'-6" Yes K-2 extending 16'-0" from column line 1 north N-S Shield Wall 2'-9" east of column line From 100'-0"to 109'-3" 3'-0" Yes L-2 extending 12'-9" from column line 1 north N-S Shield Wall 2'-9" east of column line From109'-3"to125'-0" 2'-9" Yes L-2 extending 12'-9" from column line 1 north E-W Shield Wall lO'-O" north of column From100'-0"to125'-0" 2'-9" Yes line 1 extending 13'-3" from column line N east Auxiliary Area Basemat From 1-7.3 and l-N, From 60'-6" to 66'-6" 6'-0" No excluding shield building

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 10 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Waii Thicknesses for Nuclear Island Buildings, Turbine Buiiding, and Annex Buiiding^^^

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Llnes^^) Elevation Range'^)') (Yes/No)

Auxiliary Building Walls/Floors Radlologlcally Controlled^^^^

Floor From 1 to 2 and 1 to N 82'-6" 2'-0" Yes Floor From 2 to 4 and J-1 to 82'-6" 2'-0" Yes J-2 Floor From 4 north to the 82'-6" 0'-9" Yes shield building ending 17'-4" south of column line 5 and J-1 to J-2 Pipe Chase Floor From 2 north to the 92'-6" 2"-0" Yes shield building ending 17'-4" south of column line 5 and J-1 to J-2 Floor From 2 to 3 and J-2 to 90'-3" 3'-0" Yes K-2 Floor From 3 to 4 and J-2 to 92'-6" 2'-0" Yes K-2 Floor From 4 to 7.3 and 1 to J- 82'-6" 2'-0" Yes 1

Floor From 1 to 2 and 1 to N 100'-0" 3'-0" Yes Floor From 2 to 4 and K-2 to 92'-8 1/2" 3'-2 1/2" Yes L-2 Floor From 1 to J-2 and 4 to 107'-2" 2'-0" Yes shield building and vertical wall 17'-0" south of column line 5

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 11 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^)

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines^^) Elevation Range<^><) Thlckness<2)(3MM5){9)(i8) (Yes/No)

Auxiliary Building Walls/Floors Radioiogicaiiy Controlied^^^^

Floor From 1 to shield building 105'-0" 0'-9" Yes wall and from intersecting vertical wall before column line 5 to column line 5 Floor From column line 1 to 125'-0" 3'-0" Yes lO'-O" north of column line 1 and from 2'-9" east of column line L-2 toN Floor From 12'-9" north of 118'-2 1/2" 2'-0" Yes column line 1 to 2 and from 2'-9" east of column line L-2 to N Floor From 3 to 4 and J-2 to 117'-6" 2'-0" Yes K-2 Floor From 2 to 4 and 1 to J-1 153'-0" 1'-3" Yes Roof From 1 to 4 and 1 to N 180'-0"to 180'-9" 1'-3" Yes Floor From 4 to 16'-0" south 135'-3" 0'-9" Yes of column line 5 and from 1 to intersection with shield building wall

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 12 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1 Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^**)

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wali Description Column L[nes<^) Elevation Range<^'<> (Yes/No)

Auxiliary Building Wails/Floors Radloiogicaiiy Controiied^^^)

Floor From 16'-0" south of 133'-0" 0'-9" Yes column line 5 to column line 5 and from 1 to intersection with shield building wall

U.S. Nuclear Regulatory Commission ND-19-1351 Enclosure Page 13 of 13 Attachment B: Excerpt of COL Appendix C Table 3.3-1

1. The column lines and floor elevations are identified and included on Figures 3.3-1 through 3.3-13.

2. These wall (and floor) thicknesses have a construction tolerance of +/- 1 inch, except as noted and for exterior walls below grade where the tolerance is +12 inches, -1 inch. These tolerances are not applicable to the nuclear island basemat.

3. For walls that are part of structural modules, the concrete thickness also includes the steel face plates. Where faceplates with a nominal thickness of 0.5 inches are used in the construction of the wall modules, the wall thicknesses in this column apply. Where faceplates thicker than the nominal 0.5 inches are used in the construction of the structural wall modules, the wall thicknesses in the area of the thicker faceplates are greater than indicated in this column by the amount of faceplate thickness increase over the nominal 0.5 inches. Overlay plates are not considered part of the faceplates, and thus are not considered in the wall thicknesses identified in this column.

4. For floors with steel surface plates, the concrete thickness also includes the plate thickness.

5. Where a wall (or a floor) has openings, the concrete thickness does not apply at the opening.

6. N/A to ITAAC 3.3.00.02a.i.d.

7. The Wall or Section Description, Column Line information, and Floor Elevation or Elevation Ranges are provided as reference points to define the general location. The concrete thickness of an item intersecting other walls, roofs or floors at a designated location (e.g., column line) is not intended to be measured to the stated column line, but only to the point where the intersection occurs.

8. Where applicable, the upper wall portions extend to their associated roofs, which may vary in elevation, e.g., sloped roofs.

9. From one wall/floor section to another, the concrete thickness transitions from one thickness to another, consistent with the configurations in Figures 3.3-1 through 3.3-14.

10. N/A to ITAAC 3.3.00.02a.i.d.

11. This wall thickness has a tolerance of +4 inches, -1 inch above grade.

12. N/A to ITAAC 3.3.00.02a.i.d.

13. N/A to ITAAC 3.3.00.02a.i.d.

14. N/A to ITAAC 3.3.00.02a.i.d.

15. Reconciliation of construction deviations in the nuclear island structures from the thickness and tolerances specified in this table is included in the reconciliation reports, and demonstrate that the as-built structures will withstand design basis loads without loss of structural integrity or safety functions and without impacting compliance with the radiation protection licensing basis, such as GDC 19, established radiological zoning and equipment qualification in accordance with ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.d, 3.3.00.02a.i.d, or 3.3.00.02a.i.d.

16. N/A to ITAAC 3.3.00.02a.i.d.

17. N/A to ITAAC 3.3.00.02a.i.d.

18. Nonconformances from the thicknesses and tolerances specified in Table 3.3-1 (i.e. out of tolerance conditions) are addressed under the 10 CFR Part 50, Appendix B process and subsequently are screened in accordance with the 10 CFR Part 52, Appendix D, Section VIII process, to ensure that the licensing basis is adequately maintained. Construction deviations will continue to be assessed against the licensing basis requirements and will be addressed in accordance with licensee procedures and regulatory requirements and, if applicable, a license amendment will be obtained prior to implementation of the change.