ND-20-1440, ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.c (Index Number 762)

ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.c (Index Number 762)

ML21270A044
Person / Time
Site:	Vogtle
Issue date:	09/24/2021
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ITAAC 3.3.00.02a.i.c, ND-20-1440
Download: ML21270A044 (13)

Text

Michael J. Yox 7825 River Road Sk. Southern Nuclear Regulatory Affairs Director Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel SEP 2 4 2021 Docket No.: 52-025 ND-20-1440 10 CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.c (Index Number 762]

Ladies and Gentlemen:

In accordance with 10 CFR 52.99(c)(1), this letter is to notify the Nuclear Regulatory Commission (NRC) of the completion of Vogtle Electric Generating Plant(VEGP) Unit 3 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 3.3.00.02a.i.c [Index Number 762]. This ITAAC verified that a report exists and concludes that the as-built Auxiliary Building non-radiological area structures, including critical sections, conform to the approved design and will withstand design basis loads without loss of structural integrity, safety-related functions, or radiation protection. The closure process for this ITAAC is based on 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.

This letter contains no new NRC regulatory commitments. Southern Nuclear Operating Company (SNC) requests NRC staff confirmation of this determination and publication of the required notice in the Federal Register per 10 CFR 52.99.

If there are any questions, please contact Kelli A. Roberts at 706-848-6991.

Respectfully submitted, Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 3.3.00.02a.i.c [Index Number 762]

MJY/JFV/sfr

U.S. Nuclear Regulatory Commission ND-20-1440 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III Mr. D. L. McKinney Mr. H. Nieh Mr. M. D. Meier Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Ms. J.M. Coleman Mr. C. T. Defnall Mr. C. E. Morrow Mr. K. J. Drudy Mr. J. M. Fisher Mr. R. L. Beiike Mr. S. Leighty Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reaulatorv Commission Ms. M. Bailey Mr. M. King Mr. G. Bowman Ms. A. Veil M . C. P. Patel M . G. J. Khouri M . C. J. Even M B. J. Kemker Ms. N. C. Coovert M C. Welch M J. Gaslevic M O. Lopez-Santiago M G. Armstrong M M. Webb M T. Fredette M C. Santos M B. Davis M . J. Vasquez M . J. Eargle M E. Davidson M . T. Fanelli Ms. K. McCurry M . J. Parent M B. Griman

U.S. Nuclear Regulatory Commission ND-20-1440 Page 3 of 3 Qqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinqhouse Electric Company. LLC Dr. L. Oriani Mr. D. 0. Durham Mr. M. M. CorlettI Mr. Z. 8. Harper Mr. J. L. Coward Other Mr. 8. W. Kline, 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 Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 1 of 10 Southern Nuclear Operating Company ND-20-1440 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 3.3.00.02a.i.c [Index Number 762]

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 2 of 10 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.) Wails 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.

inspections. Tests. Analysis 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.c) 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 non-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 Determination Basis Multiple ITAAC were performed to demonstrate that the Nuclear Island (Nl) structures, including the critical sections listed in VEGP Unit 3 Combined License(COL) Appendix C (Reference 1)

Table 3.3-7(Attachment A), are seismic Category I and were designed and constructed to withstand design basis loads as specified in the VEGP Unit 3 COL Appendix C Section 3.3 Design Description, without loss of structural integrity or the safety-related functions. In addition, multiple ITAAC were 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 verified inspections of the as-built structures in the non-radiologically controlled area of the auxiliary building, including the critical sections and Table 3.3-1 wall and floor thicknesses, and reconciled 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-20-1440 Enclosure Page 3 of 10

• 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 2), 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 non-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 were 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 non-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 were Inspected during construction to verify the as-bullt structures conform to the specified design, codes and standards. Construction Identified structural deviations were 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 3 through 5) exist and document the reconciliation of Nl structural deviations Identified during construction and concluded that the as-bullt structures In the non-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 Principle Closure Documents (References 3 through 5) are available for NRG Inspection as well as the Unit 3 ITAAC 3.3.00.02a.l.c Completion Package (Reference 6).

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 4 of 10 ITAAC Findings Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company(SNC) performed a review of all ITAAC findings pertaining to the subject ITAAC and associated corrective actions. This review found that there are eleven (11) relevant ITAAC NRC findings associated with this ITAAC.

1.05200025/2015002-01 (Closed - ML16032A554)

2.05200026/2015002-01 (Closed - ML16032A554)

3.05200025/2013004-01 (Closed - MLI4087A320)

4.05200025/2013003-01 (Closed - ML13207A241)

5.05200025/2013002-01 (Closed - ML13207A241)

6.05200025/2012004-02 (Closed- ML14024A594)

7.05200025/2012008-01 (Closed - ML12319A458)

8.05200025/2012008-02 (Closed- ML12319A458)

9. 99901419/2012-201-03(Closed- ML18131A260)

10. 99901409/2011-201-03(Closed - ML18186A573)

11. N RC I nspection Report 05200025/2021003(Open - M L21221A034)

The corrective actions for each finding have been completed and each finding is closed except for item 11. This inspection report (item 11) addresses a Licensee-Identified Non-Cited Violation (LIV) where the licensee identified that a subcontractor, who was not qualified to drill penetrations and install material into a Safety Class C concrete structures under a license approved Appendix B Quality Assurance Program, had installed concrete expansion anchors on the roof of the Unit 3 auxiliary building to secure sheet metal edge boxes. This condition was processed through SNC's Corrective Action Program which included an extent of condition review and implementation of corrective actions to mitigate recurrence. The corrective actions are completed. In addition, the condition was evaluated by the design authority for structural impact and it was concluded that the expansion anchor penetrations were insignificant in comparison to the robust structure. Therefore, the condition was screened out of the structural reconciliation report(Reference 3). The ITAAC completion review is documented in the IT/\AC Completion Package for ITAAC 3.3.00.02a.i.c (Reference 6) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 3.3.00.02a.i.c was performed for VEGP Unit 3 and that the prescribed acceptance criteria were met.

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

References favallable for NRC Inspection)

1. VEGP Unit 3 COL, Amendment 186

2. VEGP 3&4 UFSAR, Revision 10.1

3. SV3-1200-GCR-001, Rev. 2; Vogtle Unit #3 As-Built Summary Report: Nuclear Island Auxiliary Building.

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 5 of 10

4. SV3-1010-GCR-001, Rev. 2,"Vogtle Unit #3 As-Built Summary Report: Nuclear Island Basemaf.

5. SV3-CA20-GCR-001, Rev. 1,"Vogtle Unit #3 As-Built Summary Report: CA20 Module".

6. 3.3.00.02a.i.c-U3-CP-Rev0, ITAAC Completion Package

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

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 6 of 10 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building interior wail of auxiliary building (column line 7.3), elevation 66'-" to elevation 160'-6" West wall of main control room in auxiliary building (column line L), elevation 117'-6" to elevation 153'-0" North wall of MSIV east compartment(column line 11 between lines Land M), elevation 117'-6"to elevation 153'-0" Floor slab on metal decking at elevation 135'-3" 2'-0" slab in auxiliary building (tagging room ceiling) at elevation 135'-3" Finned floor in the main control room at elevation 135'-3" Nuclear Island Basemat Below Auxiliary Building Bay between reference column lines 9.1 and 11, and K and L

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 7 of 10 Attachment B: Excerpt of COL Appendix C Table Table 3.3-1 Definition of Wail Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^^^

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

Thlckness'^"^"'""

Auxiliary Building Walls/Floors Non-Radlologlcally <Controlled<^)

Column Line 11 wall From 1 to Q From 66'-6" to lOO'-O" 3'-0" No Column Line 11 wall From 1 to Q From 100'-0"to 117 2'-0" Yes Column Line 11 wall From 1 to L From 117'-6"toroof 2'-0" Yes Column Line 11 wall From L to M From 117'-6"to 135'-3" 4'-0" Yes Column Line 11 wall From M to P From 117*-6"to 135*-3" 2'-0" Yes Column Line 11 wall From P to Q From 117'-6"to 135'-3" 4'-0" Yes Column Line 11 wall From L to Q From 135-3" to roof 2'-0" Yes Column Line 7.3 wall From 1 to shield building From 66'-6" to 10O'-O" 3'-0" Yes Column Line 7.3 wall From 1 to shield building From lOO'-O" to roof 2'-0" No Column Line 1 wall From 7.3 to 11 From 66'-6" to lOO'-O" 3'-0" No Column Line 1 wall

• From 5 to 11 From 10O'-O" to roof 2'-0" No Column Line J wall From 7.3 to 11 From 66*-6"to 117*-6" 2'-0" No Column Line K wall From shield building From 66'-6"to 135'-3" 2'-0" Yes wall to 11 Column Line L wall From shield building From 66'-6" to roof 2'-0" Yes wall to 11 Column Line M wall From shield building From 66'-6" to roof 2'-0" Yes wall to 11 Column Line P wall From shield building From 66-6" to roof 2'-0" Yes walltol 1 Column Line Q wall From shield building From 66'-6"to lOO'-O" 3'-0" No walltol 1

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 8 of 10 Attachment B: Excerpt of COL Appendix C Table 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 Wail Description Column Lines^ Elevation Range<^'<> (Yes/No)

Auxiliary Building Wails/Floors Non-Radiologically 1Controlled<^'

Column Line Q wall From shield building From lOO'-O" to roof 2'-0" Yes wall to 11 Column Line 9.2 wall From 1 to J and K to L From 117'-6"to 135'-3" 2'-0" Yes Labyrinth Wall between J to K From 117'-6"to 135'-3" 2'-0" Yes Column Line 7.3 and 9.2 and J to K Auxiliary Area Basemat From 7.3-11 and l-Q, From 60'-6" to 66'-6" 6'-0" No excluding shield building Floor From 5 to 10'-6" south lOO'-O" 2'-0" Yes of 7.3 and 1 to shield building wall Floor From 10'-6" south of lOO'-O" 3'-0" Yes 7.3 to 7.3 and 1 to shield building wall Floor From K to L and shield lOO'-O" 0'-9" Yes building wall to column line 10 Main Control Room Floor From 9.2 to 11 and 1 to 117'-6" 2'-0" Yes L

Floor Bounded by shield 117'-6" 2'-0" Yes bidg, 7.3, J, 9.2 and L Floor From shield building to 117'-6" 2'-0" Yes 11 and L to Q

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 9 of 10 Attachment B: Excerpt of COL Appendix C Table 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)

Auxiliarv Buildina Walls/Floors Non-RadioloaicallvControlled^^^)

Floor From 5 to 7.3 and from 135"-3" 0'-9" Yes 1 to intersection with shield building wali

U.S. Nuclear Regulatory Commission ND-20-1440 Enclosure Page 10 of 10 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.c.]

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.l.c.]

11. [N/A to ITAAC 3.3.00.02a.l.c.]

12. [N/A to ITAAC 3.3.00.02a.i.c.]

13. [N/A to ITAAC 3.3.00.02a.i.c.]

14. [N/A to ITAAC 3.3.00.02a.i.c.]

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.b, 3.3.00.02a.l.c, or 3.3.00.02a.i.d.

16. [N/A to ITAAC 3.3.00.02a.i.c.]

17. [N/A to ITAAC 3.3.00.02a.l.c.]

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.