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 Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 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 - MLI 4087A320)

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.

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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