ND-21-0271, ITAAC Closure Notification on Completion of ITAAC 2.6.09.05c (Index Number 646)

ITAAC Closure Notification on Completion of ITAAC 2.6.09.05c (Index Number 646)

ML22049A543
Person / Time
Site:	Vogtle
Issue date:	02/18/2022
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-21-0271
Download: ML22049A543 (6)

Text

A Southern C<<..+ Nuclear MichaelJ.Yox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle3&4 706-848-6459 tel FEB 1 8 2022 Docket No.: 52-025 ND-21-0271 10 CFR 52.99(c)(1)

U.S. Nuclear Regulatory Commission Document Control Desk Washiington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 ITAAC Closure Notification on Completion of ITAAC 2.6.09.05c Flndex Number 6461 Ladies and Gentlemen:

In accordance with 10 CFR 52.99(c)(1), the purpose of 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 2.6.09.05c [Index Number 646]. This ITAAC confirms that the central and secondary alarm stations are designed and equipped such that, in the event of a single act, in accordance with the design basis threat of radiological sabotage, equipment needed to maintain the functional capability of either alarm station to detect and assess alarms and communicate with onsite and offsite response personnel exists.

The closure process for this ITAAC is based on the guidance described in Nuclear Energy Institute (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 Roberts at 706-848-6991.

Respectfully submitted, Michael J. Vox ^

Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 2.6.09.05c [Index Number 646]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-21-0271 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. Peter P. Sena III Mr. D. L. McKlnney Mr. H. Nieh Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. J. B. Williams 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 Regulatory Commission Ms. M. Bailey Mr. M. King Mr. G. Bowman Ms. A. Veil Mr. C. P. Patel Mr. G. J. Khouri Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. O. Lopez-Santiago Mr. G. Armstrong Mr. M. Webb Mr. T. Fredette Mr. C. Santos Mr. B. Davis Mr. J. Vasquez Mr. J. Eargle Mr. T. Fanelli Ms. K. McCurry Mr. J. Parent Mr. B. Griman Mr. V. Hall

U.S. Nuclear Regulatory Commission ND-21-0271 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 Eiectric Company. LLC Dr. L. Oriani Mr. D. C. 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., CDS 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-21-0271 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-21-0271 Enclosure Vogtle Electric Generating Plant(VEGP) Unit 3 Completion of ITAAC 2.6.09.05c [Index Number 646]

U.S. Nuclear Regulatory Commission ND-21-0271 Enclosure Page 2 of 3 ITAAC Statement Design Commitment 5.C) The central and secondary alarm stations are designed and equipped such that, in the event of a single act, in accordance with the design basis threat of radiological sabotage, the design enables the survivability of equipment needed to maintain the functional capability of either alarm station to detect and assess alarms and communicate with onsite and offsite response personnel.

Inspections/Tests/Analvses Inspections and/or analysis of the central and secondary alarm station will be performed.

Acceptance Criteria The central and secondary alarm stations are designed and equipped such that, in the event of a single act, in accordance with the design basis threat of radiological sabotage, equipment needed to maintain the functional capability of either alarm station to detect and assess alarms and communicate with onsite and offsite response personnel exists.

ITAAC Determination Basis Inspections and analysis of the central alarm station (CAS)and the secondary alarm station (SAS) were performed to verify CAS and SAS are designed and equipped such that, in the event of a single act, in accordance with the design basis threat of radiological sabotage, equipment needed to maintain the functional capability of either alarm station to detect and assess alarms and communicate with onsite and offsite response personnel exists and satisfies the applicable single act, design basis threat requirements of the VEGP Unit 3 and Unit 4 Physical Security Plan associated with 10 CFR 73.55(i)(4)(i). The VEGP Unit 3 Plant Security System ITAACs only cover the Unit 3 plant security system design commitment scope. The CAS and SAS are designed to be functionally equivalent and redundant, such that the functions needed to detect and assess alarms, and initiate response of both onsite and offsite security forces, is available in each location. The redundant design and spatial separation of CAS and SAS assure that no single act by the design basis threat described in 10 CFR 73.1(a)(1) and detailed in Regulatory Guide 5.69(Reference 1) would disable both alarm stations.

Reference 2 performed a standard plant single act design assessment of CAS and SAS to verify that the API000 standard plant is protected against the single act in accordance with the design basis threat of radiological sabotage as required by 10 CFR 73.55(i)(4)(i). The assessment concluded that at least one alarm station maintains the ability to detect and assess alarms, initiate and coordinate an adequate response to an alarm, summon offsite assistance, and provide command and control.

Reference 3 performed a site-specific assessment of VEGP Unit 3 to confirm that no single act, in accordance with the design basis threat of radiological sabotage, can disable the function of both CAS and SAS as required by 10 CFR 73.55(i)(4)(i).

ITAAC Technical Report SV3-SES-ITR-800646 (Reference 4) documents inspections performed of the as-built physical security system using construction drawings, testing documentation, and walkdowns to assess CAS/SAS structure location and layout, security computer location, intrusion detection equipment, alarm and assessment equipment, security system data and power supply/backup power supply infrastructure, onsite and offsite security communications equipment.

U.S. Nuclear Regulatory Commission ND-21-0271 Enclosure Page 3 of 3 security command and control communications equipment, and component redundancy to verify that the as-built physical security system installation is consistent with the Reference 2 standard plant physical security system design assessment assumptions, as modified by the Reference 3 site-specific assessment.

The inspection and analysis results are documented in References 2 through 4 and verify that CAS and SAS are designed and equipped such that, in the event of a single act, in accordance with the design basis threat of radiological sabotage, equipment needed to maintain the functional capability of either alarm station to detect and assess alarms and communicate with onsite and offsite response personnel exists.

References 2 through 4 are available for NRC inspection as part of the Unit 3 ITAAC 2.6.09.05c Completion Package (Reference 5).

ITAAC Finding Review 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 were no relevant ITAAC findings associated with this ITAAC. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 2.6.09.05c (Reference 5) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC 2.6.09.05c was performed for VEGP Unit 3 and that the prescribed acceptance criteria was 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(available for NRC inspection)

1. Regulatory Guide 5.69, Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development and Implementation of a Physical Security Program that Meets 10 CFR 73.55 Requirements, Rev 0(Safeguards Information)

2. APP-SES-ZOC-001, CAS & SAS Single Act Assessment, Rev 1 (Security Related Information)

3. SVO-SES-ZOC-800000, Vogtle Site CAS and SAS Single Act Assessment, Rev 0,(Security Related Information)

4. SV3-SES-ITR-800646, SES Alarm Stations Single Act Survivability: ITAAC 2.6.09.05c, Rev 0, (Security Related Information)

5. 2.6.09.05c-U3-CP-Rev0, ITAAC Completion Package