ND-22-0092, ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.b (Index Number 761)

ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.b (Index Number 761)

ML22054A216
Person / Time
Site:	Vogtle
Issue date:	02/23/2022
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-22-0092
Download: ML22054A216 (11)

Text

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Southern Nuclear FEB 2 3 2022 Michael J. Yox Regulatory Affairs Director Vogtle 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6459 tel Docket No.: 52-025 ND-22-0092 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.b [Index Number 7611 Ladles 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 3.3.00.02a.I.b [Index Number 761]. This ITAAC verified that a report exists and concludes that the as-bullt shield building structures. Including the critical sections, conform to the approved design with deviations reconciled such that It will withstand design basis loads without loss of structural Integrity, safety-related functions, and 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.

Southern Nuclear Operating Company (SNC) previously submitted ITAAC Closure Notification for Completion of ITAAC 3.3.00.02a.l.b [Index Number 761] ND-20-1378 [ML21342A138], dated December 08, 2021. This resubmlttal supersedes ND-20-1378 In Its entirety.

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 Kelll A. Roberts at 706-848-6991.

Respectfully submitted.

Michael J. Yc Regulatory Affairs/Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 3.3.00.02a.I.b [Index Number 761]

MJY/JFV/sfr

U.S. Nuclear Regulatory Commission ND-22-0092 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. 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 Nuclear Requlatorv Commission Ms. M. Bailey M

M Ms. A. Veil M

M M

M

. M. King

. G. Bowman C. P. Patel G. J. Khouri C. J. Even 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-22-0092 Page 3 of 3 Qqiethorpe 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., 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-22-0092 Enclosure Page 1 of 8 Southern Nuclear Operating Company ND-22-0092 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 Completion of ITAAC 3.3.00.02a.l.b [Index Number 761]

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 2 of 8 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 ioads 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. Analvsis 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.b) A report exists which reconciles deviations during construction, including Table 3.3-1 wall and floor thicknesses, and concludes that the as-built shield building structures, 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 Muitipie ITAAC are 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 are 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 and the safety-related functions. In addition, muitipie 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 shield building structures, 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:

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

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 3 of 8 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 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-built design summary reports which document that the seismic Category I structures meet the specified acceptance criteria.

Radiation zone and equipment qualification requirements were 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 shield building structures, 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 and were constructed as designed and as 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 shield building structures, 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-built 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-Built Summary Report (Reference 3) exists and documents the reconciliation of Nl structural deviations identified during construction and concluded that the as-built shield building structures, 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.

The Unit 3 Principal Closure Closure Document, Reference 3, is available for NRC inspection as part of the ITAAC 3.3.00.02a.i.b Completion Package (Reference 4).

ITAAC Finding 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 six (6) relevant ITAAC NRC findings associated with this ITAAC and are listed below.

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 4 of 8

1.05200025/2015002-01 (Closed - ML16032A554)

2.05200025/2012008-01 (Closed - ML12319A458)

3.05200025/2016004-02 (ML17044A539, Withdrawn by NRC, letter dated 12/10/2020 -

ML20345A348)

4. 99901419/2012-201-03 (Closed -

ML18131A260)

5. 99901409/2011 -201-03 (Closed -

ML18186A573)

6. Failure to demonstrate that the ITAAC 761 Acceptance Criteria was met when the original ICN (now withdrawn) was submitted - this finding was related to construction deviations that were not repaired or reconciled in the as-built shield building report. This issue was corrected, an extent of condition was performed, and no other issues were discovered. The as-built shield building report has been revised to demonstrate that the Acceptance Criteria was met.

The corrective actions for findings 1 through 5 have been completed and each finding is closed.

The corrective action for finding six (6) has been completed and the finding was closed by the NRC at the exit meeting. The formal closure will be documented in the next NRC report. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 3.3.00.02a.i.b (Reference 4) 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.b 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 favailable for NRC inspection)

1.

VEGP Unit 3 COL Appendix C, Amendment 188.

2.

VEGP 3&4 UFSAR, Revision 10.1.

3.

SV3-1208-GCR-001, Rev. 2, "Vogtle Unit #3 As-Built Summary Report: Shield Building".

4.

3.3.00.02a.i.b-U3-CP-Rev1, ITAAC Completion Package.

5.

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

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 5 of 8 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Shield Buildino Roof slab at elevation 180'-0" adjacent to shield building cylinder Shield building roof, exterior wall of the PCS water storage tank Shield building roof, interior wall of the PCS water storage tank Shield building roof, tension ring and air inlets Shield building SC cylinder Shield building SC to RC connection

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 6 of 8 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^^)

Wall or Section Description Column Lines^^)

Floor Elevation or Elevation Range<^'<>

Concrete Applicable Radiation Shielding Waii (Yes/No)

Shielding Buiidingt^'^i^)

Shielding Building Cylinder Not Applicable From lOO'-O" to 248'-6" 3'-0" (including 3/4 inch thick min. steel plate liner on each face on portion not protected by auxiliary building)

Yes Air Inlet Not Applicable From 248'-6" to 251'-6" 3'-0" (including 3/4 inch thick min. steel plate liner on each face)

Yes From 251'-6"to 254'-6" 3'-0" to 4'-6" (including 1 inch thick steel plate liner on each face)

Yes From 254'-6" to 266'-4" 4'-6" (including 1 inch thick min. steel plate liner on each face)

Yes Tension Ring Not Applicable From 266'-4" to 271'-6" (at top of plate) 4'-6" (including 1-1/2 inch thick steel plate liner on each face)

Yes Conical Roof Not Applicable From 271'-6" to 293'-9" 3'-0" (including 1/2 inch thick min. steel plate liner on bottom face, outside of PCS tank exterior wall)

Yes

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 7 of 8 Attachment B: Excerpt of COL Appendix C Tabie 3.3-1 Table 3.3-1 Definition of Waii Thicknesses for Nuciear island Buildings, Turbine Building, and Annex Buiiding^^)

Wall or Section Description Column Lines^^)

Floor Elevation or Elevation Range<^

Concrete Applicable Radiation Shielding Waii (Yes/No)

Shielding Buiiding'^x^^)

PCS Tank External Cylindrical Wall Not Applicable From 293'-9" to 328'-9" 2'-0" Yes PCS Tank Internal Cylindrical Wall Not Applicable From 309'-4" to 329'-0" 1'-6" Yes PCS Tank Roof Not Applicable 328'-9" (Lowest) 329'-0" (Highest) 1'-3" No Nuclear Island Basemat Below shield building From 60'-6" to containment vessel or 82'-6" S'-C'd") to 22'-0" (varies)

No

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.

The elevation ranges for the shield building items are rounded to the nearest inch.

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.

U.S. Nuclear Regulatory Commission ND-22-0092 Enclosure Page 8 of 8 Attachment B: Excerpt of COL Appendix C Table 3.3-1

9.

From one wail/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.b.

11.

N/A to ITAAC 3.3.00.02a.i.b.

12.

N/A to ITAAC 3.3.00.02a.i.b.

13.

N/A to ITAAC 3.3.00.02a.i.b.

14. The 6-foot concrete thickness includes the thickness of the containment vessel bottom head in a local area at the center of containment.

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

16.

N/A to ITAAC 3.3.00.02a.i.b.

17.

N/A to ITAAC 3.3.00.02a.i.b.

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.