ND-23-0029, 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)

ML23013A304
Person / Time
Site:	Vogtle
Issue date:	01/13/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0029, ITAAC 3.3.00.02a.i.c
Download: ML23013A304 (1)

Text

A Southern Nuclear Jamie M. Coleman Regulatory Affairs Director Vogtle 3 &4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel January 13, 2023 Docket No.: 52-026 ND-23-0029 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 4 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 ), the purpose of this letter is to notify the Nuclear Regulatory Commission (NRG) of the completion of Vogtle Electric Generating Plant (VEGP) Unit 4 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 structures in the non-radiological controlled area of the auxiliary building, including the critical sections, conform to the approved design and will withstand the design basis loads without loss of structural integrity or the safety-related functions, and without impacting compliance with the radiation protection licensing basis. 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 NRG in Regulatory Guide 1.215.

This letter contains no new NRG regulatory commitments. Southern Nuclear Operating Company (SNC) requests NRG 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,

~~

Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 3.3.00.02a.i.c_(lndex Number 762)

JMC/TUsfr

U.S. Nuclear Regulatory Commission ND-23-0029 Page 2 of 2 cc: Regional Administrator, Region II Director, Office of Nuclear Reactor Regulation (NRR)

Director, Vogtle Project Office NRR Senior Resident Inspector - Vogtle 3 & 4

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 1 of 9 Southern Nuclear Operating Company ND-23-0029 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 3.3.00.02a.i.c [Index Number 762]

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 2 of 9 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.

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 (NI) structures, including the critical sections listed in VEGP Unit 4 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 4 COL Appendix C Section 3.3 Design Description, without loss of structural integrity and the safety-related functions. In addition, multiple ITAAC were performed on walls and floors of the NI 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 4 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-23-0029 Enclosure Page 3 of 9

• 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 NI Structures. Section 3.8 specifies the applicable codes and standards governing the design, materials, fabrication, construction inspection and testing for the NI 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 structures in the non-radiologically controlled area of the auxiliary building, including the critical sections, listed in Attachment A, and walls and floors of the NI 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 4 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-radiologically controlled area of the auxiliary building, including the critical sections, listed in Attachment A, and walls and floors of the NI 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 Reports (References 3 and 4) exist and document the reconciliation of NI structural deviations identified during construction and concluded that the as-built structures in the non-radiologically controlled area of the auxiliary building, including the critical sections and walls and floors of the NI 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 4 Principal Closure Documents (References 3 and 4) are available for NRC inspection as part of the Unit 4 ITAAC 3.3.00.02a.i.c Completion Package (Reference 5).

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 4 of 9 ITAAC Finding Review In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all lTAAC findings pertaining to the subject ITAAC and associated corrective actions. This review found that there are three (3) relevant ITAAC NRC findings associated with this ITAAC.

1.05200026/2015002-01 (Closed - ML16032A554)

2. 99901419/2012-201-03 (Closed- ML18131A260)

3. 99901409/2011-201-03 (Closed - ML18186A573)

The corrective actions for each finding have been completed and each finding is closed. The ITAAC completion review is documented in the ITAAC Completion Package for ITAAC 3.3.00.02a.i.c (Reference 5) 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 4 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 (available for NRC inspection)

1. VEGP Unit 4 COL, Amendment 187

2. VEGP 3&4 Updated Final Safety Analysis Report, Rev. 11.1

3. SV4-1200-GCR-003, Rev. O; Vogtle Unit #4 As-Built Summary Report: Nuclear Island Auxiliary Building.

4. SV4-1010-GCR-001, Rev. 1, Vogtle Unit #4 As-Built Summary Report: Nuclear Island Basemat.

5. 3.3.00.02a.i.c-U4-CP-Rev0, ITAAC Completion Package

U.S . Nuclear Regulatory Commission N D-23-0029 Enclosure Page 5 of 9 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building Interior wall 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 Kand L

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 6 of 9 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< 1>

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines<7 > Elevation Range( 7H9l Thickness(2H3H4l( 5H9l( 1s1 {Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically Controlled< 15>

Column Line 11 wall From I to Q From 66'-6" to 100'-0" 3'-0" No Column Line 11 wall From I to Q From 100'-0" to 117'-6" 2'-0" Yes Column Line 11 wall From I to L From 117'-6" to roof 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 I to shield building From 66'-6" to 100'-0" 3'-0" Yes Column Line 7.3 wall From I to shield building From 100'-0" to roof 2'-0" No Column Line I wall From 7.3 to 11 From 66'-6" to 100'-0" 3'-0" No Column Line I wall

• From 5 to 11 From 100'-0" 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 wall to11 Column Line Q wall From shield building From 66'-6" to 100'-0" 3'-0" No wall to11

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 7 of 9 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< 1l Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines(7) Elevation Range< 7H8l Thickness< 2H3 H4 H5 H9 H191 (Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically Controlled<15l Column Line Q wall From shield building From 100' -0" to roof 2'-0" Yes wall to 11 Column Line 9.2 wall From I 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 1-Q, From 60' -6" to 66' -6" 6'-0" No excluding shield building Floor From 5 to 10' -6" south 100'-0" 2'-0" Yes of 7 .3 and I to shield building wall Floor From 10' -6" south of 100'-0" 3'-0" Yes 7.3 to 7.3 and I to shield building wall Floor From K to L and shield 100'-0" 0'-9" Yes building wall to column line 10 Main Control Room Floor From 9.2 to 11 and I to 117'-6" 2'-0" Yes L

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

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 8 of 9 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< 1 >

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines< 7> Elevation Range<7H8> Thickness<2H3)(4)(5)(9)(1a, {Yes/No)

Auxiliary Building Walls/Floors Non-Radiologically Controlled< 15>

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

U.S. Nuclear Regulatory Commission ND-23-0029 Enclosure Page 9 of 9 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 th ickness 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.i.c.]

11 . [N/A to ITAAC 3.3.00.02a.i.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 th is 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.c.]

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