ND-23-0030, ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.d (Index Number 763)

ITAAC Closure Notification on Completion of ITAAC 3.3.00.02a.i.d (Index Number 763)

ML23013A305
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-23-0030, ITAAC 3.3.00.02a.i.d
Download: ML23013A305 (1)

Text

A Southern Nuclear Jamie M. Coleman Regulatory Affairs Director Vogtle3&4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel January 13, 2023 Docket No.: 52-026 ND-23-0030 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.d [Index Number 763]

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 4 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item 3.3.00.02a.i.d [Index Number 763]. This ITAAC verified that a report exists and concludes that the as-built Auxiliary Building 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 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 s u b m i l t e ~

Ja

• M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC 3.3.00.02a.i.d [Index Number 763]

JMC/TUsfr

U.S. Nuclear Regulatory Commission ND-23-0030 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-23-0030 Enclosure Page 1 of 12 Southern Nuclear Operating Company ND-23-0030 Enclosure Vogtle Electric Generating Plant {VEGP) Unit 4 Completion of ITAAC 3.3.00.02a.i.d [Index Number 763]

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 2 of 12 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.d) 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 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 or 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 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:

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 3 of 12

• 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 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 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 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 through 5) exist and document the reconciliation of NI structural deviations identified during construction and concluded that the as-built structures in the 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 through 5) are available for NRC inspection as part of the Unit 4 ITAAC 3.3.00.02a.i.d Completion Package (Reference 6).

U.S. Nuclear Regulatory Commission N D-23-0030 Enclosure Page 4 of 12 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 seven (7) relevant ITAAC NRG findings associated with this ITAAC.

1.05200026/2016001-01 (Closed - ML19135A691)

2.05200026/2015002-01 (Closed - ML16032A554)

3. 99901448/2014-201-02 (Closed - ML17226A340)

4. 99901449/2014-201-02 (Closed - ML17226A340)

5. 99901425/2014-201-01 (Closed - ML18101A168)

6. 99901419/2012-201-03 (Closed - ML18131A260)

7. 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.d (Reference 6) and is available for NRG review.

ITAAC Completion Statement Based on the above information , SNC hereby notifies the NRG that ITAAC 3.3.00.02a.i.d 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. 0; Vogtle Unit #4 As-Built Summary Report: Nuclear Island Auxiliary Building.

4. SV4-101 0-GCR-001, Rev. 1, Vogtle Unit #4 As-Built Summary Report: Nuclear Island Basemat.

5. SV4-CA20-GCR-001 , Rev. 0, Vogtle Unit #4 As-Built Summary Report: CA20 Module.

6. 3.3.00.02a. i.d-U4-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-23-0030 Enclosure Page 5 of 12 Attachment A: Excerpt of COL Appendix C Table 3.3-7 Table 3.3-7 Nuclear Island Critical Structural Sections Auxiliary Building South wall of auxiliary Build ing (column line 1), elevation 66'-6" to elevation 180'-0" Divider Wall Between the spent fuel pool and the fuel transfer canal.

Nuclear Island Basemat Below Auxiliary Building Bay between reference column lines 1 and 2, and K2 and N

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 6 of 12 ATTACHMENT B Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildinas, Turbine Buildina, and Annex Building< 1>

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines<7> Elevation Ranae< 7H8> Thickness< 2H3H4H5 H9H18 > (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlled<15>

Column Line 1 wall From I to N From 66'-6" to 100'-0" 3'-0" No Column Line 1 wall From I to 5'-7" west of From 100'-0" to 109'-3" 2'-3" Yes K-2 Column Line 1 wall From 5'-7" west of K-2 From 100'-0" to 109'-3" 3'-0" Yes to N Column Line 1 wall From I to 5'-6" east of L- From 109'-3" to 180'-0" 2'-3" Yes 2

Column Line 1 wall From 5'-6" east of L-2 to From 109'-3" to 125'-0" 3'-0" Yes N

Column Line 1 wall From 5'-6" east of L-2 to From 125'-0" to 180'-0" 2'-3" Yes N

Column Line 2 wall From I to K-2 From 66'-6" to 135'-3" 2'-6" Yes Column Line 2 wall From K-2 to L-2 From 66'-6" to 135'-3" 5'-0" Yes Column Line 2 wall From L-2 to N From 82'-6" to 135'-3" 2'-6" Yes Column Line 2 wall From I to J-1 From 135'-3" to 153'-0" 2'-0" Yes Column Line 3 wall From J-1 to J-2 From 66'-6" to 82'-6" 2'-6" Yes Column Line 3 wall From J-1 to J-2 From 100'-0" to 135'-3" 2'-6" Yes Column Line 3 wall From J-2 to K-2 From 66'-6" to 135'-3" 2'-6" Yes Column Line 3 wall From K-2 to L-2 From 66'-6" to 92'-8 1/2" 2'-6" Yes Column Line 4 wall From I to J-1 From 66'-6" to 135'-3" 2'-6" Yes Column Line 4 wall From J-1 to J-2 From 66'-6" to 92'-6" 2'-6" Yes Column Line 4 wall From J-1 to J-2 From 107'-2" to 135'-3" 2'-6" Yes Column Line 4 wall From J-2 to K-2 From 66'-6" to 135'-3" 2'-6" Yes

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 7 of 12 ATTACHMENT B Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildinas, Turbine Building, and Annex Buildina< 1)

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Lines<7l Elevation Rangel 7H8l Thickness 12H3H4H5 H9H1a1 (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlledl 15l Column Line 4 wall From I to intersection From 135'-3" to 180'-0" 2'-0" Yes with shield buildina wall Column Line 5 wall From I to shield From 66'-6" to 160'-6" 2'-0" Yes building; with opening east of J-1 (below 107'-

2" floor).

Wall, 17'-3" north of Column From I to 8' east of J-1 From 66'-6" to 82'-6" 2'-0" Yes Line 7 Wall, 10'-6" south of Column From I to 5'-6"east of J- From 66'-6" to 82'-6" 2'-0" Yes Line 7.3 1 Wall, 10'-6" south of Column From I to just east of J From 82'-6" to 100'-0" 2'-0" Yes Line 7.3 Column Line I wall From 1 to 4 From 66'-6" to 100'-0" 3'-0" No Column Line I wall From 4 to 16'-0" south From 66'-6" to 107'-2" 3'-0" No of 5 Column Line I wall From 16'-0" south of 5 From 66'-6" to 105'-0" 3'-0" No to 5 Column Line I wall From 5 to 7.3 From 66'-6" to 100'-0" 3'-0" No Column Line I wall From 1 to 3 From 100'-0" to roof 2'-0" Yes Column Line I wall From 3 to 4 From 100'-0" to roof 2'-0" Yes Column Line I wall From 4 to 16'-0" south From 107'-2" to roof 2'-0" No of 5 Column Line I wall From 16'-0" south of 5 From 105'-0" to roof 2'-0" No to 5 Column Line J-1 wall From 1 to 2 From 82'-6" to 100'-0" 2'-0" Yes

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 8 of 12 ATTACHMENT B Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildinas, Turbine Building, and Annex Building< 1>

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Linesl l 7 Elevation Ranael7H 8l Thicknessl2H3H4H5H9)(1s1 (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlledl15l Column Line J-1 wall From 2 to 4 From 66'-6" to 135'-3" 2'-6" Yes Column Line J-1 wall From 2 to 4 From 135'-3" to 153'-0" 2'-0" Yes Column Line J-1 wall From 4 to shield From 66'-6" to 107'-2" 2'-0" Yes buildina Column Line J-2 wall From 2 to 4 From 66'-6" to 135'-3" 2'-6" Yes Column Line J-2 wall From 4 to intersection From 66'-6" to 135'-3" 2'-0" Yes with shield buildina wall Column Line K-2 wall From 2 to 4 From 66'-6" to 135'-3" 4'-9" Yes Column Line L-2 wall From 2 to 4 From 66'-6" to 135'-3" 4'-0" Yes Column Line N wall From 1 to 2 From 66'-6" to 100'-0" 3'-0" No Column Line N wall From 1 to 12'-9" north of From 100'-0" to 125'-0" 3'-9" Yes 1

Column Line N wall From 1 to 12'-9" north of From 125'-0" to 135'-3" 2'-0" Yes 1

Column Line N wall From 12'-9" north of 1 to From 100'-0" to 118'-2 3'-0" Yes 2 1/2" Column Line N wall From 12'-9" north of 1 to From 118'-2 1/2" to 135'- 2'-0" Yes 2 3" Column Line N wall From 2 to 4 (or to shield From 66'-6" to 98'-1" 5'-6" No buildina)

Column Line N wall From 2 to 4 (or to shield From 98'-1" to 135'-3" 5'-6" (11) Yes buildina)

Column Line N wall From 1 to 4 (or to shield From 135'-3" to 180'-0" 2'-0" Yes buildina)

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 9 of 12 ATTACHMENT B 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< 7H81 Thickness< 2H3H4H5H9H1s1 (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlled< 15>

Labyrinth Wall between Col. Not Applicable From 82'-6" to 92'-6" 2'-6" Yes Line 3 and 4 and J-1 to 5'-2" from J-2 N-S Shield Wall (low wall) 5'-7" west of column line From 100'-0" to 110'-0" 2'-6" Yes K-2 extending 16'-0" from column line 1 north N-S Shield Wall 2'-9" east of column line From 100'-0" to 109'-3" 3'-0" Yes L-2 extending 12'-9" from column line 1 north N-S Shield Wall 2'-9" east of column line From 109'-3" to 125'-0" 2'-9" Yes L-2 extending 12'-9" from column line 1 north E-W Shield Wall 10'-0" north of column From 100'-0" to 125'-0" 2'-9" Yes line 1 extending 13'-3" from column line N east Auxiliary Area Basemat From 1-7.3 and I-N , From 60'-6" to 66'-6" 6'-0" No excluding shield buildinq Floor From 1 to 2 and I to N 82'-6" 2'-0" Yes Floor From 2 to 4 and J-1 to 82'-6" 2'-0" Yes J-2 Floor From 4 north to the 82'-6" 0'-9" Yes shield building ending 17'-4" south of column line 5 and J-1 to J-2

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 10 of 12 ATTACHMENT B Table 3.3-1 Definition of Wall Thicknesses for Nuclear Island Buildinas, Turbine Building, and Annex Building< 1>

Applicable Radiation Shielding Wall or Section Floor Elevation or Concrete Wall Description Column Linesl7l Elevation Ranael7H8l Thicknessl 2H3H4H5H9 H1 s1 (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlledl 15l Pipe Chase Floor From 2 north to the 92'-6" 2'-0" Yes shield building ending 17'-4" south of column line 5 and J-1 to J-2 Floor From 2 to 3 and J-2 to 90'-3" 3'-0" Yes K-2 Floor From 3 to 4 and J-2 to 92'-6" 2'-0" Yes K-2 Floor From 4 to 7.3 and I to J- 82'-6" 2'-0" Yes 1

Floor From 1 to 2 and I to N 100'-0" 3'-0" Yes Floor From 2 to 4 and K-2 to 92'-8 1/2" 3'-2 1/2" Yes L-2 Floor From I to J-2 and 4 to 107'-2" 2'-0" Yes shield building and vertical wall 17'-0" south of column line 5 Floor From I to shield building 105'-0" 0'-9" Yes wall and from intersecting vertical wall before column line 5 to column line 5

U.S. Nuclear Regulatory Commission ND-23-0030 Enclosure Page 11 of 12 ATTACHMENT B 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 <2H3H4H5H9H18 > (Yes/No)

Auxiliary Building Walls/Floors Radiologically Controlled<15>

Floor From column line 1 to 125'-0" 3'-0" Yes 10'-0" north of column line 1 and from 2'-9" east of column line L-2 to N Floor From 12'-9" north of 118'-2 1/2" 2'-0" Yes column line 1 to 2 and from 2'-9" east of column line L-2 to N Floor From 3 to 4 and J-2 to 117'-6" 2'-0" Yes K-2 Floor From 2 to 4 and I to J-1 153'-0" 1'-3" Yes Roof From 1 to 4 and I to N 180'-0" to 180'-9" 1'-3" Yes Floor From 4 to 16'-0" south 135'-3" 0'-9" Yes of column line 5 and from I to intersection with shield buildinq wall Floor From 16'-0" south of 133'-0" 0'-9" Yes column line 5 to column line 5 and from I to intersection with shield buildinq wall

U.S. Nuclear Regulatory Commission N D-23-0030 Enclosure Page 12 of 12 ATTACHMENT B Notes

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.d.]

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 th ickness 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.d.]

11. This wall thickness has a tolerance of +4 inches, -1 inch above grade.

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

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

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

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.d.]

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

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.