ND-23-0121, ITAAC Closure Notification on Completion of ITAAC C.2.6.09.07 (Index Number 667)

ITAAC Closure Notification on Completion of ITAAC C.2.6.09.07 (Index Number 667)

ML23195A120
Person / Time
Site:	Vogtle
Issue date:	07/14/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Document Control Desk
References
ITAAC C.2.6.09.07, ND-23-0121
Download: ML23195A120 (1)

Text

Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4 7825 River Road Waynesboro, GA 30830 706-848-6926 tel July 14, 2023 Docket No.:

52-026 ND-23-0121 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 C.2.6.09.07 [Index Number 667]

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 C.2.6.09.07 [Index Number 667]. This ITAAC confirms that vital equipment is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

This ITAAC also confirms that all vital equipment is located only within a vital area and that vital equipment is located within a protected area such that access to vital equipment requires passage through the vital area barrier. 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, Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC C.2.6.09.07 [Index Number 667]

JMC/SRV/sfr

U.S. Nuclear Regulatory Commission ND-23-0121 Page 2 of 2 cc:

Regional Administrator, Region ll Director, Office of Nuclear Reactor Regulation (NRR)

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

U.S. Nuclear Regulatory Commission ND-23-0121 Enclosure Page 1 of 4 Southern Nuclear Operating Company ND-23-0121 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 4 Completion of ITAAC C.2.6.09.07 [Index Number 667]

U.S. Nuclear Regulatory Commission ND-23-0121 Enclosure Page 2 of 4 ITAAC Statement Design Commitment

7. Access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

7.a) Vital equipment is located only within a vital area.

7.b) Access to vital equipment requires passage through the vital area barrier.

Inspections/Tests/Analyses Inspection will be performed to confirm that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

Inspection will be performed to confirm that vital equipment is located within a vital area Inspection will be performed to confirm that access to vital equipment requires passage through the vital area barrier.

Acceptance Criteria Vital equipment is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

All vital equipment is located only within a vital area.

Vital equipment is located within a protected area such that access to vital equipment requires passage through the vital area barrier.

ITAAC Determination Basis Inspections were performed to verify that access to vital equipment physical barriers requires passage through the protected area perimeter barrier, vital equipment is located only within a vital area, and access to vital equipment requires passage through the vital area barrier. The inspections confirm that the applicable vital equipment location requirements of the VEGP Units 1 - 4 Physical Security Plan associated with 10 CFR 73.55(e)(9)(i) are satisfied. The VEGP Unit 4 Plant Security System ITAACs only cover the Unit 4 plant security system design commitment scope. The Unit 4 list of vital equipment is based on the AP1000 standard design vital equipment list (Reference 1), as modified by the site-specific Vogtle Unit 3 & 4 Vital Equipment List (Reference 2). The Unit 4 vital areas are identified in the VEGP Units 1 - 4 Physical Security Plan (Reference 3).

Vital equipment is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

An inspection was performed per ITAAC Technical Report SV4-SES-ITR-800667 (Reference 4) to confirm that access to the Unit 4 vital equipment located in vital equipment physical barriers requires passage through the Unit 4 protected area perimeter barrier. The inspection used the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 1 - 4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that access to vital equipment located in vital equipment physical barriers (vital area barriers) requires passage

U.S. Nuclear Regulatory Commission ND-23-0121 Enclosure Page 3 of 4 through the protected area perimeter barrier. The inspection confirmed that access to the vital equipment identified in Reference 2 requires passage through at least two physical barriers, i.e.,

the protected area barrier and a vital area barrier.

The inspection results are documented in Reference 4 and verified that the Unit 4 vital equipment is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

All vital equipment is located only within a vital area.

An inspection was performed per Reference 4 to confirm that all Unit 4 vital equipment is located only within a Unit 4 vital area. The inspection used the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 1 - 4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that all vital equipment is located only within a vital area.

The inspection results are documented in Reference 4 and verified that all Unit 4 vital equipment is located only within a vital area.

Vital equipment is located within a protected area such that access to vital equipment requires passage through the vital area barrier.

An inspection was performed per Reference 4 to confirm that all Unit 4 vital equipment is located within a Unit 4 protected area such that access to vital equipment requires passage through the vital area barrier. The inspection used the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 1-4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that vital equipment is located within a protected area such that access to vital equipment requires passage through a vital area barrier.

The inspection results are documented in Reference 4 and verified that Unit 4 vital equipment is located within a protected area such that access to vital equipment requires passage through the vital area barrier.

Reference 4 is available for NRC inspection as part of the Unit 4 ITAAC C.2.6.09.07 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 C.2.6.09.07 (Reference 5) and is available for NRC review.

ITAAC Completion Statement Based on the above information, SNC hereby notifies the NRC that ITAAC C.2.6.09.07 was performed for VEGP Unit 4 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.

U.S. Nuclear Regulatory Commission ND-23-0121 Enclosure Page 4 of 4 References (available for NRC inspection)

1. APP-SES-M3C-001, AP1000 Vital Equipment List, Rev 1 (Safeguards Information)

2. Unit 3 & 4 Vital Equipment List, 9/7/2021, (Security Related Information)

3. VEGP Units 1 - 4 Physical Security Plan, Version 18-VEGP-3 (Safeguards Information)

4. SV4-SES-ITR-800667, Vital Equipment Location and Access Inspection, Rev 0 (Security Related Information)

5. C.2.6.09.07-U4-CP-Rev0, ITAAC Completion Package