ML21224A183

NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004

ML21224A183
Person / Time
Site:	Vogtle
Issue date:	08/12/2021
From:	Bradley Davis NRC/RGN-II/DCI/CIB2
To:	Yox M Southern Nuclear Operating Co
References
IR 2021004
Download: ML21224A183 (37)

Text

August 12, 2021 Mr. Michael Yox Regulatory Affairs Director Southern Nuclear Operating Company 7825 River Road, BIN 63031 Waynesboro, GA 30830

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - NRC INITIAL TEST PROGRAM AND OPERATIONAL PROGRAMS INTEGRATED INSPECTION REPORTS 05200025/2021004, 05200026/2021004

Dear Mr. Yox:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 3 and 4. The enclosed inspection report documents the inspection results, which the inspectors discussed on July 26, 2021 with Mr. Glen Chick, Vogtle 3 & 4 Executive Vice President, and other licensee and contractor staff members.

The inspection examined a sample of construction, testing, and operational programs activities conducted under your Combined License (COL) as it relates to safety and compliance with the Commissions rules and regulations and with the conditions of these documents. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

NRC inspectors documented three findings of very low safety significance (Green) in this report.

Two of these findings involved a violation of NRC requirements. The NRC is treating these two violations as noncited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC resident inspector at the VEGP Units 3 and 4.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the VEGP Units 3 and 4.

M. Yox 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact us.

Sincerely,

/RA/

Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket Nos.: 5200025, 5200026 License Nos: NPF-91, NPF-92

Enclosure:

NRC Inspection Report (IR) 05200025/2021004, 05200026/2021004 w/attachment: Supplemental Information

M. Yox 3 cc w/ encls:

Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 Brian H. Whitley Regulatory Affairs Director Anne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, BIN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael Yox County Commissioner Regulatory Affairs Director Office of the County Commissioner Southern Nuclear Operating Company Burke County Commission 7825 River Road, BIN 63031 Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334

M. Yox 4 Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dlfulton@southernco.com (Dale Fulton) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David)

G2NDRMDC@southernco.com (SNC Document Control)

George.Taylor@opc.com (George Taylor) harperzs@westinghouse.com (Zachary S. Harper) james1.beard@ge.com (James Beard)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mphumphr@southernco.com (Mark Humphrey)

MSF@nei.org (Marvin Fertel) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) ppsena@southernco.com (Peter Sena,III) r.joshi15@comcast.net (Ravi Joshi) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sjackson@meagpower.org (Steven Jackson) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn)

M. Yox 5 wayne.marquino@gmail.com (Wayne Marquino)

William.Birge@hq.doe.gov (William Birge)

X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)

X2hagge@southern.com (Neil Haggerty)

X2wwill@southernco.com (Daniel Williamson)

M. Yox

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - NRC INITIAL TEST PROGRAM AND OPERATIONAL PROGRAMS INTEGRATED INSPECTION REPORTS 05200025/2021004, 05200026/2021004 DATED: August 12, 2021 DISTRIBUTION:

A. Veil, NRR G. Bowman, NRR V. Hall, NRR M. Webb, NRR T. Fredette, NRR G. Armstrong, NRR E. Duncan, NRR L. Dudes, RII J. Munday, RII M. Bailey, RII O. Lopez-Santiago, RII B. Davis, RII R2DCO PUBLIC ADAMS Accession No.: ML21224A183 OFFICE RII: DCO RII: DCO RII: DCO RII: DCO RII: DCO NAME Christopher Jason Theodore Jason Bradley Even Eargle Fanelli Parent Davis DATE 8/9/2021 8/4/2021 8/9/2021 8/4/2021 8/12/2021

U.S. NUCLEAR REGULATORY COMMISSION Region II Docket Numbers: 5200025 5200026 License Numbers: NPF-91 NPF-92 Report Numbers: 05200025/2021004 05200026/2021004 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Units 3 &4 Combined License Location: Waynesboro, GA Inspection Dates: April 1, 2021 through June 30, 2021 Inspectors: J. Eargle, Senior Resident Inspector - Testing, Division of Construction Oversight (DCO)

T. Fanelli, Senior Construction Inspector, DCO B. Kemker, Senior Resident Inspector, DCO K. McCurry, Technical Assistant, DCO T. Morrissey, Senior Construction Inspector, DCO J. Parent, Resident Inspector, DCO R. Patterson, Physical Security Inspector, Division of Reactor Safety N. Simonian, Security Specialist, Nuclear Security and Incident Response (NSIR)

F. Sullivan, Senior Security Specialist, NSIR S. Sanchez, Senior Emergency Preparedness Inspector, Division of Reactor Safety (DRS)

S. Downey, Senior Reactor Inspector, DRS R. Patterson, Senior Reactor Inspector, DRS T. Scarbrough, Senior Mechanical Engineer, Nuclear Reactor Regulation (NRR)

N. Hansing, Mechanical Engineer, NRR S. Prasad, Security Risk Analyst, NSIR L. Jones, Senior Reactor Inspector, DRS Approved by: Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight

SUMMARY

OF FINDINGS Inspection Report (IR) 05200025/2021004, 05200026/2021004; 04/01/2021 through 06/30/2021; Vogtle Unit 3 & 4 Combined License, initial test program and operational programs integrated inspection report.

This report covers a 3-month period of announced Inspections, Tests, Analysis, and Inspection Criteria (ITAAC), preoperational test program, startup test program, and operational program inspections by resident and regional inspectors. Three findings were determined to be of very low safety significance (Green) by the inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 2519, Construction Significance Determination Process. Cross-cutting aspects are determined using IMC 0613, Appendix F, Construction Cross-Cutting Areas and Aspects. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy and the temporary enforcement guidance outlined in enforcement guidance memorandum (EGM)11-006. The NRCs program for overseeing the safe construction of commercial nuclear power reactors is described in IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document.

A. NRC-Identified and Self Revealed Findings Inspection/Testing Cornerstone (Green) NRC inspectors identified a Green finding and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and with an associated Severity Level IV violation of 52.99(c)(1), ITAAC Closure Notification, for the licensees failure to demonstrate ITAAC acceptance criteria were satisfied in accordance with procedure ND-RA-001-006, Development and Approval of ITAAC Submittals (ICN, UIN, PCN). The licensee also failed to verify that prescribed inspections, tests, and analyses were performed and that the prescribed acceptance criteria were met for ITAAC C.2.6.09.05a in the ITAAC Closure Notification (ICN). Specifically, the licensee failed to verify the functionality of the active vehicle barriers. The licensee entered this issue into its corrective action program as condition report (CR) 50100179 and tested the functionality of the primary active vehicle barrier.

The performance deficiency was of more than minor safety significance and a finding because it is material to the acceptance criteria of the ITAAC, and the performance deficiency prevented the licensee from meeting the ITAAC Design Commitment. The finding was determined to be of very low safety significance because the finding did not impair a design function and the active vehicle barrier function was not required per 10 CFR 73.55 at that time. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of Basis for Decisions. Specifically, the licensee failed to verify the entire ITAAC acceptance criteria was met before submitting the ITAAC Closure Notification. [H.10] (Section 1A03)

(Green) A self-revealed construction finding of very low safety significance with an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to accomplish hot functional testing activities in procedure 3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Version 4.1 in accordance with NMP-AP-003, Procedure and Work Instruction Use and Adherence, Version 6.1. The licensee entered this issue into its CAP as CR 50093618, CR 50093597, and CR 50097436.

The performance deficiency was determined to be of more than minor significance because it represents a substantive failure to implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee failed to perform all steps in sequence, complete each step before moving to the next step, and sign off each step after completing it and before moving to the next step. This caused the RCS pressure to increase above the low temperature overpressure relief valve setpoints. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of Challenge the Unknown. Specifically, the licensee did not have a complete understanding of how to properly execute a set of steps in procedure 3-GEN-ITPP-517 and did not seek clarification before proceeding. [H.11] (Section 1P01)

Security Programs for Construction Inspection and Operations Cornerstone (Green) NRC inspectors identified a construction finding of very low safety significance for the licensees failure to analyze site specific conditions in accordance with NMP-SE-015, Target Set Identification, Development, and Maintenances. The licensee entered this issue into its corrective action program as CR 50031962.

The performance deficiency was determined to be of more than minor safety significance because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of Bases for Decisions. Specifically, the licensee failed to verify its understanding of the requirements for target set identification and development. [H.10] (Section 3P02)

B. Licensee-Identified Violations None

REPORT DETAILS Summary of Plant Testing Status During this report period for Unit 3, the licensee completed various activities to satisfy aspects of the Vogtle Unit 3 operational programs and initial test program. The licensee performed portions of hot functional testing activities which included testing the reactor coolant system (RCS),

residual heat removal system (RNS), passive core cooling system (PXS), main steam system, etc. at elevated temperatures and pressures. While heating the plant and operating equipment, Thermal Expansion Dynamic Effects and Vibration (TEDEV) measurements were taken to ensure piping and components are properly installed and supported such that the expected movement does not result in excessive stress or fatigue. The licensee performed preoperational and component tests of various structures, systems, and components (SSCs) and their control systems, e.g. PMS and PLS. Additionally, the licensee performed testing of air operated valves and motor operated valves; and performed response time testing of RCS resistance temperature detectors.

During this report period for Unit 4, the licensee completed the initial energization milestone by providing permanent power to plant equipment. The licensee began integrated flush activities by flushing portions of chemical and volume control system (CVS) and spent fuel pool system (SFS) and continued with installation of SSCs.

1. CONSTRUCTION REACTOR SAFETY Cornerstones: Design/Engineering, Procurement/Fabrication, Construction/Installation, Inspection/Testing Inspection Manual Chapter (IMC) 2503, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) - Related Work Inspections 1A01 (Unit 3) ITAAC Number 2.1.02.11a.ii (47) / Family 10C

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.1.02.11a.ii (47). The inspectors used the following Nuclear Regulatory Commission (NRC) inspection procedures (IPs)/sections to perform this inspection:

• 65001.C-02.02 - Construction Test Observation The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures used to test if the remotely operated valves performed their active function after receiving a signal from the protection and safety monitoring system (PMS). Specifically, the tests were observed to verify if they satisfied the applicable quality and technical requirements of the Updated Final Safety Analysis Report (UFSAR) and the ITAAC.

• B-GEN-ITPCE-039-F117;

• B-GEN-ITPCE-039-F118;

• B-GEN-ITPCE-039-F119;

• B-GEN-ITPCE-039-F120;

• B-GEN-ITPCE-039-F121;

• B-GEN-ITPCE-039-F122;

• B-GEN-ITPCE-039-F155;

• B-GEN-ITPCE-039-F156;

• B-GEN-ITPCE-039-F157;

• B-GEN-ITPCE-039-F158;

• B-GEN-ITPCE-039-F159;

• B-GEN-ITPCE-039-F160 ;

• B-GEN-ITPCE-039-F166; and

• B-GEN-ITPCE-039-F167.

The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures used to test if the remotely operated valves opened within the required time after receiving a signal from PMS. Specifically, the tests were observed to verify if they satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCE-039-F117;

• B-GEN-ITPCE-039-F118;

• B-GEN-ITPCE-039-F119;

• B-GEN-ITPCE-039-F120;

• B-GEN-ITPCE-039-F121;

• B-GEN-ITPCE-039-F122;

• B-GEN-ITPCE-039-F155;

• B-GEN-ITPCE-039-F156;

• B-GEN-ITPCE-039-F157;

• B-GEN-ITPCE-039-F158;

• B-GEN-ITPCE-039-F159; and

• B-GEN-ITPCE-039-F160.

b. Findings No findings were identified.

1A02 (Unit 3) ITAAC Number 2.2.01.09 (110) / Family 10A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.09 (110). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.C - Inspection of the ITAAC-Related Construction Test Program The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures used to test if the remotely operated valves performed their active function after receiving a signal from PMS. Specifically, the

tests were observed to verify if they satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCI-039-F169;

• B-GEN-ITPCI-039-F181; and

• B-GEN-ITPCI-039-F236.

b. Findings No findings were identified.

1A03 (Unit 3) ITAAC Number C.2.6.09.05a (664) / Family 17A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number C.2.6.09.05a (664). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.17 - Inspection of ITAAC-related Security Structure, Systems, and Components NRC inspectors performed an inspection to verify if the protected area primary personnel and vehicle access control points were installed per approved design requirements and the access control points were configured to control personnel and vehicle access per the applicable access control requirements in accordance with NRC regulatory requirements and the licensees security plan and procedures.

The inspectors performed an inspection via walkdown of the protected area primary personnel access control point to verify if personnel were channeled to the designated access control point through which personnel are processed before being granted access to the protected area. The inspectors reviewed the primary personnel access control point to verify if it was designed to ensure the identity and authorization for personnel access can be verified prior to being granted entry into the protected area. Inspectors also reviewed the primary personnel access control point to verify if it was equipped with video surveillance monitoring equipment and could be monitored by security personnel. Lastly, inspectors reviewed the primary personnel access control point to verify if it was equipped with alarmed entry control devices (e.g., doors, gates, turnstiles, card readers, or biometrics) that prevent or delay unauthorized entry into the protected area.

The inspectors reviewed the primary personnel access point to verify if it included a search area containing metal detectors, explosive detectors, and X-Ray devices configured to prevent unauthorized bypass, and was capable of detecting firearms, incendiary devices, and explosives, in accordance with NRC regulatory requirements and the licensees security plan and procedures.

The inspectors observed operational testing of the metal detectors, explosive detectors, and X-Ray equipment to confirm if the detection equipment was functioning and performing within the manufacturer design specifications. The

inspectors sampled all detection equipment to verify if the equipment detected and alarmed as required per NRC regulatory requirements, manufactures specifications and licensees testing procedures.

The inspectors also reviewed the ITAAC Closure Notification (ICN) and performed a walkdown of the active vehicle barrier to verify if the ITAAC were satisfied.

b. Findings Introduction NRC inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and with an associated Severity Level IV violation of 52.99(c)(1), ITAAC Closure Notification, for the licensees failure to demonstrate ITAAC acceptance criteria were satisfied in accordance with procedure ND-RA-001-006, Development and Approval of ITAAC Submittals (ICN, UIN, PCN). The licensee also failed to verify that prescribed inspections, tests, and analyses were performed and that the prescribed acceptance criteria were met for ITAAC C.2.6.09.05a in the ICN.

Specifically, the licensee failed to verify the functionality of the active vehicle barriers.

Description On December 21, 2020, the licensee submitted the ICN for ITAAC C.2.6.09.05a to the NRC per the requirements in 10 CFR 52.99. On May 13, 2021, NRC inspectors reviewed the ICN and performed a walkdown of the active vehicle barrier system which include two active vehicle barriers. The inspectors identified that the functionality of the active vehicle barriers were not tested as part of satisfying the acceptance criteria of the ITAAC. The ITAAC specifies that the licensee perform inspections, tests, or a combination of inspections and tests to verify the access control points for the protected area were configured to control personnel and vehicle access. By not testing the functionality of the active vehicle barriers, the licensee failed to demonstrate that the vehicle barriers were configured to control vehicle access as required by the ITAAC.

Subsequent to the NRC inspectors identifying this issue, the licensee entered this issue into its corrective action program as condition report (CR) 50100179 and tested the functionality of the primary and protected area receiving warehouse active vehicle barriers and resubmitted the ICN with this information.

Analysis The inspectors determined that the failure to follow procedure ND-RA-001-006 to demonstrate the ITAAC acceptance criteria were satisfied prior to submitting the ITAAC Closure Notification was contrary to 10 CFR 50, Appendix B, Criterion V and was a performance deficiency. Per the guidance in IMC 0613, Appendix E, Examples of Minor Construction Issues, the performance deficiency was determined to be more than minor because it is material to the acceptance criteria of the ITAAC, and the performance deficiency prevented the licensee from meeting the ITAAC Design Commitment. Specifically, the licensee failed to demonstrate that the ITAAC acceptance criteria was satisfied prior to submitting the ICN.

This finding was an ITAAC finding because the performance deficiency is material to ITAAC C.2.6.09.05a. Specifically, the ITA requires the licensee to inspect, test, or use a combination of inspections or tests to verify the access control points for the protected area are configured to control personnel and vehicle access. By not testing the active vehicle barrier, the licensee was not able to verify the protected area was configured to control vehicle access.

The inspectors determined the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP1000 Construction Significance Determination Process, Section 4. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function and the active vehicle barrier function was not required per 10 CFR 73.55 at that time.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of H.10, Basis for Decisions, in the area of Human Performance. Specifically, the licensee failed to verify the entire ITAAC acceptance criteria was met before submitting the ICN.

In addition, the Construction Reactor Oversight Process significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

The inspectors determined that the failure to provide sufficient information within the ICN to demonstrate that the prescribed inspections, tests, and analyses have been performed and the prescribed acceptance criteria were met was a violation of 10 CFR 52.99(c)(1). In accordance with Section 6.5 of the NRC Enforcement Policy, the inspectors determined this was a SL IV violation because the licensee failed to establish, maintain, or implement adequate controls over testing processes that were important to safety. Specifically, the licensee failed to perform the testing of the vehicle barriers to meet the acceptance criteria.

Enforcement 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, since December 21, 2020, the licensee failed to follow procedure ND-RA-001-006 and demonstrate that the ITAAC acceptance criteria were satisfied in its ITAAC Closure Notification. Specifically, the licensee failed to demonstrate that the ITAAC acceptance criteria for the active vehicle barriers were met.

10 CFR 52.99(c)(1), ITAAC Closure Notification, requires, in part, that ITAAC closure notification must contain sufficient information to demonstrate that the prescribed

inspections, tests, and analyses have been performed and that the prescribed acceptance criteria were met.

Contrary to the above, since December 21, 2020, the ICN submitted failed to contain sufficient information to demonstrate that the prescribed inspections, tests, and analyses that verify the prescribed acceptance criteria were met. Specifically, the licensee failed to demonstrate the functionality of the active vehicle barriers.

The licensee entered this issue into their corrective action program as CR 50100179 and tested the functionality of the primary and protected area receiving warehouse active vehicle barriers and resubmitted the ICN with this information. This issue does not represent an immediate safety concern because the licensee was not required to meet 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, at the time of the inspection.

Because this violation was not repetitive or willful, and was entered into the licensees CAP, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021004-01, Failure to Prescribe Instructions or Procedures for ITAAC activities that Affect Quality).

1A04 (Unit 3) ITAAC Number C.2.6.09.06 (666) / Family 17A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number C.2.6.09.06 (666). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.17 - Inspection of ITAAC-related Security Structure, Systems, and Components NRC inspectors performed an inspection of the access control system to verify if the system was installed to allow individuals with authorized access to the protected area and vital areas without escort in accordance with NRC regulations and SNCs security plan. The inspectors reviewed the access control system to verify if it required a numbered picture badge with the right access level to enter the protected and vital areas. The inspectors reviewed the licensees acceptance testing documentation of the hand geometry and keycard reader systems to verify if the systems installed and functioned as designed. The inspectors reviewed system procedures to verify if the systems will be maintained in accordance with the manufacturers specifications. The inspectors observed testing of several of the hand geometry units in the primary access portal and vital area doors to verify if the units and keycard readers operated as designed.

b. Findings No findings were identified.

1A05 (Unit 4) ITAAC Number C.2.6.09.08a (668) / Family 17A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number C.2.6.09.08a (668). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.17 - Inspection of ITAAC-related Security Structure, Systems, and Components The inspectors performed an inspection to determine if the openings in Vogtle Unit 4 vital area barriers for heating, ventilation, and cooling (HVAC) system vents were secured to prevent exploitation of the openings to satisfy the ITAAC and 10 CFR 73.55(e)(4).

The inspectors reviewed the design specifications and associated drawings to identify designated HVAC system openings through vital area barriers and the way they will be secured and monitored. The inspectors examined the physical installation of one HVAC system opening (SV4-VAS-AS-01) to the vital area during this inspection period. The inspectors performed direct observation inspection of the opening to determine if it was secured in a manner that would delay or prevent exploitation.

Specifically, the inspectors directly inspected the barrier, locking mechanisms, welds, and bolts associated with the opening.

b. Findings No findings were identified.

IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs 1P01 Construction Quality Assurance (QA) Criterion 16

• 35007-A16 - Appendix 16. Inspection of Criterion XVI - Corrective Action

a. Inspection Scope The inspectors conducted daily reviews of issues entered into the licensees corrective action program (CAP) to assess issues that might warrant additional follow-up inspection, to assess repetitive or long-term issues, to assess adverse performance trends, and to ensure the CAP appropriately included regulatory required non-safety related SSCs. The inspectors periodically attended the licensees CAP review meetings, held discussions with licensee and contractor personnel, and performed reviews of CAP activities during the conduct of other baseline inspection procedures.

The inspectors reviewed conditions entered into the licensees CAP to determine whether the issues were classified in accordance with the licensees QA program and CAP implementing procedures. The inspectors reviewed corrective actions associated with conditions entered into the CAP to determine whether appropriate actions to correct the issues were identified and implemented effectively, including immediate or short-term corrective actions, in accordance with the applicable QA program

requirements and 10 CFR 50, Appendix B, Criterion XVI. Additionally, the inspectors reviewed the corrective actions taken to determine whether they were commensurate with the significance of the associated conditions in accordance with the licensees CAP implementing procedures. The inspectors completed reviews of CAP entry logs to verify issues from all aspects of the project, including equipment, human performance, and program issues, were being identified by the licensee and associated contractors at an appropriate threshold and entered into the CAP as required by licensees CAP implementing procedures. The inspectors performed a focused review on the following condition reports:

• CR 50093597;

• CR 50093618; and

• CR 50097436.

b. Findings Introduction A self-revealed construction finding of very low safety significance (Green) with an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to accomplish hot functional testing activities in procedure 3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Version 4.1 in accordance with NMP-AP-003, Procedure and Work Instruction Use and Adherence, Version 6.1.

Description On May 22, 2021, the plant was in a water solid condition and operators were establishing plant conditions to support performance of chemical volume and control system dynamic effects testing per 3-GEN-ITPP-517. This procedure was designated as a continuous use procedure. SNC corporate procedure NMP-AP-003, Section 4.3, specifies, in part, that for a continuous use procedure operators perform all steps in sequence, complete each step before moving to the next step, and sign off each step after completing it and before moving to the next step.

During the performance of procedure 3-GEN-ITPP-517, operators performed Step 4.3.10 to isolate normal RNS purification before completing Step 4.3.7 to establish purification flow from the reactor coolant pumps (RCPs) to CVS. As a result of performing these steps out of sequence, letdown was inadvertently isolated while makeup remained in service. The RCPs automatically tripped due to low letdown line pressure which caused the reactor coolant system pressure to increase above the low temperature overpressure relief valve setpoints. Subsequent to the low temperature overpressure relief valves lifting, the licensee restored letdown and reduced RCS pressure. The licensee entered this issue into its CAP as CR 50093618, CR 50093597, and CR 50097436.

Analysis The inspectors determined the failure to accomplish hot functional testing activities in procedure 3-GEN-ITPP-517 in accordance with procedure NMP-AP-003 was contrary to 10 CFR 50, Appendix B, Criterion V and was a performance deficiency. The

performance deficiency was determined to be of more than minor significance because it represented a substantive failure to implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee failed to perform all steps in sequence, complete each step before moving to the next step, and sign off each step after completing it and before moving to the next step. This caused the RCS pressure to increase above the low temperature overpressure relief valve setpoints.

The inspectors concluded the finding was associated with the Inspection/Testing Cornerstone and assessed the finding in accordance with IMC 2519, Construction Significance Determination Process, Appendix A, AP 1000 Construction Significance Determination Process, Section 4. The inspectors determined the finding was associated with the RCS and was of very low safety significance (Green) because the event did not impair a design function of the RCS.

The performance deficiency did not impact an ITAAC, thus it was determined to be a construction finding.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of H.11, Challenge the Unknown, in the area of Human Performance. Specifically, the licensee did not have a complete understanding of how to properly execute a set of steps in procedure 3-GEN-ITPP-517 and did not seek clarification before proceeding.

Enforcement 10 CFR 50, Appendix B, Criterion V, states in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on May 22, 2021, the licensee failed to follow procedure NMP-AP-003 when performing hot functional testing activities in procedure 3-GEN-ITPP-517. Specifically, when performing 3-GEN-ITPP-517, the licensee failed to perform all steps in sequence, complete each step before moving to the next step, and sign off each step after completing it and before moving to the next step. The licensee entered this issue into its CAP as CR 50093618, CR 50093597, and CR 50097436. Corrective actions were planned and this finding does not present an immediate safety concern because the system responded as designed to the loss of letdown and no safety limit was exceeded.

Because this violation was not repetitive or willful, was of very low safety significance (Green), and was entered into the licensees corrective action program, this violation is being treated as a NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05200025/2021004-02, Failure to Follow Procedure 3-GEN-ITPP-517).

1P02 Pre-operational Testing

• 70702-02.04 - Test Witnessing

a. Inspection Scope

The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure used to test the adequacy of RCS resistance temperature detectors time response testing to verify that the protection channels sensors meet time limits specified in the Technical Specifications. Specifically, the test was observed to verify if the test satisfied the applicable quality and technical requirements of the UFSAR.

• 3-PMS-OTS-17-002

b. Findings No findings were identified.

3. OPERATIONAL READINESS Cornerstones: Operational Programs IMC 2503, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) - Related Work Inspections 3T01 (Unit 3) ITAAC Number 2.1.02.08b (30) / Family 06D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.1.02.08b (30). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.D-02.02-Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure used to test the adequacy of RCP rotating inertia that provided RCS flow coast down on loss of power to the RCPs. Specifically, the test was observed to verify if the test satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• 3-RCS-ITPP-506

b. Findings No findings were identified.

3T02 (Unit 3) ITAAC Number 2.1.02.09a (41) / Family 14D

a. Inspection Scope

The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.1.02.09a (41). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.D-02.02-Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure used to test the adequacy of RCS flow rates to remove heat from the core. Specifically, the test was observed to verify if the test satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• 3-RCS-ITPP-506

b. Findings No findings were identified.

3T03 (Unit 3) ITAAC Number 2.1.02.13b (64) / Family 10D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.1.02.13b (64). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.D-02.02-Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures used to test whether the RCPs tripped after receiving a signal from PMS. Specifically, the tests were observed to verify if they satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCI-039-F026;

• B-GEN-ITPCI-039-F027;

• B-GEN-ITPCI-039-F028; and

• B-GEN-ITPCI-039-F032.

The inspectors also used appropriate portions of the IP to review the test results that verified the RCPs tripped after receiving a signal from PMS. Specifically, the test results were reviewed to determine whether they contained sufficient information to meet the requirements of the UFSAR and ITAAC acceptance criteria.

b. Findings No findings were identified.

3T04 (Unit 3) ITAAC Number 2.2.01.11b (118) / Family 07D

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.01.11b (118). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.D-02.02-Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedures used to test if after a loss of motive power the motor operated valves assume the loss of motive power position. Specifically, the tests were observed to verify if they satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCI-039-F236; and

• B-GEN-ITPCI-039-F244.

b. Findings No findings were identified.

3T05 (Unit 3) ITAAC Number 2.2.03.10 (206) / Family 10A

a. Inspection Scope The inspectors performed a direct inspection of construction activities associated with ITAAC Number 2.2.03.10 (206). The inspectors used the following NRC IPs/sections to perform this inspection:

• 65001.D-02.02 - Test Witnessing The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure used to verify if the valve performed its active safety function within 20 seconds after an actuation signal from the PMS. Specifically, the test was observed to verify if the test satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCI-039-F079 The inspectors used appropriate portions of the IP to observe the licensees performance of the following procedure used to verify if the valve performed its active safety function after an actuation signal from the PMS. Specifically, the test was observed to verify if the test satisfied the applicable quality and technical requirements of the UFSAR and the ITAAC.

• B-GEN-ITPCI-039-F116

b. Findings

No findings were identified.

IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs 3P01 Preservice Testing

• 73758-App A.02.01 Functional Design and Qualification

• 73758-App B Implementation of Functional Design and Qualification for Pumps, Valves, and Dynamic Restraints

a. Inspection Scope Functional Design and Qualification The inspectors performed the following activities related to the development and implementation of the Functional Design and Qualification Program for pumps, valves, and dynamic restraints that will perform safety-related functions at Vogtle Units 3 & 4:

• The inspectors reviewed motor-operated valve (MOV) application reports, and other documents, related to the qualification of a sample of motor-operated globe valves at Vogtle Units 3 & 4 during the 2021 second quarter inspection.

Application reports and related documents for a sample of motor-operated gate valves were reviewed during the 2021 first quarter inspection (IRs 05200025/2021002 and 05200026/2021002). The inspectors discussed the MOV qualification activities described in these documents with licensee staff and contractors. On this basis, the inspectors determined that the licensee satisfied the design specification provisions for implementing ASME Standard QME 2007, which the NRC accepted in Regulatory Guide 1.100 (Revision 3), for the MOVs listed below:

o SGS-PL-V027A/B (Steam Generator 1 and 2 PORV Isolation Valves) which are 12 X 10 X 12 Globe Style Isolation Control Valves with Limitorque SB-2-80 Motor Actuators o RCS-PL-V002A/B (ADS Stage 2 Control Valves) and RCS-PL-V003A/B (ADS Stage 3 Control Valves) which are Size 8 Class 1530 Globe Valves with Limitorque SB-0-5 (DC) Motor Actuators

• The inspectors reviewed design reports, and other documents (including the verification and validation process for incorporating the Boiling Water Reactor Owners Group Direct Current (DC) Motor Methodology into the Teledyne MIDAS MOV Calculation Software), related to the qualification of a sample of motor-operated gate valves to verify that appropriate justifications were provided for assumptions made in the valve set point data sheet (SPDS), including the assumptions of a 0.58 valve coefficient of friction (COF), the Limitorque SB-00 actuator maximum thrust, the 10% margin tracking method, and thermal binding open thrust factors. Based on the review of MOV documentation and detailed discussions with licensee personnel and contractors, the inspectors determined that the assumptions in the SPDS for the following MOVs are justified:

o PXS-PL-V117A/B (Containment Recirculation Sump A/B to RCS Isolation Valves) which are 8-inch torque-seated flexible wedge gate (FWG) valves with Limitorque SB-00-15 DC Motor Actuators o RCS-PL-V011A/B (ADS Stage 1 Isolation Valves) which are 4-inch limit-seated FWG valves with Limitorque SB-1-60 DC Motor Actuators o RCS-PL-V012A/B and V013A/B (ADS Stage 2 and Stage 3 Isolation Valves) which are 8-inch limit-seated FWG valves with Limitorque SB 150 DC Motor Actuators o RNS-PL-V001A/B and V002A/B (RNS Suction from RCS Inner Isolation Valves and RNS Suction from Outer Isolation/IC Containment Isolation Valves) which are 10-inch torque-seated FWG valves with Limitorque SB-3-150 DC Motor Actuators

b. Findings No findings were identified.

3P02 Physical Security

• 81000.14.02.01 - Review of Events and Logs

• 81000.14-02.02 - Target Set Identification and Development Process Review

• 81000.14-02.03- Verification of Complete and Accurate Target Sets

• 81000.14-02.04 - Cyber Security

• 81000.14-02.05 - Review of Configuration Changes

• 81000.14-02.06 - Physical Protection Program Review

a. Inspection Scope The inspector performed the first week of this inspection in October 2019 (ADAMS Accession No. ML20044C867). During the second week of the inspection, the inspector performed an inspection of the licensee's target set procedures and identified target sets for Unit 3. The inspector reviewed documents, interviewed staff that provided input to target set development, performed walk downs of target set equipment to verify completeness and accuracy of the target sets, and reviewed corrective actions related to target sets.

The inspector reviewed the following (specific documents are listed under the documents reviewed) to verify the above:

• target set implementation and maintenance;

• AP1000 fault tree target set analysis;

• transition to operations users guide; and

• cyber security assessment plan, B-GEN-CSEC-003- Attachment 4.

Safety/Security Interface,

• abnormal and emergency operating procedures;

• safety/security interface procedure;

• target set identification and grouping; and

• one-line diagrams.

In addition, the inspector reviewed an analysis related to how cyber security identified critical digital assets that could control elements are identified and documented in target sets. The inspector performed a walk down of identified target set elements, and in some cases, re-verified target set locations were complete and accurate using a 3-D simulation model of the site.

The inspector also reviewed a sample of procedures to verify that assumptions made in target sets were accurately represented in emergency and abnormal operating procedures. Further, the inspectors reviewed condition reports and technical evaluations of quality records to verify issues affecting target sets were being adequately identified and addressed.

b. Findings Introduction The NRC inspectors identified a construction finding of very low safety significance (Green) for the licensees failure to analyze site specific conditions in accordance with NMP-SE-015, Target Set Identification, Development, and Maintenances.

Description In October 2019, during the first target set inspection week, the NRC inspectors questioned if the licensee performed their analysis of target sets in accordance with NMP-SE-015, Target Set Identification, Development, and Maintenances. The licensee created CR 50031962 dated October 17, 2019, and as a result, performed an analysis, DCP-SV0-000461, dated January 8, 2020. Based on the analysis, the licensee identified and implemented changes to their target sets. The inspectors determined that all steps of the procedure were not performed. By not analyzing the specific conditions required by the procedure, the licensee failed to demonstrate that target sets were in accordance with their program requirements.

Analysis The inspectors determined that the failure to analyze specific conditions was contrary to NMP-SE-015, Target Set Identification, Development, and Maintenances, was a performance deficiency. Per the guidance in IMC 0613, Appendix E, Examples of Minor Construction Issues, the performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function.

The inspectors concluded the finding was associated with the Security Programs for Construction Inspection and Operations Cornerstone and assessed the finding in accordance with the Target Set Significance Determination Process Flowchart in IMC 0609, Significance Determination Process, Appendix E, Part 1 Baseline Security Significance Determination Process for Power Reactors. The inspectors determined the finding was of very low safety significance (Green) because the process for developing target sets was not affected. Specifically, the licensee failed to analyze site specific conditions in accordance with NMP-SE-015.

The performance deficiency did not impact an ITAAC, thus it was determined to be a construction finding.

In accordance with IMC 0613 Appendix F, Construction Cross-Cutting Areas and Aspects, the inspectors determined the finding had a cross-cutting aspect of H.10, Bases for Decisions, in the area of Human Performance. Specifically, the licensee failed to verify its understanding of the requirements for target set identification and development.

Enforcement Inspectors did not identify a violation of regulatory requirements associated with this finding. Corrective actions have been performed and this finding does not present an immediate safety concern because 10 CFR 73.55 was not required to be implemented at the time of the inspection (FIN 05200025/2021004-03, Failure to Analyze Target Sets in Accordance with Procedures).

4. OTHER INSPECTION RESULTS 4OA6 Meetings, Including Exit

.1 Exit Meeting.

On July 26, 2021, the inspectors presented the inspection results to Mr. G. Chick, Vogtle 3&4 Executive Vice President, and other licensee and contractor staff members.

Proprietary information was reviewed during the inspection period but was not included in the inspection report.

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensees and Contractor Personnel E. Riffle, ITP Director A. Nix, NI Manager T. Petrak, ITAAC Manager M. Hickox, Test Support Manager C. Alexander, Milestone Manager S. Boyle, Milestone Manager D. Pagan-Diaz, ITP Turnover. Manager J. Olsen, NI Supervisor S. Leighty, SNC Licensing Supervisor C. Castell, SNC Licensing Engineer N. Patel, SNC Licensing Engineer J. Cole, SNC Licensing Engineer J. Weathersby, SNC Licensing Engineer C. Main, ITAAC Project Manager D. Wade, ITAAC Project Manager B. Macioce, Principle Engineer Digital Testing R. McKay, ITP Test Engineer S. Turner, ITP Test Engineer G. Weaver, ITP Test Engineer R. Nicoletto, ITP Test Engineer W. Pipkins, ITP Test Engineer D. Melton, ITP Test Engineer R. Espara, ITP Test Engineer J. Clark, ITP Test Engineer K. Morgan, ITP Test Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description 0500025/2021004-01 NCV Open/Closed Failure to Prescribe Instructions or Procedures for ITAAC activities that Affect Quality 0500025/2021004-02 NCV Open/Closed Failure to Follow Procedure 3-GEN-ITPP-517 0500025/2021004-03 FIN Open/Closed Failure to Analyze Target Sets in Accordance with Procedures

LIST OF DOCUMENTS REVIEWED Section 1A01 B-GEN-ITPCI-039-F117, RCS-PL-V001A Component Test, Revision (Rev.) 1.2 WO 1241530 B-GEN-ITPCI-039-F118, RCS-PL-V001B Component Test, Rev. 1.2 WO 1241531 B-GEN-ITPCI-039-F119, RCS-PL-V002A Component Test, Rev. 1.2 WO 1241532 B-GEN-ITPCI-039-F120, RCS-PL-V002B Component Test, Rev. 1.2 WO 1241533 B-GEN-ITPCI-039-F121, RCS-PL-V003A Component Test, Rev. 1.2 WO 1241534 B-GEN-ITPCI-039-F122, RCS-PL-V003B Component Test, Rev. 1.2 WO 1241535 B-GEN-ITPCI-039-F155, RCS-PL-V011A Component Test, Rev. 1.2 WO 1241536 B-GEN-ITPCI-039-F156, RCS-PL-V011B Component Test, Rev. 1.2 WO 1241537 B-GEN-ITPCI-039-F157, RCS-PL-V012A Component Test, Rev. 1.2 WO 1241538 B-GEN-ITPCI-039-F158, RCS-PL-V012B Component Test, Rev. 1.2 WO 1241539 B-GEN-ITPCI-039-F159, RCS-PL-V013A Component Test, Rev. 1.2 WO 1241540 B-GEN-ITPCI-039-F160, RCS-PL-V013B Component Test, Rev. 1.2 WO 1241541 B-GEN-ITPCE-039-F166, RCS-PL-V150B Component Test, Rev. 1 WO 1109868 B-GEN-ITPCE-039-F167, RCS-PL-V150D Component Test, Rev. 1 WO 1109868 Section 1A02 B-GEN-ITPCI-039-F169, RNS-PL-V001A Component Test, Rev. 1.2 WO 1241546 B-GEN-ITPCI-039-F236, VFS-PL-V009-S1 Component Test, Rev. 1.2 WO 1109906 B-GEN-ITPCI-039-F181, SFS-PL-V038 Component Test, Rev. 1.1 WO 1109872 WO 1241555 Section 1A03 ND-20-1406, ITAAC Closure Notification on Completion of ITAAC C.2.6.09.05a [Index Number 664], December 21, 2020 Section 1A04 90014-C Alarm Station Operations, Rev. 21 90200-C Security Seven Day Vital Area Portal Inspections, Rev. 36 90202-C Testing Explosive Detector Units, Rev. 19 90203-C Metal Detector Testing, Rev. 18

90204-C X-Ray Equipment Test Procedure, Rev. 16 NMP-SE-012 Safety/Security Interface, Rev. 5 NMP-SE-021 Security Search Process, Rev. 9 Fiber SenSys Walls and Masonry Structures Manual CEIA Walk-Through Metal Detectors Use and maintenance Manual Entry Scan 4 Users Manual Smith Detection Conventional HI-Scan X-Ray Units Operating Instruction Manual Section 1A05 APP-VAS-MD-659, Auxiliary Building Area 5 Elevation 153'0" VAS Duct ISO View, Rev. 9 APP-MD03-V2-850003, DFDAF-330 Damper Schedule, Rev. 15 APP-MD03-V2-850006, Fire Damper Grating Assembly, Rev. 1 APP-AB01-AB-010, Blockouts and Barriers (Penetrations, Seals and Fire Stops) Details Sheet 10, Rev. 4 APP-AB01-AB-012, Blockouts and Barriers (Penetrations, Seals and Fire Stops) Details Sheet 12, Rev. 0 Engineering & Design Coordination Report No. APP-FSAR-GEF-061, Addition of AS04 Specialty Device Detail to HVAC, Rev. 0 Engineering & Design Coordination Report No. APP-SES-GEF-031, Updates to Barrier Matrix, Rev. 0 APP-AS21-A1-001, AP1000 Security Barrier Design Requirements, Rev. 1 APP-GW-MD-103, HVAC Details Sheet 1, Rev. 1 Section 1P01 3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Rev. 4.1 NMP-AP-003, Procedure and Work Instruction Use and Adherence, Rev. 6.1 Operator Logs, 05/22/2021 B-GEN-ITPA-004, Conduct of Test, Rev. 22 NMP-OS-007-001, Conduct of Operations Standards and Expectations, Rev. 18 Section 1P02 3-PMS-OTS-17-002, RCS RTD Time Response Testing, Rev. 0 Section 3T01 3-RCS-ITPP-506, Reactor Coolant Pump and Reactor Coolant Flow Precore Hot Function, Rev.

3.0.

3-GEN-ITPP-509, Reactor Coolant System Dynamic Effects and Vibration Testing, Rev. 2.0 3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Rev. 5.0 Section 3T02 3-RCS-ITPP-506, Reactor Coolant Pump and Reactor Coolant Flow Precore Hot Function, Rev.

3.0.

3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Rev. 5.0 Section 3T03 B-GEN-ITPCI-039-F026, ECS-ES-32 Component Test, Revision 1.1 B-GEN-ITPCI-039-F027, ECS-ES-41 Component Test, Revision 1.0 B-GEN-ITPCI-039-F028, ECS-ES-42 Component Test, Revision 1.0 B-GEN-ITPCI-039-F032, ECS-ES-62 Component Test, Revision 1.1

SV3-ECS-T0W-1241524 PMS CIM Component Retest ECS-ES-32 SV3-ECS-T0W-1241525 PMS-CIM Component Retest ECS-ES-62 SV3-ECS-T0W-1109892 PMS CIM Component Test for ECS Components (ECS-ES-41 &42)

ND-19-0717 Letter, Resubmittal of Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item 2.1.02.13b [Index Number 641], 05/2021 SV3-RCS-ITR-800064 Final ITAAC Technical Report, 05/2021 CR50088839 CR50088865 SV3-ECS-T0W-1241525 Signature log SV3-ECS-T0W-1241525 Test Deficiency Report SV3-ECS-T0W-1241524 Test Narrative Log SV3-ECS-T0W-1241524 Test Deficiency TDR_CR Log SV3-ECS-T0W-1241524 Test Deficiency Report SV3-ECS-T0W-1241525 Test Narrative Log SV3-ECS-T0W-1109892 Test Deficiency Report SV3-ECS-T0W-1241525 Test Deficiency TDR_CR Log SV3-ECS-T0W-1109892 Signature log SV3-ECS-T0W-1109892 Test Deficiency TDR_CR Log SV3-ECS-T0W-1241524 Signature log SV3-ECS-T0W-1109892 Test Narrative Log SV3-PMS-J1-105 RCP Trip Logic SV3-PMS-J1-112 CMT Logic Diagram PMS Mimic Section 3T04 WO 1109906, PMS CIM Component Test - VFS-V004-SI and VFS-V009-SI B-GEN-ITPCI-039-F244, WLS-PL-V057-S1 Component Test, Rev. 1.0 WO 1050043 Section 3T05 B-GEN-ITPCI-039-F079, PXS-PL-V108A-S1 Component Test, Rev. 1.0 3-PXS-OTS-10-001, Passive Core Cooling System Valve Stroke Test, Rev. 0 WO 1109879 B-GEN-ITPCI-039-F116, PXS-PL-V130B-S1 Component Test, Rev. 1.1 3-GEN-OTS-10-004, Division D Quarterly Valve Stroke Test Rev. 0 WO 1109911 Section 3P01 Application Reports Westinghouse SV0-PV01-VPR-132002, Vogtle Units 3 and 4 PV01 QME-1 Application Report for Datasheet APP-PV01-Z0D-132, Rev. 0 Westinghouse SV0-PV01-VPR-208002, Application Report for Valves for Datasheet APP-PV01-Z0D-208 for Vogtle Units 3 and 4, Rev. 0 Equipment Qualification Flowserve RAL-7631, Equipment Qualification Plan QME-1-2007, Rev. 4 Flowserve RAL-7668, QME-1 Functional Qualification Test Procedure A/D Flexwedge Gate Valves Size 3-14, Class 150-1530, Edward Globe Valves Size 3-8, Class 1530-1850, Rev. 4

Westinghouse APP-PV01-VBR-011, Equipment Qualification Summary Report for Flowserve Flex Wedge Gate Valves with Limitorque Motor Operators for Use in the AP1000 Plant, Rev.

2 Westinghouse APP-PV01-VBR-013, Equipment Qualification Summary Report for Flowserve Globe Stop Valves with Limitorque Motor Operators for Use in the AP1000 Plant, dated Rev. 2 Westinghouse APP-PV01-VBR-015, Equipment Qualification Summary Report for IMI CCI Motor Operated 12-inch DRAG Globe Valves for Use in the AP1000 Plant, Rev. 0 Westinghouse APP-PV01-VPR-001 (RAL-7990), Functional Qualification Summary & Analysis Report per ASME QME-1-2007, Rev. 0 Westinghouse APP-PV01-VPR-005 (RAL-7987), QME-1 Functional Qualification Report per ASME QME-1-2007 for Flowserve Size 3 Figure B2016(CF3M)JMTY with SMB-1-25, Rev. 0 Westinghouse APP-PV01-VPR-006 (RAL-7988), QME-1 Functional Qualification Report per QME-1-2007 for Flowserve Size 4 Figure BD2026(CF3M)JMTY with SMB-00-10, Rev. 0 Westinghouse APP-PV01-VPR-007 (RAL-7989), QME-1 Functional Qualification Report per ASME QME-1-2007 for Flowserve Size 8 Figure BD2026(CF3M)JMTY with SMB-0-5, Rev. 0 Westinghouse APP-PV01-VPR-008 (RAL-7991), Functional Qualification Summary and Analysis Report per ASME QME-1-2007 for Edward Heritage T-Pattern Globe Valves, dated Rev. 1 Westinghouse APP-PV01-VPR-009 (RAL-7889), AP1000 PV01 Correlation of QME-1 Test Results with Calculation Methods for Determining Valve Assembly Primary Mode Natural Frequencies, Rev. 0 Westinghouse APP-PV01-VPR-010 (RAL-70259), Supplemental Functional Test Report for Piston Ring Configuration on a Flowserve Size 8 Figure BD2026(CF3M)JMTY with SMB 5,Rev. 0 Westinghouse APP-PV95-VPR-101, Equipment Qualification Test Report for the Limitorque Valve Actuators for Use in the AP1000 Plant, Rev. 0 Set Point Data Sheets (SPDS)

SPDS SV0-PV01-T9-103, Revision 2, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-103, dated 3-30-2021, for RCS-PL-V011A and B SPDS SV0-PV01-T9-113, Revision 1, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-113, dated 9-17-2020, for RCS-PL-V012A/B and V013A/B SPDS SV0-PV01-T9-115, Revision 0, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-115, dated 11-5-2018, for PXS-PL-V117A/B SPDS SV0-PV01-T9-116, Revision 0, Set Point Data Sheet (SPDS) for Valves Built to PV01-Z0D-116, dated 8-8-2018, for RNS-PL-V001A/B and V002A/B Section 3P02 Condition Report 50031958, dated October 17, 2019 Condition Report 50031962 dated October 17, 2019 Condition Report 50098499, dated July 1, 2021 Technical Evaluations Quality Record # 60027420, dated July 1, 2021 Technical Evaluations Quality Record # 60027422, dated July 1, 2021 Technical Evaluations Quality Record # 60027424, dated July 1, 2021 ND-AD-VNP-029, Transition to Operations Users Guide, dated March 26, 2021 3-EOP-E-0, Reactor Trip of Safeguards Actuation, Version 1, dated March 19, 2021 NMP-SE-015, Target Set Identification, Development, and Maintenance, Version 8.0, dated February 20, 2021

NMP-SE-012, Safety/Security Interface, Version 5.0, dated December 15, 2020 B-GEN-CSEC-003- Attachment 4, Cyber Security Assessment Plan, Version 7

LIST OF ACRONYMS CAP corrective action program CFR Code of Federal Regulations CR condition report CVS chemical and volume control system DC direct current DCO Division of Construction Oversight DRS Division of Reactor Safety FWG flexible wedge gate HVAC heating, ventilation, and cooling ICN ITAAC Closure Notification IMC inspection manual chapter IP inspection procedure IR inspection report ITAAC inspections, tests, analysis, and acceptance criteria MOV motor operated valve NCV Noncited Violation NRC Nuclear Regulatory Commission PMS protection and safety monitoring system PXS passive core cooling system QA quality assurance RCP reactor coolant pump RCS reactor coolant system Rev. Revision RNS residual heat removal system SFS spend fuel pool system SGS steam generator system SL severity level SPDS set point data sheet SSC structures, systems, and components TEDEV Thermal Expansion Dynamic Effects and Vibration UFSAR Updated Final Safety Analysis Report

ITAAC INSPECTED No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 30 2.1.02.08b 8.b) The RCPs have A test will be performed The pump flow a rotating inertia to to determine the pump coastdown will provide RCS flow flow coastdown curve. provide RCS flows coastdown on loss of greater than or equal power to the pumps. to the flow shown in Figure 2.1.2-2, Flow Transient for Four Cold Legs in Operation, Four Pumps Coasting Down.

41 2.1.02.09a 9.a) The RCS Testing and analysis to The calculated post-provides circulation of measure RCS flow with fuel load RCS flow coolant to remove four reactor coolant rate is > 301,670 heat from the core. pumps operating at gpm.

noload RCS pressure and temperature conditions will be performed. Analyses will be performed to convert the measured pre-fuel load flow to postfuel load flow with 10percent steam generator tube plugging.

No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 47 2.1.02.11a.ii 10. Safety-related Inspection will be Safety-related displays identified in performed for displays identified in Table 2.1.2-1 can be retrievability of the Table 2.1.2-1 can be retrieved in the MCR. safety-related displays retrieved in the MCR.

11.a) Controls exist in the MCR. ii) Stroke ii) Controls in the in the MCR to cause testing will be MCR operate to the remotely operated performed on the other cause the remotely valves identified in remotely operated operated valves Table 2.1.2-1 to valves listed in Table (other than squib perform active 2.1.2-1 using controls in valves) to perform functions. 11.b) The the MCR. ii) Testing active functions. ii) valves identified in will be performed on the The other remotely Table 2.1.2-1 as other remotely operated operated valves having PMS control valves identified in identified in Table perform an active Table 2.1.2-1 using real 2.1.2-1 as having safety function after or simulated signals PMS control perform receiving a signal into the PMS. iii) the active function from the PMS. 12.b) Testing will be identified in the table After loss of motive performed to after receiving a power, the remotely demonstrate that signal from PMS. iii) operated valves remotely operated RCS These valves open identified in Table valves RCSV001A/B, within the following 2.1.2-1 assume the V002A/B, V003A/B, times after receipt of indicated loss of V011A/B, V012A/B, an actuation signal:

motive power V013A/B open within V001A/B < 40 sec position. the required response V002A/B, V003A/B <

times. Testing of the 100 sec V011A/B <

remotely operated 30 sec V012A/B, valves will be V013A/B < 60 sec performed under the Upon loss of motive conditions of loss of power, each remotely motive power. operated valve identified in Table 2.1.2-1 assumes the indicated loss of motive power position.

64 2.1.02.13b 13.b) The RCPs trip Testing will be The RCPs trip after after receiving a performed using real or receiving a signal signal from the PMS. simulated signals into from the PMS.

the PMS.

No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 110 2.2.01.09 9. Safety-related Inspection will be Safety-related displays identified in performed for displays identified in Table 2.2.1-1 can be retrievability of the Table 2.2.1-1 can be retrieved in the MCR. safety-related displays retrieved in the MCR.

10.a) Controls exist in the MCR. Stroke Controls in the MCR in the MCR to cause testing will be operate to cause those remotely performed on remotely remotely operated operated valves operated valves valves identified in identified in Table identified in Table 2.2.1- Table 2.2.1-1 to 2.2.1-1 to perform 1 using the controls in perform active safety active functions. the MCR. Testing will functions. The 10.b) The valves be performed on remotely operated identified in Table remotely operated valves identified in 2.2.1-1 as having valves listed in Table Table 2.2.1-1 as PMS control perform 2.2.1-1 using real or having PMS control an active safety simulated signals into perform the active function after the PMS. function identified in receiving a signal the table after from the PMS. receiving a signal from PMS.

118 2.2.01.11b 11.b) After loss of Testing of the remotely After loss of motive motive power, the operated valves will be power, each remotely remotely operated performed under the operated valve valves identified in conditions of loss of identified in Table Table 2.2.1-1 assume motive power. 2.2.1-1 assumes the the indicated loss of indicated loss of motive power motive power position. position.

No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 206 2.2.03.10 10. Safety-related Inspection will be Safety-related displays of the performed for the displays identified in parameters identified retrievability of the Table 2.2.3-1 can be in Table 2.2.31 can safety-related displays retrieved in the MCR.

be retrieved in the in the MCR. ii) Stroke ii) Controls in the MCR. 11.a) Controls testing will be MCR operate to exist in the MCR to performed on remotely cause remotely cause the remotely operated valves other operated valves other operated valves than squib valves than squib valves to identified in Table identified in Table 2.2.3- perform their active 2.2.3-1 to perform 1 using the controls in functions. ii) their active the MCR. ii) Testing Remotely operated function(s). 11.b) will be performed on the valves other than The valves identified remotely operated squib valves perform in Table 2.2.3-1 as valves other than squib the active function having PMS control valves identified in identified in the table perform their active Table 2.2.3-1 using real after a signal is input function after or simulated signals to the PMS. iii) receiving a signal into the PMS. iii) These valves open from the PMS. 12.b) Testing will be within 20 seconds After loss of motive performed to after receipt of an power, the remotely demonstrate that actuation signal.

operated valves remotely operated PXS After loss of motive identified in Table isolation valves PXS- power, each remotely 2.2.3-1 assume the V014A/B, V015A/B, operated valve indicated loss of V108A/B open within identified in Table motive power the required response 2.2.3-1 assumes the position. 13. times. Testing of the indicated loss of Displays of the remotely operated motive power parameters identified valves will be position. Displays in Table 2.2.3-3 can performed under the identified in Table be retrieved in the conditions of loss of 2.2.3-3 can be MCR. motive power. retrieved in the MCR.

Inspection will be performed for retrievability of the displays identified in Table 2.2.3-3 in the MCR.

No. ITAAC No. Design Commitment Inspections, Tests, Acceptance Criteria Analysis 664 C.2.6.09.05a 5. Access control Tests, inspections, or The access control points are established combination of tests points for the to: a) control and inspections of protected area: a) personnel and vehicle installed systems and are configured to access into the equipment at the control personnel and protected area. b) access control points to vehicle access. b) detect firearms, the protected area will include detection explosives, and be performed. Tests, equipment that is incendiary devices at inspections, or capable of detecting the protected area combination of tests firearms, incendiary personnel access and inspections of devices, and points. installed systems and explosives at the equipment at the protected area access control points to personnel access the protected area will points.

be performed.

668 C.2.6.09.08a 8.a) Penetrations Inspections will be Penetrations and through the protected performed of openings through the area barrier are penetrations through protected area barrier secured and the protected area are secured and monitored. 8.b) barrier. Inspections will monitored.

Unattended openings be performed of Unattended openings (such as underground unattended openings (such as underground pathways) that that intersect the pathways) that intersect the protected area intersect the protected area boundary or vital area protected area boundary or vital area boundary. boundary or vital area boundary will be boundary are protected by a protected by a physical barrier and physical barrier and monitored by monitored by intrusion detection intrusion detection equipment or equipment or provided surveillance provided surveillance at a frequency at a frequency sufficient to detect sufficient to detect exploitation. exploitation.