NL-14-0180, Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

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Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)
ML14057A776
Person / Time
Site: Hatch  
Issue date: 02/26/2014
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-14-0180
Download: ML14057A776 (8)
v • d • e


Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham. AL 35201 Tel 205.992.7872 Fax 205.992.7601 February 26, 2014 Docket Nos.: 50-321 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 SOUTHERN A COMPANY NL-14-0180 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012.
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012.

4. Edwin I. Hatch Nuclear Plant-Units 1 and 2 Initial Status Report in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated October 23, 2012.
5. Edwin I. Hatch Nuclear Plant-Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013.

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Edwin I. Hatch Nuclear Plant - Units 1 and 2 (HNP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C.1.a of Reference 1.

Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

U. S. Nuclear Regulatory Commission NL-14-0180 Page 2 Reference 4 provided the HNP initial status report regarding mitigation strategies.

Reference 5 provided the HNP overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of.

Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, t.11. ~

C. R. Pierce Regulatory Affairs Director CRP/JMG/RCW

?toand :ubscrib"!!before me this 21£ day of~~

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Notary Public My commission expires: /O / t/c;? o { '1 rr

Enclosure:

Edwin I. Hatch Nuclear Plant - Units 1 and 2

'2014.

Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President-Hatch Mr. B. L. lvey, Vice President - Regulatory Affairs Mr. D. R. Madison, Vice President-Fleet Operations RType: CVC?OOO

U.S. Nuclear Regulatory Commission NL-14-0180 Page 3 U.S. Nuclear Regulatory Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager-Hatch Mr. E. D. Morris, Senior Resident Inspector-Hatch Ms. J. A. Kratchman, NRR/JLD/PMB Mr. E. E. Bowman, NRR/DPR/PGCB State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Edwin I. Hatch Nuclear Plant-Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure Edwin I. Hatch Nuclear Plant-Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-14-0180 Second Six-Month Status Report of FLEX Implementation Edwin I. Hatch Nuclear Plant-Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) 1 Introduction Edwin I. Hatch Nuclear Plant-Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of December 31, 2013:

None 3

Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion date does not impact the Order implementation date.

Target Activity Revised Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Develop Modifications-Unit 2 Apr 2014 Started Initiate Phase 2 Equipment Procurement Jun 2014 Started Develop Strategies (Playbook) with RRC Jun 2015 Started Submit 6 Month Status Report Auq 2014 Not Started Perform Staffinq Analysis (Phase 2)

Aug 2014 Not Started Develop Operational Procedure Changes Sep 2014 Started Create Maintenance Procedures Nov 2014 Not Started Develop Training Material Nov 2014 Not Started Submit 6 Month Status Report Feb 2015 Not Started Issue FSGs Mar 2015 Started Unit 2 Implementation Outage **

Mar 2015 Not Started Implement Training Mar 2015 Started Develop Modifications-Unit 1 Apr 2015 Not Started Submit 6 Month Status Report Aug 2015 Not Started Submit 6 Month Status Report Feb 2016 Not Started Unit 1 Walk-throughs or Demonstrations Apr 2016 Not Started Unit 1 Implementation Outage

  • Apr 2016 Not Started Mar 2016 Submit 6 Month Status Report Aug 2016 Not Started Page 1

Enclosure to NL-14-0180 Second Six-Month Status Report of FLEX Implementation Unit 2 Walk-throughs or Demonstrations Dec 2016 Not Started Unit 2 Implement Non-Outage Mods**

Dec 2016 Not Started Submit Completion Report Dec 2016 Not Started

  • Full compliance after second listed refueling outage
    • Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016 4

Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1 of this enclosure).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant-Units 1 and 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan. The Interim Staff Evaluation (ISE) has not yet been issued.

Overall Integrated Plan Open Item Status

1. Structure, content and details of the Regional SAFER Team developing Pilot Response Center playbook will be determined.

Playbook Interim Staff Evaluation Open Items Status Not yet issued.

N/A 7

Potential Draft Staff Evaluation Impacts The NRC has not issued an Interim Staff Evaluation (ISE) for HNP, therefore, there are no potential impacts to the ISE identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013.

Page 2

Enclosure to NL-14-0180 Second Six-Month Status Report of FLEX Implementation

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12, 2012.

9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but does not constitute a change in strategy:

1. A structure to provide protection of the FLEX equipment will be constructed to meet the requirements identified in NEI 12-06 Section 11. Construction of the FLEX Storage Facility will be completed for 2 sets of FLEX equipment by the date the first unit will reach the Order EA-12-049 implementation completion due date.
2. For the method of SFP makeup referenced on page 35 of Reference 1, (and updated in Reference 3), operators would require opening 7 manual valves per unit (1 P41-F1383, 1P41-F070A, 1P41-F103, 1G41-F217, and new RHRSW-RBSW manual valves 1E11-F904A, 1 E11-F906A and 1 E11-F907 A for Unit 1; 2P41-F1386, 2P41-F070B, 2P41-073, 2G41-F040 and new RHRSW-RBSW manual valves 2E11-F904B, 2E11-F906B and 2E11-F907B for Unit 2) versus the 2 valves stated in the OIP.
3. The revised calculation values for the MCR heat-up to greater than 11 ooF is 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> versus the assumed value of 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> in Reference 1. The mitigation strategy has changed from opening doors based on an assessment of outside temperature, to blocking open the entrance at the stairwell to the MCR and the lower stairwell doors coupled with the opening of the outside freight elevator doors and doors from MCR to the turbine building at or before 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> following the BDBEE initiation. Preliminary assessment indicates that by employing this strategy and modifying MCR lighting with LED bulbs, the MCR temperature will not exceed 11 ooF at approximately the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> point by which time Phase 2 actions can be implemented.
4. The most recent calculation performed for the RCIC room heat-up over an extended period of operation concludes that the room remains below 148°F for the duration of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, with no operator required actions, after which RCIC is not assumed to be required.
5. To maintain the Main Control Room (MCR) temperature below 11 ooF during Phase 2, two 42,000 scfm fans will be directed at the stairwell door at the 130' elevation stairs to the control room. This will establish a flow from the lower control building (and outside) to the control room at the 164' elevation and provide for forced air to be delivered to the MCR.
6. For the timing of RCIC suction swap from CST back to Torus due to CST depletion, a correction in the timing from 6.5-7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 6.05-7.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> was made to accurately reflect calculation results.
7. To enable faster response time and ease the process of deployment, a single large, diesel driven, trailer mounted pump capable of supplying cooling water for both Unit 1 and Unit 2 at twice the amount required has been chosen vs. the two or more pumps referred to in Reference 1.
8. The method for extracting fuel oil for powering Phase 2 and 3 equipment has changed from using manual or battery operated pumps to repowering the existing Diesel Fuel Oil Storage Page 3

Enclosure to NL-14-0180 Second Six-Month Status Report of FLEX Implementation Tanks (DFOST) transfer pumps and transferring fuel to a portable tank/trailer. The DFOST transfer pumps will be repowered from the FLEX Phase 2 600V Diesel Generator through installed in-plant breaker alignments.

9. For the Spent Fuel Pool area, the description of the pneumatic seals that need to be provided with backup air supply has been corrected. The discussion in Reference 1 on "Spent Fuel Pool Gate Seals" was corrected to refer to the "Transfer Canal Seismic Gap Seals". The transition piece which connects the transfer canal between Unit 1 and Unit 2 is provided with pneumatic seals to prevent leakage of water from the transfer canal. The seals are supplied by the service air system with a backup supply from an accumulator that provides sufficient air to keep the seismic gap seals pressurized for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During Phase 2, the transition assembly seals are pressurized as necessary by valving in backup air from the FLEX air compressor located on the east side of the RB. The air compressor will be connected at the reactor building penetration and supplies the transition assembly seals via hose run from the 130' elevation to the refueling floor and to the service air system that supplies the seals. In addition, the seals can be pressurized using backup nitrogen bottles in accordance with procedure 34SO-P51-002, Instrument and Service Air System.
10. SNC is in the process of evaluating Phase 3 strategies and timing; any changes in Phase 3 strategies will be reflected in a future six month status report.

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