NL-14-0181, 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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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)
ML14058A664
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 02/26/2014
From: Pierce C
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-14-0181
Download: ML14058A664 (8)
v • d • e


Text

Charles R. Pierce Southern Nuclear Regulatory Affa1rs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 A

Birmmgham. AL 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY February 26, 2014 Docket Nos.: 50-424 NL-14-0181 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating 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)

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. Vogtle Electric Generating 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. Vogtle Electric Generating 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 Vogtle Electric Generating Plant - Units 1 and 2 (VEGP) 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-14-0181 Page 2 Reference 4 provided the VEGP initial status report regarding mitigation strategies.

Reference 5 provided the VEGP 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, C.R.~

C. R. Pierce Regulatory Affairs Director CRP/JMG/RCW Sworn to and subscribed before me this :2 Co dayofJr~~ '2014.

0

~~~x~k Notary Public My commission expires: fo /J /2ot I I

Enclosure:

Vogtle Electric Generating 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) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. E. Tynan, Vice President- Vogtle Mr. B. L. lvey, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President - Fleet Operations RType: CVC7000

U. S. Nuclear Regulatory Commission NL-14-0181 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. E. Martin, NRR Senior Project Manager- Vogtle Mr. L. M. Cain, Senior Resident Inspector- Vogtle 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

Vogtle Electric Generating 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 Vogtle Electric Generating 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-14-0181 Second Six-Month Status Report of FLEX Implementation Vogtle Electric Generating 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 Vogtle Electric Generating 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 Revised Target Activity Milestone Completion Completion Status Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Com21ete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Equipment Procurement Sep 2013 Com_£jete N/A Develop Operational Procedure Changes Dec 2013 Started Oct 2014 Develop Modifications Jan 2014 Started Oct 2014 Submit 6 Month Status Report Feb 2014 Complete N/A Develop Training Material Mar 2014 Started Develop Strategies (Playbook) with RRC Jun 2014 Started Submit 6 Month Status Report Aug 2014 Not Started Phase 2 Equipment Procurement Complete (new) Started Aug 2014 Issue FSGs Sep 2014 Started Implement Training Oct 2014 Started Unit 2 Walk-throughs or Demonstrations Oct 2014 Not Started Unit 2 Implementation Outage

  • Oct 2014 Not Started Submit 6 Month Status Report Feb 2015 Not Started Submit 6 Month Status Report Aug 2015 Not Started Unit 1 Walk-throughs or Demonstrations Oct 2015 Not Started Unit 1 Implementation Outage
  • Oct 2015 Not Started Submit Completion Report Fall 2015 Not Started
  • Full compliance after second listed refueling outage Page 1

Enclosure to NL-14-0181 Second Six-Month Status Report of FLEX Implementation 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 Vogtle Electric Generating Plant- Unit 1 expects to comply with the order implementation date and no relief/relaxation is required at this time. Southern Nuclear Operating Company will be providing a relief request for the Vogtle Electric Generating Plant- Unit 2 by separate letter.

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 and any open items documented in the Interim Staff Evaluation (ISE).

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 Item Status 3.2.4.10.A Load Reduction to Conserve DC Power In Progress

- The licensee stated that the Class 1E batteries are capable maintaining critical loads for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> prior to reaching the minimum voltage during an ELAP event, with margin. However, on page 10 of the Integrated Plan the licensee stated that the 480V Flex DGs will be available at any point past 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore power to one battery charger on each Class 1 E 125Vdc distribution bus. The licensee's response does not address the additional 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that the critical loads would be powered from the Class 1E batteries and whether the minimum voltage would be exceeded during this time.

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Enclosure to NL-14-0181 Second Six-Month Status Report of FLEX Implementation 7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time, except for those identified in Section 6.

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

1. Vogtle Electric Generating 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.
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.

3. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0714 and MF0715), dated January 16, 2014 9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but do 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. Based on updated calculations:
a. The ability to monitor 2 (redundant) channels of instruments is reduced from 16 to 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> only in the event the FLEX DG is not installed and operating as planned and expected per the OIP. The ability to monitor a single channel extends past 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> without the FLEX DG installed.
b. The SFP water inventory heat up rates for the maximum normal design basis heat load has been adjusted from 130°F to 212°F after 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 100°F to 212°F after 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
c. The time to boil following an emergency design basis heat load (full core offload) has been adjusted from 5 to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The time to reach the minimum safe shielding water coverage of 15 feet above the top of irradiated fuel has been adjusted from approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to approximately 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />. The acceptability of the initiation of phase 2 actions at approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> due to SFP evaporation has been adjusted from less than 3 feet to less than 2 feet.

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Enclosure to NL-14-0181 Second Six-Month Status Report of FLEX Implementation

d. The projections for the control room to surpass 11 OoF have been adjusted from less than 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Specifying blocking open the MCR access doors within 1.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> has been added to the phase 1 strategy for MCR accessibility. The time for load shed actions outlined in plant procedures to provide reliable illumination in the control room horseshoe area has been adjusted from more than 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to more than 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.
e. The temperature heat up in the TDAFW pump room with no ventilation has been adjusted from no more than 121 oF during the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SBO coping period to no more than 116°F during the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation.
3. No Phase 1 or Phase 2 coping strategies are required for maintaining containment integrity if the BDBEE occurs while the plant is operating in Modes 1 through 4.
4. A Phase 1 coping strategies will be required for maintaining containment integrity if the BDBEE occurs during operating Modes 5 and 6 with steam generator heat removal not available. Containment venting utilizing the ILRT penetration or acceptable alternative provides this containment coping strategy.
5. Opening the large missile shield doors is no longer credited for SFP area venting.
6. 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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