NL-15-0243, Fourth 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)

Fourth 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)

ML15057A245
Person / Time
Site:	Farley
Issue date:	02/26/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-0243
Download: ML15057A245 (8)

Text

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

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham, AL 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY FEB 2 6 2015 Docket Nos.: 50-348 NL-15-0243 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Fourth 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. Joseph M. Farley 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.

5. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third 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) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP),

Revision 4.

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 Joseph M. Farley Nuclear Plant - Units 1 and 2 (FNP) 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.

U. S. Nuclear Regulatory Commission NL-15-0243 Page 2 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.

Reference 4 provided the initial FNP overall integrated plan (OIP). A revised O I P was submitted with the fall 2014 six-month update ( Reference 5).

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 fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, delineating progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments and schedule adjustments since the last status report.

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, J c.f{

) ' ,

C. R. Pierce Regulatory Affairs Director ) '*

C RP/JMG/GLS Sworn to and subsc c; ore me this 21t_ day otJJ , 2015.

WM_L'd.

t Notary Public My commission expires: J b

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Enclosure:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

U. S. Nuclear Regulatory Commission NL-15-0243 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. R. R. Martin, Regulatory Manager - Farley RType: CFA04.054 U. S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. G. E. Miller, N R R Senior Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector - Farley Ms. J. A. Kratchman, N RR/JLD/ PMB Mr. E. E. Bowman, N R R/D PRI PGCB Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant - Units 1 and 2 Fourth 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 Joseph M. Farley Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-15-0243 Fourth Six-Month Status Report of FLEX Implementation Joseph M. Farley Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) 1 Introduction Joseph M. Farley 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 enclosure 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 previous 6-month update, and are current as of December 31, 2014:

• None 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 1).

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 Target and Revised Target Completion Dates are based on the approval of one additional refueling cycle for full implementation of the Order for Joseph M. Farley Nuclear Plant - Units 1 and 2 (References 4 & 5).

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 Complete N/A Unit 2 1st RFO May_2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Equipment Procurement Sep 2013 Com_plete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aug 2014 Complete Submit 6 Month Status Report Feb 2015 Complete N/A Develop Strategies (Farley Response Plan)

June 2015 In Progress with National SAFER Response Center Submit 6 Month Status Report (new) Not Started Aug 2015 Develop Operational Procedure Changes Oct 2015 In Progress Develop Modifications Oct 2015 In Progress Develop Training Material Dec 2015 In Progress Develop FSGs Dec 2015 In Progress Submit 6 Month Status ReQort (newl Not Started Feb 2016 Phase 2 Equipment Procurement Complete Mar 2016 In Progress Issue FSGs Mar 2016 Not Started lm_plement Training Mar 2016 In Progress Unit 2 Walk-throughs or Demonstrations Mar 2016 Not Started Unit 2 Implementation Outage

• April 2016 Not Started Submit 6 Month Status Report (new) Not Started Aug 2016 E-1

Enclosure to NL-15-0243 Fourth Six-Month Status Report of FLEX Implementation Target Revised Target Activity Milestone Completion Completion Status Date Date Unit 1 Walk-throughs or Demonstrations Sep 2016 Not Started Unit 1 Implementation Outage

• Oct 2016 Not Started Submit Completion Report Dec 2016 Not Started

• Full compliance cons1stent With NRC-approved extens1on (Reference 5) 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Joseph M. Farley Nuclear Plant - Units 1 and 2 requested and received a schedule relaxation of one additional refueling cycle for full implementation of the Order requirements and expects to comply with the relaxed date (References 4 & 5). No additional relief/relaxation is required or anticipated 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 and any open items documented in the Interim Staff Evaluation (ISE).

Overall Integrated Plan Open Item Status Structure, content and details of the Farley SAFER Team developing Response Plan will be determined. Pilot Response Plan Interim Staff Evaluation Open Item Status ISE was issued on February 27, 2014 N/A (ML13337A584) with no Open Items.

7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation ( ISE) for F N P (Reference 3) with no Open Items.

The ISE states that, "the NRC concludes that the licensee has provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will meet the requirements of Order EA-12-049 at the Joseph M. Farley Nuclear Plant, Units 1 and 2."

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Enclosure to NL-15-0243 Fourth Six-Month Status Report of FLEX Implementation 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Joseph M. Farley 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.

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, Joseph M. Farley Nuclear Plant - Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) {TAC NOS. MF0716 and MF0717), dated January 17,2014.

4. Joseph M. Farley Nuclear Plant- Units 1 and 2, Request for Relaxation of Commission Order Modifying Licenses With Regards to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2014.

5. NRC Letter, Joseph M. Farley Nuclear Plant- Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies Beyond Design Basis External Events dated April 14, 2014.

6. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third 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) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

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. The Main Control Room (MCR) access doors that provide an open pathway to the building exterior at plant grade level are blocked open within the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> post-BDBEE instead of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as mentioned in the OIP Revision 4. This strategy will provide sufficient ventilation to equalize the MCR temperature to approximately that of the outside air.

2. Prior to depletion of the initial Condensate Storage Tank (CST) inventory and supplemental Reactor Makeup Water Storage Tank ( RMWST) inventory, the CST or RMWST will require makeup from the Refueling Water Storage Tank (RWST) sufficient to continue decay heat removal from the steam generators. The RWST volume is sufficient to provide makeup capability for cooling beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> post event. The service water pond (UHS) will be utilized as a makeup source following depletion of the RWST. The National SAFER Response Center (NSRC) will furnish portable water treatment equipment (filtration/demineralizer) that may be utilized to clean the makeup water from the service water pond when available. Water sources to satisfy FLEX strategies will be prioritized, with clean water sources preferred. The approach of using the RWST before using the UHS was not stated in the O I P Revision 4.

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Enclosure to NL-15-0243 Fourth Six-Month Status Report of FLEX Implementation

3. Each Seismic Category 1 CST (one per unit) is nominally a 500,000 gallon tank; however, only the bottom 164,000 gallons are missile protected and credited for injection to the steam generators. For conservatism, a value of 150,000 gallons is used in the analyses to determine timing of required actions. This conservatism of using 150,000 gallons was not explained in the OIP Revision 4.

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