NL-15-0245, 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)

ML15057A286
Person / Time
Site:	Vogtle
Issue date:	02/26/2015
From:	Pierce C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-0245
Download: ML15057A286 (7)

Text

Charles A. 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.: 50-424 NL-15-0245 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating 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. 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.

5. Vogtle Electric Generating 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- Vogtle 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 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.

U. S. Nuclear Regulatory Commission NL-15-0245 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 VEGP overall integrated plan (OIP). A revised OIP 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, C. R. Pierce Regulatory Affairs Director ' .

CRP/JMG/GLS Sworn to and subscribed before me this JfL_ day of J ,2015.

(i'cl.

Notary Public My commission expires: It>""-dol '1

Enclosures:

Vogtle Electric Generating 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-15-0245 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Vogtle Mr. M.D. Meier, Vice President- Regulatory Affairs Mr.B. J. Adams, Vice President - Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle RType: CVC7000 U. S. Nuclear Regulatorv Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 Ms. J. A. Kratchman, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPRIPGCB State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating 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 Vogtle Electric Generating 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-15-0245 Fourth Six-Month Status Report of FLEX Implementation Vogtle Electric Generating Plant- Units 1 and 2 Fourth Six-Month Status Report Regarding 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 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:

• Develop Modifications 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 Completion Dates are also based on the approval of one additional refueling cycle for full implementation of the order for Vogtle Electric Generating Plant- Unit 2

{References 4 & 5).

Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Cof1}21ete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Equipment Procurement Sep 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aug 2014 Com_Qiete N/A Develop Training Material Jan 2015 In Progress June 2015 Submit 6 Month Status Report Feb 2015 Com_Qiete N/A Develop Modifications Mar 2015 Complete N/A Develop Strategies (Vogtle Response Plan)

Jun 2015 In Progress with National SAFER Response Center Submit 6 Month Status Report Ay_g_ 2015 Not Started Develop Operational Procedure Changes Oct 2015 In Progress Develop FSGs Oct 2015 In Pro_g_ress Issue FSGs Oct 2015 Not Started Implement Training Oct 2015 In Pro_g_ress Unit 1 Walk-throughs or Demonstrations Oct 2015 Not Started Unit 1 Implementation Outage

• Oct 2015 Not Started Phase 2 Equipment Procurement Complete Dec 2015 In Progress Unit 2 Walk-throughs or Demonstrations AJ>r 2016 Not Started Unit 2 Implementation Outage

• Apr 2016 Not Started Submit 6 Month Status Report Feb 2016 Not Started Submit Completion Report Jun 2016 Not Started

• Full compliance after the Implementation/second refueling outage or as approved by NRC extension (Reference 5)

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Enclosure to NL-15-0245 Fourth 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).

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. Vogtle Electric Generating Plant- Unit 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) dated January 16,2014 (ML13339A781).

Overall Integrated Plan Open Item Status

1. Structure, content and details of the Vogtle SAFER Team developing Pilot Response Plan will be determined. Response Plan Interim Staff Evaluation Open Item Status 3.2.4.10.A Load Reduction to Conserve DC Closed (pending NRC concurrence)

Power - The licensee stated that the Class 1 E batteries are capable Page 9 of Vogtle FLEX OIP-maintaining critical loads for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> Revision 4 states,the Class 1 E prior to reaching the minimum voltage batteries are capable of during an ELAP event, with margin. maintaining critical loads for more However,on page 10 of the Integrated than 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> following the Plan the licensee stated that the 480V initiation of an ELAP event without Flex DGs will be available at any point going below minimum battery 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 voltage limits established in the battery charger on each Class 1 E current licensing basis 125Vdc distribution bus. The licensee's calculation."

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 1 E batteries and whether the minimum voltage would be exceeded during this time.

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Enclosure to NL-15-0245 Fourth Six-Month Status Report of FLEX Implementation 7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for VEGP (Reference 3) with the Open Item listed in Section 6 above. 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 Vogtle Electric Generating Plant, Units 1 and 2."

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.

4. Vogtle Electric Generating Plant - Unit 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,Vogtle Electric Generating Plant,Unit 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 August 14,2014.

6. Vogtle Electric Generating 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 - Vogtle 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 inventory of each NSCW basin accessible to the FLEX Submersible Pump is capable of providing spray for both SFPs (500 gpm total flow) for approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> instead of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> as stated in the OIP Revision 4.

2. Analysis indicates that execution of specified load shed actions (Main Control Room lighting in the "Horseshoe" aligned to the associated unit's D Battery) outlined in plant procedures provides a reliable source of illumination in the Main Control Room for more than 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> instead of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> as stated in the OIP Revision 4.

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