NL-16-0024, Sixth 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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Sixth 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)
ML16057A161
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 02/25/2016
From: Pierce C
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-16-0024
Download: ML16057A161 (8)


Text

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham , AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN * \

NUCLEAR A SOUTHERN COMPANY fEB 2 5 20\6 Docket Nos.: 50-424 NL-16-0024 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Sixth 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 CEA-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.
6. SNC Letter NL-15-1777, Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated November 20, 2015.

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

U.S. Nuclear Regulatory Commission NL-16-0024 Page2 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.

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 sixth 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. Reference 6 documents compliance with NRC Order EA-12-049 on VEGP Unit 1 in fall 2015. 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.

C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Swam to and subscribed before me this .d..i_ day of~ 12016.

~~~~~~

My commission expires; /6 . o ~.-t.o II

Enclosure:

Vogtle Electric Generating Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

  • r --= :-:'i' .+... . :;::::::y;::::c. ** -1;::  ::;:u:= w

U. S. Nuclear Regulatory Commission NL-16-0024 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President- Vogtle 1& 2 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 1 & 2 RType: CVC7000 U. S. Nuclear Regulatorv Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspector- Vogtle 1 & 2 Mr. A. M. Alen Resident Inspector- Vogtle 1 & 2 Mr. E. E. Bowman, NRRIJLD!TSD State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant- Units 1 and 2 Sixth 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 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Vogtle Electric Generating Plant- Units 1 and 2 Sixth 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 Accomplishment s 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, 2015:

  • Develop Operational Procedure Changes
  • Unit 1 Walk-throughs or Demonstrations
  • Unit 1 Implementation Outage
  • Develop FSGs (Unit 1 only)
  • Issue FSGs (Unit 1 only)
  • Implement Training
  • Phase 2 Equipment Procurement Complete 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 Complete 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 Com_plete N/A Submit 6 Month Status Report Feb 2014 Com_piete N/A Submit 6 Month Status Report Aug 2014 Comj)lete N/A Submit 6 Month Status Report Feb 2015 Comj)(ete N/A Develop Modifications Mar 2015 Comj)(ete N/A Develop Training Material Jun 2015 Coi'I}Q!ete N/A Develop Strategies (Vogtle Response Plan} Jun 2015 Complete N/A with National SAFER Response Center Submit 6 Month Status Report Aug 2015 Coi'I}Q!ete N/A Develop Operational Procedure Changes Oct 2015 Coi'I}Q!ete N/A Unit 1 Walk-throughs or Demonstrations Oct 2015 Com~ete N/A Unit 1 Implementation Outage

  • Oct 2015 Complete N/A Develop FSGs Oct 2015 In Progress April2016-lssueFSGs Oct 2015 In Progress April2016-E-1

Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Implement Training Oct 2015 Complete N/A Phase 2 Equipment Procurement Complete Dec 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Unit 2 Walk-throughs or Demonstrations Apr 2016 In Progress Unit 2 Implementation Outage

  • Apr 2016 Not Started Submit Completion Report Jun 2016 Not Started
  • Full compliance after the Implementation/second refueling outage or as approved by NRC extens1on (Reference 5)
    • Unit 1 FSGs developed and issued; Unit 2 FSGs in progress with new target date 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 has completed the implementation of this Order and the compliance letter has been submitted to the NRC dated November 20, 2015 (Reference 7).

As noted in Section 2, the Milestones accomplished by December 31, 2015 are included in this report. 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 Complete Response Plan will be determined.

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Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Interim Staff Evaluation Open Item Status 3.2.4.10.A Load Reduction to Conserve DC Closed Power - The licensee stated that the Class 1E batteries are capable NRC reviewed and closed in maintaining critical loads for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> VEGP, Units 1 and 2- Report for prior to reaching the minimum voltage the Audit Regarding during an ELAP event, with margin. Implementation of Mitigating However, on page 10 of the Integrated Strategies for Order EA-12-049 as Plan the licensee stated that the 480V documented on page 6 of section Flex DGs will be available at any point 3.2.b last paragraph, dated 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 August 25, 2015. (ML15210A510) battery charger on each Class 1E 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.

7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (IS E) 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.

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Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation

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.
7. SNC Letter NL-15-1777, Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated November 20, 2015.

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham , AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN * \

NUCLEAR A SOUTHERN COMPANY fEB 2 5 20\6 Docket Nos.: 50-424 NL-16-0024 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Sixth 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 CEA-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.
6. SNC Letter NL-15-1777, Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated November 20, 2015.

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

U.S. Nuclear Regulatory Commission NL-16-0024 Page2 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.

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 sixth 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. Reference 6 documents compliance with NRC Order EA-12-049 on VEGP Unit 1 in fall 2015. 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.

C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Swam to and subscribed before me this .d..i_ day of~ 12016.

~~~~~~

My commission expires; /6 . o ~.-t.o II

Enclosure:

Vogtle Electric Generating Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

  • r --= :-:'i' .+... . :;::::::y;::::c. ** -1;::  ::;:u:= w

U. S. Nuclear Regulatory Commission NL-16-0024 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President- Vogtle 1& 2 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 1 & 2 RType: CVC7000 U. S. Nuclear Regulatorv Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspector- Vogtle 1 & 2 Mr. A. M. Alen Resident Inspector- Vogtle 1 & 2 Mr. E. E. Bowman, NRRIJLD!TSD State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant- Units 1 and 2 Sixth 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 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Vogtle Electric Generating Plant- Units 1 and 2 Sixth 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 Accomplishment s 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, 2015:

  • Develop Operational Procedure Changes
  • Unit 1 Walk-throughs or Demonstrations
  • Unit 1 Implementation Outage
  • Develop FSGs (Unit 1 only)
  • Issue FSGs (Unit 1 only)
  • Implement Training
  • Phase 2 Equipment Procurement Complete 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 Complete 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 Com_plete N/A Submit 6 Month Status Report Feb 2014 Com_piete N/A Submit 6 Month Status Report Aug 2014 Comj)lete N/A Submit 6 Month Status Report Feb 2015 Comj)(ete N/A Develop Modifications Mar 2015 Comj)(ete N/A Develop Training Material Jun 2015 Coi'I}Q!ete N/A Develop Strategies (Vogtle Response Plan} Jun 2015 Complete N/A with National SAFER Response Center Submit 6 Month Status Report Aug 2015 Coi'I}Q!ete N/A Develop Operational Procedure Changes Oct 2015 Coi'I}Q!ete N/A Unit 1 Walk-throughs or Demonstrations Oct 2015 Com~ete N/A Unit 1 Implementation Outage

  • Oct 2015 Complete N/A Develop FSGs Oct 2015 In Progress April2016-lssueFSGs Oct 2015 In Progress April2016-E-1

Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Implement Training Oct 2015 Complete N/A Phase 2 Equipment Procurement Complete Dec 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Unit 2 Walk-throughs or Demonstrations Apr 2016 In Progress Unit 2 Implementation Outage

  • Apr 2016 Not Started Submit Completion Report Jun 2016 Not Started
  • Full compliance after the Implementation/second refueling outage or as approved by NRC extens1on (Reference 5)
    • Unit 1 FSGs developed and issued; Unit 2 FSGs in progress with new target date 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 has completed the implementation of this Order and the compliance letter has been submitted to the NRC dated November 20, 2015 (Reference 7).

As noted in Section 2, the Milestones accomplished by December 31, 2015 are included in this report. 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 Complete Response Plan will be determined.

E-2

Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation Interim Staff Evaluation Open Item Status 3.2.4.10.A Load Reduction to Conserve DC Closed Power - The licensee stated that the Class 1E batteries are capable NRC reviewed and closed in maintaining critical loads for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> VEGP, Units 1 and 2- Report for prior to reaching the minimum voltage the Audit Regarding during an ELAP event, with margin. Implementation of Mitigating However, on page 10 of the Integrated Strategies for Order EA-12-049 as Plan the licensee stated that the 480V documented on page 6 of section Flex DGs will be available at any point 3.2.b last paragraph, dated 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 August 25, 2015. (ML15210A510) battery charger on each Class 1E 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.

7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (IS E) 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.

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Enclosure to NL-16-0024 Sixth Six-Month Status Report of FLEX Implementation

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.
7. SNC Letter NL-15-1777, Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated November 20, 2015.

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