ND-19-0880, Units 3 and 4 Twelfth 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)
| ML19239A334 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/27/2019 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| EA-12-049, ND-19-0880 | |
| Download: ML19239A334 (10) | |
Text
Southern Nuclear Michael J. Yox Regulatory Affairs Director Vogtle 3&4 August 27, 2019 Docket Nos.: 52-025 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 7825 River Road Waynesboro, GA 30830 706 848 6459 tel myox@souttiernco. com ND-19-0880 Vogtle Electric Generating Plant -
Units 3 and 4 Twelfth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitiaation Strateaies for Bevond-Desiqn-Basis External Events (EA-12-0491
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. SNC Letter ND-13-1702, Vogtle Electric Generating Plant Units 3 and 4 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 August 22, 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 directed the Vogtle Electric Generating Plant - Units 3 and 4 (VEGP 3&4) 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 3 of Reference 1.
Reference 1 required submission of an Overall Integrated Plan within one year after issuance of the final NRC Interim Staff Guidance (Reference 2). Reference 2 endorses industry guidance document NE112-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the VEGP 3&4 Overall Integrated Plan.
U. S. Nuclear Regulatory Commission ND-19-0880 Page 2 Reference 1 requires submission of a status report at six-month intervals following submittai of the Overall Integrated Plan. Reference 3 provides direction regarding the content of the status reports and was followed in developing the enclosed report. The purpose of this letter is to provide the twelfth 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 status report provides an update of milestone accomplishments since the last six-month update, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
This letter contains no new regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
If you have any questions, please contact Mr. Dave Midlik at 706-848-6737.
I declare under penalty of petjury that the foregoing is true and correct. Executed on the 27**^
day of August 2019.
Respectfully submitted.
Michael J. Vox Vogtle 3&4 Regulatory Affairs Director Southern Nuclear Operating Company MJY/DWM/sfr
Enclosure:
Twelfth 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)
U. S. Nuclear Regulatory Commission ND-19-0880 Page 3 go:
Southern Nuclear Operating Company / Georgia Power Company Mr. 8. E. Kuczynski (w/o enclosures)
Mr. P. P. Sena III (w/o enclosures)
Mr. M. D. Meier (w/o enclosures)
Mr. D. H. Jones (w/o enclosures)
Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)
Mr. T. W. Yelverton (w/o enclosures)
Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. M. Ronnlund Mr. D. L. Fulton Mr. M. J. Vox Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee Ms. A. Gibson Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. BIythe Document Services RTYPE: VND.LI.LOO File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)
Ms. J. Dixon-Herrity Mr. C. Patel Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker Mr. N.D. Karlovich Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Ms. K. P. Carrington Mr. P.J. Heher Mr. M. Webb
U. S. Nuclear Regulatory Commission ND-19-0880 Page 4 State of Georgia Mr. R. Dunn Oalethoroe Power Corporation Mr. M. W.
Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Mr. L. Oriani (w/o enclosures)
Mr. T. Rubenstein (w/o enclosures)
Mr. M. Corletti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. 8. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NU8, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GD8 Associates, Inc.
Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. 8. Franzone, Florida Power & Light
Southern Nuclear Operating Company ND-19-0880 Enclosure Vogtle Electric Generating Plant Units 3 and 4 Twelfth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Bevond-Desion-Basis External Events (EA-12-0491 (This enclosure consists of 6 pages including this cover page)
ND-19-0880 Enclosure Twelfth 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 3 and 4 developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Nuclear Regulatory Commission Order EA-12-049 (Reference 2). This status report provides an update of milestone accomplishments since the last six-month update, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 Milestone Accompiishments In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the last six-month update (Reference 3),
and are current as of August 3, 2019:
- None 3
Milestone Schedule Status The following table provides an update to the milestone schedule. The table provides the activity status of each item and indicates whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
During this reporting period, a modification was made to the following line items:
Ensuring operational procedures include necessary information - this line item was split into two line items. One line item is for the Operations' Beyond-Design-Basis (BDB) procedures (i.e., FLEX Support Guidelines/Strategy Implementing
.Guidelines (FSGs/SIGs)), and one line item is for the BDB Nuclear Management Procedure (NMP) revisions and program documents (e.g.. Emergency Operations Facility (EOF), Technical Support Center (TSC), and Security (SEC) responses, and Emergency Preparedness (EP) procedures).
Develop Response Plan with National SAFER Response Center (NSRC)
(storage plan and procedural guidance for strategy/maintenance) - this line item was split into two line items, one for Unit 3 and one for Unit 4.
Initiate Phase 3 Equipment Procurement - this line item was split into two line items, one for Unit 3 and one for Unit 4.
Demonstration - these line items were removed. BDB response actions will be factored into the EP 8-year drill cycle. Refer to Section 4 of this letter for more information.
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ND-19-0880 Enclosure Twelfth 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)
Milestone Target Completion Date Activity Status Revised Target Completion Date (Aug 3, 2019 data date)
Subm 160 Day Status Report Oct2012 Complete N/A Subm t Overall Integrated Plan (OIP)
Aug 2013 Complete N/A Subm16 Month Status Report Feb 2014 Complete N/A Subm16 Month Status Report Aug 2014 Complete N/A Subm16 Month Status Report Feb 2015 Complete N/A Subm16 Month Status Report Aug 2015 Complete N/A Subm 16 Month Status Report Feb 2016 Complete N/A Subm16 Month Status Report Aug 2016 Complete N/A Subm 16 Month Status Report Feb 2017 Complete N/A Subm16 Month Status Report Aug 2017 Complete N/A Subm16 Month Status Report Feb 2018 Complete N/A Subm16 Month Status Report Aug 2018 Complete N/A Subm 111"' 6-Month Status Report Feb 2019 Complete N/A Subm 112"^ 6-Month Status Report Aug 2019 Complete N/A Develop FLEX training Aug 2019 In Progress Feb 20 Staffing Analysis Complete Oct2019 Ensure Operations' BOB procedures (i.e., FSGs/SIGs) include necessary information Nov2019 In Progress Jun 2020 Ensure BOB Nuclear Management Procedure (NMP) revisions and program documents (e.g., EOF, ISC, and SEC responses, EP procedures) include necessary information NOV2019 In Progress Mar 2020 Develop Response Plan with NSRC (storage plan and procedural guidance for strategy/maintenance) -
Units NOV2019 In Progress Dec 2019 Develop Response Plan with NSRC (storage plan and procedural guidance for strategy/maintenance) -
Unit 4 NOV2019 In Progress Mar 2020 Initiate Phase 3 Equipment Procurement -
Unit 3 Dec 2019 Not Started Feb 2020 Initiate Phase 3 Equipment Procurement -
Unit 4 Dec 2019 Not Started Feb 2021 Training complete and documented for Phase 3 to include connection Feb 2020 Not Started Aug 2020 Page 3 of 6
ND-19-0880 Enclosure Twelfth 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) and use of redundant offsite equipment for Ancillary Equipment.
Submit 13"' 6-Month Status Report Feb 2020 Not Started N/A NSRC Operational for Unit 3 Apr 2020 Not Started Jun 2020 Submit Order EA-12-049 Compliance Report for Unit 3 Jun 2020 Not Started Sept 2020 Submit 14"^ 6-Month Status Report Aug 2020 Not Started N/A Submit 15"' 6-Month Status Report Feb 2021 Not Started N/A NSRC Operational for Unit 4 Apr 2021 Not Started Jun 2021 Submit 16'" 6-Month Status Report Aug 2021 Not Started N/A Submit Order EA-12-049 compliance Report for Unit 4 and Final Integrated Plan (FIP)
Jun 2021 Not Started Sept 2021
- An update to Southern Nuclear Operalting Company's (SNCs) response to Reference 4 is in progress. A revised completion date will be established in that updated response and will be carried in future FLEX status reports.
4 Changes to Compliance Method Simulator scenarios Simulator scenarios are not a part of the FLEX training as originally listed in Section 7a of Reference 1. For Vogtle Units 3 and 4, training is provided for responding to a loss of normal power source to 6.9kV or 480V buses, including a prolonged loss of all AC power.
NE112-06 Section 11.6.4 states, "'ANSI/ANS 3.5, Nuclear Power Plant Simulators for use in Operator Training' certification of simulator fidelity (if used) is considered to be sufficient for the initial stages of the beyond-design-basis external event scenario until the current capability of the simulator model is exceeded. Full scope simulator models will not be upgraded to accommodate FLEX training or drills." In addition, the final rule 10 CFR 50.155 does not explicitly require simulator scenarios.
Drills An exception is taken to NE112-06 Section 11.6.5, which states that industry guidance for conducting FLEX drills is provided in NE113-06. SNC will instead utilize NEI 12-06 training and NEI 12-06 Appendix E Validations on an 8-year frequency.
The long-term conclusions from the Rule as published in the Federal Register Notice Vol.
84, No. 154, August 9, 2019 states that conduct of a drill or exercise is not required to meet the order. Performing the actions conducted to show compliance with order, on an 8-year frequency, satisfy the approved rule 10 CFR 50.155.
Plant Modifications Two plant modifications/enhancements were designed for installation during plant construction:
Design change to add a simplified connection point for an alternate feed to the division B and C voltage regulating transformers for transportable generator.
This change provides confidence that class 1E post-accident monitoring instrumentation will receive power following a BOB event if the permanently Page 4 of 6
ND-19-0880 Enclosure Twelfth 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) installed ancillary diesel generators are not operable.
I Design change to add an engineered means of using the Passive Containment Cooling Ancillary Water Storage Tank as a water source for the FLEX pumps. A 5" Storz connection will be added to the drain/overflow line.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Vogtle Electric Generating Plant - Units 3 and 4 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 Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.
Overall Integrated Plan Open Item Status N/A N/A Draft Safety Evaluation Open Item Status Draft Safety Evaluation not received N/A 7
Potential Draft Safety Evaluation Impacts A Draft Safety Evaluation has not been received.
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ND-19-0880 Enclosure Twelfth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Deslgn-Basis External Events (EA-12-049) 8 References The following references support the updates to the Overall Integrated Plan described In this enclosure.
- 1. SNC Letter ND-13-1702, Vogtle Electric Generating Plant Units 3 and 4 Overaii 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 August 22, 2013.
- 2. NRG Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events, dated March 12, 2012.
- 3. SNC letter ND-19-0021, Vogtle Electric Generating Riant -
Units 3 and 4 Eleventh Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis Extemal Events (EA-12-049), dated February 25, 2019.
- 4. NRC letter entitled. Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima DaNchi Accident (Accession No. ML12053A340), dated March 12, 2012.
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