ND-21-0087, Fifteenth 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)
| ML21056A102 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/25/2021 |
| From: | Yox M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, ND-21-0087 | |
| Download: ML21056A102 (10) | |
Text
Michael J. Yox Southern Nuclear Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3&4 706 848 6459 tel myox@southernco.com February 25, 2021 Docket Nos.: 52-025 ND-21-0087 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 3 and 4 Fifteenth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Bevond-Desiqn-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. 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 Extemal Events(Order Number EA-12-049), dated August 22, 2013.
- 5. SNC Letter ND-20-0164, Vogtle Electric Generating Plant Units 3 and 4 Updated Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events (Order EA-12-049), dated May 15, 2020.
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 NEI 12-06, Revision 0(Reference 3) with clarifications and exceptions identified in Reference 2. VEGP 3&4 has provided the original VEGP 3&4 Overall Integrated Plan (Reference 4) and an updated VEGP 3&4 Overall Integrated Plan (Reference 5).
U. S. Nuclear Regulatory Commission ND-21-0087 Page 2 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 and was followed in developing the enclosed report. The purpose of this letter is to provide the Fifteenth 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. Nick Kellenberger 706-437-2333.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25'^^
day of February 2021.
Respectfully submitted.
Michael J. Vox Vogtle 3&4 Regulatory Affairs Director Southern Nuclear Operating Company MJY/KMS/sfr
Enclosure:
Fifteenth 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-21-0087 Page 3 go:
Southern Nuclear Ooeratino Company / Georgia Power Company M . 8. E. Kuczynski (w/o enclosure)
M P. P. Sena III (w/o enclosure)
M M. D. Meier(w/o enclosure)
M G. Chick M S. Stimac M P. Martino M D. L. McKinney (w/o enclosures)
M T. W. Yelverton (w/o enclosures)
M B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. D. L. Fulton Mr. M. J. Vox Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee M M. Humphrey Ms. A. C. Chamberlain M S. Leighty M N. Kellenberger Ms. K. Roberts Mr. J. Haswell Mr. D. T. BIythe Mr. K. Warren Mr. A. S. Parton Mr. A. Nix Document Services RTYPE: VND.LI.LOO File AR.01.02.06 Nuclear Reoulatorv Commission Mr. M. King (w/o enclosure)
Ms. M. Bailey (w/o enclosure)
Ms. A. Veil Mr. G.J. Khouri Mr. G. Armstrong Mr. C. Patel Mr. C. Santos Mr. B. Kemker Mr. J. Eargle Mr. C. J. Even Mr. S. Walker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. O. Lopez-Santiago Mr. M. Webb Mr. B. Gleaves Mr. T. Fredette
U. S. Nuclear Regulatory Commission ND-21-0087 Page 4 Mr. S. Rose Ms. K. McCurry Mr. B. Davis State of Georgia Mr. R. Dunn Oalethorpe Power Corporation Mr. M. W. Price Mr. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georoia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinohouse Electric Company. LLC Mr. L. Oriani (w/o enclosures)
Mr. T. Rubenstein (w/o enclosures)
Mr. M. Corletti 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 Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham
Southern Nuclear Operating Company ND-21-0087 Enclosure Vogtle Electric Generating Plant Units 3 and 4 Fifteenth 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 fEA-12-0491 (This enclosure consists of 6 pages Including this cover page)
ND-21-0087 Enclosure Fifteenth 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) 1 Introduction Vogtle Electric Generating Plant(VEGP)- Units 3 and 4 developed an Overall Integrated Plan (Reference 1 in Section 8), followed by an Updated Overall Integrated Plan (Reference 2), documenting the diverse and flexible strategies (FLEX) in response to Nuclear Regulatory Commission Order EA-12-049(Reference 3). 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 Accomplishments 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 4),
and are current as of February 20, 2021:
- National SAFER (Strategic Alliance for FLEX Emergency Response) Response Center(NSRC)Operational for Units 3 and 4
- Develop Response Plan with NSRC (storage plan and procedural guidance for strategy/maintenance)- Units 3 and 4
- Training complete and documented for Phase 3 to include connection and use of redundant offsite equipment for Ancillary Equipment.
3 Milestone Schedule Status The following table provides an update to the milestone schedule with 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 dates do not impact the Order implementation date.
Revised Target Target Activity Completion Date Milestone Completion Status (Feb 20,2021 Date data date)
Subm 160 Day Status Report Oct2012 Complete N/A Subm t Overall Integrated Plan (OIP) Aug 2013 Complete N/A Subm 16 Month Status Report Feb 2014 Complete N/A Subm 16 Month Status Report Aug 2014 Complete N/A Subm 16 Month Status Report Feb 2015 Complete N/A Subm 16 Month Status Report Aug 2015 Complete N/A Subm 16 Month Status Report Feb 2016 Complete N/A Subm 16 Month Status Report Aug 2016 Complete N/A Subm 16 Month Status Report Feb 2017 Complete N/A Subm 16 Month Status Report Aug 2017 Complete N/A Subm 16 Month Status Report Feb 2018 Complete N/A Subm 16 Month Status Report Aug 2018 Complete N/A Page 2 of6
ND-21-0087 Enclosure Fifteenth 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)
Revised Target Target Activity Completion Date Milestone Completion Status (Feb 20, 2021 Date data date)
Submit 11"^ 6-Month Status Report Feb 2019 Complete N/A Submit 12*'^ 6-Month Status Report Auq 2019 Complete N/A Staffing Analysis Complete Unit 3 Get 2019 Complete N/A Submit 13"^ 6-Month Status Report Feb 2020 Complete N/A Submit 14'^ 6-Month Status Report Aug 2020 Complete N/A Develop FLEX training May 2020 Complete N/A Initiate Fhase 3 Equipment Procurement-Feb 2020 Complete N/A Units 3 and 4 Ensure remaining BOB Nuclear Management Procedure(NMF)revisions and program documents (e.g., EGF,ISC, Get 2020 In Frogress June 2021 and SEC responses, EF procedures) include necessary information Ensure Gperations' BOB procedures (e.g.,
Get 2020 In Frogress May 2021 FSGs/SIGs) include necessary information Develop Response Flan with NSRC (storage plan and procedural guidance for Sept 2020 Complete N/A strategy/maintenance)- Units 3 and 4 Training complete and documented for Fhase 3 to include connection and use of Nov 2020 Complete N/A redundant offsite equipment for Ancillary Equipment.
National SAFER Response Center Get 2020 Complete N/A (NSRC)Gperational for Units 3 and 4 Submit Grder EA-12-049 Compliance Nov 2020 In Frogress June 2021 Report for Unit 3 Submit 15*'^ 6-Month Status Report Feb 2021 Complete N/A Submit 16"^ 6-Month Status Report Aug 2021 Not started N/A Staffing Analysis Complete Unit 4(adding May 2021 In Frogress Aug 2021 Unit 4 to completed Unit 3 analysis)
Submit Grder EA-12-049 Compliance Report for Unit 4 and Final Integrated Flan Get 2021 Not started April 2022 (FIF) 4 Changes to Compliance Method The following update to the information provided in the VEGP Units 3 and 4 Updated GIF (Reference 2) does not change compliance with Nuclear Energy Institute (NEI) 12-06 (Reference 6).
SAFER equipment delivery time extension Section 2.4.3 of the Updated GIF (Reference 2)currently states:
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ND-21-0087 Enclosure Fifteenth 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)
The current SAFER response plan (Reference 17)for the Vogtle site will be updated to include Units 3 and 4 prior to initial fuel load. The SAFER plan details the deployment ofSAFER equipment to the Vogtle site for use. it includes contingencies and aitemate deployment paths to ensure equipment can be delivered within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from SAFER notification.
For VEGP Units 1 and 2, first arriving equipment will be delivered to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request. However, VEGP Units 3 and 4 have a 72-hour passive system coping time, after which installed plant ancillary equipment is capable of supporting passive system cooling from 3 to 7 days. The SAFER Response Pian for Vogtle Electric Generating Plant, updated in October 2020 to include VEGP Units 3 and 4 into the SAFER program, specifies shipment of VEGP Units 3 and 4 equipment within 72-hours from SAFER notification.
If an event affects all four VEGP units, the SAFER Response Plan prioritizes equipment for Units 1 and 2for delivery within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from SAFER notification. The SAFER Response Plan provides two separate NSRC Facility Preparation Checklists, one checklist for VEGP Units 1 and 2 equipment to be prepared and shipped first (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of notification) and one checklist for VEGP Units 3 and 4 equipment to be shipped second (within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of notification). Although the SAFER Response Plan specifies that the single point of contact for all four units can request the VEGP Units 3 and 4 equipment be shipped earlier, shipping the VEGP Units 3 and 4 equipment after the Units 1 and 2 equipment reduces potential confusion associated with having equipment for all four VEGP units arriving at the same time.
The 24-hour time period for delivery of VEGP Units 3 and 4 SAFER equipment currently designated in the VEGP Units 3 and 4 Updated DIP section 2.4.3 will be modified in the Units 3 and 4 FIP to reflect delivery of the VEGP Units 3 and 4 equipment within 72-hours from SAFER notification.
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 and status of the open items documented in the Updated Overall Integrated Plan (DIP)and the confirmatory items documented in the NRC's Interim Safety Evaluation (ISE), dated October 27, 2020(Reference 5). The FLEX program document NMP-GM-038-004 will initially be issued prior to U3 fuel load and updated for U4.
Overall Integrated Plan Open Item Status N/A N/A Page 4 of6
ND-21-0087 Enclosure Fifteenth 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)
Interim Staff Evaluation (ISE) Confirmatory Items Status (Section 3.2.3) Confirmatory Item 1: The design efforts In orooress. Confirmation that related to the modifications noted in the DIP related to FLEX construction and testing of the are complete. However, SNC should confirm that the modifications as described will construction and testing of the described modifications will be included in the U3 be completed prior to implementation of OIP. Compliance Report.
(Section 3.2.3) Confirmatory Item 2: In the original OIP, SNC In orooress. The uodated provided simplified sketches depicting flow paths and FLEX sketches as described will be connections. These sketches should be updated and included in the FLEX program provided in appropriate program documents, including the document NMP-GM-038-004 FIP. and the FIP.
(Section 3.2.3) Confirmatory Item 3: SNC should provide an approved equipment list to delineate required FLEX In orooress. Aooroved equipment(pumps, generators, fans, etc.), capacities, need equipment list to be included in for spares, and associated support (hoses, cables, the FLEX program document connections, ducting, etc.) similar to the information provided NMP-GM-038-004 and the FIP.
in original OIP and NE1 12-06. The list should include the required critical performance criterion.
In orooress. 3-RNS-P72-001.
Post 72-Hour Operations of Containment Makeup, is (Section 3.2.3) Confirmatory Item 4: SNC should provide a included in OIP Section 2.19.2.
strategy to provide makeup water to containment as Additional clarification will be discussed in DCD/FSAR Section 5.4.7.5.
added to the FLEX program document NMP-GM-038-004 and the FIP.
(Section 3.2.3) Confirmatory Item 5: SNC updated the "Cold Weather Checklist" procedure for VEGP Units 1 and 2 to incorporate a check of roads and access routes in the OCA In orooress. 11877-2."VEGP and protected area for icing conditions. The checklist 1-2 Cold Weather Checklist", is designated a sand procurement location and to deploy ice being updated to include VEGP melt from a storage warehouse. SNC needs to confirm that Units 3 and 4 FLEX routes.
this checklist has been extended to cover the FLEX deployment routes for VEGP Units 3 and 4.
(Section 3.2.3) Confirmatory Item 6: OIP References 63 and In orooress. References 63 64 are noted in Section 2.20.1 as an evaluation of the haul and 64 will be added to the paths for Units 3 and 4. These references are not included in FLEX program document NMP-the OIP list of references. GM-038-004 and the FIP.
Potential Draft Safety Evaluation Impacts Any potential impact to the Interim Staff Evaluation has been previously discussed in Section 4 of this letter.
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ND-21-0087 Enclosure Fifteenth 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) 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 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemai Events(Order Number EA-12-049), dated August 22, 2013.
- 2. SNC Letter ND-20-0164, Vogtie Electric Generating Plant Units 3 and 4 Updated Overall integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemai Events(Order EA-12-049), dated May 15, 2020.
- 3. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemai Events, dated March 12, 2012.
- 4. SNC letter ND-20-1003, Vogtie Electric Generating Plant- Units 3 and 4 Fourteenth Six-Month Status Report of the implementation ofthe Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis Extemai Events (EA-12-049), dated August 28, 2020.
- 5. NRC Letter, Vogtie Electric Generating Plant, Units 3 and 4- Staff Evaluation Regarding implementation of Mitigating Strategies Related to Order EA-12-049(EPiD L-2020-LRQ-0002), dated October 27, 2020.
- 6. NEI 12-06, Diverse and Flexible Coping Strategies(FLEX)implementation Guide, Revision 0, dated August 2012.
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