ND-22-0502, Completion of Required Action for Nrg Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events

Completion of Required Action for Nrg Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events

ML22311A457
Person / Time
Site:	Vogtle
Issue date:	11/07/2022
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0502, EA-12-049
Download: ML22311A457 (1)

Text

~ Southern Nuclear Jamie M. Coleman Regu latory Affairs Director 7825 River Road Waynesboro , GA 30830 Vogtle 3&4 706-848-6926 tel November 7, 2022 ND-22-0502 Docket No.: 52-025 U.S. Nuclear Regulatory Commission Document Control Desk Washington , D.C. 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 Completion of Required Action for NRG Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directs the Vogtle Electric Generating Plant (VEGP) Units 3 and 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. This letter, along with the Enclosure, provides the notification required by Item IV.C .3 of Order EA-12-049 that full compliance with the requirements described in Attachment 3 of the Order has been achieved for VEGP Unit 3.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information .

If there are any questions regarding this letter, please contact Will Garrett at (706) 848-7154.

Respectfully submitted ,

Jamie M. Coleman Vogtle 3&4 Regulatory Affairs Director Southern Nuclear Operating Company JMC/KMS/sfr

Enclosure:

Completion of Required Action for NRG Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events

U.S. Nuclear Regulatory Com mission ND-22-0502 Page 2 of 2 cc: Regional Administrator, Region II VPO Project Manager Senior Resident Inspector - Vogtle 3 & 4 Director, Environmental Protection Division - State of Georgia

Southern Nuclear Operating Company ND-22-0502 Enclosure Vogtle Electric Generating Plant Unit 3 Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events (This enclosure consists of 9 pages including this cover page)

ND-22-0502 Enclosure Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Oesign-Basis External Events (Reference 1), to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directed the Vogtle Electric Generating Plant (VEGP) Units 3 and 4 to provide diverse and flexible strategies (FLEX) in response to NRC Order EA-12-049.

SNC developed the VEGP Units 3 and 4 Overall Integrated Plan (OIP) (Reference 5) and the VEGP Units 3 and 4 Updated OIP (Reference 19) to provide FLEX. The information provided in this submittal, as well as the implementation of the OIPs, documents full compliance for VEGP Unit 3 in response to the NRC Order (Reference 1).

Open Item Resolution Licensee-identified Open Items documented in the 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 External Events (Order EA-12-049), dated May 15, 2020 (Reference 19) have been completed by SNC for Unit 3 as follows:

Updated Overall Integrated Plan (OIP) Open Items Unit 3 Status (Section 2.15) Open Item ComQlete Communications - Procurement of Satellite phones (Section 2.15) Open Item Communications - Transfer of company assets to Vogtle 3 and 4 (One RapidCom ComQlete and one Rapid Case)

(Section 2.15) Open Item ComQlete Communications - Upgrade hardware and software for these units as required (Section 2.19.1) Open Item ComQlete Overall Proqram Document - Completion of NMP-GM-038 and NMP-GM-038-004 (Section 2.19.2) Open Item ComQlete Procedural Interfaces - lssuinq Procedures as Version 1.0 (Section 2.19.3) Open Item ComQlete Staffinq - Complete 12-01 staffinq study for Units 3 and 4 (Section 2.19.4) Open Item ComQlete Traininq - Complete development of traininq modules (Section 2.19.4) Open Item ComQlete Training - Training provided and documented IAW site procedures (Section 2.19.5) Open Item FLEX Equipment List - Contract with SAFER {Strategic Alliance for FLEX ComQlete Emerqencv Response}

(Section 2.19.5) Open Item ComQlete FLEX Equipment List - Revise Vogtle SAFER Plan to include Vogtle 3 and 4 Page 2 of 9

ND-22-0502 Enclosure Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events NRC Confirmatory items (Cls) documented in the Vogtle Electric Generating Plant, Units 3 and 4 - Staff Evaluation Regarding Implementation of Mitigating Strategies Related to Order EA 049 (EPID L-2020-LRQ-0002), dated October 27, 2020 (Reference 25) have been completed by SNC for Unit 3 as follows:

Interim Staff Evaluation (ISE)

Unit 3 Status Confirmatory Items (Cl)

(Sections 3.2.3, 3.4.3, 3.4.8) Confirmatory Complete. Construction and testing of the described Item 1 modifications is complete for VEGP Unit 3, including the The design efforts related to the connection on the passive containment cooling auxiliary modifications noted in the 01 P related to water storage tank (PCCAWST) drain line to allow a FLEX are complete. However, SNC should SAFER supplied pump to move water from the tank to confirm that the construction and testing of the passive cooling system and the spent fuel pool, the described modifications will be installation of two electrical receptacles and transfer completed prior to implementation of OIP. switches for connection of a SAFER supplied 480V 150kW diesel generator and walkdown verification of the FLEX equipment fit up to these connections. Technical Evaluation (TE) 60019750 is tracking inclusion of Cl 1 in the VEGP Units 3&4 Final Integrated Plan (FIP), to be issued at VEGP Unit 4 compliance .

(Section 3.2.3) Confirmatory Item 2 Complete. The VEGP Unit 3&4 updated sketches are In the original OIP, SNC provided simplified included as Attachment 3 in FLEX program document sketches depicting flow paths and FLEX NMP-GM-038-004, issued for VEGP Unit 3 FLEX connections. These sketches should be compliance. TE 60019751 is tracking the inclusion of Cl updated and provided in appropriate 2 in the VEGP Units 3&4 FIP, to be issued at VEGP Unit proqram documents, includinq the FIP. 4 compliance.

(Sections 3.2.3, 3.5.1) Confirmatory Item 3 Complete. Phase 2 and Phase 3 required FLEX SNC should provide an approved equipment equipment, including capacities , spares, critical list to delineate required FLEX equipment performance criterion and associated spares, is included (pumps, generators, fans, etc.), capacities , as Table 7 in the FLEX program document NMP-GM-need for spares, and associated support 038-004, issued for VEGP Unit 3 FLEX compliance. TE (hoses, cables, connections , ducting , etc.) 60019751 is tracking inclusion of Cl 3 in the VEGP Units similar to the information provided in original 3&4 FIP, to be issued at VEGP Unit 4 compliance .

OIP and NEI 12-06. The list should include the required critical performance criterion.

(Sections 3.2.3, 3.8) Confirmatory Item 4 Complete. Section 2.19.2 in the Updated OIP currently SNC should provide a strategy to provide references 3-RNS-P72-001 , Post 72-Hour Operations of makeup water to containment as discussed Containment Makeup, which provides instructions for in DCD/FSAR Section 5.4.7.5. emergency makeup to containment during an extended loss of offsite power and normal makeup methods are unavailable. This information is also included in Section 4.1.4 of the FLEX program document NMP-GM-038-004, issued for VEGP Unit 3 FLEX compliance. TE 60019751 is tracking the inclusion of Cl 4 in the VEGP Units 3&4 FIP, to be issued at VEGP Unit 4 compliance Page 3 of 9

ND-22-0502 Enclosure Completion of Requi red Action for NRG Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Interim Staff Evaluation (ISE)

Unit 3 Status Confirmatory Items (Cl)

(Section 3.3.4) Confirmatory Item 5 Complete. Version 24 of 11877-2, Cold Weather SNC updated the "Cold Weather Checklist" Checklist, effective 08/05/21 , includes VEGP Unit 3 procedure for VEGP Units 1 and 2 to FLEX deployment routes as depicted in NMP-OS-019-incorporate a check of roads and access 405, Vogtle Unit 3 FSG-5, Initial Assessment and FLEX routes in the OCA and protected area for Equipment Staging, in Attachment 5.

icing conditions. The checklist designated a sand procurement location and to deploy ice melt from a storage warehouse . SNC needs to confirm that this checklist has been extended to cover the FLEX deployment routes for VEGP Units 3 and 4.

(Section 3.4.2) Confirmatory Item 6 Complete. Ref 63 is 23162-000-30R-M1 0R-00003, FLEX OIP References 63 and 64 are noted in Debris Evaluation Vogtle Electric Generating Plant Units Section 2.20.1 as an evaluation of the haul 3 and 4, and Ref 64 is 23162-000-K0C-00V-00001, paths for Units 3 and 4. These references FLEX Haul Road Liquefaction Analysis. Both are are not included in the 01 P list of references. included as references in the FLEX program document NMP-GM-038-004, issued for VEGP Unit 3 FLEX compliance .

Milestone Schedule - Items Complete VEGP Unit 3 Milestone Completion Date Submit 60 Dav Status Report Oct 2012 Submit Overall lnteqrated Plan (OIP) Auq 2013 1st 6 Month Update Feb 2014 2 nd 6 Month Update Auq 2014 3 rd 6 Month Update Feb 2015 4 th 6 Month Update Aug 2015 5th 6 Month Update Feb 2016 5th 6 Month Update Auq 2016 7th 6 Month Update Feb 2017 sth 6 Month Update Auq 2017 9th 6 Month Update Feb 2018 1oth 6 Month Update Aug 2018 11 th 6-Month Update Feb 2019 12th 6-Month Update Aug 2019 Staffinq Analysis Complete Unit 3 Oct 2019 13th 6-Month Update Feb 2020 Initiate Phase 3 Equipment Procurement Feb 2020 Submit Updated OIP May 2020 Develop FLEX train ing May 2020 14th 6-Month Update Auq 2020 Develop Response Plan with National SAFER Response Center (NSRC) Sept2020 NSRC Operational Oct 2020 Training complete and documented for Phase 3 Nov 2020 Page 4 of 9

ND-22-0502 Enclosure Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events VEGP Unit 3 Milestone Completion Date 15th 6-Month Update Feb 2021 16th 6-Month Update Auq 2021 17th 6-Month Update Feb 2022 Staffing Analysis Complete (addinq Unit 4 to completed Unit 3 analysis) (1) June 2022 Ensure Operations' BOB procedures include necessary information June 2022 18 th 6-Month Update Aug 2022 Ensure remaining BOB Procedure revisions and program documents include Aug 2022 necessary information (1 ) VEGP Units 3&4 staffing analysis completed in August 2021 was updated and submitted in June 2022 (listed as July 2022 on 18th Six-Month Update ND-22-0628)

Order EA-12-049 Compliance Elements Summary The elements identified below for VEGP Unit 3, the OIP (Reference 5) , the Updated OIP (Reference 19) , the 6-Month Status Reports (References 6 - 18 and 20 - 24) and additional docketed correspondence , demonstrate VEGP Unit 3 compliance with Order EA-12-049.

Strategies - Complete VEGP Unit 3 strategies comply with Order EA-12-049 with no open strategy-related Open Items or Confirmatory Items. The combined VEGP Units 3&4 FIP for mitigating strategies will be submitted with the VEGP Unit 4 Compliance Letter.

Modifications (Construction) - Complete The initial construction and testing of the modifications required to support the FLEX strategies for VEGP Unit 3 have been completed in accordance with station processes.

A design change was developed to add an engineered means of using the PCCAWST as a FLEX water source for the passive containment cooling and spent fuel cooling systems using a SAFER supplied FLEX pump. A 5" Storz connection has been added to the PCCAWST drain/overflow line to allow for an easy connection for a SAFER portable pump.

In addition , electrical receptacles and transfer switches have been installed for connection of a SAFER supplied 480V 150kW diesel generator.

Equipment - Procured, Maintenance and Testing - Complete The equipment required to implement the FLEX strategies for VEGP Unit 3 has been procured, received at VEGP , initially tested and performance verified as recommended in accordance with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Reference 3), and is available for use.

VEGP Unit 3 FLEX credited equipment (including ancillary equipment and portable support equipment) is subjected to initial acceptance testing and to periodic maintenance and testing utilizing the guidance provided in INPO AP-913, Equipment Reliability Process Description, to verify proper function. Maintenance and testing activities have been identified. The standard EPRI industry Preventative Maintenance (PM) process is used to establish the maintenance and testing actions for FLEX equipment. Maintenance and testing requirements are included in the VEGP PM program such that equipment reliability is monitored and maintained .

Page 5 of 9

ND-22-0502 Enclosure Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events The SAFER equipment is procured, tested, and maintained in accordance with the SAFER services agreement.

Protected Storage - Complete VEGP Unit 3 is utilizing the same FLEX storage facility as VEGP Units 1&2. The storage facility is constructed and designed to provide adequate protection for equipment stored for the VEGP Unit 3 FLEX response.

The one-site portable equipment credited to implement the FLEX strategies for VEGP Unit 3 is stored in the FLEX storage facility. In addition, the FLEX ancillary equipment is installed or staged in areas of the plant that provide adequate protection configurations.

Procedures - Complete VEGP Unit 3 utilizes FLEX Support Guidelines (FSGs) and AP1000 design Post 72-Hour procedures (P72s), which have been developed and integrated with existing plant procedures. The FSGs, P72s, and other FLEX applicable procedures have been verified and are available for use in accordance with the site procedure control program .

Training - Complete Training for VEGP Unit 3 has been developed and delivered using the systematic approach to training (SAT) process, satisfying the applicable requirements of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Reference 3) .

Staffing - Complete The VEGP Unit 3 Phase 2 Staffing Analysis (Reference 26) performed in accordance with NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities (Reference 27) , endorsed by the NRC on May 15, 2012 (Reference 28), satisfies the Phase 2 Staffing Assessment for response functions related to Near-Term Task Force Recommendation 4.2 (mitigating strategies). In a letter dated February 19, 2021 (Reference 29), the NRC staff concluded that the VEGP Unit 3 Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a Beyond Design Basis External Event using VEGP procedures and guidelines.

Communications - Complete Communications equipment is available immediately with hand-held satellite phones and augmented within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a rapidly deployable communication kit, RapidCase ,

and a mobile communication system , RapidCom.

On August 16, 2019, SNC provided the results of the communications assessment (Reference 30) for VEGP Units 3&4 in response to the 10 CFR 50.54(f) request for Information regarding communications . NRC letter dated January 30 , 2020 (Reference 31 ),

determined that SNC's assessment for communications is reasonable and the proposed enhancements will help to ensure that communications are maintained.

National SAFER Response Centers - Complete SNC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. PEICo will support VEGP Unit 3 with Phase 3 Page 6 of 9

ND-22-0502 Enclosure Completion of Required Action for N RC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events FLEX equipment stored in the National SAFER Response Centers in accordance with the VEGP Units 3&4 site specific SAFER Response Plan .

Validation - Complete SNC has completed validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the FLEX OIP (Reference 5) and Updated OIP (Reference 19) for Order EA-12-049 (Reference 1).

FLEX Program Development - Established The SNC VEGP Unit 3 FLEX Program Document, NMP-GM-038-004, has been developed in accordance with the requirements of NEI 12-06, Diverse and Flexible Coping Strategies

{FLEX) Implementation Guide (Reference 3).

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, Draft Revision 0, dated August 2012.

4. SNC Letter ND-12-2157, Vogtle Electric Generating Plant Units 3 and 4 Southern Nuclear Operating Company's Initial Status Report 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 October 23, 2012

5. 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.

6. SNC Letter ND-14-0182, Vogtle Electric Generating Plant - Units 3 and 4 First 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 February 25 , 2014

7. SNC Letter ND-14-1243, Vogtle Electric Generating Plant- Units 3 and 4 Second 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 18, 2014

8. SNC Letter ND-15-0300 , Vogtle Electric Generating Plant - Units 3 and 4 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 February 27, 2015

9. SNC Letter ND-15-1555, Vogtle Electric Generating Plant - Units 3 and 4 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),

dated August 28, 2015 1o. SNC Letter ND-16-0199, Vogtle Electric Generating Plant - Units 3 and 4 Fifth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Page 7 of 9

ND-22-0502 Enclosure Completion of Required Action for N RC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049),

dated February 26, 2016

11. SNC Letter ND-16-1278, Vogtle Electric Generating Plant - Units 3 and 4 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) ,

dated August 29, 2016

12. SNC Letter ND-17-0070, Vogtle Electric Generating Plant - Units 3 and 4 Seventh Six-Month Status Report of the Implementation of the 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 24, 2017

13. SNC Letter ND-17-1264, Vogtle Electric Generating Plant - Units 3 and 4 Eighth 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 31 , 2017

14. SNC Letter ND-18-0154, Vogtle Electric Generating Plant - Units 3 and 4 Ninth 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 February 26, 2018

15. SNC Letter ND-18-0986, Vogtle Electric Generating Plant - Units 3 and 4 Tenth 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 29, 2018

16. SNC Letter ND-19-0021, Vogtle Electric Generating Plant - 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 External Events (EA-12-049),

dated February 25, 2019

17. SNC Letter 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 Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049),

dated August 27, 2019

18. SNC Letter ND-20-0165, Vogtle Electric Generating Plant - Units 3 and 4 Thirteenth 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 February 28, 2020

19. 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 External Events (Order Number EA-12-049), dated May 15, 2020.

20. SNC Letter ND-20-1003, Vogtle Electric Generating Plant - Units 3 and 4 Fourteenth 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 28, 2020

21. SNC Letter ND-21-0087, 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 Beyond-Design-Basis External Events (EA-12-049),

dated February 25, 2021 Page 8 of 9

ND-22-0502 Enclosure Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events

22. SNC Letter ND-21-0718, Vogtle Electric Generating Plant - Units 3 and 4 Sixteenth 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 25, 2021

23. SNC Letter ND-22-0040, Vogtle Electric Generating Plant - Units 3 and 4 Seventeenth 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 February 24, 2022

24. SNC Letter ND-22-0628, Vogtle Electric Generating Plant - Units 3 and 4 Eighteenth 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 24, 2022

25. NRC Letter, Vogtle 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.

26. SNC Letter ND-20-0799, Vogtle Electric Generating Plant Unit 3 Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, dated November 12, 2020.

27. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012

28. NRC letter, U. S. Nuclear Regulatory Commission Review of NE/ 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", Revision 0, Dated May 2012, dated May 15, 2012

29. NRC Letter, Response Regarding Vogtle Unit 3 Phase 2 Staffing Submittal Associated with Near Term Task Force Recommendation 9.3 Related to the Fukushima Dai-/chi Nuclear Power Plant Accident, dated February 19, 2021

30. SNC Letter ND-19-0753, Vogtle Electric Generating Plant- Units 3 and 4 Emergency Preparedness Communications Assessment Requested by NRG Letter, 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 Dai-ichi Accident dated March 12. 2012, dated August 16, 2019

31. NRC Letter, Vogtle Electric Generating Plant, Units 3 and 4 - Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (EPID L-2019-LRQ-0002), dated January 30, 2020 Page 9 of 9