ND-23-0021, Nineteenth 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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Nineteenth 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)
ML23053A213
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 02/22/2023
From: Coleman J
Southern Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-23-0021, EA-12-0249
Download: ML23053A213 (1)
v • d • e


Text

~ Southern Nuclear Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6926 tel February 22, 2023 ND-23-0021 Docket Nos.: 52-025 52-026 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Vogtle Electric Generating Plant - Units 3 and 4 Nineteenth 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. NRG 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. NRG 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.
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 External Events (Order EA-12-049), dated May 15, 2020.

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRG) 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 NRG Interim Staff Guidance (Reference 2). Reference 2 endorses industry guidance document NEI 12-06, Revision O (Reference 3) with clarifications and exceptions identified in

U.S. Nuclear Regulatory Commission ND-23-0021 Page 2 of 2 Reference 2. VEGP 3&4 has provided the original VEGP 3&4 Overall Integrated Plan (Reference 4) and the VEGP 3&4 Updated Overall Integrated Plan (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 and was followed in developing the enclosed report. The purpose of this letter is to provide the nineteenth 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 there are any questions regarding this letter, please contact Will Garrett at (706) 848-7154.

Respectfully submitted,

~~

Jamie M. Coleman Regulatory Affairs Director Vogtle 3&4 JMC/KMS/sfr

Enclosure:

Nineteenth 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) 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-23-0021 Enclosure Vogtle Electric Generating Plant Units 3 & 4 Nineteenth 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)

(This enclosure consists of 6 pages including this cover page)

ND-23-0021 Enclosure Nineteenth 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 (VEGP) Units 3&4 developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8), followed by an Updated OIP (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 7, 2023:

  • Submit Order EA-12-049 Compliance Report for Unit 3 (Reference 7) 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 7, 2023 Date data date)

Submit 60 Dav Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan (OIP} Aug 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aua 2014 Complete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Submit 6 Month Status Report Aug 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Submit 6 Month Status Report Aua 2016 Complete N/A Submit 6 Month Status Report Feb 2017 Complete N/A Submit 6 Month Status Report Aug 2017 Complete N/A Submit 6 Month Status Report Feb 2018 Complete N/A Submit 6 Month Status Report Auo 2018 Complete N/A Submit 11 th 6-Month Status Report Feb 2019 Complete N/A Submit 12th 6-Month Status Report Aug 2019 Complete N/A Staffino Analysis Complete Unit 3 Oct 2019 Complete N/A Submit 13th 6-Month Status Report Feb 2020 Complete N/A Submit 14th 6-Month Status Report Auo 2020 Complete N/A Submit 15th 6-Month Status Report Feb 2021 Complete N/A Submit 16th 6-Month Status Report Auo 2021 Complete N/A Page 2 of 6

ND-23-0021 Enclosure Nineteenth 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 7, 2023 Date data date)

Submit 17th 6-Month Status Report Feb 2022 Complete N/A Submit 18th 6-Month Status Report Auq 2022 Complete N/A Submit 19th 6-Month Status Report Feb 2023 Complete N/A Develop FLEX training May 2020 Complete N/A Initiate Phase 3 Equipment Procurement -

Feb 2020 Complete N/A Units 3 and 4 Ensure remaining BDB Nuclear Management Procedure (NMP) revisions and program documents (e.g., EOF, TSC, Apr2022 Complete N/A and SEC responses, EP procedures) include necessary information Ensure Operations' BDB procedures (e.g.,

Mar 2022 Complete N/A FSGs/SIGs) include necessary information Develop Response Plan with NSRC (storage plan and procedural guidance for Sept2020 Complete N/A strateav/maintenance) - Units 3 and 4 Training complete and documented for Phase 3 to include connection and use of Nov 2020 Complete N/A redundant offsite equipment for Ancillary Equipment.

National SAFER Response Center Oct 2020 Complete N/A (NSRC) Operational for Units 3 and 4 Submit Order EA-12-049 Compliance Report for Unit 3 Nov 2022( 1l Complete N/A Staffing Analysis Complete Unit 4 (adding July 2022 (2l Complete N/A Unit 4 to completed Unit 3 analysis)

Submit Order EA-12-049 Compliance Report for Unit 4 and Final Integrated Plan Feb 2023 In Progress May 2023 (FIP)

(l l Target Completion Date was "Oct 2022" on August 24, 2022 submittal; actual Completion Date was November 7, 2022 2

( l Unit 3 & 4 staffing analysis provided in August 2021 was updated and submitted in July 2022 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Updated OIP (Reference 2) since the August 2022 six-month update (Reference 4).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation VEGP Unit 3 has completed the implementation of this Order and the compliance letter dated November 7, 2022 (Reference 7), has been submitted to the NRC. As noted in Section 2, the Milestone accomplished by February 7, 2023 is included in this report.

Page 3 of 6

ND-23-0021 Enclosure Nineteenth 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)

VEGP Unit 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 NRC Staff Evaluation The following tables provide a summary and status of the open items documented in the Overall Integrated Plan (OIP) and the confirmatory items documented in the NRC's Interim Staff Evaluation (ISE), dated October 27, 2020 (Reference 5).

Common information for VEGP 3&4 has been added to the FLEX program document NMP-GM-038-004 issued for Unit 3. Specific Unit 4 information will be added to NMP-GM-038-004 when updated for Unit 4.

Overall Integrated Plan Open Item Status N/A N/A NRC Staff Evaluation Confirmatory Unit 3 Status Unit 4 Status Items (Cl)

Unit 4 In Progress.

Unit 3 Complete. Construction (Section 3.2.3) Confirmatory Item 1: The Confirmation that and testing of the described design efforts related to the modifications construction and testing of modifications for VEGP Unit 3 noted in the OIP related to FLEX are the modifications for VEGP are confirmed in the VEGP complete. However, SNC should confirm Unit 4 will be included in the Unit 3 FLEX Compliance that the construction and testing of the VEGP Unit 4 FLEX Letter.

described modifications will be completed Compliance Letter.

prior to implementation of 01 P. Cl 1 will be included in the VEGP Units 3&4 Final Integrated Plan (FIP), issued at VEGP Unit 4 compliance.

(Section 3.2.3) Confirmatory Item 2: In the Units 3&4 Complete. The VEGP Units 3&4 updated sketches original OIP, SNC provided simplified have been included as Attachment 3 in FLEX program sketches depicting flow paths and FLEX document NMP-GM-038-004, issued for VEGP Unit 3 FLEX connections. These sketches should be compliance. Cl 2 will be included in the VEGP Units 3&4 FIP, updated and provided in appropriate issued at VEGP Unit 4 compliance.

program documents, including the FIP.

(Section 3.2.3) Confirmatory Item 3: SNC should provide an approved equipment list to delineate required FLEX equipment Units 3&4 Complete. The VEGP Units 3&4 FLEX equipment (pumps, generators, fans, etc.),

has been included as Table 7 in the FLEX program document capacities, need for spares, and NMP-GM-038-004, issued for VEGP Unit 3 FLEX associated support (hoses, cables, compliance. Cl 3 will be included in the VEGP Units 3&4 FIP, connections, ducting, etc.), similar to the issued at VEGP Unit 4 compliance.

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

Page 4 of 6

ND-23-0021 Enclosure Nineteenth 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)

NRC Staff Evaluation Confirmatory Unit 3 Status Unit 4 Status Items (Cl)

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

(Section 3.2.3) Confirmatory Item 5: SNC updated the "Cold Weather Checklist

Unit 3 Complete. 11877-2, procedure for VEGP Units 1 and 2 to Cold Weather Checklist, incorporate a check of roads and access Version 24, effective Unit 4 In Progress.

routes in the OCA and protected area for 08/05/21, includes VEGP Unit 11877-2, Cold Weather icing conditions. The checklist 3 FLEX deployment routes as Checklist, will be updated to designated a sand procurement location depicted in NMP-OS-019- include VEGP Unit 4 FLEX and to deploy ice melt from a storage 405, Vogtle Unit 3 FSG-5, routes.

warehouse. SNC needs to confirm that Initial Assessment and FLEX this checklist has been extended to cover Equipment Staging.

the FLEX deployment routes for VEGP Units 3 and 4.

(Section 3.2.3) Confirmatory Item 6: OIP Units 3&4 Complete. 23162-000-30R-M10R-00003, VEGP References 63 and 64 are noted in Units 3 and 4 FLEX Debris Removal Assessment, and Section 2.20.1 as an evaluation of the 23162-000-K0C-00V-00001, FLEX Haul Road Liquefaction haul paths for Units 3 and 4. These Analysis, have been added to the FLEX program document references are not included in the OIP list NMP-GM-038-004.

of references.

7 Potential Staff Evaluation Impacts There are no potential impacts to the NRC Staff Evaluation since submittal of the August 2022 six-month update (Reference 4).

8 References The following references support the Updated OIP 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 External Events (Order Number EA-12-049), dated August 22, 2013
2. 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 EA-12-049), dated May 15, 2020 Page 5 of 6

ND-23-0021 Enclosure Nineteenth 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)

3. 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
4. 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
5. 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
6. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
7. SNC Letter ND-22-0502, Vogtle Electric Generating Plant Unit 3 Completion of Required Action for NRG Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events, dated November 7, 2022 Page 6 of 6
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