Text

Compliance with Order EA-12-049
	ML23233A124
Person / Time
Site:	Vogtle
Issue date:	08/21/2023
From:	; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML23233A122	List: ML23233A123; ND-23-0025, Compliance with Order EA-12-049;
References
	ND-23-0025, EA-12-049
	Download: ML23233A124 (1)
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Southern Nuclear Operating Company ND-23-0025 Enclosure 1 Vogtle Electric Generating Plant Units 3&4 Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Compliance with Order EA-12-049 (This enclosure consists of 9 pages including this cover page)

ND-23-0025 Compliance with Order EA-12-049 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-Design-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 Units 3&4 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 Units 3&4 as follows:

Units 3&4 Updated Overall Integrated Plan (OIP) Open Items Status (Section 2.15) Open Item Complete Communications - Procurement of Satellite phones (Section 2.15) Open Item Communications - Transfer of company assets to Vogtle 3 and 4 (One RapidCom Complete and one RapidCase)

(Section 2.15) Open Item Complete Communications - Upgrade hardware and software for these units as required (Section 2.15) Open Item Complete Communications - Procure a RapidCase for Unit 4 (Section 2.19.1) Open Item Complete Overall Program Document - Completion of NMP-GM-038 and NMP-GM-038-004 (Section 2.19.2) Open Item Complete Procedural Interfaces - Issuing Procedures as Version 1.0 (Section 2.19.3) Open Item Complete Staffing - Complete 12-01 staffing study for Units 3 and 4 (Section 2.19.4) Open Item Complete Training - Complete development of training modules (Section 2.19.4) Open Item Complete Training - Training provided and documented lAW site procedures (Section 2.19.5) Open Item FLEX Equipment List - Contract with SAFER {Strategic Alliance for FLEX Complete Emergency Response}

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

ND-23-0025 Enclosure 1 Compliance with Order EA-12-049 NRC Confirmatory items (CIs) 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 Units 3&4 as follows:

Interim Staff Evaluation (ISE) Confirmatory VEGP Units 3&4 Status Items (CI)

(Sections 3.2.3, 3.4.3, 3.4.8) Confirmatory Item 1 Complete. Construction and testing of the (to include in the FIP) The design efforts related to modifications as described in the VEGP Units 3&4 the modifications noted in the OIP related to FLEX Final Integrated Plan (FIP) were completed prior are complete. However, SNC should confirm that to implementation of OIP.

the construction and testing of the described modifications will be completed prior to implementation of OIP.

(Section 3.2.3) Confirmatory Item 2 (to include in Complete. The VEGP Units 3&4 updated the FIP) In the original OIP, SNC provided sketches are included as Attachment 3 in FLEX simplified sketches depicting flow paths and FLEX program document NMP-GM-038-004 and connections. These sketches should be updated Attachment 1 in the VEGP Units 3&4 FIP.

and provided in appropriate program documents, including the FIP.

(Sections 3.2.3, 3.5.1) Confirmatory Item 3 (to Complete. Phase 2 and Phase 3 required FLEX include in the FIP) SNC should provide an equipment, including capacities, spares, critical approved equipment list to delineate required performance criterion and associated spares, is FLEX equipment (pumps, generators, fans, etc.), included as Table 7 in the FLEX program capacities, need for spares, and associated document NMP-GM-038-004 and Attachment 2 in support (hoses, cables, connections, ducting, etc.) the VEGP Units 3&4 FIP.

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

(Sections 3.2.3, 3.8) Confirmatory Item 4 (to Complete. Section 2.19.2 in the Updated OIP include in the FIP) SNC should provide a strategy currently references 3-RNS-P72-001, Post 72-to provide makeup water to containment as Hour Operations of Containment Makeup, which discussed in DCD/FSAR Section 5.4.7.5. provides instructions for 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 and section 2.8.3 in the VEGP Units 3&4 FIP.

(Section 3.3.4) Confirmatory Item 5 Complete. B-GEN-OPS-009 Version 4.0 SNC updated the Cold Weather Checklist Attachment 2 adds the Unit 3 and Unit 4 FLEX procedure for VEGP Units 1 and 2 to incorporate a Deployment Paths.

check of roads and access routes in the OCA and protected area for 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.

Page 3 of 9

ND-23-0025 Enclosure 1 Compliance with Order EA-12-049 Interim Staff Evaluation (ISE) Confirmatory VEGP Units 3&4 Status Items (CI)

(Section 3.4.2) Confirmatory Item 6 Complete. Ref 63 is 23162-000-30R-M10R-OIP References 63 and 64 are noted in Section 00003, FLEX Debris Evaluation Vogtle Electric 2.20.1 as an evaluation of the haul paths for Units Generating Plant Units 3 and 4, and Ref 64 is 3 and 4. These references are not included in the 23162-000-K0C-00V-00001, FLEX Haul Road OIP list of references. Liquefaction Analysis. Both are included as references in the FLEX program document NMP-GM-038-004.

Milestone Schedule - Items Complete VEGP Units 3&4 Milestones Completion Date Submit 60 Day Status Report Oct 2012 Submit Overall Integrated Plan (OIP) Aug 2013 1st 6 Month Update Feb 2014 2nd 6 Month Update Aug 2014 3rd 6 Month Update Feb 2015 4th 6 Month Update Aug 2015 5th 6 Month Update Feb 2016 6th 6 Month Update Aug 2016 7th 6 Month Update Feb 2017 8th 6 Month Update Aug 2017 9th 6 Month Update Feb 2018 10th 6 Month Update Aug 2018 11th 6-Month Update Feb 2019 12th 6-Month Update Aug 2019 Staffing 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 training May 2020 14th 6-Month Update Aug 2020 Develop Response Plan with National SAFER Response Center (NSRC) Sept 2020 NSRC Operational Oct 2020 Training complete and documented for Phase 3 Nov 2020 15th 6-Month Update Feb 2021 16th 6-Month Update Aug 2021 17th 6-Month Update Feb 2022 Staffing Analysis Complete (adding Unit 4 to completed Unit 3 analysis) (1) June 2022 Ensure Operations BDB procedures include necessary information June 2022 18th 6-Month Update Aug 2022 Ensure remaining BDB Procedure revisions and program documents include Aug 2022 necessary information Submit Order EA-12-049 Compliance Report for Unit 3 Nov 2022 19th 6-Month Update Feb 2023 (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)

Page 4 of 9

ND-23-0025 Compliance with Order EA-12-049 Order EA-12-049 Compliance Elements Summary The elements identified below for VEGP Units 3&4 are included in the Final Integrated Plan (FIP) (Enclosure 2) and demonstrate compliance with Order EA-12-049.

Strategies - Complete VEGP Units 3&4 strategies are in compliance with Order EA-12-049 with no open strategy-related Open Items or Confirmatory Items.

Modifications (Construction) - Complete The initial construction and testing of the modifications required to support the FLEX strategies for VEGP Units 3&4 have been completed in accordance with station processes.

A design change was developed to add an engineered means of using the passive containment cooling auxiliary water storage tank (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 Units 3&4 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 Units 3&4 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.

The SAFER equipment is procured, tested, and maintained in accordance with the SAFER services agreement.

Protected Storage - Complete VEGP Units 3&4 utilizes 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 Units 3&4 FLEX response.

The one-site portable equipment credited to implement the FLEX strategies for VEGP Units 3&4 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.

Page 5 of 9

ND-23-0025 Compliance with Order EA-12-049 Procedures - Complete VEGP Units 3&4 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 Units 3&4 personnel has been completed in accordance with a 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 Units 3&4 Phase 2 Staffing Analysis (Reference 33) 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 October 4, 2022 (Reference 34), the NRC staff concluded that the VEGP Units 3&4 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 SNCs 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 Units 3&4 with Phase 3 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 FIP (Enclosure 2) for Order EA-12-049 (Reference 1).

FLEX Program Development - Established The SNC VEGP Units 3&4 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).

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ND-23-0025 Compliance with Order 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, 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

10. 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 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 Page 7 of 9

ND-23-0025 Compliance with Order EA-12-049

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

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 Page 8 of 9

ND-23-0025 Compliance with Order EA-12-049 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 NEI 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-Ichi 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 NRC 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

32. SNC Letter ND-23-0021, 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),

dated February 22, 2023

33. SNC Letter ND-22-0328, Vogtle Electric Generating Plant Unit 3 and 4 Response to March 12, 2012, 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 June 29, 2022

34. NRC Letter, Response Regarding Vogtle Units 3 and 4 Phase 2 Staffing Submittal Associated with Near Term Task Force Recommendation 9.3 Related to the Fukushima Dai-ichi Nuclear Power Plant Accident, dated October 4, 2022 Page 9 of 9

Southern Nuclear Operating Company ND-23-0025 Enclosure 3 Vogtle Electric Generating Plant Units 3&4 Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Final Integrated Plan (FIP) (Non-Proprietary)

(This enclosure consists of 70 pages including this cover page)

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Vogtle 3&4 FIP FINAL INTEGRATED PLAN NUCLEAR REGULATORY COMMISSION ORDER EA-12-049 STRATEGIES FOR BEYOND DESIGN BASIS EXTERNAL EVENTS VOGTLE ELECTRIC GENERATING PLANT Units 3 and 4 August 2023 SV0-GW-GLY-006 Page 2 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Vogtle 3&4 FIP Introduction In response to Nuclear Regulatory Commission (NRC) Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Reference 1), the Vogtle Electric Generating Plant Units 3 and 4 (VEGP 3&4) Diverse and Flexible Mitigation Capability (FLEX) Overall Integrated Plan (OIP) was submitted to the NRC on August 22, 2013 (Reference 2).

This VEGP 3&4 OIP submittal, developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events, consisted of Westinghouse report APP-GW-GLR-170, AP1000 FLEX Integrated Plan (Reference 3) and the VEGP 3&4 specific Milestone Schedule.

As discussed during the June 12, 2019, Category I public meeting, Southern Nuclear Operating Company (SNC) submitted an Updated OIP Plan (ND-20-0164), dated May 15, 2020 (Reference 4), in a format similar to the Final Integrated Plans (FIP) for the SNC fleet, containing specific guidance on VEGP 3&4 compliance with NRC Order EA-12-049 requirements. Since the Updated OIP is a supplement to SNCs August 22, 2013, OIP, the initial OIP may be needed for reference for certain proprietary information.

Nuclear Energy Institute (NEI) implementation guide NEI 12-06 Rev. 4 (Reference 5),

includes the boundary conditions for establishing site-specific FLEX strategies, specifically that a beyond-design-basis external event (BDBEE) occurrence impacts all units at a site. Since VEGP 3&4 is located near VEGP 1&2, as VEGP 3&4 were completed, the VEGP 1&2 protected area (PA) was extended from VEGP 1&2 to encompass VEGP 3 and then VEGP 4, forming one single PA for all four operating units.

Based on the NEI 12-06 guidance that all units at a site are impacted by BDBEE, the VEGP 3&4 Updated FLEX Plan is based on the premise that VEGP 3&4 would be combined with VEGP 1&2 to form one single site for FLEX classification and response.

VEGP U3&4 uses the VEGP 1&2 debris clearing equipment and the FLEX diesel refueling equipment stored in the Vogtle FLEX storage building (FSB).

NRC Order EA-12-049 Section IV. A. 3 requires Part 52 combined license (COL) holders to complete full implementation of the required in Attachment 3 to the Order prior to initial fuel load. With the implementation of the Order EA-12-049 for VEGP 3&4, all four units now fully comply with the NRC Order EA-12-049.

SV0-GW-GLY-006 Page 3 of 70

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Vogtle 3&4 FIP VEGP 1&2s full compliance with NRC Order EA-12-049 (References 6 and 7) did not require any re-analysis resulting from the VEGP 3&4 implementation of NRC Order EA-12-049 requirements and eventual formation of a single site for FLEX classification and response.

On September 9, 2019, the NRC issued 10 CFR 50.155, Mitigation of beyond-design-basis events (Reference 8) which included the requirements of NRC Order EA-12-049 and Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (Reference 9). Those two Orders were withdrawn by the NRC on September 9, 2022, per the 10 CFR 50.155 rule.

SV0-GW-GLY-006 Page 4 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Vogtle 3&4 FIP Table of Content

1.0 Background

2.0 Combined Licenses (COLs) Under 10 CFR Part 52 2.1 Baseline Coping Capability 2.1.1 Initial Plant Conditions 2.1.2 Event Initial Conditions 2.2 Strategies 2.2.1 Approach 2.2.2 Assessment 2.3 AP1000 Three Phase Approach 2.3.1 Passive 0-72 Hours 2.3.2 3-7 Days 2.3.3 Beyond 7 Days 2.4 Extreme External Hazards 2.4.1 Seismic 2.4.2 External Flooding 2.4.3 Severe Storms With High Winds 2.4.4 Snow, Ice, Extreme Cold 2.4.5 Extreme Heat 2.5 Haul Path Description and Analysis 2.6 FLEX Capabilities 2.7 Protection of FLEX Equipment 2.8 Maintain Core Cooling, Containment Cooling, and Spent Fuel Pool Inventory 2.8.1 Installed and Portable Equipment (Phases 1 & 2) 2.8.2 Portable (Offsite) Equipment Phase 3 2.8.2.1 Primary Strategy 2.8.2.2 Alternative Strategy (modified from original) 2.8.3 Containment Inventory Makeup (Phases 1, 2 & 3) 2.9 Safety Function Support - I&C 2.9.1 Installed and Portable Equipment (Phases 1 & 2) 2.9.2 Portable (Offsite) Equipment Phase 3 2.9.2.1 Primary Strategy 2.9.2.2 Alternative Strategy (modified from original) 2.10 MCR and I&C Rooms Ventilation 2.10.1 Installed and Portable Equipment (Phases 1 & 2) 2.10.2 Portable Equipment Phase 3 2.10.2.1 Primary Strategy 2.10.2.2 Alternate Strategy SV0-GW-GLY-006 Page 5 of 70

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Vogtle 3&4 FIP 2.11 Habitability and Operations 2.11.1 Equipment Operating Conditions 2.11.2 Heat Tracing/Freeze Protection 2.12 Personnel Habitability 2.13 Lighting 2.14 Communications 2.15 Water Sources 2.16 Shutdown and Refueling Analysis 2.17 Programmatic Elements 2.17.1 Overall Program Document 2.17.2 Procedural Interfaces 2.17.2.1 P72 Procedures 2.17.2.2 Entry Into the Post 72-Hour Procedures 2.17.2.3 Summary of Post 72-Hour Procedures 2.17.2.4 FLEX Support Guidelines 2.17.2.5 Strategy Implementation Guidelines 2.17.3 Staffing 2.17.4 Training 2.17.5 FLEX Equipment List 2.17.6 N+1 Equipment Requirements 2.17.7 Equipment Maintenance and Testing 2.17.8 FLEX Equipment Unavailability Tracking 2.18 Off-Site Resources - Utilization of SAFER 2.19 Plant Modifications to Support FLEX Strategies 3.0 References 4.0 Attachments Attachment 1 - FLEX Simplified Strategy Sketches Figure 1 Water Makeup Pathway to PCS and the SFP Figure 2 Phase 2 Ancillary Power Configuration Figure 3 Phase 3 Power Option 1 Figure 4 Phase 3 Power Options 2 and 3 Attachment 2 - Phase 2 and Phase 3 FLEX Equipment Attachment 3 - VEGP 3&4 Haul Paths SV0-GW-GLY-006 Page 6 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Vogtle 3&4 FIP 1.0 Background The Fukushima Dai-ichi accident in Japan in March of 2011 was the result of an earthquake-inducted tsunami that exceeded the Fukushima plants design basis and flooded the sites emergency power supplies and electrical distribution system. An extended loss of alternating current (AC) power (ELAP) compromised the key safety functions of core cooling, containment integrity, spent fuel cooling, and ultimately led to core damage in three of the units. The event at Fukushima Dai-ichi showed that external phenomena beyond what is accounted for in the design basis, though unlikely, could present challenges to accident prevention, mitigation, and emergency preparedness at nuclear power plants. The NRC determined that additional requirements must be imposed to mitigate BDBEE.

Guidance and strategies must be available if there is a loss of AC power, motive force, and/or normal access to the Ultimate Heat Sink (UHS) to prevent fuel damage in a reactor and/or spent fuel pool (SFP). This event can affect all units at a site simultaneously.

On March 12, 2012, the NRC issued EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Reference 1). The Order is based on Recommendation 4.2 of NRC SECY-11-0093, Recommendations for Enhancing Reactor Safety in the 21st Century, the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, which was determined to be a high priority (Tier 1) action.

Order EA-12-049 applies to all applicable power reactor licensees, holders of construction permits and COL holder reactor sites.

NRC Order EA-12-049 Attachment 2 required a three-phased approach for mitigating BDBEE. The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment integrity, and SFP inventory. The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from offsite. The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

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Vogtle 3&4 FIP 2.0 Combined Licenses (COLs) Under 10 CFR Part 52 NRC Order EA-12-049, Attachment 3, provides the following discussion on FLEX compliance for COL holders.

The design bases of VEGP 3&4 includes passive design features that provide core, containment, and SFP cooling capability for the initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , without reliance on alternating current (ac) power. These features do not rely on access to any external water sources since the containment vessel and the passive containment cooling system serve as the safety-related ultimate heat sink. The NRC staff reviewed these design features prior to issuance of the combined licenses for these facilities and certification of the AP1000 design referenced therein. The passive design features are considered the initial phase for the mitigation of a BDBEE.

To meet the transition phase, the AP1000 design includes permanently installed or staged ancillary equipment which will maintain the required safety functions in the long term (beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months through 7 days) and includes the capability to replenish water supplies.

To meet the final phase (beyond 7 days), connections are provided for portable generators and pumping equipment that can be brought to the site to back up the ancillary installed or staged equipment. The staff concluded in its final safety evaluation report for the AP1000 design (Reference 10) that the plant installed or staged ancillary equipment (and alternatively, the use of transportable equipment) is capable of supporting indefinite operation of the passive safety system functions.

NRC Order EA-12-049, Attachment 3, requires VEGP 3&4 to address the following requirements relative to the final phase:

(1) Licensees shall develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment and SFP cooling capabilities following a beyond-design-basis external event.

(2) These strategies must be capable of mitigating a simultaneous loss of all ac power and loss of normal access to the normal heat sink and have adequate capacity to address challenges to core cooling, containment, and SFP cooling capabilities at all units on a site subject to this Order.

(3) Licensees must provide reasonable protection for the associated equipment from external events. Such protection must demonstrate that there is adequate capacity to address challenges to core cooling, SV0-GW-GLY-006 Page 8 of 70

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Vogtle 3&4 FIP containment, and SFP cooling capabilities at all units on a site subject to this Order.

(4) Licensees must be capable of implementing the strategies in all modes.

(5) Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

2.1 Baseline Coping Capability The VEGP 3&4 baseline coping capability was established based on the assumed set of plant initial and boundary conditions associated with a BDBEE as described in NEI 12-06, Rev. 4, Appendix F.3 Step 1: Establishing Baseline Coping Capability:

2.1.1 Initial Plant Conditions (from NEI 12-06 Rev. 4 Section 3.2.1.2)

1. Prior to the event the reactor has been operating at 100 percent rated thermal power for at least 100 days or has just been shut down from such a power history as required by plant procedures in advance of the impending event.

2. At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.

2.1.2 Event Initial Conditions (from NEI 12-06 Rev. 4, Section 3.2.1.3)

1. No specific initiating event is applied. The initial condition is assumed to be a loss of off-site power (LOOP) for the entire plant site affecting all Vogtle units simultaneously. The LOOP is assumed to result from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period.

2. All design basis installed sources of emergency on-site AC power are assumed to be not available and not imminently recoverable. Station batteries and associated direct current SV0-GW-GLY-006 Page 9 of 70

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Vogtle 3&4 FIP (DC) buses along with AC power from buses fed by station batteries through inverters remain available.

3. Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.

4. Loss of access to the ultimate heat sink (LUHS) makeup, but credited water inventories remain available and robust piping to the UHS remains intact.

5. Fuel for FLEX equipment stored in structures with designs which are robust with respect to seismic events, floods and high winds and associated missiles, remains available.

6. The SFP is intact, and thus SFP spray capability is not required.

7. Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available (Structural design requirements (1) seismic (Reference 11),

(2) floods (Reference 12), (3) high winds (Reference 13), and (4) missiles (Reference 14).)

8. Other equipment, such as portable AC power sources, portable back up DC power supplies, spare batteries, and equipment for (formerly) 10 CFR 50.54(hh)(2), (now) 10 CFR 50.155(b)(2), may be used provided it is reasonably protected from the applicable external hazards and has predetermined hookup strategies with appropriate procedural guidance and the equipment is stored in a relatively close vicinity of the site.

9. The installed Class 1E electrical distribution systems, including inverters and battery chargers, that are protected consistent with current station design are available.

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Vogtle 3&4 FIP

10. No additional events (including security events) or failures are assumed to occur immediately prior to or during the BDBEE.

11. The fire protection system ring header as a water source is acceptable only if the header is robust for the applicable hazard(s).

2.2 Strategies 2.2.1 Approach The VEGP 3&4 OIP, consisting of the VEGP 3&4 milestone schedule and the Westinghouse authored AP1000 FLEX Integrated Plan (Reference 3), was submitted to the NRC August 22, 2013 (Reference 2).

VEGP 3&4 specific guidance for compliance with Order EA-12-049 Phase 3 requirements is provided in Appendix F to NEI 12-06, Rev.

4 (Reference 5) as endorsed by the NRC (Reference 15). NEI 12-06 includes the boundary conditions to apply for establishing the site-specific FLEX strategies. NEI 12-06 indicates the BDBEE occurs and impacts all four units at a site.

VEGP 3&4 are constructed in close proximity to VEGP 1&2. The Vogtle protected area (PA) has been extended from VEGP 1&2 to encompass VEGP 3&4, forming one single PA for all four operating units.

Since NEI 12-06 indicates that all units at a site are affected by the BDBEE, VEGP 3&4 are combined with VEGP 1&2 to form one single site for FLEX classification and response. NRC Order EA-12-049 required full FLEX implementation in each VEGP 3&4 unit prior to the initial fuel load for the associated unit. The VEGP 1&2 final integrated plan (FIP) was submitted to the NRC May 23, 2016 (Reference 6). The FLEX deployment at VEGP 1&2, including access to all equipment contained within the FLEX storage building (FSB) for Phase 2 responses, has been accepted by the NRC, with the safety evaluation report for VEGP 1&2 issued November 14, 2016 (Reference 7).

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Vogtle 3&4 FIP This VEGP 3&4 FIP plus the VEGP 1&2 submittal provides full compliance for the Vogtle site.

VEGP 3&4 passive safety systems have a substantial impact on the level of effort required for FLEX response compared with the rest of the SNC operating fleet. As a result, there are limited onsite equipment needs and minimal offsite equipment requirements for VEGP 3&4.

To integrate all four units into one site, evaluations of the identified external hazards for VEGP 1&2 for applicability to VEGP 3&4 were performed to determine if additional actions are required for Phase 3 VEGP 3&4 FLEX response.

From NEI 12-06, Appendix F:

By nature of the passive safety approach and its licensing basis, AP1000 is designed to provide a significant coping period for a station blackout. Hence, the focus on this guidance is to define the required review of the AP1000 design relative to the transition from passive systems operation and their initial coping capabilities (i.e., 72 hr.), to indefinite, long term operation of the passive cooling systems with support using off-site equipment and resources.

The principles identified in this appendix thus discuss the extension of the passive systems operation indefinitely during an extended loss of AC power (ELAP) and the loss of ultimate heat sink makeup (LUHS). These principals have been applied during the design and development of the AP1000 and thus, the extended coping strategies are accomplished with existing passive safety and coping systems within the standard design utilizing existing connection points for FLEX equipment. Specifically, coping with extended loss of AC power in the AP1000 is covered by design and by post 72-hour procedures described in Section 1.9.5.4 of the AP1000 Design Control Document (DCD), Revision 19 (Reference 17).

The use of passive systems with their extended coping times is an important difference because whereas active plants are expected to show primary and diverse connection points for maintaining core cooling, AP1000 core cooling is maintained by the passive safety SV0-GW-GLY-006 Page 12 of 70

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Vogtle 3&4 FIP systems without reliance on ac power. The passive safety systems, however, should have the ability to have their operation extended indefinitely. The standard design licensing basis demonstrates safety-related means of providing core cooling, containment cooling, and SFP cooling for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The standard design also demonstrates primary and alternate means of extending passive safety system cooling indefinitely as part of the baseline capability assessment as described in Section 1.9.5.4 of the Design Control Document (DCD), Revision 19.

The assessment of the AP1000 design was the same as for the site specific evaluation and is documented by this process:

Step 1: Establish standard design baseline coping capability considering design basis hazards.

Step 2: Apply beyond-design-basis (BDB) external hazards and perform margin assessment, and confirm the capability to extend core, containment and spent fuel pool cooling also under beyond-design-basis conditions.

Step 3: Identify any enhancements to baseline capability to address BDB scenarios, if applicable.

2.2.2 Assessment It is understood that the FLEX Phase 1 and 2 actions/requirements are satisfied for VEGP 3&4 by the 72-hour passive coping design of the AP1000 and the ancillary diesel generators and fans that can operate for at least four additional days. However, this plan includes a brief synopsis of the baseline capabilities of the VEGP 3&4 AP1000 passive coping design approved by the NRC in the AP1000 DCD approval and issuance of the safety evaluation.

2.3 AP1000 Three Phase Approach As stated in NEI 12-06, Rev. 4, Appendix F.3, For the AP1000, the underlying strategies for coping with extended loss of ac power events involve a three phase approach:

2.3.1 Passive 0-72 Hours SV0-GW-GLY-006 Page 13 of 70

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Vogtle 3&4 FIP Initial coping is through installed plant equipment, without any ac power or makeup to the UHS. For the AP1000 this phase is already covered by the existing licensing basis This covers the 0 to 72-hour basis for passive systems performance for core, containment and spent fuel pool cooling.

The AP1000 Standard passive nuclear power plant design includes safety-related passive systems and equipment that automatically establish and maintain safe shutdown conditions following a prolonged station blackout with the most limiting single failure. For the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after an accident, the Class 1E batteries provide power for post-accident monitoring. The Class 1E DC and uninterruptible power supply (UPS) System (IDS) is designed with four independent, Class 1E 250 VDC divisions (A, B, C, and D). All four divisions have one 24-hour battery bank. Divisions B and C also each have one 72-hour battery bank. Passive heat sinks provide cooling of the main control room (MCR) and the instrumentation and controls (I&C) rooms. The initial water supply in the passive containment cooling water storage tank (PCCWST) provides for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of passive containment cooling system (PCS) cooling. The initial water volume in the SFP normally provides for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of spent fuel cooling without makeup.

The AP1000 design provides the passive core cooling system (PXS), PCS, and spent fuel pool cooling system (SFS), which provide coping capabilities with an extended loss of AC power for core, containment and spent fuel cooling. The BDBEE response capabilities for these systems are described in their respective system specification documents for PXS, PCS and SFS (References 18, 19, and 20).

2.3.2 3-7 Days Per NEI 12-06, Revision 4, Appendix F.3b, Following the 72-hour passive system coping time, support is required to continue passive system cooling. This support can be provided by installed plant ancillary equipment or by off-site equipment installed to connections provided in the AP1000 design. The installed ancillary equipment is capable of supporting passive system cooling from 3 to 7 days.

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Vogtle 3&4 FIP Permanently installed or staged ancillary or plant equipment is available for use as directed in the series of post 72-hour procedures. The installed or staged ancillary equipment (or alternately offsite equipment) maintains the following functions for the AP1000:

Supply power to the post-accident monitoring instrumentation for the reactor, containment, and the SFP.

Provide makeup water supply to the PCCWST or PCS distribution bucket for containment cooling water flow.

Provide makeup water to the SFP to maintain shielding and cooling of the spent fuel.

Provide MCR and I&C room ventilation.

Provide a vent path from the fuel handling area to the outside environment to vent water vapor generated by the SFP.

Additionally, a compliance assessment (Reference 21) was performed by Westinghouse to identify reference documents for the AP1000 design compliance as well as required modifications made to the VEGP 3&4 design since the original issuance of NUREG-1793 (Reference 10).

For VEGP 3&4, the primary FLEX strategy is to utilize the permanently installed or staged ancillary equipment. Two ancillary diesels per unit are provided for the loss of power to Class 1E 72 hr.

battery loads (Reference 22). These diesels are in the annex building and provide AC power for Class 1E post-accident monitoring, MCR lighting, MCR and I&C room ancillary ventilation, and pump power to refill the PCCWST and the SFS when all other power sources are not available. The ancillary diesel fuel tank is in the same room as the ancillary diesels to allow operation from hour 72 through day 7 after the initiating BDBEE. The primary connection for use of the ancillary diesel generators is through the distribution panel located in the same room (References 23 and 24).

For VEGP 3&4, the ancillary diesels and fuel tank are not utilized for normal plant operation, are non-safety related components, seismic category II (Reference 11), and installed in the annex building. The annex building is classified seismic category II. Seismic category II SV0-GW-GLY-006 Page 15 of 70

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Vogtle 3&4 FIP building structures are designed for the safe shutdown earthquake using the same methods and design stress limits as are used for seismic category I structures. Additional evaluations for FLEX tornado missile generations were performed and demonstrate the annex building is unaffected (Reference 26).

Power to the ancillary fans to provide post 72-hour ventilation of the MCR and the I&C rooms is supplied from divisions B and C regulating transformers through two series fuses for isolation. The fuses protect the regulating transformers from failures of the non-1E fan circuits.

For VEGP 3&4, one passive containment cooling auxiliary water storage tank (PCCAWST) is provided per unit for filling the PCCWST, SFP or PCS water distribution bucket using the PCS recirculation pumps during an extended loss of both offsite and onsite AC power sources for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The PCCAWST contains adequate water volume using the unit specific PCS recirculation pumps (two per unit) to provide required flow from hour 72 through day 7 after the initiating BDBEE. The PCCAWST and PCS recirculation pumps are seismic category II to ensure their ruggedness and availability. For VEGP 3&4, there is a PCCAWST in the yard adjacent to the auxiliary building. There were evaluations for tornado missile generation performed and demonstrate the PCCAWSTs will remain intact and available (Reference 27). The PCS recirculation pumps are located inside the seismic category I auxiliary building.

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Enclosure 3 Vogtle 3&4 FIP The post-accident monitoring system (PAMS) is powered by the ancillary diesels post 72-hours. The system provides the following key parameters for monitoring the status of the units post BDBEE (References 28 and 29):

Parameters Monitored Instrumentation Function Div B Instrument

Div C Instrument*

Neutron flux, Reactivity RXS-NE001B RXS-NE001C source range control RCS wide range RCS integrity, RCS-PT140B-Q RCS-PT140C-Q pressure core cooling RCS wide range RCS integrity, RCS-TE135A RCS-TE135B (HL2) temperature, hot core cooling (HL1) leg (T-hot)

Containment RCS integrity PXS-LT051 PXS-LT052 water level Containment RCS integrity, PCS-PT006-Q PCS-PT007-Q pressure containment Pressurizer level RCS inventory RCS-LT195B RCS-LT195C Hot leg level RCS inventory RCS-LT160B RCS-LT160A Core exit Core cooling (CETs in PMS-JD- (CETs in PMS-JD-temperature QDPB01) QDPC01)

(CET)

Passive residual Heat sink PXS-FT049B PXS-FT049A heat removal (PRHR) flow PRHR outlet Heat sink N/A RCS-TE161 temperature PCCWST water Heat sink PCS-LT011 PCS-LT010 storage tank level PCS water flow Heat sink PCS-FT-002 PCS-FT001 rate SFP level Spent fuel SFS-LT019B SFS-LT019C cooling

Instruments listed are designated the same in both units except for the unit number.

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Vogtle 3&4 FIP 2.3.3 Beyond 7 Days The AP1000 Preliminary FLEX Capability Summary is provided in Table F.3.2-1 of NEI 12-06. This summary indicates VEGP 3&4 beyond 7-day coping requirements include the use of a portable diesel generator, a portable PCS/SFP Makeup pump, a portable PCCAWST Makeup pump, diesel fuel oil, and required hoses, couplings, electrical cabling to connect the offsite equipment.

Communications equipment is available immediately with hand-held satellite phones and augmented within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with both RAPIDCASE and RAPIDCOM satellite units.

The PCS has a safety-related connection on the exterior of the auxiliary building for the portable PCS\SFP Makeup pump connection (References 19, 20, 31 & 32) and a non-safety connection on the PCCAWST drain/overflow line (Reference 30).

Offsite support to be provided by equipment delivery from Strategic Alliance for FLEX Emergency Response (SAFER) and additional personnel resources. The SAFER response plan (Reference 33),

for the Vogtle site has been updated to include VEGP 1-4. The SAFER plan details the deployment of SAFER equipment to the Vogtle site for use. For VEGP 3&4, it includes contingencies and alternate deployment paths to ensure equipment can be delivered within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from SAFER notification. This delivery time ensures that SAFER offsite resources will be available for VEGP 3&4 to support continued function of the passive cooling coping capabilities and plant stability.

Protected connections for SAFER equipment have been included at VEGP 3&4 to support containment pressure and temperature control, spent fuel pool water level, and power for required I&C and ventilation.

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Vogtle 3&4 FIP 2.4 Extreme External Hazards The hazards applicable to VEGP 3&4 are seismic, high wind, ice, and extreme heat. Evaluations of external hazards and debris removal for site access during FLEX activities have been performed (References 34 and

35) and are summarized below.

2.4.1 Seismic The Vogtle Ground Motion Response Spectra (GMRS), geotechnical conditions, and ground material have differences from the design analyses performed for the AP1000 seismic analyses so that site specific analysis is required. The AP1000 Certified Seismic Design Response Spectra (CSDRS) has peak ground accelerations for the safe shutdown earthquake equal to 0.30g for the AP1000 design.

The vertical peak ground acceleration is conservatively assumed to equal the horizontal value of 0.30g. These response spectra are based on Regulatory Guide (RG) 1.60 with an additional control point specified at 25 Hz. The spectral amplitude at 25 Hz is 30 percent higher than the Regulatory Guide 1.60 spectral amplitude.

The AP1000 CSDRS are applied at the foundation level in the free field at hard rock sites, and at the finished grade for the other soil generic conditions in VEGP 3&4 Updated Final Safety Analysis Report (UFSAR), Appendix 2.5E (Reference 36).

For the AP1000 standard design, the seismic margin assessment (SMA) demonstrates the robustness of the passive safety systems and the associated structures to beyond design basis conditions and is already included in the AP1000 licensing basis for design certification. The SMA demonstrated margin over the safe shutdown earthquake of 0.3g through confirmation that the plant high confidence, low probability of failures (HCLPFs) is at least 0.5g peak ground acceleration (References 37 and 38).

Coincident with the issuance of Order EA-12-049 on March 12, 2012, the NRC issued a request for information in accordance with 10 CFR 50.54(f) (Reference 39), instructing licensees to reevaluate flood and seismic hazards. Interim Staff Guidance JLD-ISG-2012-01, Rev 2, Section 6 (Reference 15) instructs licensees to SV0-GW-GLY-006 Page 19 of 70

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Vogtle 3&4 FIP reevaluate flood and seismic hazards in accordance with Revision 4 of the NEI 12-06 guidance.

In compliance with NRC endorsed Electric Power Research Institute (EPRI) guidance, SNC submitted the response to the 50.54(f) letter on March 31, 2014 (Reference 41) for VEGP 1&2. The NRC accepted the updated seismic evaluations by letter dated April 20, 2015 (Reference 42).

SNC submitted updated ground motion spectra and foundation input response spectra for VEGP 3&4 December 5, 2014 (Reference 44),

in response to a request from the NRC dated November 5, 2014, (Reference 43).

Per the NRC staff assessment dated August 12, 2015 (Reference 45), The staff agrees that the use of the VEGP Units 1 and 2 GMRS for VEGP Units 3 and 4 is appropriate given the proximity and similarity of subsurface conditions. Therefore, utilization of the VEGP Units 1 and 2 GMRS for VEGP 3&4 FLEX evaluations is acceptable.

2.4.2 External Flooding The design basis flood for the VEGP site was determined by selecting the maximum flood elevation on the Savannah River obtained by considering all flooding scenarios applicable to the location, including an approximate estimate of the probable maximum flood (PMF), flooding due to probable maximum precipitation (PMP) over local drainage courses, and potential dam failures coincident with wind set-up and wave run-up. Flood surge from ocean storms and tsunami-caused flooding were not considered because the VEGP site is approximately 151 river miles inland.

The controlling event for the VEGP site was determined to be from the breach of the upstream dams, using the Standard Project Flood discharge as a starting condition, including wind set-up and wave run-up. The design basis flooding level derived from this event, SV0-GW-GLY-006 Page 20 of 70

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Vogtle 3&4 FIP including wave setup, is El. 178.10 ft mean sea level (msl), which is 41.9 ft below the site grade elevation of 220.0 ft msl (Reference 46).

2.4.3 Severe Storms With High Winds VEGP 3&4 are located at approximately 33°09 N latitude and 81°46 W longitude. The AP1000 design basis is included in in the general design criteria document (Reference 47) and summarized in Table 2.0-201 of the VEGP 3&4 UFSAR. The approved design of the AP1000 envelopes the VEGP 3&4 site-specific BDBEE values for the post 72-hour passive coping period.

AP1000 DCD VEGP 3&4 Site Parameter Site Parameter Operating Basis 145 mph (3 second gust); 104 mph (3 second gust);

Wind Speed importance factor 1.15 exposure C; topographic (safety), 1.0 (non-safety); factor 1.0. (Importance factor exposure C; topographic is not a property of the wind factor 1.0 speed.)

Tornado Wind 300 mph 300 mph Maximum pressure 2.0 lb/in2 differential of 2.0 lb/in2 2.4.4 Snow, Ice, Extreme Cold The AP1000 post 72-hour passive coping equipment design basis is included in in the general design criteria document (Reference 47) and summarized in Table 2.0-201 of the VEGP 3&4 UFSAR. The approved design of the AP1000 envelopes the VEGP 3&4 site-specific BDBEE values for the post 72-hour passive coping period.

Air Temperature AP1000 DCD VEGP 3&4 Site Parameter Site Parameter Minimum Safety -40°F -8°F Minimum Normal -10°F 21°F The guidelines provided in NEI 12-06 generally exclude the need to consider extreme snowfall at plant sites in the southeastern U.S.

below the 35th parallel.

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Vogtle 3&4 FIP The VEGP 1-4 are located at approximately 33° N latitude and thus the capability to address hindrances caused by extreme snowfall with snow removal equipment need not be provided. In the unlikely event that an ELAP event occurred concurrent with a BDBEE snowfall, snow removal could be accomplished with debris removal equipment stored in the FLEX Storage Building (FSB) in accordance with NEI 12-06 F.8 [Section 8.3.2].

The Vogtle site is located within the region characterized by EPRI as ice severity level 5. As such, the Vogtle site is subject to severe icing conditions. In accordance with NEI 12-06 guidance, the FSB is designed to maintain the indoor temperature between 50°F and 100°F (Reference 48) to ensure equipment stored in the FSB is available for use during extreme weather conditions in accordance with NEI 12-06 F.8 [Section 8.3.2]. FLEX support equipment stored in the FSB can deploy along the haul paths in snowy or icy conditions.

VEGP 3&4 UFSAR Section 2.4.7.1 states, it is very unlikely that surface or frazil ice formation would occur in the Savannah River in the vicinity of the proposed VEGP Units 3 and 4 river intake location. The Savannah River is the credited makeup water source for VEGP 3&4, and therefore will be available as a source with the SAFER equipment deployment.

2.4.5 Extreme Heat The AP1000 post 72-hour passive coping equipment design basis is included in the general design criteria document (Reference 47) and summarized in Table 2.0-201 of the VEGP 3&4 UFSAR. The approved design of the AP1000 envelopes the VEGP 3&4 site-specific BDBEE values for the post 72-hour passive coping period.

Air AP1000 DCD VEGP 3&4 Temperature Site Parameter Site Parameter Maximum Safety 115°F 115°F Maximum Normal 101°F 97°F SV0-GW-GLY-006 Page 22 of 70

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Vogtle 3&4 FIP In accordance with NEI 12-06 guidance, the FSB is designed to maintain the indoor temperature between 50° F and 100° F (Reference 48) to ensure equipment stored in the FSB (debris clearing equipment and haul vehicles for Vogtle 3&4) is available for use during extreme weather conditions in accordance with NEI 12-06 F.9 [Section 9.3.2].

Extreme high temperatures are not expected to impact the ability of personnel to implement the required FLEX strategies and deploy support equipment from the FSB to VEGP 3&4. For equipment deployment activities required within the auxiliary building it is determined the temperatures will remain below 110°F (Reference 49). Site industrial safety procedures currently address activities with a potential for heat stress to prevent adverse impacts on personnel.

SAFER equipment is generically designed to operate in deployments across the contiguous United States, where temperatures in excess of 120°F have been recorded. However, the SAFER equipment for VEGP 3&4 is site-specific and not part of the generic equipment procured to the above mentioned temperature.

VEGP 3&4 SAFER equipment is specified to operate up to 110°F, which envelopes the normal maximum temperatures of 97°F.

Note: The FSB is not used for storing VEGP 3&4 Phase 3 major equipment. This equipment will be housed at the National SAFER Response Center (NSRC) in Phoenix.

2.5 Haul Path Description and Analysis VEGP 1-4 are considered one site and all units are affected by the BDBEE. All four units enter FLEX response procedures following established emergency protocols. The VEGP 3&4 haul paths are a continuation of the VEGP 1&2 Haul paths. Refer to Attachment 3 of this document.

The VEGP 3&4 haul paths have been analyzed for liquefaction (Reference 50). The analyses indicate that there are potentially liquefiable soils below the design groundwater level and that some SV0-GW-GLY-006 Page 23 of 70

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Vogtle 3&4 FIP settlement may occur along the travel paths following an earthquake.

The magnitude of the settlement expected to occur is not anticipated to make the road impassable for the selected haul vehicles and wheeled loader. Equipment deployment for VEGP 3&4 will take advantage of the earlier VEGP 1&2 deployment plan and path clearing due to the substantial coping time allotted by the 72-hour passive coping period.

Additional analysis was not required for the VEGP 1& 2 haul paths to support VEGP 3&4.

FLEX haul routes utilized for VEGP 1&2 will be cleared within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with equipment stored in the FSB following the initiation of a BDBEE and will be available for use to access VEGP 3&4. All required equipment for VEGP 1&2 response for clearing haul paths and transporting trailers and refueling activities will be made available for VEGP 3&4 once VEGP 1&2 activities are complete.

VEGP 1&2 FLEX response is implemented in accordance with the strategies accepted by the NRC by Safety Evaluation Report (SER) dated November 14, 2016 (Reference 7) and require no additional evaluations to support VEGP 3&4 FLEX response.

The tow vehicles utilized to transport FLEX response equipment for VEGP 3&4 are the same vehicles utilized for VEGP 1&2 FLEX response.

All paths to all units will be suitably cleared for operation of tow vehicles and trailers.

Tow vehicles and trailers stored in the FSB or delivered from SAFER are designed to withstand small debris punctures and razor wire cuts/penetrations (i.e., large commercial/military grade, run-flat, non-pneumatic tires).

Based on walkdowns of the site and reviews of plant drawings, the primary and alternate haul paths for VEGP 3&4 can support a minimum of two lanes of vehicular traffic. This decreases the likelihood of either route being completely blocked by debris for all scenarios, except the seismic event of complete building 302 collapse in a North direction which would result in a large debris pile on the primary haul path. Because of the low likelihood of the haul routes being completely blocked by debris, and the substantial coping period (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) from the initiation of the BDBEE to site personnel SV0-GW-GLY-006 Page 24 of 70

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Vogtle 3&4 FIP taking actions to maintaining the passive functions, any debris required to be removed to allow passage of tow vehicles and trailers can be accomplished with the onsite debris removal equipment such that a single passable lane is established.

In all locations along the VEGP 3&4 haul paths, the ability to move off the roadway exists except for the crossing over the spillway between VEGP 1&2 and VEGP 3&4. There are no significant debris sources located in close proximity to the crossing so deposition of debris should be minimal and any possible debris can be cleared with onsite debris removal equipment if necessary.

Additional evaluations of the VEGP 1&2 haul road are not required, as the design has been reviewed and determined unaffected as part of the VEGP 1&2 FLEX response. The VEGP 3&4 haul road is the same type/construction and is acceptable for continued use as part of the FLEX response for VEGP 3&4.

2.6 FLEX Capabilities The AP1000 passive coping design allows for a significantly reduced FLEX deployment compared to traditional units. The passive design effectively removes the Phase 1 and significantly reduces Phase 2 equipment and deployment activities allowing for a significantly longer coping period before activation of required equipment connections (through day 7). NSRC will provide equipment for VEGP 1-4 once the site contacts SAFER per procedures at any unit. It is recognized that VEGP 1&2 deployment activities for the SAFER equipment will be prioritized over the VEGP 3&4 activities because of the difference in coping period (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months verses 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ), and the substantially greater actions for Phase 1 and Phase 2 responses that are required for VEGP 1&2. All equipment for VEGP 1&2 response for clearing haul paths and transporting trailers and refueling activities will be made available for VEGP 3&4 once VEGP 1&2 activities are complete.

2.7 Protection of FLEX Equipment Equipment required for VEGP 3&4 FLEX response beyond the passive coping period is very limited. The permanently installed ancillary diesels, SV0-GW-GLY-006 Page 25 of 70

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Vogtle 3&4 FIP PCS recirculation pumps and the PCCAWST are the primary components required for Phase 2. The protection of these SSCs has been discussed above.

SAFER equipment for extending the mitigation of the BDBEE is stored at the NSRC facility in Phoenix, Arizona, sufficient distance from the site such that it would not reasonably be subject to the same hazards.

Note:

The VEGP 1&2 FLEX Phase 2 equipment, communications trailers, debris clearing equipment and trucks/trailers, etc. are stored in the FSB. The FSB is designed (Reference 48) to provide adequate protection for equipment stored for BDBEE FLEX response. The RAPIDCOM communications trailer is the only major onsite portable piece of FLEX equipment credited for VEGP 3&4 stored in the FSB.

2.8 Maintain Core Cooling, Containment Cooling, and Spent Fuel Pool Inventory 2.8.1 Installed and Portable Equipment (Phases 1 & 2)

The design basis of the AP1000 plant includes passive design features that provide core, containment, and spent fuel cooling capability for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , without reliance on AC power. These features do not rely on access to any external water sources since the containment vessel and the passive containment cooling system serve as the safety-related ultimate heat sink. The NRC staff reviewed these design features prior to issuance of the combined licenses for these facilities and certification of the AP1000 design. The AP1000 design also includes equipment to maintain the required safety functions in the long term (beyond the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months through day 7), including the capability to replenish water supplies. Connections are provided for portable generators and pumping equipment that can be brought to the site to back up the installed equipment. The NRC staff concluded in its final safety evaluation report for the AP1000 design that the installed equipment (and alternatively, the use of transportable equipment) is capable of supporting extended operation of the passive safety systems to maintain required safety functions in the long term.

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Vogtle 3&4 FIP For these reasons, further consideration of Phases 1 and 2 is not necessary for VEGP 3&4.

2.8.2 Portable (Offsite) Equipment Phase 3 2.8.2.1 Primary Strategy The primary strategy is use of one of the two installed PCS recirculation pumps through installed piping in accordance with post 72-hour procedures. Beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , additional inventory for the PCS and SFP can be supplied from the unit specific onsite PCCAWST using a PCS recirculation pump powered using one of the two onsite ancillary diesel generators or an offsite replacement generator. This flowpath can be seen in Attachment 1, Figure 1 of this document.

Note that the PCS recirculation pumps, the onsite ancillary diesel generators, and the PCCAWST are non-safety-related components. However, these components are rugged components located in nuclear seismic structures with seismic category II anchorage and are likely to be available or easily repairable following a BDBEE. The PCS recirculation pumps are located in the seismic category I auxiliary building. The onsite ancillary diesel generators are located in the seismic category II annex building. The PCCAWST is a seismic category II tank in the yard.

For indefinite coping after 7 days, Phase 3 equipment includes a self-powered pump (PCCAWST makeup pump) and appropriate connection materials to refill the PCCAWST from the Savannah River.

2.8.2.2 Alternate Strategy (modified from original)

In the unlikely event that plant installed PCS recirculation pumps are unavailable, an offsite self-powered PCS recirculation pump equivalent will take suction from the PCCAWST via the connection added to the overflow/drain SV0-GW-GLY-006 Page 27 of 70

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Vogtle 3&4 FIP line (Reference 30) instead of the portable pump supply coming from the closest river, lake, or ocean source, and discharging to a safety-related, seismically qualified flange (References 19, 20, 31 and 32).

If makeup to the PCCAWST is required, an offsite PCCAWST self-powered makeup pump will be setup to draw water from the Savannah River and provide makeup to the PCCAWST on either or both units simultaneously. This configuration allows makeup to the SFP and the PCCWST as highlighted in Attachment 1, Figure 1 of this document. The minimum required head and maximum pump discharge head for the PCS recirculation pump equivalent is documented in Table 3-1 Section 11 (Reference 21). The SAFER pumps meet these criteria.

2.8.3 Containment Inventory Makeup (Phases 1, 2, & 3)

As discussed in UFSAR 5.4.7.5, VEGP 3&4 have the capability to provide long term containment inventory makeup through the normal residual heat removal system (RNS). For an extended loss of offsite power, with normal makeup methods unavailable, and with the maximum allowable containment leak rate, makeup to containment is NOT required for about 30 days. Procedures 3-RNS-P72-001, Post 72-Hour Operations of Containment Makeup, for VEGP 3 and 4-RNS-P72-001, Post 72-Hour Operations of Containment Makeup, for VEGP 4, direct this process. The makeup process involves providing borated water from a suitable alternative borated water source using a temporary portable pump. This water is pumped into the RNS test connection and once the makeup process is successful, this process is not expected to be needed again for about 30 days. (Addresses Confirmatory Item 4 of ML20269A399 -

TE- 60019751) 2.9 Safety Functions Support - I&C 2.9.1 Installed and Portable Equipment (Phases 1 & 2)

The design basis of the AP1000 plant includes passive design SV0-GW-GLY-006 Page 28 of 70

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Vogtle 3&4 FIP features that provide core, containment, and spent fuel cooling capability for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , without reliance on AC power sources.

Required post-accident I&C is powered by four safety-related DC battery banks for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and by two safety-related DC battery banks through 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . One of these 72-hour safety-related trains is powered through division B, and the other is powered through division C. The AP1000 design also includes AC power equipment to maintain the required safety functions in the long term (beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months through day 7) including capability to power post-accident I&C monitoring. Installed connections are provided for connecting generators and pumping equipment that can be brought to the site to back up the installed equipment. The NRC staff concluded in its final safety evaluation report for the AP1000 design that the installed equipment (and alternatively, the use of transportable equipment) is capable of supporting extended operation of the passive safety systems to maintain required safety functions in the long term.

For these reasons, further consideration of Phases 1 and 2 is not necessary for VEGP 3&4.

2.9.2 Portable (Offsite) Equipment Phase 3 Beyond the initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , instrument power can be supplied by the use of onsite permanently installed ancillary diesel generators or offsite portable generators with quick and accessible connection points. The onsite ancillary diesel generators, located in the annex building of each unit, are capable of providing power for Class 1E post-accident monitoring, MCR lighting, MCR and I&C room ventilation, and power to refill the PCCWST using the PCS recirculation pumps. This capability is described in VEGP 3&4 UFSAR Section 8.3.1.1.1.

Each ancillary diesel generator output is connected to a distribution panel in the same room as the ancillary diesel generators. The distribution panel contains outgoing feeder circuit breakers directly connected to the division B and division C voltage regulating transformers that power the post-accident monitoring loads, the lighting in the MCR, and the ventilation in the MCR and division B SV0-GW-GLY-006 Page 29 of 70

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Vogtle 3&4 FIP and C I&C rooms. This configuration is depicted in VEGP 3&4 UFSAR Figures 8.3.1-3 and 8.3.2-2, and Attachment 1, Figure 2 of this document. The ECS post 72-hour procedure, discussed in Section 2.17.2.3 of this document, include provisions to configure, connect, operate, or replace the ancillary diesel generators.

2.9.2.1 Primary Strategy The primary strategy is to use the onsite ancillary diesel generators, in accordance with post 72-hour procedures, if they are available post event, or offsite portable generators, if the ancillary diesel generators are unavailable. The AP1000 design does not require that the ancillary diesel generators be safety related. Their operation is not required following a loss of all AC power for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months because they are easily replaced with offsite portable generators, which are capable of being connected to the distribution panel in the same room or to one of the two connection points into the voltage regulating transformer to a safety-related connection as described in Westinghouse AP1000 DCD Revision 19, Section 1.9.5.4 and as referenced in VEGP 3&4 UFSAR Section 1.9.5.4. This section of the Westinghouse AP1000 DCD states: the AP1000 design includes both onsite equipment and safety-related connections for use with transportable equipment.

2.9.2.2 Alternate Strategy (modified from original) a,c SV0-GW-GLY-006 Page 30 of 70

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Vogtle 3&4 FIP a,c 2.10 MCR and I&C Rooms Ventilation 2.10.1 Installed and Portable Equipment (Phases 1 & 2)

The design basis of the AP1000 plant includes appropriate design features to provide ventilation of the MCR and division B and C I&C rooms for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , without reliance on AC power sources. These features do not rely on external power sources and cooling is performed through passive heat sinks. The NRC staff concluded in its final safety evaluation report for the AP1000 design that the installed equipment (and alternatively, the use of transportable equipment) is capable of supporting extended operation of the passive safety systems to maintain required safety functions in the long term.

For these reasons, further consideration of Phases 1 and 2 is not necessary for the AP1000 design.

2.10.2 Portable Equipment Phase 3 The AP1000 design provides habitability systems with the capability to maintain the MCR environment suitable for occupancy for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , as well as provisions for maintaining appropriate temperatures in the division B and C I&C rooms.

The VBS post 72-hour procedure, discussed in Section 2.17.2.3 of this document, includes provisions to configure, connect, operate, or replace the MCR fan.

2.10.2.1 Primary Strategy Beyond the initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , MCR habitability and I&C room cooling can be maintained using permanently installed or staged ancillary fans powered by ancillary diesel generators SV0-GW-GLY-006 Page 31 of 70

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Vogtle 3&4 FIP located in the annex building. This capability is described in Westinghouse AP1000 DCD Revision 19, Section 8.3.1.1.1, and as referenced in the VEGP 3&4 UFSAR Section 8.3.1.1.1 and Attachment 1, Figure 2 of this document.

Each ancillary diesel generator output is connected to a distribution panel in the same room as the ancillary diesel generators. The distribution panel contains outgoing feeder circuit breakers directly connected to the division B and C voltage regulating transformers that power the ventilation in the MCR and division B and C I&C rooms. This configuration is depicted in Westinghouse AP1000 DCD Revision 19, and in VEGP 3&4 UFSAR Figures 8.3.1-3 and 8.3.2-2.

One of the two MCR ancillary fan staged outside the MCR is relocated into the MCR for operation. The fan directs outside air from the nuclear island nonradioactive ventilation system (VBS) air intake under the MCR floor for cooling. The warmer air from the MCR is vented to the annex building. See Figure 4 and Figure 5 (Reference 2) for simple sketches of this air flow path. This configuration is depicted in Westinghouse AP1000 DCD Revision 19, Figure 9.4.1-1 (sheet 5), and described in VEGP 3&4 UFSAR Section 9.4.1.2.3.1.

The onsite installed ancillary fans located in the division B and C I&C rooms can maintain room temperature below the qualification temperature of the I&C equipment.

The outside air pathway to the I&C room ancillary fans is through the VBS outside air intake and vented to the annex building. This configuration is described in Westinghouse AP1000 DCD Revision 19, Section 9.4.1.2.3.2 and as referenced in the VEGP 3&4 UFSAR 9.4.1.2.3.2. See Figure 6, Figure 7, and Figure 8 (Reference 2) for simple sketches of this air flow path.

The VBS and ECS post 72-hour procedures, discussed in section 2.17.2.3 of this document, include provisions to replace, start, and connect the ancillary diesel generators and SV0-GW-GLY-006 Page 32 of 70

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Vogtle 3&4 FIP initiate the respective ancillary fans as a primary strategy for post 72-hour ventilation.

2.10.2.2 Alternate Strategy a,c SV0-GW-GLY-006 Page 33 of 70

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Vogtle 3&4 FIP 2.11 Habitability and Operations 2.11.1 Equipment Operating Conditions Following a BDBEE and subsequent ELAP event at VEGP, ventilation providing cooling to occupied areas and areas containing FLEX strategy equipment could be lost. Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution under the adverse conditions (unavailability of installed plant lighting, ventilation, etc.)

possible following a BDBEE resulting in an ELAP/LUHS. The primary concern with regard to ventilation is the heat buildup which occurs with the loss of forced ventilation in areas that continue to have heat loads.

A loss of ventilation analyses was performed to quantify the maximum steady state temperatures expected in specific areas related to FLEX implementation. This ensures the environmental conditions remain acceptable for personnel habitability or accessibility and within equipment limits, (Reference 49).

2.11.2 Heat Tracing/Freeze Protection The PCCWST is constructed to provide sufficient thermal inertia insulation to prevent freezing and ensure water delivery to the containment can be accomplished following system actuation even with loss of the recirculation heater.

The PCCWST recirculation lines L004 and L046 shall have flow from PCCWST recirculation during sub-freezing environmental conditions. Since portions of these lines are located within the walls of the Shield Building with no heat tracing because of inaccessibility, freezing may occur.

The PCCWST recirculation lines are drained as necessary during freezing environmental conditions while they are not in use during the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after an accident. The recirculation piping will be required for post 72-hour containment cooling. In cold SV0-GW-GLY-006 Page 34 of 70

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Vogtle 3&4 FIP environmental conditions, the recirculation piping will have water flow to avoid freezing of the PCCWST and pipe contents. However, during a loss of site power, this is not possible and draining may be required if freezing conditions exist.

The supply line to the water distribution bucket from the post 72-hour makeup flanged connection is maintained dry by layout requirements and leaving drain valve V015 open. Also, the non-safety piping between the PCCAWST and the Auxiliary Building is maintained dry by layout requirements.

Electrical heating source shall be provided to the following by the Special Process Heat Tracing System (EHS):

Between the PCCAWST and tank isolation valves V037, V048 The PCCAWST is insulated such that, should the heater fail, the insulation and thermal inertia of the tank and contents will assure that the contents will prevent freezing for seven days.

PCCAWST nozzles are insulated to prevent freezing within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months at minimum normal temperatures. After 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the PCS recirculation pumps can be used to circulate the water to prevent freezing of PCCAWST nozzles.

Heat tracing will be installed on the accessible portions of PCCAWST outlet recirc lines L063, L064, L068, and L069 that could be exposed to freezing temperatures. Those portions of the above piping embedded in concrete within the Shield Building will not have heat tracing due to inaccessibility.

2.12 Personnel Habitability An analytical model of the auxiliary building was developed using the GOTHIC computer code. The purpose of the model is to provide a study of best estimate maximum Auxiliary Building temperatures during a loss of AC power event for an indefinite period of time (30 days) for use as supporting information in the development of the beyond design basis scenario FLEX program. The model is geared towards analysis of the room temperatures following a long-term loss of air conditioning (LOAC). The LOAC disables SV0-GW-GLY-006 Page 35 of 70

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Vogtle 3&4 FIP operation of the normal heating, ventilating, and air-conditioning (HVAC) systems, leading to increasing temperatures throughout the building. The model includes doorways and other features that could be used by the plant operators to promote air circulation through the building and thereby limit the temperatures in the rooms requiring operator access (Reference 49).

The model is used to examine the viability of accomplishing specific actions in FLEX scenarios due to the environmental conditions of a long-term LOCA. The desired limit for environmental conditions related to FLEX scenarios is temperatures in accessed areas remaining below 110°F. This is based on the assumed maximum temperature for efficient human performance as described in NUMARC 87-00. While not specifically an acceptance criterion for the analysis performed, comparison of the results to this temperature value is used (Reference 49).

Summary: Temperatures within rooms requiring entry during FLEX scenarios with a loss of AC power are expected to be habitable for an indefinite period of time (30 days) when opening the Auxiliary Building room doors listed in Appendix A of Reference 49 to the atmosphere.

2.13 Lighting Power to normal and emergency lighting in the main control room and in the remote shutdown room is supplied from the redundant divisions of Class 1E DC and UPS system through two series fuses for isolation. The fuses protect the batteries from failures of the non-1E lighting circuits. The Class 1E batteries provided in the Class 1E DC and UPS system are capable of powering the emergency lighting in these rooms for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the normal AC sources are not available.

Following the 72-hour period after a loss of all AC power sources, the lighting in the main control room is powered from two ancillary AC generators.

Provisions are also made to power the post-accident monitoring systems and the main control room lighting loads in divisions B and C from ancillary AC generators during the post 72-hour period as described in VEGP 3&4 4 UFSAR Subsection 8.3.2.1.1.2.

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Vogtle 3&4 FIP In order to validate the adequacy of supplemental lighting and the adequacy and practicality of using portable lighting to perform FLEX strategy actions, all operators are required to have flashlights (Reference 67). In addition, the MCR and Maintenance Shop include a stock of flashlights and batteries to further assist the staff responding to a BDBEE event during low light conditions.

2.14 Communications Site communications equipment is deployed as required for coordination efforts across the VEGP 1-4.

(Excerpts from Reference 72)

Sufficient satellite telephones will be procured and deployed enabling use by either units main control room (MCR) or the Technical Support Center (TSC) until either the RAPIDCASE or RAPIDCOM systems are deployed.

Two of the handheld satellite phones will be located in each MCR, and one will be maintained in the TSC. Internal batteries and external AC/DC power sources can be used to power these hand-held portable devices.

A rapidly deployable communications kit, RAPIDCASE (one for VEGP 3 and one for VEGP 4), and a mobile communication system, RAPIDCOM, have been procured with the capability to supply multiple satellite phone lines within the TSC and the MCR. The RAPIDCOM system will also supply a UHF/VHF capability supporting multiple radio stations on site.

The RAPIDCASE are to be deployed within six hours from the start of the ELAP. The RAPIDCASE and their electronics are stored in Room 40352 of the associated annex building which is expected to survive the initial Large Scale External Event (LSEE.) The RAPIDCASE can be deployed by two people.

The RAPIDCASE antenna and electronic are setup in a previously determined location in the yard east of the associated unit with a clear view of the southwestern sky. The signal from the RAPIDCASE system is provided by fiber optic cable to a FLEX switch in Room 40350 in the annex building. This switch provides service to seven phones in the MCR. The RAPIDCASE antenna and electronics are powered by a single portable 2kW propane generator with a second generator powering the FLEX switch in the annex building in Room 40350. These generators are operated SV0-GW-GLY-006 Page 37 of 70

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Enclosure 3 Vogtle 3&4 FIP outside of any structures.

The RAPIDCOM can be deployed within six hours after a debris path has been cleared. The RAPIDCOM trailer for VEGP 3&4 is stored in the FSB and can be deployed once the FLEX haul path from VEGP 1&2 to VEGP 3&4 has been adequately cleared. The RAPIDCOM trailer is setup in a previously determined location in the yard east of Building 302 with a clear view of the southwestern sky. The signal from the RAPIDCOM is provided to the TSC by fiber optic cable running to a FLEX switch in Building 305, Room 114. From Room 114 the RAPIDCOM signal is hardwired to a FLEX switch in Room B103. The FLEX switch provides service to seven phones in the TSC.

Although the RAPIDCOM trailer does have two onboard propane generators, three propane tanks, and a UPS for powering the trailer, VEGP 3&4 use them as backups. The primary power sources are from a portable 2kW propane generator located at the trailer and a second portable generator powering the FLEX switch in Building 305 (TSC). These generators are located and operated outside of any structures.

2.15 Water Sources Makeup water will be required for the beyond 7 days coping period. The table below provides a comprehensive list of on-site makeup water sources considered for PCCAWST makeup. It includes each sources design robustness with respect to seismic events, floods, high winds, and associated missiles and each sources water quality (relative to reactor water chemistry requirements). Only the Savannah River meets the qualification guidelines of NEI 12-06 for an injection source that can be credited for the ELAP/LUHS event. Other tanks and basins are included in the table to provide a comprehensive list of site water sources. These non-creditable water sources, depending on the cause of the event may be available for injection and although are not credited, could be considered for use during an actual event.

On-Site Makeup Water Sources Water Source Minimum Normal Water Chemistry Source Volume (gallons) Qualification Savannah River Continuous Source Raw Credited SV0-GW-GLY-006 Page 38 of 70

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Enclosure 3 Vogtle 3&4 FIP Condensate Storage 656,000 (one per unit) Clean Non-Seismic Tank (Reference 51)

Demineralized Water 126,000 (one per unit) Clean Non-Seismic Tank (Reference 51)

Fire Water Tank 300,000 (minimum) Raw Non-Seismic (Reference 52) 504,000 (maximum)

(two per unit)

Service Water 230,000 (one basin per Raw (but chemically Non-Seismic System Cooling unit) treated normally)

Tower Basin (Reference 53)

Circulating Water 6,395,000 (one basin per Raw (but chemically Non-Seismic System Cooling unit) treated normally)

Tower Basins (Reference 54) 2.16 Shutdown and Refueling Analysis The basic strategies are identical for all modes with minor differences in parameters (e.g., required passive containment cooling system and spent fuel pool makeup flow depending on location of fuel). Refer to Table 3.4 of Reference 19 for Reactor Decay Heat Loads, Spent Fuel Pool Decay Heat Loads, Containment Cooling Makeup Water Source Requirements and Spent Fuel Pool Makeup Water Source Requirements. Plant procedures provide the necessary instructions to provide Core/Containment Cooling and Spent Fuel Cooling during all modes of operation including Shutdown and Refueling.

2.17 Programmatic Elements 2.17.1 Overall Program Document Southern Nuclear Operating Company's (SNC) program for Diverse and Flexible Coping Strategies (FLEX) in response to a BDBEE is described in two documents:

The program description for common elements applicable to all SNC sites (Reference 55)

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Vogtle 3&4 FIP

The program document specific for VEGP 3&4 is NMP-GM-038-004 (Reference 56)

Together, these two documents describe the FLEX program for VEGP 3&4.

Key elements of the VEGP FLEX program include:

A summary of FLEX strategies including validation methods

A description of FLEX equipment including:

Quality attributes

Maintenance and testing

Availability tracking

Storage

Requirements for deployment

A description of SNC's FLEX procedure development including:

Procedure interfaces

Procedure maintenance

Application of procedures during emergencies

Plant Configuration Control:

Changes to FLEX strategies

Configuration Management

Activities that Potentially Affect FLEX Strategies

Plant Configuration Control Processes during Emergencies

A summary of personnel related items including staffing and training Permanently installed ancillary equipment is classified in accordance with the AP1000 graded approach (Reference 57). The AP1000 design has a graded approach to quality based on the relative importance of the structure, system or component (SSC) (Reference 58). The quality assurance applied to SSCs is defined in Reference

59. The AP1000 plant design reliability assurance program applies short-term availability controls to equipment (Reference 60).

The Technical Requirements Manual (TRM) (Reference 61) provides for testing requirements of permanently installed equipment SV0-GW-GLY-006 Page 40 of 70

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Vogtle 3&4 FIP at VEGP 3&4 in compliance with the design reliability assurance program (Reference 60).

Requirement for testing / surveillance of the PCCAWST and the recirculation pumps: TRM 3.6.1, Passive Containment Cooling Water Storage Tank (CCAWST) and Spent Fuel Pool Makeup

- Long Term Shutdown

Requirements for testing / surveillance of MCR ancillary fan:

TRM 3.7.5 Main Control Room (MCR) Cooling - Long Term Shutdown

Requirements for testing / surveillance of I&C ancillary fan:

TRM 3.7.6 I&C Room Cooling - Long Term Shutdown

Requirements for testing / surveillance of ancillary diesel: TRM 3.8.3 AC Power Supplies - Long Term Shutdown SAFER equipment is be procured, tested, and maintained in accordance with the SAFER services agreement.

2.17.2 Procedural Interfaces NEI 12-06 Figure F.11-1 provides an overview of the AP1000 operating procedures hierarchy and the relationships to the post 72-hour (P72) procedures:

The AP1000 design and licensing basis as described in AP1000 DCD Section 1.9.5.4 provides a set of procedures (referred to as SV0-GW-GLY-006 Page 41 of 70

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Vogtle 3&4 FIP Post 72-Hour Procedures) that address the actions that would be necessary 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsequent to an extended loss of all AC power (extended SBO) to maintain core, containment, and spent fuel cooling for an indefinite period of time.

2.17.2.1 P72 Procedures The following procedures are the VEGP 3&4 versions of the generic AP1000 P72 procedures:

Document Title Number 3-ECS-P72-001 Post 72-Hour Operations of Ancillary Diesels 3-PCS-P72-001 Post 72-Hour Operations of Passive Containment Cooling 3-RNS-P72-001 Post 72-Hour Operations of Containment Makeup 3-SFS-P72-001 Post 72-Hour Operations of Spent Fuel Pool Cooling 3-VBS-P72-001 Post 72-Hour Operations of Main Control Room Ventilation 4-ECS-P72-001 Post 72-Hour Operations of Ancillary Diesels 4-PCS-P72-001 Post 72-Hour Operations of Passive Containment Cooling 4-RNS-P72-001 Post 72-Hour Operations of Containment Makeup 4-SFS-P72-001 Post 72-Hour Operations of Spent Fuel Cooling 4-VBS-P72-001 Post 72-Hour Operations of Main Control Room Ventilation 2.17.2.2 Entry Into the Post 72-Hour Procedures Vogtle 3/4-AOP-302, Loss of AC Power, is the controlling procedure for entry into the Vogtle Post 72-hour (P72 series) procedures. The Post 72-hour procedures are used to perform actions not covered by normal operating procedures, abnormal operating procedures (AOPs), or emergency operating procedures (EOPs) and are independent of the severe accident management guidelines (SAMGs).

2.17.2.3 Summary of Post 72-Hour Procedures SV0-GW-GLY-006 Page 42 of 70

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Vogtle 3&4 FIP

3/4-ECS-P72-001 (Operations of Ancillary Diesels)

This procedure provides instructions for providing limited on-site emergency power during an extended loss of off-site power and the on-site auxiliary generators are unavailable.

This includes operation of the installed ancillary diesels and electrical distribution of that power. Additionally, the procedure includes instructions for establishing limited power using portable generators and cabling.

3/4-VBS-P72-001 (Operations of Main Control Room Ventilation)

This procedure provides instructions for providing Control Room ventilation during an extended loss of off-site power and when normal ventilation is unavailable. It also provides instructions for placing I&C Room Division B and C Ancillary Fans in service.

3/4-PCS-P72-001 (Operations of Passive Containment Cooling)

This procedure provides instructions for normal operation of the Post 72-Hour Operations of Passive Containment Cooling. This procedure provides instructions for the connection of externally stored or procured pumps and water sources to add water to the PCCWST and/or the SFP.

3/4-SFS-P72-001 (Operations of Spent Fuel Pool Cooling)

This procedure provides instructions for makeup to the Spent Fuel Pool with electrical power unavailable due to volume loss caused by a loss of SFP cooling. Also provides instructions on operation of the Fuel Handling Area Relief Damper to limit SFP Area temperature increases.

3/4-RNS-P72-001 (Operations of Containment Makeup)

This procedure provides instructions for emergency makeup to Containment during an extended loss of offsite power and normal makeup methods are unavailable.

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Vogtle 3&4 FIP The Post 72-hour procedures provide directions for mitigating an ELAP event that includes the potential for depletion of the 24- and 72-hour batteries and maintaining the following required functions:

The critical safety functions of subcriticality, core cooling, heat sink, and containment.

The function of main control room (MCR) habitability.

The function of SFP cooling.

Post accident monitoring from the MCR.

After the initial safety-related cooling period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the AP1000 standard passive design includes both onsite equipment in the form of the ancillary diesel generators, as well as safety-related connections, non-safety connections as additional defense-in-depth, designed to interface with transportable emergency equipment that can provide cooling water and address the needs of required plant functions through at least 7 days.

During an ELAP, when a loss of all AC occurs due to an external event, the operating crew would need to determine if there is confidence in restoration of power within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , if not, an ELAP should be declared as soon as possible, and the Emergency Offsite Facility notified to contact SAFER.

The sooner this call is made, the sooner equipment begins to travel to site. If Vogtle 1 and/or 2 have declared an ELAP, VEGP 1&2 procedures have this determination made within the first hour. Once SAFER is contacted, all of the equipment for the site (VEGP 1-4) will be dispatched. There is guidance related to the Vogtle site for implementation of FLEX strategies in the event of an Extended Loss of AC Power (References 55 and 56).

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Vogtle 3&4 FIP 2.17.2.4 FLEX Support Guidelines The following Flex Support Guidelines and Strategy Implementing Guidelines are developed for VEGP 3&4.

FLEX Support Guidelines Document Title Number NMP-OS-019-405 Vogtle Unit 3 FSG-5, Initial Assessment and FLEX Equipment Staging NMP-OS-019-407 Vogtle Unit 3 FSG-7, Loss of Vital Instrumentation or Control Power NMP-OS-019-413 Vogtle Unit 3 FSG-13, Transition from FLEX Equipment NMP-OS-019-425 Vogtle Unit 4 FSG-5, Initial Assessment and FLEX Equipment Staging NMP-OS-019-427 Vogtle Unit 4 FSG-7, Loss of Vital Instrumentation or Control Power NMP-OS-019-433 Vogtle Unit 4 FSG-13, Transition from FLEX Equipment 2.17.2.5 Strategy Implementation Guidelines The following Flex Support Guidelines and Strategy Implementing Guidelines are developed for VEGP 3&4:

Strategy Implementation Guidelines Document Title Number NMP-OS-019-367 Vogtle Unit D SIG-7, Diesel Fuel Oil Transfer NMP-OS-019-469 Vogtle Units 3&4 SIG-9, Communications NMP-OS-019-470 Vogtle Units 3&4 SIG-10, Ventilation SV0-GW-GLY-006 Page 45 of 70

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Vogtle 3&4 FIP Procedure Interface 2.17.3 Staffing Using the methodology of NEI 12-01, Guideline tor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, assessments of the capability of the VEGP 3&4 on-shift staff and ERO to respond SV0-GW-GLY-006 Page 46 of 70

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Vogtle 3&4 FIP to a BDBEE have been performed for Phase 1 and Phase 2 for VEGP 3&4 (References 66 and 67) 2.17.4 Training Training will primarily consist of the typical objective-based procedure training that operators receive on the procedures and guidelines that integrate these hypothetical events. The training for the FLEX aspects of the AP1000 design will build upon the training that is already required for the post 72-hour operational requirements. Training material is being developed in accordance with the systems approach to training (SAT) as delineated in 10 CFR 55.4. This includes the development of the following:

Objective-based training for the procedures

Objective-based training on the integration of the AP1000 design and operator responses and operator tasks for these beyond design basis events

Exam items for this training as appropriate The SNC general population is trained using NANTeL courses provided by the Emergency Response Training Development (ERTD) Working Group (INPO facilitated). The ERTD conducted a job analysis to identify common training topics and coordinated the design and development of common training materials. All station personnel are required to take basic NANTeL Diverse and Flexible Coping Strategy (FLEX) computer-based training (CBT),

S-EP-10700. New employees are included in this population. Key ERO personnel are required to take advanced NANTeL FLEX CBT, S-EP-10701.

SNC staff responsible for the implementation of the FSGs will complete additional training developed and delivered using the SAT process. The training conducted by SNC satisfies the applicable requirements of NEI 12-06, Section 11.6.

Emergency response leaders are those site and corporate emergency response personnel assigned leadership roles, as defined by the Emergency Plan, for managing emergency response SV0-GW-GLY-006 Page 47 of 70

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Vogtle 3&4 FIP to design basis and beyond-design-basis plant emergencies will receive additional training on directing actions and implementing strategies following a BDBEE.

Deviations from Original OIP: Simulator scenarios are not part of the operator training for FLEX implementation. Simulator scenarios may be used to identify and declare that an ELAP has occurred.

This information was provided to NRC in Reference 68.

2.17.5 FLEX Equipment List VEGP 3&4 selected, procured, and delivered the needed equipment for VEGP 3&4 FLEX Phase 3 and included it in the Vogtle SAFER Response Plan (Reference 33). The equipment necessary for the implementation of the FLEX strategies in response to a BDBEE at VEGP 3&4 was developed based on the final sizing and selection of the FLEX generator, pumps and associated cabling, hose connectors, fittings, etc. Due to the design of the AP1000, no phase 1 and very limited Phase 2 equipment will be stored on-site.

Attachment 2 contains a comprehensive list of the Phase 2 equipment stored on site and the Phase 3 SAFER supplied equipment.

2.17.6 N+1 Equipment Requirement For an AP1000, a single response center is acceptable per NEI 12-06, Appendix F.3.2: Use of more than one storage location is not necessary as long as the storage site is far enough away from the site(s) such that the same extreme hazard could not affect both the plant(s) and the storage location.

N+1 will be procured for a single response center. Consistent with NEI 12-06, Section 3.2.2.16, 3 pieces of portable equipment will be provided when a separate train is needed for each unit (portable generator and PCCWST Makeup Pump) and two pieces will be provided when a single train can supply both units (ultimate makeup from the Savannah River, the credited source for VEGP 3&4). This equipment will be stored at the regional response center in Phoenix, AZ.

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Vogtle 3&4 FIP 2.17.7 Equipment Maintenance and Testing FLEX equipment (including 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.

The standard EPRI industry Preventative Maintenance (PM) process (similar to the Preventive Maintenance Basis Database) is used to establish the maintenance and testing actions for FLEX equipment.

This provides assurance that stored or pre-staged FLEX equipment is being properly maintained and tested.

EPRI FLEX maintenance templates (where provided) were used to develop the specific maintenance and testing guidance for the associated FLEX equipment. In the absence of an EPRI FLEX template, existing maintenance templates (where available) were used to develop the specific maintenance and testing guidance. For all other equipment not covered by a maintenance template, manufacturer OEM or industry standards were used to determine the recommended maintenance and testing.

The PM Templates include activities such as:

Functional Test and Inspection

Fluid Filter Replacement

Fluid Analysis

Generator Load Test

Component Operational Inspection

Standby Walkdown 2.17.8 FLEX Equipment Unavailability Tracking The unavailability of FLEX equipment and applicable connections that directly perform a FLEX mitigation strategy for core, containment, and SFP is managed such that risk to mitigating strategy capability is minimized. Maintenance/risk guidance conforms to the guidance of NEI 12-06.

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Vogtle 3&4 FIP The unavailability of FLEX equipment and connections is controlled using the tracking application in the Shift Operations Management System (eSOMS).

FLEX equipment and connections will not normally be used for purposes other than emergency response. It is permissible, however, to pre-stage and/or use FLEX equipment and connections provided the following requirements are met:

Permission is received from the Shift Manager or Emergency Director.

The proper action to restore the equipment to an available status is determined and the status of the affected equipment and/or connection is tracked per procedure NMP-OS-019-013 (Reference 69).

2.18 Off-Site Resources - Utilization of SAFER The industry has established two (2) NSRCs to support utilities during BDBEEs. SNC has established contracts for VEGP 1&2 with the Pooled Equipment Inventory Company (PEICo) to participate in the process for support of the NSRCs as required. The contracts are revised to include VEGP 3&4.

For an AP1000, a single response center is required per NEI 12-06, Appendix F.3.2:

Use of more than one storage location is not necessary as long as the storage site is far enough away from the site(s) such that the same extreme hazard could not affect both the plant(s) and the storage location. N+1 will be procured for a single response center. Consistent with NEI 12-06, Section 3.2.2.16, three pieces of portable equipment will be procured when a separate train is needed for each unit (portable generator and PCCWST Makeup Pump) and two pieces will be procured when a single train can supply both units (ultimate makeup from the Savannah River, the credited source for VEGP 3&4).

This equipment will be stored at the regional response center in Phoenix, AZ to minimize the probability of a single external event affecting both Plant Vogtle and the response center. In the event of a BDBEE and subsequent ELAP, equipment will be moved from an NSRC to a local assembly area SV0-GW-GLY-006 Page 50 of 70

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Vogtle 3&4 FIP established by the SAFER team. FLEX Strategy requests to the NSRC will be directed by FSG-5.

For Vogtle, the local assembly area (Staging Area C) is the Barnwell Regional Airport, South Carolina. From there, equipment can be delivered to the Vogtle site by helicopter if ground transportation routes are not available. Communications will be established between the Vogtle plant site and the SAFER team via satellite phones. First arriving equipment will be for VEGP 1&2 and will be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request. The VEGP 3&4 equipment will start delivery to the site within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from initial request. The order at which equipment is delivered is identified in the Vogtle SAFER Response Plan.

NSRC personnel will commence delivery of a pre-selected equipment set from the NSRC upon notification by the plant site. Plans are to deliver equipment from offsite sources via truck or air lift. VEGP 3&4 deliveries will likely travel by aircraft to Staging Area C and then by truck to the site using preselected routes and with any necessary escort capabilities to ensure timely arrival at the plant site staging area.

Depending on time constraints, equipment can be flown commercially to a major airport near the plant site and trucked or air lifted from there to the staging areas. The use of helicopter delivery is typically considered when routes to the plant are impassable and time considerations for delivery will not be met with ground transportation. Multiple pre-selected routes are one method to circumvent the effects of seismic events, floods, etc. and these routes will consider potentially impassible areas such as bridges, rivers, heavily wooded areas and towns. The drivers will have the routes marked and will be in communication with the NSRC to ensure that the equipment arrives on time.

SAFER equipment deployment will take advantage of the earlier VEGP 1&2 deployment plan and path clearing due to the substantial coping time allotted by the 72-hour passive coping period. Deployment from VEGP 1&2 over to the VEGP 3&4 paths are shown in Attachment 2.

Evaluations of the acceptability of the haul paths has been performed (References 50 and 66.) SAFER equipment being supplied (pumps, diesel SV0-GW-GLY-006 Page 51 of 70

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Vogtle 3&4 FIP generators, cables, and hoses) has been evaluated and found acceptable for use at VEGP 3&4 by References 62, 63, 64 and 65.

2.19 Plant Modifications to Support FLEX Strategies a,c A design change was developed to add an engineered means of using the PCCAWST as a water source for the FLEX pumps. A 5 Storz connection will be added to the drain/overflow line to allow for an easy connection for a portable FLEX pump (Reference 30).

3.0 References

1. U.S. Nuclear Regulatory Commission (NRC), Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012 (ML12054A735)

2. 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), August 22, 2013 (ML13235A228)

3. APP-GW-GLR-170, Revision 0, AP1000 FLEX Integrated Plan (Proprietary Version)

4. SNC letter ND-20-0164, Vogtle Electric Generating Plant Units 3 and 4 Updated Overall Integrated Plan in Response to March 12, SV0-GW-GLY-006 Page 52 of 70

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Vogtle 3&4 FIP 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), May 15, 2020 (ML20136A454)

5. Nuclear Energy Institute (NEI) 12-06, Revision 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, December 2016

6. NL-16-0228, Vogtle Electric Generating Plant - Units 1 and 2, Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events, May 23, 2016 (ML16146A607)

7. Vogtle Electric Generating Plant, Units 1 and 2 - Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (CAC NOS. MF0714, MF0715, MF0723, and MF0724),

November 14, 2016 (ML16301A419)

8. NRC 10 CFR 50.155 - Mitigation of Beyond-Design-Basis Events

9. U.S. Nuclear Regulatory Commission (NRC), Order EA-12-051, Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, March 12, 2012

10. NUREG-1793, Final Safety Evaluation Report Related to Certification of the AP1000 Standard Design, September 2004, including: Supplement 1, December 2005 and Supplement 2, September 2011

11. APP-GW-G1-003, Revision 7, AP1000 Seismic Design Criteria

12. APP-GW-N1-007, Revision 5, AP1000 Design Criteria for Protection from Flooding

13. APP-GW-C1-001, Revision 5, AP1000 Civil/Structural Design Criteria SV0-GW-GLY-006 Page 53 of 70

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14. APP-GW-N1-008, Revision 1, AP1000 Design Criteria and Guidelines for Protection from Tornado and Hurricane-Generated Missiles

15. JLD-ISG-2012-01, Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, February 2017 (ML17005A188)

16. Not used

17. AP1000 Design Control Document (DCD), Revision 19

18. APP-PXS-M3-001, Revision 9, Passive Core Cooling System, System Specification Document, August 2017

19. APP-PCS-M3-001, Revision 11, Passive Containment Cooling System -System Specification Document, November 2018

20. APP-SFS-M3-001, Revision 12, AP1000 Spent Fuel Pool Cooling System - System Specification Document, October 2018

21. SV0-GW-GLR-724, Revision 0, APP-GW-GLR-170 Compliance Assessment for Vogtle 3 & 4 AP1000 Units, March 2019

22. APP-ECS-E8-001, Revision 3, Main AC Power System - System Specification Document

23. APP-FSAR-GEF-043, Revision 0, Connection Addition to IDS for Post 72-Hour FLEX

24. APP-1020-P2-0011, Revision 6, Nuclear Island Auxiliary Bldg Area 1 & 2 General Arrangement Plan at Elev 82-6

25. Not used

26. APP-4000-CCC-006, Revision 0, AP1000 Annex Building Tornado Missile Analysis for Diverse and Flexible Coping Strategies (FLEX)

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27. APP-MT04-S2C-003, Revision 0, PCCAWST Tornado Missile Analysis for Diverse and Flexible Coping Strategies (FLEX)

28. APP-PMS-J7-001, Revision 2, AP1000 Protection and Safety Monitoring System - System Specification Document

29. APP-GW-M3R-008, Revision 0, Post Accident Monitoring System (PAMS) Design Basis Document

30. APP-PCS-GEF-152, Revision 0, Modification to PCCAWST Drain/Overflow Line for Post 72-Hour Equipment Connection

31. APP-PCS-M6-002, Revision 11, Piping and Instrumentation Diagram Passive Containment Cooling System

32. APP-PCS-M6-001, Revision 12, Piping and Instrumentation Diagram Passive Containment Cooling System

33. 38-9238015-002, SAFER Response Plan for the Vogtle Electric Generating Plant

34. 23162-000-30R-M10R-00004, Version 0.0, FLEX External Hazards Evaluation Vogtle Electric Generating Plant Units 3 and 4

35. 23162-000-30R-M10R-00003, Version 0.0, FLEX Debris Evaluation Vogtle Electric Generating Plant Units 3 and 4

36. VEGP Units 3 and 4 UFSAR

37. CN-RRA-02-05, Revision 1, AP1000 PRA Seismic Margins Evaluation, May 2002

38. APP-PRA-GSC-027, Revision 2, AP1000 PRA-Based Seismic Margin Assessment Update, February 2011

39. Request for Information Pursuant to Title 10 of the Code of Federal Regulations 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the SV0-GW-GLY-006 Page 55 of 70

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Vogtle 3&4 FIP Fukushima Daiichi Accident, dated March 12, 2012, November 12, 2012 (ML12053A340)

40. Not used

41. SNC letter NL-14-0344, Vogtle Electric Generating Plant - Units 1 and 2, Seismic Hazard and screening Report for CEUS Sites, March 31, 2014 (ML14092A019)

42. Vogtle Electric Generating Plant, Units 1 and 2 - Staff Assessment of Information Provided Pursuant to Title 10 of the Code of Federal Regulations Part 50, Section 50354(f), Seismic Hazard Reevaluations Relating to Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident (TAC NOS. MF3770 and MF3771), April 20, 2015 (ML15054A296)

43. Request for Submittal of Updated Ground Motion Spectra and Foundation Input Response Spectra, November 5, 2014 (ML14302A180)

44. SNC letter ND-14-1863, Vogtle Electric Generating Plant - Units 3 and 4, Response to Request for Submittal of Updated Ground Motion Spectra and Foundation Input Response Spectra, December 5, 2014 (ML14339A849)

45. Vogtle Electric Generating Plant Units 3 and 4 - Updated Ground Motion Response Spectra (TAC No. RP0411), August 12, 2015 (ML15139A516)

46. SV0-0000-X7C-800002, Version 1.0, Vogtle Units 3 and 4 Local Probable Maximum Precipitation Flood Analysis -Interim Construction Condition - Unit 3 Operational

47. APP-GW-G1-001, Revision 4, AP1000 Plant Design Criteria

48. FHC-S-13-001 / X1AR50, Version 2.0, Procurement Specification for FLEX Equipment Storage Building for Alvin W. Vogtle Electric Generating plant - Units 1 & 2, Edwin I. Hatch Nuclear Plant - Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2 SV0-GW-GLY-006 Page 56 of 70

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49. APP-GW-GLR-726, Revision 0, Auxiliary Building Best Estimate Temperatures during a Loss of AC Power Results

50. 23162-000-K0C-00V-00001, Rev. 000, FLEX Haul Road Liquefaction Analysis.

51. APP-DWS-M3-001, Revision 2, "Demineralized Water Transfer and Storage (DWS), System Specification Document Safety Classification B", June 2016

52. APP-FPS-M3-001, Revision 0, "API000 Fire Protection System (FPS) System Specification Document"

53. APP-SWS-M3-001, Revision 3, "AP1000 Service Water System System Specification Document"

54. SV0-ME71-Z0-001, Revision 3, "Supply and Erection of Natural Draft Cooling Tower Vogtle Units 3 and 4," December 2012

55. NMP-GM-038, Diverse and Flexible Coping Strategies (FLEX)

Program

56. NMP-GM-038-004, Vogtle Electric Generating Plant Diverse and Flexible Coping Strategies (FLEX) Program Document

57. APP-GW-G1-014, Revision 9, AP1000 Plant Nuclear Safety Classification and Seismic Requirement Methodology

58. APP-GW-GAH-010, Revision 10, Project Quality Assurance Program Interface for Domestic AP1000 Projects

59. APP-GW-GAH-020, Revision 6, AP1000 Plant Systems, Structures, and Components Quality Requirements

60. APP-GW-GRR-009, Revision 3, AP1000 Design Reliability Assurance Program

61. Vogtle Units 3 and 4 Technical Requirements Manual (TRM)

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62. 23162-000-30R-M10R-00005, Version 0.0, FLEX Portable Pump Evaluation for PCCWST and SFS Makeup for Vogtle Electric Generating Plant Units 3 and 4

63. 23162-000-30R-M10R-00006, Version 0.0, FLEX Water Makeup from Savannah River for Vogtle Electric Generating Plant Units 3 and 4

64. 23162-000-30H-E01G-00001, Version 1.0, FLEX Diesel Generator Sizing

65. 23162-000-30H-E01G-00002, Version 1.0, FLEX Cable Sizing

66. SNC letter ND-20-0799, VEGP Unit 3 Fukushima Response NEI 12-01 On-Shift Staffing Analysis Phase 2 Report, Revision 1.0, Standard Emergency Plan Annex, Revision 4.0, November 12, 2020

67. SNC letter ND-22-0328, Vogtle Electric Generating Plant Units 3 &

4 Fukushima Response NEI 12-01 On-Shift Staffing Analysis Phase 2 Report, Revision 3.0, Standard Emergency Plan Annex, Revision 6.0, June 29, 2022

68. 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),

August 27, 2019, (ML19239A334)

69. NMP-OS-019-013, Beyond Design Basis Equipment Unavailability Tracking

70. 23162-000-M0-00V-00001, Version 1.0, VEGP Units 3 and 4 FLEX Deployment Pathways Drawing

71. NMP-OS-007-001, Conduct of Operations Standards and Expectations SV0-GW-GLY-006 Page 58 of 70

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72. ND-19-0753, "Vogtle Electric Generating Plant - Units 3 and 4 Emergency Preparedness Communications Assessment Requested by NRC 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,"

August 16, 2019 (ML19240A069)

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Vogtle 3&4 FIP Attachment 1 FLEX SIMPLIFIED STRATEGY SKETCHES (Addresses Confirmatory Item 2 of ML20269A399)

SV0-GW-GLY-006 Page 60 of 70

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Vogtle 3&4 FIP Attachment 1 FLEX SIMPLIFIED STRATEGY SKETCHES SV0-GW-GLY-006 Page 61 of 70

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Vogtle 3&4 FIP Attachment 1 FLEX SIMPLIFIED STRATEGY SKETCHES Figure 3. Simplified Sketch Showing Phase 3 480V Diesel Power Option 1 a,c SV0-GW-GLY-006 Page 62 of 70

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Vogtle 3&4 FIP Attachment 1 FLEX SIMPLIFIED STRATEGY SKETCHES Figure 4. Simplified Sketch Showing Phase 3 Power Options 2 and 3 a,c SV0-GW-GLY-006 Page 63 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT (Addresses Confirmatory Item 3 in ML20269A399 - TE 60019750)

Phase 2 - Stored Onsite Equipment Performance Credited/ Applicable Quantity FLEX Equipment Criteria/Storage Location Support Strategies 1* Medium Wheeled Loader Debris Removal/Tow Vehicle/FSB S All Tow Vehicles - 1 large, 1 Towing Pumps and Diesel 2* S All small Generators/FSB Provide fuel to diesel powered FLEX 3* FLEX Fuel Tanker S All equipment/FSB 20 kW FLEX Diesel FSB, miscellaneous power 3* S All Generator supplies/FSB 4* Diesel Powered Lights Misc. lighting/FSB S All Rapidly Deployable Relies on satellites/portable propane 2/1 Communications Kit generators/VEGP 3&4 annex S All per unit (RAPIDCASE) buildings/FSB/MCRs 14/7 per Phones for use in MCR/SO Ready FLEX Phones S All unit Room.

4/2 per One switch outside the MCR and one at Cisco FLEX Switches S All unit the satellite/annex building.

2/1 per 600ft Spool of Fiber Optical Provide signal from satellite switch to S All unit Cable MCR switch/annex building.

1 for Mobile Communications Relies on satellites/portable propane S All Units 3-4 System (RAPIDCOM) generators/TSC/FSB 7 for TSC Phones for service in TSC or alternate

+ one FLEX Phones S All TSC/TSC. (Room B129) spare One in TSC and one onboard 2/2 Cisco FLEX Switches S All RAPIDCOM /TSC and FSB 400ft Spool of Fiber Optical Provide signal from RAPIDCOM switch 1/1 S All Cable to TSC switch/FSB.

Food, water, bedding, personal

Various Commodities hygiene, etc., in support of S All personnel/FSB.

2kW propane generators for Continued telecommunication 7** S All RAPIDCASE & RAPIDCOM power/FSB.

6 + one 100ft 120V electric power For 2kW generators for RAPIDCASE S All spare cords and RAPIDCOM /FSB MCR Ancillary Fan diffuser, 2 sets / Equipment required for relocation and portable duct, clamps, one per operation of the MCR Ancillary S All adapters, handcart, and unit Fans/FSB power cord

Shared equipment with Units 1-2

- Two for Units 3-4 RAPIDCASE and two for the RAPIDCOM, plus one spare SV0-GW-GLY-006 Page 64 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity Equipment FLEX Equipment Provd/ Performance Uses Notes Description Reqd Criteria This diesel generator is used 480V, 150kW, 0.8PF, to replace the 3 Phase WYE, plus ancillary diesels, if Neutral and Ground, required. The These are trailer-3 gen / 1 Capable of Parallel diesel provides mounted diesel-per unit and Portable Generator Operation, Voltage power to the same driven portable 1 spare Variance +/- 5%, selected loads as generators.

Frequency Variance the ancillary

+/- 0.25%. diesels depending on their point of plant connection.

600V, 1/C, 4/0 This is the main These cables are on AWG, in 100 ft 40 lengths power cable from reels in the 7 special lengths w/E-1022 each of four the portable electrical cable ISU Generator Power plug and E-1022 conductors / generator pigtails 90 containers. The Cabling cap. Conductor 20 lengths to the plant total lengths of cable colors - Brown, per unit connection supplied includes Orange, Yellow, pigtails. spare lengths.

White.

These cables are on Ground cable from reels in the 7 special generator 4/0 2kV, in 4 lengths / 2 This is the ground electrical cable ISU Generator 50 ft lengths w/E-for each cable from the 90 containers. The Ground 1022 plug and E-unit. generators itself. total lengths of cable 1022 cap. Conductor supplied includes color - Green.

spare lengths.

4/0 2kV, 10 ft length 3 sets of 5 w/E-1016 plug and This is the pigtail These pigtail sets are conductors / Generator Pigtail E-1022 cap. set that connects stored in the 7 1 set for - Gen to Main Conductor colors - the generator to special electrical each unit Power Cable Brown, Orange, the 5 main power cable ISU 90 and 1 spare Yellow, White, conductor cables. containers.

Green.

SV0-GW-GLY-006 Page 65 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity Equipment FLEX Equipment Provd/ Performance Uses Notes Description Reqd Criteria Assembly - W PPA, 4 These assemblies 2 AWG 4 conductor, assemblies / and pigtail sets are Crouse Hinds Arktite 2 for each stored in the 7 special assembly APJ10487, This is the unit. electrical cable ISU 7 ft length w/ four (4) assembly and 90 containers.

E-1016 plugs. pigtail set that Electrical Pigtail This is not the connects the

- Gen Main primary method for generator main Power Cable to connecting the power cable to the Wall Receptacle generator to the Pigtail - 4/0 2kV, 10 installed wall 4 pigtail sets plant. It is one of ft lengths w/E-1022 receptacles in the of 4 several methods.

plug and 1016 cap plant conductors / The multiple methods Conductor colors -

2 for each are considered as the Brown, Orange, unit spares.

Yellow, Green.

Pigtail set - 4/0 2kV, 10 ft lengths w/ E-1022 plug and 2 hole 3 sets of 3 3/8 lug. Conductor conductors / colors - Brown, 1 set per Orange, Yellow.

unit and 1 This pigtail set has spare. This is the pigtail several options Electrical Pigtail set that connects available for 3 - Gen Main the generator main grounding.

conductors / Power Cable to Pigtail - 4/0 2kV, 10 power cable to the These pigtail sets are 1 per unit Regulating ft lengths w/ E-1022 regulating stored in the 7 special and 1 spare Transformer plugs and single hole transformers in the electrical cable ISU 5/16 lug. Conductor plant 90 containers.

3 color - Green.

conductors /

1 per unit Pigtail - 4.0 2kV, 10 and 1 spare ft lengths w/E-1022 plug and ground clamp. Conductor color - Green.

SV0-GW-GLY-006 Page 66 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity FLEX Equipment Equipment Provd/ Uses Notes Description Performance Criteria Reqd 4 sets of four 3 conductors /

Pigtail - 4/0 2kV, 10 ft 2 sets per unit lengths w/E-1022 plug one of which and Shoo Pin. These pigtail sets These pigtail is a spare. Electrical Pigtail Conductor colors - can connect the sets are stored

- Gen Main Brown, Orange, Yellow. generator main in the 7 special Power Cable to Pigtail - 4/0 2kV, 10 ft power cable to the electrical cable Test Load lengths w/E-1022 plug test load breaker in ISU 90 Breaker and 2 hole NEMA 1/2 the plant. containers.

4 conductors /

lug. Conductor color -

2 per unit one Green.

of which is a spear.

1 hp, 1700 cfm, fan, with 300 ft detachable hose, electric rating: single These fans are phase 115 VAC. provided to replace the ancillary fans in These fans are 7 fans / 3 per Fan must meet: the MCR and the Electric contained in unit and 1 MCR requires I&C rooms, if Ventilation Fans ISU 90 spare. 1700 cfm@0.65 in. required. There is 1 containers.

of water. fan in the MCR and 2 fans in the I&C I&C rooms require 1500 rooms.

cfm@0.71 inches of water.

These ducts These are the ducts are contained 16 lengths / 8 to ensure the Phase Anti-Static, 16 diameter in ISU 90 lengths per Fan Ducts 3 replacement fans in 25 ft lengths containers unit. can be installed in along with the the plant.

fans SV0-GW-GLY-006 Page 67 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity FLEX Equipment Equipment Provd/ Uses Notes Description Performance Criteria Reqd These pigtail 2/3C PPA Cable w/ These are the main sets are stored 32 lengths / Meltric DS200 Male power cables from Fan Power in the 7 special 16 lengths per Plug and Meltric DS200 the from the gen to Cables electrical cable unit. Female Plug; 50 Ft operating the Phase ISU 90 lengths 3 fans, if required.

containers.

Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity Equipment FLEX Equipment Provd/ Performance Uses Notes Description Reqd Criteria

10 AWG wires These are the w/Meltric DS200 pigtails from 6 lengths / 3 Fan Pigtails Gen These pigtail sets are stored Male receptacle and the gen to the lengths per to Main Power in the 7 special electrical male NEMA L5-30 main power unit. Cable cable ISU 90 containers.

Twistlock, 10 ft cables for the lengths. fans

12 AWG wires These are the w/Meltric DS200 6 lengths / 3 Fan Pigtail Main pigtails from These pigtail sets are stored Male receptacle and lengths per Power Cable to the main in the 7 special electrical female NEMA L5-20 unit. Fan power cable to cable ISU 90 containers.

Twistlock, 10 ft the fans.

lengths.

These are Each of these pumps are in 135 gpm at 236 ft.

3 pumps / 1 trailer-mounted a single ISU 90 container PCS/SFP developed head and per unit and diesel-driven that includes a fuel cell and Makeup Pump 100 gpm at 273 ft.

1 spare. portable two 20 ft lengths of suction developed head.

generators. hose and adapters.

SV0-GW-GLY-006 Page 68 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Enclosure 3 Vogtle 3&4 FIP Attachment 2 PHASE 2 AND PHASE 3 FLEX EQUIPMENT Offsite Phase 3 Stored at SAFER Quantity Equipment FLEX Equipment Provd/ Performance Uses Notes Description Reqd Criteria This pump is used for Each of these pumps are indefinite supplied with redundant makeup to the hydraulic booster pumps PCCAWST by with floatation devices to 2 pumps / 1 PCCAWST pumping water ensure the booster pumps 300 gpm pressure pump Makeup Pump from the are not drawing from the rating RGT 200 psi services (Main pump with Savannah bottom of the river. The with minimum 26 ft.

both units hydraulic booster River, if main pump comes in a suction lift.

and 1 spare pump required. The single ISU 90 container. In a pump second ISU 90 container are discharges the fuel cell, 4 suction hose, directly into the the hydraulic pumps and top of hoses, valves, and adapters.

PCCAWST.

5-inch double jacket, These hoses and fittings are 300 psi service contained in ISU 90 pressure hose in 50 ft containers. The amount of lengths. The hose and hose used for each unit is fittings support determined by the both the configuration during the 220 hose PCS/SFP event mitigation. Three (3)

Pump Discharge lengths / Makeup Pump lengths of the total lengths Hose/Fittings two WYEs and the are used as discharge hose 5 x 5 x 5 WYE PCCAWST for the PCS/SFP makeup with 3 valves to spilt Makeup Pump pumps. One (1) length for flow from the river to discharges. each unit and one (1) spare.

both units and The total length of hose various 5 Storz supplied includes spare hose adapters lengths.

SV0-GW-GLY-006 Page 69 of 70

Westinghouse Non-Proprietary Class 3 ND-23-0025 (Non-Proprietary)

Vogtle 3&4 FIP Attachment 3 VEGP 3&4 Haul Paths Security-Related Information, Withhold Under 10 CFR 2.390d SRI SR I

SV0-GW-GLY-006 Page 70 of 70

Southern Nuclear Operating Company ND-23-0025 Enclosure 4 Vogtle Electric Generating Plant Units 3&4 Westinghouse Affidavit CAW-23-030 (This enclosure consists of 4 pages including this cover page)

ND-23-0025 Westinghouse Non-Proprietary Class 3 Westinghouse Affidavit AFFIDAVIT CAW-23-030 Page 2 of 4 Page 1 of 3 Commonwealth of Pennsylvania:

County of Butler:

(1) I, Zachary Harper, Senior Manager, Licensing Engineering, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of SV0-GW-GLY-006, Rev. 1 as submitted by Southern Nuclear Operating Company letter ND-23-0025 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

ND-23-0025 Westinghouse Non-Proprietary Class 3 Westinghouse Affidavit AFFIDAVIT CAW-23-030 Page 3 of 4 Page 2 of 3 (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

ND-23-0025 Westinghouse Non-Proprietary Class 3 Westinghouse Affidavit AFFIDAVIT CAW-23-030 Page 4 of 4 Page 3 of 3 I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 8/17/2023 _____________________________

Signed electronically by Zachary Harper

ND-23-0025, Compliance with Order EA-12-049

Text

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