NL-13-1764, 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)

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)

ML13240A239
Person / Time
Site:	Vogtle
Issue date:	08/27/2013
From:	Ivey B Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-13-1764
Download: ML13240A239 (7)

Text

B. L. "Pete" Ivey Southern Nuclear Vice President Operati ng Company, Inc.

Regulatory Affairs 40 Inverness Center Par1<.way Post Office Box 1295 Birmingham , AL 35242 Tel 205.992. 76 19 Fax 205992 .521 7 sou August 27, 2013 Docket Nos.: 50-424 NL-13-1764 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 First Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for 8eyond-Design-8asis External Events (EA-12-049)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis 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 8eyond-Design-8asis External Events, Revision 0, dated August 29,2012

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012

4. Vogtle Electric Generating Plant - Units 1 and 2 Initial Status Report in Response to Commission Order with Regard to Mitigation Strategies for 8eyond-Design-8asis External Events (EA-12-049), dated October 23,2012

5. Vogtle Electric Generating Plant - Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for 8eyond-Design-8asis External Events (EA-12-049), dated February 27, 2013 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Vogtle Electric Generating Plant - Units 1 and 2 (VEGP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C.1 .a of Reference 1.

Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

U. S. Nuclear Regulatory Commission NL-13-1764 Page 2 Reference 4 provided the VEGP initial status report regarding mitigation strategies. Reference 5 provided the VEGP overall integrated plan .

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan . Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2 , of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. B. L. Ivey states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, Mr. B. L. Ivey Vice President - Regulatory Affairs BLl/CLN/lac Sworn to and subscribed before me this ~y of !+/-~l/JII?+- , 2013.

11 A./rtr/;;~}C-: lk/~btJr'-/

tary Public My commission expires: II\AxM, t-~I 2- 0'i

Enclosure:

Vogtle Electric Generating Plant - Units 1 and 2 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) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. E. Tynan, Vice President - Vogtle Mr. C. R. Pierce, Regulatory Affairs Director Mr. B. J. Adams, Vice President - Fleet Operations RType: CVC7000

U. S. Nuclear Regulatory Commission NL-13-1764 Page 3 U. S. Nuclear Regulatory Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Vogtle Mr. L. M. Cain , Senior Resident Inspector - Vogtle Ms. J. A. Kratchman, NRRlJLD/PMB Mr. E. E. Bowman, NRRlDPRlPGCB State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Vogtle Electric Generating Plant - Units 1 and 2 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)

Enclosure Vogtle Electric Generating Plant - Units 1 and 2 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)

Enclosure to NL-13-1764 First Six-Month Status Report of FLEX Implementation Vogtle Electric Generating Plant - Units 1 and 2 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) 1 Introduction Vogtle Electric Generating Plant - Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of June 30, 2013:

• None 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion date does not impact the Order implementation date.

Target Revised Target Activity Milestone Completion Completion Status Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Com2iete N/A Complete Submit 6 Month Status Report Aug 2013 (see Sec. 2)

N/A Initiate Phase 2 Equipment Procurement Sep 2013 Started Develop Strategies (playbook) with RRC Nov 2013 Started Jun 2014 Develop Operational Procedure Changes Dec 2013 Started Develop Modifications Jan 2014 Started Submit 6 Month Status Report Feb 2014 Not Started Develop Training Material Mar 2014 Started Submit 6 Month Status Report Aug 2014 Not Started Issue FSGs Sep 2014 Not Started Implement Training Oct 2014 Not Started Unit 2 Walk-throughs or Demonstrations Oct 2014 Not Started Unit 2 Implementation OutaQe

• Oct 2014 Not Started Submit 6 Month Status Report Feb 2015 Not Started Submit 6 Month Status Report AUj1 2015 Not Started Unit 1 Walk-throughs or Demonstrations Oct 2015 Not Started Unit 1 Implementation Outage

• Oct 2015 Not Started Submit Completion Report Fall 2015 Not Started

'Full compliance after second listed refueling outage Page 1

Enclosure to NL-13-1764 First Six-Month Status Report of FLEX Implementation 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1 of this enclosure).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Vogtle Electric Generating Plant - Units 1 and 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item .

Overall Integrated Plan Open Item Status

1. Structure, content and details of the Regional SAFER Team developing Pilot Response Center playbook will be determined . Playbook Draft Safety Evaluation Open Item Status None Received to date N/A 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Vogtle Electric Generating Plant - Units 1 and 2 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 27,2013.

2. 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.

9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but do not constitute a change in strategy:

Page 2

Enclosure to NL-13-1764 First Six-Month Status Report of FLEX Implementation

1. Prior to depletion of the first CST, the TDAFW pump (or SG FLEX pump, as applicable) will require makeup from the second CST. The time to align the second CST for SG injection (table item 12) has been determined to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> versus 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> as stated in Reference 1 of this enclosure. This is due to a conservative change in the CST level from the low level alarm value to the technical specification low level.

2. Based on a more accurate calculation, the volume of de-mineralized water assumed in the RMWST has been adjusted from 127,050 gallons to 148,000 gallons, which increases the time this water source is available from 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

3. Instead of relying on the RRC for some Phase 3 cooling, repowering of the CCW and support systems such as room coolers and motor coolers will be performed. This Phase 3 strategy will continue to evolve as Phase 3 equipment is defined.

4. The FLEX primary 480V FLEX Diesel Generator connection point will be outside of plant structures but designed for protection from the plant hazards.

Page 3