NL-14-0250, Unit 2 Request for Relaxation of Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Unit 2 Request for Relaxation of Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14057A780
Person / Time
Site:	Vogtle
Issue date:	02/26/2014
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-14-0250
Download: ML14057A780 (6)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs D1rector Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 B1rmmgham. AL 35201 Tel 205.992.7872 Fax 205 992.7601 SOUTHERN...\.

COMPANY February 26, 2014 Docket Nos.: 50-425 NL-14-0250 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 2 Request for Relaxation of Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number 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. ML12056A045.

2. Letter to NRC, Vogtle Electric Generating Plant - Units 1 and 2, Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013. ML13059A382.

Ladies and Gentlemen:

This letter transmits a request for relaxation of the requirements contained in NRC Order EA-12-049. On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs the Vogtle Electric Generating Plant (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. As described in the Overall Integrated Plan for VEGP (Reference 2), one assumption of the VEGP mitigation strategies is dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals.

SNC planned to install RCP shutdown seals by the Fall 2014 refueling outage (2R17) that would have supported our FLEX strategies for the plant. However, recent post-operational testing of RCP shutdown seals has potentially invalidated that assumption.

U. S. Nuclear Regulatory Commission NL-14-0250 Page 2 An extension of one additional refueling cycle is requested, which would move the implementation date to completion of the Spring 2016 refueling outage.

Section IV of NRC Order EA-12-049 (Reference 1) states that licensees proposing to deviate from requirements contained in NRC Order EA-12-049 may request that the Director, Office of Nuclear Reactor Regulation, relax those requirements. Therefore, in accordance with Section IV of NRC Order EA-12-049, SNC is requesting that the Director, Office of Nuclear Reactor Regulation, relax the requirement for completion of full implementation as prescribed in Section IV.A.2 of NRC Order EA-12-049 and as described in the attachment to this letter.

SNC considers that, upon approval by the NRC, the alternative full implementation date proposed in the attachment will constitute a relaxation to the NRC Order EA-12-049 for VEGP Unit 2.

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

Mr. C. R. Pierce states he is the Regulatory Affairs Director for 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,

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C. R. Pierce Regulatory Affairs Director CRP/JMG/RCW Swom to and subscribed before me this~ day of ~~ 1 2014.

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My commission expires: /D /~!J.or1

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Enclosure:

Vogtle Electric Generating Plant - Unit 2 Request for Relaxation

U.S. Nuclear Regulatory Commission NL-14-0250 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. T. E. Tynan, Vice President- Vogtle Mr. B. L. lvey, Vice President - Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations RType: CVC7000 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, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPRIPGCB Alabama Department of Public Health Mr. J. H. Turner, Environmental Director Protection Division

Vogtle Electric Generating Plant - Unit 2 Request for Relaxation of Requirement IV.A.2 of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure Vogtle Electric Generating Plant - Unit 2 Request for Relaxation

Enclosure to NL-14-0250 Request for Relaxation Vogtle Electric Generating Plant- Unit 2 Request for Relaxation 1 Relaxation Request In accordance with the process specified in Section IV of 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), Southern Nuclear Operating Company(SNC) hereby submits a request for schedule relaxation from the Order requirements for completion of full implementation for Vogtle Electric Generating Plant (VEGP) Unit 2 either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required in Condition C.l.a of the Order, or December 31, 2016, whichever comes first.

2 Order Requirement from Which Relaxation is Requested NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation of the Order requirements either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required by Condition C.l.a, or December 31, 2016, whichever comes first.

In accordance with the requirements of the Order, SNC submitted the Overall Integrated Plan for VEGP (Reference 2) on February 27, 2013. The Overall Integrated Plan milestone schedule identified the completion dates for full implementation of NRC Order EA-12-049 for Unit 1 as completion of the Fall 2015 refueling outage, and for Unit 2 as completion of the Fall 2014 refueling outage.

NRC Order EA-12-049 requires the development, implementation, and maintenance of 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 (BDBEE). As described in the Overall Integrated Plan for VEGP, these mitigation strategies are dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals. These seals will ensure the safety functions of containment integrity (during an extended loss of alternating current power or ELAP), and core cooling (RCS inventory and level) are maintained for beyond design basis external events (BDBEEs).

3 Justification for Relaxation Request The RCP shutdown seals provide additional safety margin during a BDBEE by serving as a passive means of protecting the reactor. The seals reduce the risk to the plant (Core Damage Frequency) by limiting the loss of reactor coolant system (RCS) water inventory during the event.

Due to recent post-operational testing of the RCP shutdown seals at other plants, there is a need to enhance that design. The total implications of the shutdown seal testing results for reactor coolant pumps are currently being assessed. Resolution of these issues will require additional analytical work. Additionally, procedural development and training will also be necessary. These factors also affect SNC's ability to safely plan, and implement activities supporting FLEX.

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Enclosure to NL-14-0250 Request for Relaxation Based on this timeline, there is uncertainty that the full implementation of the mitigation strategies in accordance with NRC Order EA-12-049 would be completed by the Order requirement date.

The current required implementation date for Unit 2 is at the end of the Fall 2014 refueling outage. An extension of one additional refueling cycle is requested, which would move the implementation date to the end of the Spring 2016 refueling outage. This revised completion date is still within the maximum allowed time frame of December 2016. The extension would provide additional time to resolve industry issues; design, test and qualify the new seals; and, for SNC to safely plan, schedule, and install the new seals at VEGP. Additionally, the new seals will provide added safety margin during a BDBEE.

4 Conclusion As described above, compliance with the current NRC Order EA-12-049 schedule requirement for full completion of implementation of mitigation strategies would result in hardship or unusual difficulty without a compensating increase in the level of safety. Therefore, in accordance with the provisions of Section IV of the Order, SNC requests relaxation of the requirement described in Section IV.A.2, as explained above.

5 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. 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.

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