NL-15-0244, 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)

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)

ML15057A315
Person / Time
Site:	Hatch
Issue date:	02/26/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-0244
Download: ML15057A315 (7)

Text

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

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham, AL 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY February 26, 2015 Docket Nos.: 50-321 NL-15-0244 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 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)

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, Revision 0, dated August 2012.

4. Edwin I. Hatch Nuclear 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.

5. Edwin I. Hatch Nuclear Plant- Units 1 and 2 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 August 26, 2014, including Enclosure 2 -Hatch Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

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 Edwin I. Hatch Nuclear Plant - Units 1 and 2 (HNP) to develop, implement, and maintain guidance and strategies to maintain c;>r 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.

U. S. Nuclear Regulatory Commission NL-15-0244 Page 2 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 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the initial HNP overall integrated plan (OIP). A revised OIP was submitted with the fall 2014 six month update (Reference 5).

Reference 1 requires submission of a status report at six-month intervals following the content of the status reports. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C. 2, of Reference 1, delineating progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments and schedule adjustments since the last status report.

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, e.fi.f C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Sworn to and subscribed before me this J.lg_day of 1 2015.

c{ p My commission expires: } 0 ,

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Enclosure:

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

U. S. Nuclear Regulatory Commission NL-15-0244 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President -Hatch Mr. M. D. Meiers, Vice President -Regulatory Affairs Mr. B. J. Adams, Vice President -Engineering Mr. D. R. Madison, Vice President -Fleet Operations Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02. 004 U. S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager -Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch Ms. J. A. Kratchman, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPR/PGCB State of Georgia Mr. J. H. Turner, Director -Environmental Protection Division

Edwin I. Hatch Nuclear Plant - Units 1 and 2 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)

Enclosure Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-15-0244 Fourth Six-Month Status Report of FLEX Implementation Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) 1 Introduction Edwin I. Hatch Nuclear Plant - Units 1 and 2 developed an Overall Integrated Plan (OIP)

(Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. Reference 5 of this enclosure provided a revised OIP in fall 2014.

This enclosure provides an update of milestone accomplishments since submittal of the last status report, 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 previous 6-month update, and are current as of December 31, 2014:

• Perform Staffing Analysis (Phase 2) 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 5).

The dates are planning dates subject to change as design and implementation details are developed.

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 Complete N/A Submit 6 Month Status Report Aug 2013 ComJete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Initiate Phase 2 Equipment Jun 2014 Com_Qiete N/A Submit 6 Month Status Report Aug 2014 Complete N/A Perform Staffing Analysis (Phase 2) Oct 2014 Com_Qiete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Unit 2 Implementation Outage** Mar 2015 Not Started Develop Modifications- Unit 2 Apr 2015 In Progress Develop Strategies (Hatch Response Jun 2015 In Progress Plan)

Develop Modifications- Unit 1 Aug 2015 In Progress Submit 6 Month Status Report Aug 2015 Not Started Develop Operational Procedure Sep 2015 In Progress Create Maintenance Procedures Nov 2015 In Prqg_ress Develop Training Material Nov 2015 In Progress Submit 6 Month Status Report Feb 2016 Not Started Phase 2 Equipment Procurement Mar 2016 In Progress Unit 1 Implementation Outage* Mar 2016 Not Started Issue FSGs Apr 2016 Not Started Implement Training Apr 2016 In Progress Unit 1 Walk-throughs Apr 2016 Not Started Submit 6 Month Status Report Aug 2016 Not Started E-1

Enclosure to NL-15-0244 Fourth Six-Month Status Report of FLEX Implementation Target Revised Target Activity Milestone Completion Completion Status Date Date Unit 2 Walk-throughs Dec 2016 Not Started Unit 2 Implement Non-Outage Mods*' Dec 2016 In Progress Submit Completion Report Dec 2016 Not Started

• Full compliance after second listed refueling outage

• • Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 5).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant - Units 1 and 2 expect to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan.

Overall Integrated Plan Open Item Status

1. Structure, content and details of the Hatch SAFER Team developing Pilot Response Plan will be determined. Response Plan Interim Staff Evaluation Open Items Status ISE was issued on February 27, 2014 N/A (ML13364A202) with no Open Items.

7 Potential Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for HNP (Reference 3) with no Open Items.

The ISE states that, "the NRC concludes that the licensee has provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will meet the requirements of Order EA-12-049 at the Edwin I. Hatch Nuclear Plant, Units 1 and 2."

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Enclosure to NL-15-0244 Fourth Six-Month Status Report of FLEX Implementation 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Edwin I. Hatch Nuclear 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.

3. Edwin I Hatch Nuclear Plant, Units 1 and 2 -Interim Staff Evaluation Related to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS.

MF0712 and MF0713).

4. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Response to Request for Information Pursuant to Title 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the NTTF Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012, providing the Hatch Phase 2 On-Shift Staffing Analysis report sent October 9, 2014.

5. Edwin I. Hatch Nuclear Plant- Units 1 and 2 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 August 26, 2014, including Enclosure 2 -Hatch Units 1 & 2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

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

1. A more recent calculation performed for the Main Control Room Heat-up concludes that, with no mitigating actions, the temperature in the MCR will exceed 11oaF in 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, rather than 3.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as stated in OIP Revision 4. Taking into account Phase 1 actions to open doors, however, the MCR will not exceed 11oaF until after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, not 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> as stated in OIP Revision 4. Therefore, using the strategies as described in the OIP, the temperature in the MCR will not exceed 11oaF for the duration of the coping period.

2. The connection to the FLEX pump at the RHRSW piping is a permanent hose connection, not flanged as stated in the OIP Revision 4.

3. Current analysis of the pressure and flow requirements of the FLEX pump include the most limiting case for SFP cooling utilizing the spray monitor. According to the NEI 12-06 guide, a 250 gpm flow rate is required for SFP spray. The required head at this flow rate is 462 ft (200 psia), not 315 ft (135 psia) as stated in OIP Revision 4.

4. The station battery rooms have been evaluated for heat loads and the current analysis shows that temperatures will not exceed the equipment qualification temperature of 122aF for the duration of the coping period. The OIP Revision 4 previously indicated that no evaluation was necessary.

5. Current analysis for the generation of hydrogen in the battery rooms following an ELAP indicates that the time at which the concentration of hydrogen exceeds 2%, with no ventilation, will not occur until after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The OIP Revision 4 previously stated that this would occur in 2.5 days.

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