Text

Notification of Full Compliance of Required Action for NRC Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events
	ML16146A607
Person / Time
Site:	Vogtle
Issue date:	05/23/2016
From:	Pierce C; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, NL-16-0228
	Download: ML16146A607 (102)
	v • d • e

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY 1 May 23, 2016 Docket No.: 50-424 NL-16-0228 50-425 U. S. Nuclear Regulatory Commission .

ATTN: Document Control Desk Washington, D. C. 20555-0001 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 Ladies and Gentlemen:

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, to Southern Nuclear Operating Company (SNC). This Order 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. This letter provides the notific;:ation required by Item IV.C.3 of Order EA-12-049 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for both VEGP Units 1 and 2 on March 27, 2016 as Unit 2 completed refueling outage U2R18. SNC previously notified the NRC of the Unit 1 compliance with the Order on November 20, 2015. summarizes VEGP Units 1 and 2's compliance with Order EA-12-049. Enclosure 2 contains the VEGP Units 1 and 2 Final Integrated Plan (FIP) which provides strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design basis external event. Prior to the issuance of Order EA-12-049, the Nuclear Energy Institute notified the NRC of an industry initiative on procurement of equipment for the diverse and flexible coping strategy (letter dated February 24, 2012). The VEGP Units 1 and 2 FIP includes a list of equipment used for implementation of this Order wnich is more refined and supersedes the list which was procured for the 2012 initiative.

The VEGP FIP is based on NEI 12-06, Rev. 2 with the exception of Appendix E which was finalized after the validation process was completed. Other aspects of NEI 12-06, Rev. 2, while not applicable to this Order compliance, will be utilized for upcoming submittals (e.g., use of re-evaluated hazards, Appendix G and Appendix H) and rulemaking (e.g., references to NEI 13-06 and NEI 14-01).

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

U.S. Nuclear Regulatory Commission NL-16-0228 Page 2 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.

Rec.e~lyp;:ed,

.,': ~-

C.R. Pierce Regulatory Affairs Director *'

CRP/JMG/MRE

.d-Sw rn to and sub cribed before me this Z:J day of /YI CJ f '2016.

My commission expires: 1/z/zofg.

I I

Enclosures:

1. Compliance with Order EA-12-049

2. Vogtle Electric Generating Plant Final Integrated Plan cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President - Vogtle 1& 2 Mr. M. D. Meier, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Vogtle 1 & 2 Mr. A. M. Alen Resident Inspector - Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director - Environmental Protection Division

Vogtle Electric Generating Plant - Units 1 and 2 Notification of Full Compliance of for NRG Orders EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 1 Compliance with Order EA-12-049 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 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 effective immediately and directed the Vogtle Electric Generating Plant (VEGP) - Units 1 and 2 to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049. SNC developed an Overall Integrated Plan (OIP) (Reference 2 and revised in Reference 11) to provide FLEX. The information provided herein, as well as the implementation of the OIP, documents full compliance for VEGP Units 1 and 2 in response to the Order (Reference 1).

Open Item Resolution Following issuance of the NRC Audit Report (Reference 13), there were no open items from either it or the NRC Interim Staff Evaluation (ISE) (Reference 7). All identified items in the audit have been addressed and documented in the site CAP program.

Interim Staff Evaluation (ISE) Open Items - VEGP Units 1 and 2 has no open or pending items

Licensee Identified Open Items - VEGP Units 1 and 2 has no open or pending licensee identified open items

Audit Questions/Audit Report Open Items - VEGP Units 1 and 2 FLEX has no open or pending items Milestone Schedule - Items Complete VEGP Unit 1 & 2 Milestone Completion Date Submit 20 Day Letter Acknowledging Receipt of Order March 2012 Submit Overall Integrated Plan February 2013 1*t 6 Month Update August 2013 2nd 6 Month Update February 2014 Unit 1 - 1st Refueling Outage April 2014 3rd 6 Month Update August 2014 Unit 2 - 1st Refueling Outage October 2014 4th 6 Month Update February 2015 Develop Modifications March 2015 Develop Training Material June 2015 Develop Strategies (Vogtle Response Plan) with June 2015 National SAFER Response Center 5th 6 Month Update August 2015 Develop Operational Procedure Changes October 2015 Unit 1 Walk-throughs or Demonstrations October 2015 E1-1 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 Compliance with Order EA-12-049 VEGP Unit 1 & 2 Milestone Completion Date Implement Training October 2015 Unit 1 - 2nd Refueling Outage/ Implementation Complete October 2015 Phase 2 Equipment Procurement Complete December 2015 61h 6 Month Update February 2016 Develop FSGs February 2016 Issue FSGs February 2016 Unit 2 Walk-throughs or Demonstrations February 2016 Unit 2 - 2nd Refueling Outage/ Implementation Complete March 27, 2016 Order EA-12-049 Compliance Elements Summary The elements identified below for VEGP Units 1 and 2 are included in the Final Integrated Plan (FIP) (Enclosure 2) and demonstrate compliance with Order EA-12-049.

Strategies - Complete

VEGP Units 1 and 2 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit

Questions/Audit Report Open Items.

Modifications - Complete The modifications required supporting the FLEX strategies for VEGP Unit 1 and 2 have been fully implemented in accordance with the station processes.

Equipment - Procured and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for VEGP Unit 1 and 2 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, and is available for use.

Maintenance and testing requirements are included in the VEGP Preventative Maintenance Program such that equipment reliability is monitored and maintained. All maintenance and testing activities have been identified. All six month or less PM's have been developed and performed. Greater than 6 month PMs have been developed and will be performed before their due date.

Protected Storage - Complete The storage facility required to implement the FLEX strategies for VEGP Unit 1 and 2 has been constructed and provides adequate protection from the applicable site hazards. The equipment required to implement the FLEX strategies for VEGP Unit 1 and 2 is stored in its protected configuration.

Procedures - Complete FLEX Support Guidelines (FSGs) for VEGP Unit 1 and 2 have been developed E1-2 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 Compliance with Order EA-12-049 and integrated with existing procedures. The FSGs and applicable procedures have been verified and are available for use in accordance with the site procedure control program.

Training - Complete Training for VEGP Unit 1 and 2 personnel has been completed in accordance with an accepted training process, as recommended in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

Staffing - Complete The VEGP Phase 2 staffing study for VEGP (Reference 15) has been completed in accordance with 10 CFR 50.54(f) letter (Reference 16). The NRG has reviewed the Phase 2 staffing study and concluded that it adequately addresses the response strategies needed to respond to a beyond design basis external event using Vogtle procedures and guidelines. This is documented in NRG letter dated September 29, 2014 (Reference 17). After completion of the validation plan, SNC reviewed the phase 2 staffing study to ensure it remained effective.

Communications - Complete VEGP committed to compliance with the communications capabilities in accordance with the 10 CFR 50.54(f) letter (Reference 16). Implementation of the backup satellite service ultimately did not include shared cellular or data capability as origii:ially planned; however, those capabilities were not relied on for compliance. The Rapidcom system has the capability to provide data communications should the TSC deem it is needed.

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 Committees) for off-site facility coordination. It has been confirmed that PEICo is ready to support VEGP 1 and 2 with Phase 3 FLEX equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation - Complete SNC has completed validation in accordance with industry developed guidance to assure req.uired tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the FLEX 01 P and FIP for Order EA-12-049.

FLEX Program Document - Established The SNC VEGP FLEX Program Document has been developed in accordance with the requirements of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

E1-3 to N L-16-0228 Vogtle Electric Generating Plant - Units 1&2 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. 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.

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.

4. 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.

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

6. Vogtle Electric Generating Plant - Units 1 and 2 First Six-Month Status Report of the Implementation of the Requirements of the Commiss.ion Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated August 27, 2013.

7. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Stra~egies) (TAC NOS. MF0714 and MF0715), dated January 16, 2014.

8. Vogtle Electric Generating Plant - Units 1 and 2 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 February 26, 2014.

9. 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) dated February 26, 2014.

10. NRC Letter, Relaxation of Certain Schedule Requirements for Order EA-12-049, dated April 14,2014. .

11. Vogtle Electric Generating 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 - Vogtle Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP),. Revision 4.

12. Vogtle Electric Generating 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), dated February 26, 2015.

E1-4 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 Compliance with Order EA-12-049

13. NRC letter, Vogtle Electric Generating Plant, Units 1 and.2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF071.4, MF0715, MF0723, and MF0724), dated August 25, 2015.

14. Vogtle Electric Generating Plant - Units 1 and 2 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 August 27, 2015.

15. Vogtle Electric Generating 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, dated May 16, 2014.

16. 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-lchi Accident, dated March 12, 2012.

17. NRC Letter, Response Regarding Licensee Phase 2 Staffing Submittals Associated With Near-Term Task Force Recommendation 9.3 Related To The Fukushima Dai-lchi Nuclear Power Plant Accident, dated September 29, 2014.

18. Vogtle Electric Generating Plant Notification of Commitment Completion - NTTF Recommendation 9.3, dated October 15, 2015.

19. Vogtle Electric Generating Plant - Unit 1, Completion of Required Action for NRC Orders EA-12-049 & EA-.12-051, Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated November 20, 2015.

20. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 2, dated December 2015.

21. 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 1, dated January 22, 2016.

E1-5

Vogtle Electric Generating Plant - Units 1 and 2 Notification of Full Compliance of for NRG Orders EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 2 Vogtle Electric Generating Plant Final Integrated Plan (93 pages)

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant

May 2016 Units 1 and 2 FINAL INTEGRATED PLAN U.S. NUCLEAR REGULATORY COMMISSION ORDER EA-12-049 STRATEGIES FOR BEYOND DESIGN BASIS EXTERNAL EVENTS VOGTLE ELECTRIC GENERATING PLANT Units 1 & 2 May 2016 Page 1 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table of Contents

1. Background ......................................................................~ ..................................... 5

2. NRC Order EA-12-049 - Mitigation Strategies (FLEX) ......................................... 7 2.1 General Elements .............................. ;................................................................ 7 2.1 .1 General Criteria and Baseline Assumptions ............................................... 7 2.2 Strategies ........................................................................................................... 7 2.2.1 Objective and Approach ............................................................................. 7 2.2.2 Method of Compliance with NRC Order EA-12-049 ................................... 8 2.3 Electric Power ............................. :.................................................................... 1O 2.3.1 Phase 1 Strategy ......................................... ,............................................ 1O 2.3.2 Phase 2 Strategy ...................................................................................... 11 2.3.3 Phase 3 Strategy ................................................................ :..................... 11 2.3.4 Systems, Structures, Components ............ ,........................ ,..................... 12 2.3.5 FLEX* Connections ................................................................................... 13 2.3.6 Electrical Analysi~r .................................................................................... 13 2.3.7 480V FLEX Generator .............................................................................. 14 2.4 Reactor Core Cooling and Heat Removal Strategy MODES 1-4 and MODE 5 with Steam Generators Available ..... ~ ............................................................... 14 2.4.1 Phase* 1 Strategy ........................................................................................ 15 2.4.2 *Phase 2Strategy .. *.********:**************************************************************************16 2.4.3 Phase 3 Strategy ...................................................................................... 20 2.4.4 Systems, Structures, Components .........*............................ :.................... 21 2.4.5 FLEX Connections ................................................................................... 25 2.4.6 Key Reactor Parameters ............. :............................................................ 26 2.4.7 Thermal Hydraulic Analyses ............... '. ..................................................... 28 2.4.8 Reci~culation Pump Seal Leakage ................................................... :....... 30 2.4.9 Shutdown Activity Analysis ....................................................................... 32 2.4.10 FLEX Pumps and Water Supplies ............................................................ 33

2.5 Spent Fuel Pool Cooling/Inventory ................................................................... 38 2.5.1 Phase 1 Strategy ...................... .- ............................................................... 38 2.5.2 Phase 2 Strategy ......................................................................................39 2.5.3 Phase 3 Strategy .......................................................................................41 2.5.4 Structures, Systems, and Components ................................................... .41 2.5.5 Key Reactor Parameters ........................................................ ,................ .43 2.5.6 Thermal-Hydraulic Analyses ................................................................... .43 2~5.7 FLEX Pump and Water Supplies ............................................................. .43 2.5.8 Electrical Analysis ....................................................................................43 Page 2 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.6 Containment Integrity MODES 1-4 and MODE 5 with Steam Generators Available ............................................... ,............................................................ 44 2.6.1 Phase 1..................................................................................................... 44 2.6.2 Phase 2 ....................................................................................................44 2.6.3 Phase 3 ............... :................................... ;................................................. 44 2.6.4 Structures, Systems, Components ........................................................... 45 2.6.5 Key Containment Parameters .................................................................. 46 2.6.6 Thermal-Hydraulic Analyses ................................................................... .46 2.6.7 FLEX Pump and Water Supplies .............................................................. 47 2.6.8 Electrical Analysis .............................. ~ ...................................................... 47 2.7 Characterization of External Hazards ....................................... ,........................ 47 2.7.1 Seismic .....................................................................................................47 2.7.2 External Flooding ......................................................................................47

2.7.3 Severe Storms with High Wind .......................... ~ ..................................... .48 2.7.4 Ice, Snow and Extreme Cold .................................................................... 49 2.7.5 High Temperatures ................................................................................... 50 2.8 Protection of FLEX Equipment ................................................. ,........................ 50 2:9 Deployment of FLEX Equipment ...................................................................... 55 2.9.1 . Haul Paths and Accessibility .; .................................................................. 55 2.10 Fueling of Equipment ...................................... ;................................................ 56 2.11 Offsite Resources ................................ ,...........................................................,.57.

2.11.1 National SAFER Response Centers .......................................................... 57 2.11.2 Equipment List ............ ,..................................................................... :...... 58 2.12 Habitability and Operations .............................................................................. 61 2.12.1 Equipment Operating Conditions ............................................................. 61 2.12.2 Heat Tracing ................:................................................................. :.......... ,.65 2.13 Personnel Habitability....................*........................... ~ .................................. ;.... 66 2.14 Lighting ........................................ .'..................................................................... 66 2.15 Communications ................................................................................................ 67 2.16 Water sources .................................................................................................. 68 2.16.1 Secondary Water Sources ....................................................................... 68 2.17 Shutdown and Refueling Analysis ..................................................... :.............. 70 2.17.1 RCS Inventory and Reactivity Control MODE 5 without Steam Generators Available ...................................................................................................70 2.17.2 RCS Inventory and Reactivity Control MODE 6 ....................................... 71 2.17.3 Spent Fuel Pool Cooling/Inventory ....................................................,....... 72 Page 3 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.17.4 Containment Integrity, MODES 5 & 6 ....................................................... 72 2.18 Sequence of Events ......................................................................................... 73 2.19 Programmatic Elements ................................................................................... 79 2.19.1 Overall Program Document.. .................................................................... 79 2.19.2 Procedural Guidance ................................................................................ 80 2.19.3 Staffing ..................................................................................................... 81 2.19.4 Training .....................................................................................................81 2.19.5 FLEX Equipment List.. .............................................................................. 81 2.19.6 N+ 1 Equipment Requirement.. ................................................................. 82 2.19.7 Equipment Maintenance and Testing ....................................................... 85 2.19.8 FLEX Equipment Unavailability Tracking ................................................. 85

3. References ............................................................................................................87 Page 4 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

1. Background

In 2011, an earthquake-induced tsunami caused Beyond-Design-Basis (Bi;>B) flooding at the Fukushima Dai-ichi Nuclear Power Station in Japan. The flooding caused the emergency power supplies and electrical distribution systems to be inoperable, resulting in an extended loss of alternating current (ac) power (ELAP) in five of the six units on the site. The ELAP led to (1) the loss of core cooling, (2) loss of spent fuel pool cooling capabilities, and (3) a significant challenge to maintaining containment integrity. All direct current (de) power was lost early in the event on Units 1 and 2 and after some period of time at the other units. Core damage occurred in three of the units along with a loss of containment integrity resulting in a release of radioactive material to the surrounding environment.

The US Nuclear Regulatory Commission (NRC) assembled a Near-Term Task Force (NTTF) to advise the Commission on actions the US nuclear industry should take to preclude core damage and a release of radioactive material after a natural di$aster such as that seen at Fukushima. The NTTF report (Reference 3.1) contained many recommendations to fulfill this charter,. including assessing extreme external event hazards and strengthening station capabilities for responding to beyond-design-basis external events.

Based on NTTF Recommendation 4.2, the NRC issued Order EA-12-049 (Reference 3.2) on March 12, 2012 to implement mitigation strategies for Beyond-

. Design-Basis (BOB) External Events (BDBEEs). The order provided the following requirements for strategies to mitigate BDBEEs:

1. Licensees shall develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities following a BDBEE.

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

Page 5 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 The order specifies a three-phase approach for strategies to mitigate BDBEEs:

Phase 1 - The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment and spent fuel pool (SFP) cooling capabilities.

Phase 2 - 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 off site.

Phase 3 - The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

NRC Order EA-12-049 (Reference 3.2) required licensees of operating reactors to submit an overall integrated plan, including a description of how compliance with these requirements would be achieved by February 28, 2013. The Order also required licensees to complete implementation of the requirements no later than two refueling cycles after submittal of the overall integrated plan or December 31, 2016, whichever comes first.

The Nuclear Energy Institute (NEI) developed NEI 12-06, Rev. 0, which provided guidelines for nuclear stations to assess extreme external event hazards and implement the mitigation strategies specified in NRG Order EA-12-049. The NRG issued Interim Staff Guidance JLD-ISG-2012-01 (Reference 3.4), dated August 29, 2012, which endorsed NEI 12-06, Rev. 0 with clarifications on determining baseline coping capability and equipment quality. Since that time, NEI. 12-06, Rev. 2 was issued (Reference 3.3) and endorsed by the NRG on January 22, 2016 (Reference 3.81).

NRG Order EA-12-05 r (Reference 3.5) required licensees to install reliable SFP instrumentation with specific design features for monitoring SFP water level. This order was prompted by NTTF Recommendation 7.1 (Reference 3.1 ).

NEI 12-02 (Reference 3.6) provided guidance for compliance with Order EA-12-051 .

The NRG determined that, with the exceptions and clarifications provided in JLD-ISG-2012-03 (Reference 3.7), conformance with the guidance in NEI 12-02 is an acceptable method for satisfying the requirements in Order EA-12-051.

This Final Integrated Plan (FIP) addresses compliance with NRG Order EA-12-049.

Compliance with Order EA-12-051 can be found in References 3.45 and 3.46.

Page 6 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

2. NRC Order EA-12-049 - Mitigation Strategies (FLEX) .

1 2.1 General Elements 2.1.1 General Criteria and Baseline Assumptions

.The assumptions used for the evaluations of a VEGP ELAP/loss of normal access to the ultimate heat sink (LUHS) event and the development of FLEX strategies are stated below.

Key assumptions associated with implementation of FLEX Strategies*

for VEGP are described below: *

The applicable PWR Criteria and Initial Plant Conditions listed in NEI 12-06, Revision 2 (Reference 3.3), ,Sections 3.2.1.1 :-

3.2.1.6, are applicable to VEGP without exception.

Additional staff resources are expected to. begin arriving at 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the site will be fully staffed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event (References 3.74 and 3.75).

Temperature is not expected to impact the utilization of off.. site resources or the ability of personnel to implement the required.

FLEX strategies.

.Vogtle has installed low leakage *Reactor Coolant Pump (RCP) seals (Westinghouse SHIELD Passive Shutdown Seal). RCP seal leakage is assumed to be 1 gpm per RCP after seal actuation. An additional 1 gpm o1 unidentified leakage is included in the total RCS leakage (the Technical Specificc;i.tions maximum allowed unidentified leakage, Reference 3.13, TS 3.4.13). (Reference 3.8) 2.2 Strategies 2.2.1 Objective and Approach The objective of the *FLEX Strategies is to establish an indefinite coping capability to prevent damage to the fuel in. the Jeactor and 'SFPs and to maintain the containment function using installed equipment, on-site portable equipment, and off-site resources. This indefinite coping capability will address an extended loss of all ac power (ELAP)

- loss of off-site power, *emergency diesel generators and any alternate ac source (as defined in 10 CFR 50.2) but not the loss of ac power to Page 7 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 buses fed by station batteries through inverters - with a simultaneous loss of access to the ultimate heat sink (LUHS).

The plant indefinite coping capability is attained through the implementation of pre-determined strategies (FLEX str~tegies) that are focused on maintaining or restoring key plant safety functions. The FLEX strategies are not tied 'to any specific damage state or mechanistic assessment of external events. Rather, the strategies are developed to maintain the key plant safety functions based on the evaluation of plant response to the coincident ELAP/LUHS event. A safety function-based approach provides consistency with, and allows coordination with, existing plant emergency operating procedures (EOPs). FLEX strategies are implemented in support of EOPs using FLEX Support Guidelines (FSGs) and Strategy Implementation Guides (SIGs). Sf Gs were developed to have operator actions in the field included in a separate "operator friendly" procedure format. The FSGs and SI Gs together are equivalent to th.e PWROG generic FSGs.

The str,ategies for coping with the plant conditions that result from an ELAP/LUHS event involve a three-phase approach; *

Phase 1 - Initially cope by relying on installed plant equipment and on-site resources:

Phase 2 - Transition from *instailed plant equipment to on-site FLEX equipment.

Phase 3 - Obtain additional capability and redundancy from off-site equipment and resources until power, water, and coolant injection systems are restored or commissioned.

The duration *Of each phase ,is specific to the installed and portable equip.ment utilized for the particular FLEX strategy employed to mitigate the plant condition.

2.2.2 Method of Compliance with NRC Order EA-12-049 Core decay heat is removed by adding wat~r to the steam generators (SGs) and releasing steam from the SGs to the atmosphere. The water will initially be added by the turbine-driven auxiliary feedwater (TDAFW) pump, taking suction from the condensate storage tanks (CSTs). Eventually, the reactor coolant system (RCS) will be cooled down, which will reduce the RCS and SG pressures. When the Page 8 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1*and 2 TDAFW pump can no longer be operated due to the lowering SG pressure, a FLEX pump (also taking suction from the CSTs) will be used to add water to the SGs. If the CSTs are depleted, the Reactor Makeup Water Storage Tank (RMWST) can supply makeup water to the CSTs via another FLEX pump. The Nuclear Service Cooling Water basins serve as alternate supplies of makeup water to the CSTs.

Borated water will be added to the RCS for reactivity control. Initially, boron will be injected using the safety injection accumulators, followed by injection using a motor-driven FLEX pump, powered by a FLEX generator, taking suction from the Boric Acid Storage Tank (BAST) or Refueling Water Storage Tank (RWST).

FLEX generators will be used to reenergize the installed battery chargers to keep the necessary direct current (de) buses energized, which will then keep the 120 volt ac instrument buses energized.

Vogtle will utilize the industry National SAFER Response Centers (NSRCs) for supplies of Phase 3 equipment, with the intent of reenergizing certain plant safety buses and establishing long-term cooling from the ultimate heat sink (UHS), as necessary.

In the postulated ELAP eveht, the SFPs will initial.ly heat. up due to the unavailability of the normal cooling system. Gravity feed from the RWST will be established as needeq for SFP makeup during the initial phase of an ELAP. A FLEX pump will be aligned and used to add water to the SFPs of both units to maintain level as the pools boil.

Three paths will be available for SFP makeup; via hoses directly discharging into the pools; via connections to the existing SFP makeup lines; or via hoses directed to portable spray monitors positioned around the SFPs. Makeup will maintain a sufficient amount of water above the top of the fuel assemblies for cooling and shielding. The

long term strategy for SFP makeup is to continue the strategies described above. When supplemented by portable equipment delivered from off-site (NSRC), water from the Savannah River can be used to replace depleted on-site Seismic Category 1 water inventories.

However, the associated actions are not relied upon in the FLEX strategy during the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following ELAP.

Vogtle has a large dry containment building. Vogtle utilizes low-leakage seals on the reactor coolant pumps. Should the event occur with the plant in MODES 1-4 (power operation, startup, hot standby, hot shutdown), the low leakage seals will limit the leakage inside the containment. This ensures that containment pressure and temperature Page 9 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May2016 Units 1 and 2 remain within design limits without active containment cooling until well beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Since no time sensitive Phase 3 actions have been identified, instructions for connection and utilization of NSRC equipment for long term coping or recovery will be provided by Technical Support Center (TSC) personnel who will have assessed the condition of the plant and infrastructure, plant accessibility, and additional available offsite resources (both equipment and personnel) fol.lowing the BDBEE.

Should the event occur with the plant in MODES 5 (cold shutdown) or 6 (refueling), local manual actions are credited to establish a vent flow path through one of the two installed lines provided for Integrated Leak Rate Testing.

The specific strategies described in Sections 2.3, 2.4, 2.5, and 2.6 below are capable of mitigating an ELAP/LUHS resulting from a BDBEE by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities at VEGP. Though specific strategies have* been developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. As previously discussed, the$e strategies, in the form of FSGs and SIGs, have been incorporated into the VEGP emergency operating procedures in accordance with established EOP change processes, and their impact to the design basis capabilities of the unit evaluated under 10 CFR 50.59.

2.3 Electric Power 2.3.1 Phase 1 Strategy Following an ELAP, inverters would maintain Control Room Instrumentation and requir~d control features with power supplied from the Train A, B & C station batteries. Critical 125V DC loads would also be maintained from the batteries. In order to extend battery life for all Station Blackout (SBO) events, operators are directed to take steps to minimize the load on the station batteries by shedding unnecessary loads in accordance with station procedures; load shedding is completed by 45 minutes after the start of the event, thus ensuring the station batteries are available for a minimum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Reference 3.15).

Page 10 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Control Room lighting is initially supplied with power from battery ballasts included in each light fixture which provide 90 minutes of lighting. Prior to depleting the battery ballasts, control room lighting can be transferred to the Train D station batteries. All loads are shed from the D train batteries allowing one train of control room lighting to be powered by the D train batteries via a transfer switch. (Reference 3.15)

Following an ELAP, inverters would maintain th.e plant Public Address (PA) system with power supplied from the N~Train TSC batteries. In order to extend battery life, operators are directed to take steps to minimize the load on the TSC batteries by shedding unnecessary loads in accordance with station procedures. The PA system equipment and the power supplies are located in the Control Building.

2.3.2 Phase 2 Strategy A 480V FLEX DG per unit will be deployed to power an installed 480V FLEX Switchboard (Reference 3.41 ). The FLEX Switchboard distributes power to one battery charger for each of the four Class 1E 125V DC Switchgear (providing continuity of power for - critical

instr.umentation, remote TDAFW pump operation, lighting in the "horseshoe" area of the Main Control Room), and one portable FLEX pump (Boron Injection or RCS Makeup, as needed). Installed FLEX transfer switches transfer power from the normal 1E source to the 480V FLEX Switchboard for each of the battery chargers. In addition to the 480V FLEX Switchboard, the 480V FLEX DG supplies power to a fuel oil transfer pump, SFP level indication system, and the plant public address system. Diverse connection points. for the 480V FLEX DG are provided outside and inside the Control Building (primary and alternate, respectively); see Section 2.3.5 for additional detail.s.

Ventilation fans for the battery and DC switchgear rooms are power by recep~acles available on the 480V FLEX Switchboard; see Section 2.12.1.3 tor additional details.

2.3.3 Phase 3 Strategy .

Since no time sensitive Phase 3 actions have been identified, instructions for connection and utilization of NSRC equipment for long term coping or recovery will be provided by TSC personnel who will have assessed the condition of the plant and infrastructure, plant Page 11 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 accessibility, and additional available offsite resources (both equipment and personnel) following the BDBEE. An example of this follows:

Two 1 MW 4kV turbine generators from the NSRC per unit can be connected together using NSRC provided paralleling equipment and necessary cables. The NSRC 4kV power can be connected to either A or B Train 4kV 1E buses. Loads that can be supported by the turbine generators include, Containment Coolers, AHR pumps, CCW pumps and SFP pumps.

2.3.4 Systems, Structures, Components 2.3.4.1 Installed DC Electrical Power There are four safety-related 125-V-dc systems (identified A, B, C, and D) per unit. These four de systems are credited in the Phase 1 coping strategies to maintain critical loads including: critical instrumentation; remote TDAFW pump operation: and lighting in the "horseshoe" area of the Main Control Room for at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Refer to VEGP FSAR (Reference 3.24) Section 8.3.2 for a description of the 125-V-dc system.

The Class 1E 125-V-dc systems are Safety Class 1, Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.5.1.4).

2.3.4.2 480V FLEX Electrical Connections Permanent nonsafety-related, non-Class 1E, seismically qualified 480V FLEX switchboards installed on Level B of the Control Building are used to support FLEX strategies for coping with an ELAP resulting from a BDBEE. The_

switchboards, via permanently installed cables, are connected to one of the two Class 1E battery chargers per train via safety-related, - Cla?s 1E, seismically qualified transfer switches. In addition, a safety-related seismically qualified transfer switch is used to align the- D train battery to Control Room lighting. A nonsafety-related, non-Class 1E, seismically qualified receptacle on level C of the Auxiliary Building is also provided to allow powering portable RCS Page 12 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 and Boron Injection FLEX Pumps. The FLEX switchboards have the capability to be crosstied.

Permanently installed nonsafety-related, seismically qualified connection boxes are provided for connection of the portable 480V FLEX DGs to the 480V FLEX switchboards. The primary 480V FLEX DG connection boxes are installed on the north wall outside the Control Building. The alternate 480V FLEX DG connection boxes are installed in the Train "A" vertical chases at grade level inside the Control Building.

A connection

box and transfer switch are installed in the TSC of the Control Building to power the PA system directly from the 480V FLEX diesel generator following a BDBEE.

2.3.5 FLEX Connections 2.3.5.1 Primary Electrical Connection The primary connection *point for the 480V FLEX DGs is installed outside the Control Buil.ding at grade level. The p.rimary connection point is designed to withstand applicable seismic loads* but do not have missile protection. See Section 2.3.4.2, Figure 2 and Figure 3.

2.3.5.2 Secondary Electrical Connection The secondary connection point for the 480V FLEX DG -

located inside the Control Building - is designed and installed to withstand all applicable hazards. The Control Building is a Category 1 safety-related structure which meets design requirements for all site hazards including missile protection. (See Section 2.3.4.2, Figure 2 and Figure 3) 2.3.6 Electrical Analysis Battery calculations demonstrate that battery capacity is sufficient to provide three trains (A, B & C) of critical loads for greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Reference 3.15). Battery capacity was calculated in accordance with the IEEE-485 methodology using manufacturer discharge test data applicable to the licensee's FLEX strategy as

outlined in the NEI white paper on Extended Battery Duty Cycles (Reference 3.39) as endorsed by the NRC (Reference 3.40).

Page 13 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Battery calculations demonstrate D train battery capacity is sufficient to provide MCR lighting for greater than 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months (Reference3.15) and that the TSC battery capacity is sufficient to provide power to the PA system at full load (emergency sirens on) for greater than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months (Reference 3.16). Battery capacity was calculated in c;tccordance with the IEEE-485 methodology using manufacturer discharge test data applicable to the licensee's FLEX strategy as outlined in the NEI white.

paper on Extended Battery Duty Cycles (Reference 3.39) as endorsed by the NRC (Reference 3.40).

2.3.7 480V FLEX Generator The selected diesel generator has sufficient capacity to* supply the Phase 2 loads as determined by the 480V FLEX Diesel Generator sizing calculation (Reference 3.9).

2.4 Reactor Core Cooling and Heat Removal Strategy MODES 1-4 and MODE 5 with Steam Generators Available Initially, core decay heat is removed. by adding water to the steam generators (SGs) and releasing steam from the SGs from the main steam safeties to the atmosphere. The water will initially be added by the turbine-driven auxiliary feedwater (TDAFW) pump, taking suet.ion from the condensate storage tanks (CSTs).*

At 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , depressurization of the SGs is initiated via loc8il operation of

Atmospheric Relief Valves (ARVs). RCS cooldown occurs at the same time as the SGs are depressurized. This enables boration via accumulators and ,

Boron Injection FLEX Pump to maintain sub-criticality margin. No credit is taken for boron added from the SI accumulators.

As soon as resources are available, but no later than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the start of the event, a diesel driven SG FLEX Pump (taking suction from either the CSTs or the HMWST) will be deployed and available for operation. This

action provides defense in depth for when adequate steam pressure is no longer available to drive the TDAFW pump's turbine.

At approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the portable Boron Injection FLEX Pump is available to initiate supplemental boration (with letdown as necessary) transferring water from the BASTs to the RCS .to ensure adequate boration

and maintain sub-criticality following RCS cooldown.

If the initial CSTs' water supply are depleted, the RMWST can supply makeup water to the CSTs via the diesel driven Makeup FLEX Pump. The r-..)uclear Page 14 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Service Cooling Water basins serve as alternate supplies of makeup water to the CSTs using the FLEX Submersible Pump.

2.4.1 Phase 1 Strategy Core Cooling and Heat Removal Immediately following the ELAP event, reactor core cooling (decay heat removal) will be accomplished by natural circulation of the Reactor Coolant System (RCS) through the steam generators. The heatsink is maintained by operation of the Turbine-Driven Auxiliary Feedwater (TDAFW) pump supplying feedwater to all four (4) steam generators (see Figure 1). Heat removal is accomplished by steam release from the Main Steam Safety Valves (MSSVs). Operation of the TDAFW pump will be automatically actuated within 1 minute of a loss of AC power. (Reference 3.11)

The TDAFW pump is designed to supply the feedwater flow required for removal of 200 percent of the decay heat from the reactor. The TDAFW pump supplies flow to all four steam generators through individual de motor-operated control valves. Control of the valves, as well as manual or automatic speed control for the TDAFW pump, is provided in the control room and at the local control panels located in the AFW pump house. Operating status of the TDAFW pump is indicated locally and in the control room.

Suction to the TDAFW pump will be from the Seismic Category 1 CSTs (see Figure 1), which are also protected from tornado missiles (Reference 3.12). All Category 1 structures are designed for SSE and OBE conditions (Reference 3.24 Section 3.7.B). Each unit has two (2)

CSTs, each with a credited inventory equal to 340,000 gallons of de-mineralized water (see Section 2.4.4.6). Based on the minimum volume of water available, the credited volume in the CSTs can support core cooling and heat removal requirements in MODES 1 through 4 for a minimum 89 hours0.00103 days 0.0247 hours 1.471561e-4 weeks 3.38645e-5 months (see Table 3 and Reference 3.14).

The initial phase of reactor core cooling will be heavily dependent upon the operation of the TDAFW pump to remove the decay heat from the reactor core. Operation of the TDAFW pump from the MCA is reliant upon an available battery powered source. In the event that battery power is unavailable, local manual operation of the TDAFW pump can be performed without reliance on battery power per procedural guidance.

Page 15 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 RCS lnventorv Control and Reactivity Control Vogtle has installed safe shutdown/low leakage Reactor Coolant Pump (RCP) seals (Westinghouse SHIELD Passive Shutdown Seal) for the Reactor Coolant Pumps (RCP).

No Phase 1 actions are required for inventory control. With RCP shutdown seals and the injection of accumulator inventory, analyses demo~nstrates that natural circulation in the RCS can be maintained for at least . 70 hours8.101852e-4 days 0.0194 hours 1.157407e-4 weeks 2.6635e-5 months without reliance upon FLEX RCS injection.

(Reference 3.19)

The Phase 1 action for RCS long term sub-criticality will be to cool down and depressurize the RCS at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after the event. This allows for injection of the Safety Injection (SI) Accumulators which adds boron and coolant inventory to the RCS. Prior to injecting the entire contents of the SI accumulators, they will be vented to avoid nitrogen .injection into the RCS. Introduction of nitrogen has the potential to inhibit natural circulation. Procedural guidance for stopping RCS cooldown and depressurization prior to nitrogen injection is provided in the appropriate emergency operating procedure. No credit is taken for the boron addition from the SI accumulators.

2.4.2 Phase 2 Strategy Primary Strategy Core Cooling and Heat Removal The primary strategy for maintaining reactor core cooling in Phase 2 remains the same as Phase 1 and is dependent upon the continued operation of the TDAFW pump. The TDAFW pump is capable of feeding the steam generators provided there is adequate steam pressure available to drive the, turbine and an adequate supply of water in the CSTs.

Alternate Strategy Core Cooling and Heat Removal In the event that the TDAFW pump fails or when adequate steam pressure is no longer available to drive the TDAFW pump's turbine, the Phase 2 alternate coping strategy for reactor core cooling requires depressurization of the steam generators, if needed and connecting a diesel driven SG FLEX Pump for injection of water irito the steam generators (see Figure 1).

Page 16 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 If not already complete, implementing this capability requires depressurizing the steam generators. To complete this .activity, operations personnel will be dispatched to the main steam valve rooms to manually reposition the Atmospheric Relief Valves (ARVs) and reduce pressure in the steam generators to approximately 300 psig.

Manual operation of these valves is relatively light work of short duration. Maximum normal temperature in these spaces is 115°F; abnormal temperature is 126°F (Reference 3.17). The manual operating station is located near openings in the vertical walls that communicate with the ambient outdoor environment via security grating. Continuous standby in the area is not required and operators can cycle in and out of the room as necessary to make minor adjustments directed by the MGR operator. Thus the impact of heat stress on the operators is minimized.

The SG FLEX Pump is sized based on the decay heat removal requirements at one hour after reactor shutdown in accordance with the Pressurized Water Reactor Owners Group (PWROG) position for alternate low pressure feedwater pump requirements (Reference 3.18).

Thus, the SG FLEX Pumps are capable of delivering 300 gpm at a discharge pressure equ.al to the specified steam generator injection pressure of 300 psig (at the SG feedring) in addition to all head losses (e.g., hoses, piping, connections, and elevation of the feed injectiori point) from the discharge of the SG FLEX Pump to the steam generator.

Throughout Phase 2, it is expected that either the TDAFW pump with suction from the CST, or the SG FLEX Pump, with suction from either the CSTs or the RMWST, will be in operation and aligned to discharge to the SGs. For injection using the SG FLEX Pump, the pump will be deployed at a location near the AFW pump house (see Figure 3).

The discharge of the SG FLEX Pump will be directed to all four steam generators via hose *and adapters connected to either of two injection points (primary and alternate) located in the AFW pump house. The two injection points are from diverse locations: one located in the Train C AFW Pump room on the TDAFW pump discharge header; the other located in the Train A AFW Pump room on the motor-driven AFW \

(MDAFW) pump discharge header cross-tie line (see Figure 1). The two rooms housing the connection points are accessed through grade level doors on opposite sides of the AFW Pump House (a Class I structure).

Page 17 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May2016 Units 1 and 2 Following depre~surization of the steam generators via the ARVs, these injection points are used as the alternate injection pathway for the SG FLEX Pump core cooling strategy. Each of the connections serves a discharge header that feeds all four SGs. When the injection point downstream of the TDAFW pump (primary) is used, symmetric cooldown of all four* SGs will be controlled by the associated dc-powered .MOVs. If the injection point downstream of the MDAFW pumps (alternate) is used, plant personnel will manually align the Train A and Train B ac-powered MOVs (located on Level A-outside of the Radiation Controlled Area-in the Auxiliary Building and Control Building, respectively) to control feedi~g all four SGs simultaneously effectively providing symmetric cool down of all four SGs.

Prior to depletion, the CSTs can be /provided makeup from the RMWST (primary) or one of the Nuclear Service Cooling Water (NSCW) basins (alternate) (see Figure 1). Both the RMWST and the NSCW

basins are protected (i.e., Seismic Category 1) sources of water. The preferred source of makeup for SG injection is the RMWST; this makeup will occur prior to exhausting the initial inventory.

of the CSTs. The RMWST also co*ntains de-mineralized water with a minimum inventory of 148,000 gallons (see Section 2.4.4.7) that is capable of providing at least 30 additional hours of makeup after depletion of the CSTs (see Table 3 and Reference 3.14).

Makeup from the RMWST requires the use of on-site equipment including a portable pump (Makeup FLEX Pump). The diesel driven Makeup FLEX Pump suction will be aligned to the RMWST via a connection located in the moat adjacent to the RMWST valve gallery (see Figure 1 and Figure 3). The isolation valve for this suction source is located in the RMWST valve gallery. The Makeup FLEX Pump discharges to either of the CSTs (two per unit) via diverse fill connection points and/or the cross-tie (see Figure 1). Hoses will be used for these supply and disct:iarge connections.

When the RMWST inventory is depleted as a CST makeup source, then the self-powered portable FLEX Submersible Pump will be used to supply makeup from one of the NSCW Basins. The discharge from the portable FLEX Submersible Pump will be connected by hose to any of the available CST fill connections. (See Figure 1 and Figure 3)

Page 18 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 RCS lnventorv and Reactivity Control No additional action is required for RCS inventory control during Phase

2. Wit.h the assumed RCS leakage (refer to Section 2.4.8) it is not anticipated that any additional makeup beyond the SI accumulator volume added in Phase 1 will be required to maintain RCS inventory until Phase 3.

The reactivity control evaluation for VEGP (Reference 3.19). indicates that it will be necessary to initiate supplemental boron injection (with letdown as necessary) to maintain sub-criticality margin. Therefore, following injection of the SI accumulators (at approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following shutdown) and prior to the peak reactivity addition resulting from xenon decay, a means for injecting additional borated water into the RCS as needed for reactivity control will be made available as discussed in the following paragraphs.

The addition of borated water is accomplished by a Boron Injection FLEX Pump. The Boron Injection FLEX Pump is deployed and available for operation approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months into the event. This pump will be powered by a 480V FLEX DG and is sized to provide sufficient borated water at the RCS injection point to meet the makeup needs associated with both primary inventory control and subcriticality requirements. Diverse connections (primary and alternate) for discharge of the Boron Injection FLEX Pump are located downstream of each RHR pump on the piping that discharges to the RCS cold legs (see Figure 1).

The BAST is the primary suction source for the Boron Injection FLEX Pump. The BAST has a usable capacity of 46,000 gallons (see Section 2.4.4.9). The Boron Injection FLEX Pump has a capacity of 20 gpm.

The RWST is also available as a* source of borated water for boron injection if needed. The RWST has a usable capacity of 686,000 gallons (see Section 2.4.4.8).

Depending on the source of borated water, venting of the RCS may be necessary. The RCS can be vented using 125V DC powered Reactor Head Vent valves operated from the MCR.

Sufficient shutdown margin is achieved in less than 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months using the BAST as RCS make~p source (Reference 3.20). The 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months includes a mixing* delay period of 60 minutes following the addition of

'the targeted quantity of boric acid to the reactor coolant system. The Page 19 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

-time sensitive action for reactivity control must be completed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event. The Vogtle strategy begins RCS injection at hour 12 at a rate of 10 gpm from the BAST. In addition, initiating RCS makeup flow prior to losing natural circulations prevents* reflux cooling from occurring. At this rate of injection the required amount of boric acid injected into the RCS will be completed by hour 22, which ensures sufficient time for complete mixing of injected borated water throughout the RCS. The Boron Injection FLEX Pumps are capable of delivering a flowrate of 20 gpm from the* BAST, however a 1O gpm flowrate is assumed based on the evaluations performed to support FLEX strategies (Reference 3.19).

With RCP shutdown seals, the injection of accumulator inventory, and injection of borated water to maintain sub-criticality, natural circulation in the RCS can be maintained for greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

2.4.3 Phase 3 Strategy Primary Strategy The primary coping strategy is to extend the Phase 2 strategy for reactor cooling to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and beyond with no immediate reliance on equipment from the NSRC until after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This requires long-term reliance on SGs for core cooling via the TDAFW or the SG FLEX Pump. Expected long-term plant conditions include:

Maintaining SGs at 120 psig, which is adequate to maintain TDAFW operation (Reference 3.23), and

Maintaining RCS cold leg temperature maintained at 350°F which is below the value for maintaining integrity of the RCP seals (Reference 3.18).

NSRC equipment is utilized to backup the Phase 2 equipment and to transition to Phase 3 coping. For example, for RCS injection beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , boron* mixing equipment (delivered from the NSRC) can *be employed to restore the RWST inventory (the RWST has the capacity to supply borated water to the RCS for 47 days after the BAST is depleted, see Table 3).

See Table 2 for a list of equipment that will be delivered to the site by the NSRC after notification by the plant; refer to Section 2.11 for a discussion on NSRC supplied equipment.

Page 20 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Since no time sensitive Phase 3 actions have been identified, instructions for connection and utilization of NSRC equipment for long term coping or recovery will be provided by TSC personnel who will have assessed the condition of the plant and infrastructure, plant*

accessibility, and additional available offsite resources (both equipment and personnel) following the BDBEE.

2.4.4 Systems, Structures, Components 2.4.4.1 Turbine Driven Auxiliary Feedwater (TDAFW) Pump The TDAFW pump is utilized to maintain the heatsink for decay heat removal following *an ELAP event, by supplying feedwater to all four SGs. The TDAFW pump is operated from the MCA if de power is available or it can be manually operated locally if de power is not available. DC power is maintained throughout the event, initially by the safety-related station batteries and subsequently by the battery chargers once the onsite 480V FLEX DG is operating, which ensures control power will be available for the TDAFW pump. Refer to VEGP FSAR (Reference 3.24) Section 10.4.9 for a description and discussion of capabilities of the TDAFW pump.

The TDAFW Pump Turbine and the TDAFW Pump are both Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Reference

3.24, Table 3.2.2-1, Section 3.5.1.4).

2.4.4.2 TDAFW Pump Discharge Isolation/Flow Control Valves The TDAFW pump discharge motor-operated isolation/flow control valves are used to modulate the auxiliary feedwater flow to maintain the required steam generator water level.

The valves can be controlled from either the MCA or local

panels. Additionally, the valves can be operated locally by the handwheel if de power is lost. DC power is maintained throughout the event, initially by the safety-related station batteries and subsequently by the battery chargers once the onsite 480V FLEX DG is operating, which ensures power will be available for the valves. Refer to VEGP FSAR (Reference 3.24) Section 10.4.9 for a description of the isolation/flow control valves.

Page 21 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 The TDAFW Pump discharge motor-operated isolation/flow control valves and their motors are both Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.5.1.4).

2.4.4.3 Main Steam Safety Valves (MSSVs)

During the initial stages of the event, heat generated by the reactor is dissipated by steam release by the spring-loaded MSSVs. Refer to VEGP FSAR (Reference 3.24) Section 10.3 for a description of the MSSVs.

The MSSVs are Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.5.1.4).

2.4.4.4 Atmospheric Relief Valves (ARVs)

During a BDBEE, the ARVs are manually operated locally to cooldown and depressurize the RCS to .c;illow SG makeup via the SG FLEX Pump and also to allow boration via the SI accumulators (not credited) and the Boron Injection FLEX Pump. Refer to VEGP FSAR (Reference 3.24) Section 10.3 for a description of the ARVs.

The ARVs are Seismic Category 1 components which are also *protected from the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.5.1.4).

2.4.4.5 Reactor Vessel Head Vent System (RVHVS)

A safety-grade letdown path is provided by the RVHVS. The RVHVS provides a head vent letdown path, if needed, to inject a sufficient volume of borated water. The RVHVS valves are DC powered solenoid valves and are operated manually from th~ Main Control Room. DC power is maintained throughout the event, initially by the safety-related station batteries and subsequently by the battery chargers once the onsite 480V FLEX DG is operating. Refer to VEGP FSAR (Reference 3.24) Section 5.4.15 for a description of the RVHVS.

Page 22 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 The RVHVS piping and valves are located in Containment are Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Reference 3.24, Section 3.5.1.4).

2.4.4.6 Condensate Storage Tank Suction to the TDAFW pump will be from the Seismic Category 1 CSTs, which are also protected from tornado missiles (Reference 3.12). Each unit has two (2) CSTs, each with a credited inventory equal to 340,000 gallons of de-mineralized water (Reference 3.13, Bases 3.7.6). Based on the minimum volume of water available, the credited volume in the CSTs can support core cooling and heat removal requirements in MODES 1 through 4 for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (see Table 3 and Reference 3.14). Refer to VEGP FSAR (Reference 3.24) Sections 3.8.4.1.8, 9.2.6.1.1.C, 9.2.6.3.2 and 10.4.9.2.2.4 for a description of the CSTs.

The Seismic Category 1 CSTs are designed to withstand the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.3.2). The CSTs are protected against externally generated missiles (Reference 3.24, Section 3.5.1.4 and Table 3.5.1-7).

2.4.4.7 Reactor Makeup Water Storage Tank (RMWST)

If the CSTs' initial inventories are depleted, the RMWST can supply makeup water to the CSTs via the diesel driven Makeup FLEX Pump. The RMWST can also be used as the alternate connection point for the SG FLEX pump. The RMWST contains de-mineralized water with a minimum inventory of 148,000 gallons (Reference 3.14). Refer to VEGP FSAR (Reference 3.24) Sections 9.2.7.2.2 and 9.2.7.3 for a description of the RMWST.

The Seismic Category 1 RMWST is designed to withstand the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Section 3.3.2). The RMWST is protected against externally generated missiles (Reference 3.24, Section 3.5.1.4 and Table 3.5.1-7).

Page 23 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.4.4.8 Refueling Water Storage Tank (RWST)

The borated water inventory in the RWST is available as a backup source for RCS injection during MODES 1 through 4 and MODE 5 with SGs available and as a backup source for SFP cooling (i.e., backup to CSTs, RMWST, and NSCW basins). During MODE 6 and MODE 5 without SGs available, makeup to the RCS from the RWST can be provided. The RWST contains a minimum of 686,000 gallons (Reference 3.13, Tech Specs and Bases SR 3.5.4.2). The boron concentration of the RWST is maintained ~ 2400 ppm and :5 2600 ppm (Reference 3.13, SR 3.5.4.3). Refer to VEGP FSAR (Reference 3.24) Section 6.2.2.2.2.3.1 for a description of the RWST.

The RWST is a Seismic Category 1 structure which is also.

designed to withstand the effects due to the design basis tornado (Reference 3.24, Table 3.2.2-1, Sections 3.3.2, 3.8.5.1.9). The RMWST is protected against externally generated missiles (Reference 3.24, Section 3.5.1.4 and Table 3.5.1-7).

2.4.4.9

Boric Acid Storage Tank (BAST)

The Boric Acid Storage Tank (BAST) is the primary source for boron addition using the portable Boron Injection FLEX Pump. The BAST has a usable capacity of 46,000 gallons (Reference 3.24, Table 9.3.4-2). The BAST has a minimum required volume of 36,674 gallons (Reference 3.25 TRS 13.1.7.4). Refer to VEGP FSAR (Reference 3.24) Section 9.3.4.1.2.5.12 for a description of the BAST.

The BAST is Seismic Category 1 (Reference 3.24, Table 3.2.2-1, Sections 3.3.2, Table 9.3.2-4). The BAST is protected against externally generated missiles by the Auxiliary Building (Reference 3.24, Section 3.5.1.4 and Table 3.5.1-7).

2.4.4.10 Nuclear Service Cooling Water (NSGW) Basin The NSCW basins can be used to provide makeup to the

CSTs. Additionally, the NSCW basins are the preferred source of makeup to the SFP during all MODES. The minimum capacity of each basin is 3.65 x 106 gal (30.1 x 106 Page 24 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 lbs) of water (Reference 3.24, Section 9.2.5.2.2). Refer to VEGP FSAR (Reference 3.24) Section 9.2.5 for a description of the NSCW basins.

The NSCW cooling towers are Seismic Category . 1 structures which are designed to withstand the effects due to the design basis tornado (Reference. 3.24, Table 3.2.2-1, Sections 3.3.2, 3.8.5.1.8). The NSCW basins are located below grade and protected against externally generated missiles (Reference 3.24, Sections 3.5.1.4, 9.2.5.2.3).

2.4.5 FLEX Connections 2.4.5.1 Primary SG FLEX Pump Discharge Connection The discharge of the SG FL.EX Pump can .be directed to all four steam generators via hose and adapters connected to the primary connection point in the Train C AFW Pump room on the TDAFW pump discharge header (see Figure 1) located in the AFW pump house. The AFW Pump House is a Seismic Category 1 structure.

2.4.5.2 Alternate SG FLEX Pump Discharge Connection .

In the event that the primary AFW Pump discharge .

connection is not available, an alternate connection location is provided. The alternate connection point is located in the Train A AFW Pump room on the motor-driven AFW (MDAFW) pump discharge header cross-tie line (see Figure 1). If the injection point downstream of the MDAFW pumps (alternate) is used, plant personnel will. manually align the Train A and Train B ac-powered MOVs *(located on Level .

A-.outside of the Radiation Controlled Area-in the Auxiliary Building and Control Building, respectively) to control feeding all four SGs simultaneously.

2.4.5.3 Primary SG FLEX Pump Suction Connection The primary suction connection point for the SG FLEX pump is located in the CST Vaive gallery on the TDAFW suction line from CST #1 (see Figure 1). The CST Valve gallery is a Seismic Category 1 Structure (Reference 3.24 Section 3.8.4.1.8 and Reference 3.12) ..

Page 25 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.4.5.4 Alternate SG FLEX Pump Suction Connection The alternate SG FLEX pump suction connection is the RMWST Suction connection. See section 2.4.5.8.

2.4.5.5 Primary CST Makeup Connection Each CST has a fill connection available to allow makeup to

.the CST's from any available source, including the RMWST and the NSCW basins. These fill connections are seismically qualified. (See Figure 1) 2.4.5.6 Alternate CST Makeup Connection In the event that both of the CST fill connections are not available, makeup to' the CSTs can be accomplished by connecting to either or both CST drain lines. ' The drains lines are seismically qualified. and are located at opposite ends of the CSTs. (See Figure 1) 2.4.5.7 Primary and Alternate RCS Connection Diverse connections (primary and alternate) for discharge of the Boron Injection FLEX Pump are located downstream of each RHR pump on the piping that discharges to the RCS cold legs. The connection points are located in the Auxiliary Building which is a Seismic Category 1 Structure. (See Figure 1) 2.4.5.8 RMWST Suction Connection The RMWST suction connection is the RMWST drain line located in the moat adjacent to the RMWST valve gallery.

The isolation valve for the drain line is located in the RMWST valve gallery. The drain line is seismically qualified.

(See Figure 1) 2.4.6 Key Reactor Parameters The instruments monitoring the listed parameters in Table 1 for reactor

core cooling and decay heat removal strategy remain available following specified load shed actions outlined in plant procedures.

Analysis (Reference 3.15) indicates this strategy provides a minimum of two channels of instrumentation for a minimum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while relying on the Station Batteries, which allows for the installation of the Page 26 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 480V FLEX DGs by 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after the start of the event. Only a single channel is needed for FLEX strategy implementation.

In addition, local indications such as CST tank level will remain available and the Key Reactor Parameters can be determined from a local reading using standard l&C instruments.

Table 1 Essential Monitored Parameters and Associated Instrumentation Parameter Available Channel Power Source I

SG-1 Pressure Pl-514A ' A-Train Battery Pl-515A B-Train Battery SG-2 Pressure Pl-524A A-Train Battery Pl-525A S:*Train Battery SG-3 Pressure Pl-534A A-Train Battery Pl-535A B-Train Battery SG-4 Pressure Pl-544A A-Train Battery Pl-545A B-Train Battery SG-1 Narrow Range Level Ll-551 A-Train Battery Ll-519 B-Train Battery SG-2 Narrow Range Level Ll-529 A-Train Battery Ll-552 B-Train Battery SG-3 Narrow Range Level Ll-539 A-Train Battery Ll-553 B-Train Battery SG-4 Narrow Range Level Ll-554 A-Train Battery Ll-549 B-Train Battery CST Level Ll-5100 N/A Ll-5115 TDAFW Pump Flow to SG-1 Fl-5152A A-Train Battery TDAFW Pump Flow to SG-2 Fl-5151A B-Train Battery TDAFW Pump Flow to SG-4 Fl-5150A A-Train Battery TDAFW Pump Flow to SG-3 Fl-5153A B-Train Battery RCS WR T-Cold Tl-413B LP1 CL B-Train Battery Tl-423B LP2 CL B-Train Battery Tl-433B LP3 CL B-Train Battery Tl-443B LP4 CL B-Train Battery Page 27 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 1 Essential Monitored Parameters and Associated Instrumentation Parameter Available Channel Power Source RCSWRT-Hot Tl-413A LP1 HL A-Train Battery Tl-423A LP2 HL A-Train Battery Tl-433A LP3 HL A-Train Battery Tl-443A LP4 HL A-Train Battery RCS Pressure Pl-405 LP4 HL WR A-Train Battery Pl-428 LP4 HL WR B-Train Battery Pl-438 lP1 HL WR A-Train Battery Pl-403 LP1 HL WR B-Train Battery Source & Intermediate Range N31/35 A-Train Battery Neutron Flux N32/36 B-Train Battery CETs Plant Safety Monitoring A-Train Battery System (PSMS) B-Train Battery RVLIS Plant Safety Monitoring A-Train Battery System (PSMS) B-Train Battery Contingencies for alternate instrumentation monitoring are provided to the control room team following a BDBEE via procedural guidance for establishing alternate indications for essential instrumentation.

Portable FLEX equipment is supplied with the, local instrumentation needed to operate the equipment. The use of these instruments is detailed in the operating procedures for each piece of FLEX equipment.

2.4.7 Thermal Hydraulic Analyses The FLEX strategies used to implement the coping capabilities are discussed in detail in the following sections. The strategies are based on the analysis presented in Calculation X4CPS0173, Required Makeup Flows and Water Availability for a Beyond Design Basis External Event at Vogtle Electric Generating Plant (Reference 3.14) and Evaluations to Support SNC FLEX Strategies for Vogtle Electric Generating Plant performed by Westinghouse (Reference 3.19).

These analyses demonstrate that the strategies provide the ability of Vogtle to successfully cope from the baseline conditions of the ELAP and LUHS resulting from a postulated BDBEE using diverse and redundant combinations of installed, and portable equipment. The Page 28 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 analyses also demonstrate that the overall coping capabilities provide sufficient margin during each of the coping durations described above so as to provide defense-in-depth against the many unknowns associated with BDBEEs. The coping strategy for each essential function is evaluated and described in detail in the following sections.

2.4.7.1 Secondary Analysis Immediately following the ELAP event, reactor core cooling (decay heat removal) will be accomplished by natural circulation of the RCS through the steam generators. The heatsink is maintained by operation of the TDAFW pump supplying feedwater to all four (4) steam generators.

Suction to the TDAFW pump will be from the Seismic Category 1 CSTs, which are also protected from tornado missiles (Reference 3.12). Each unit has two (2) CSTs, each with a credited inventory equal to 340,000 gallons of de-mineralized water (Reference 3.13, Bases 3.7.6). Based on the minimum volume of water available, the credited volume in the CSTs can support core cooling and heat removal requirements in MODES 1 through 4 for a minimum of 89 hours0.00103 days 0.0247 hours 1.471561e-4 weeks 3.38645e-5 months (see Table 3 and Reference 3.14).

When adequate steam pressure is no longer available to

drive the TDAFW pump's turbine, the alternate coping strategy for reactor core cooling requires depressurization of the steam_ generators and connecting a diesel driven SG FLEX Pump for injection of water into the steam generators.

Implementing this capability requires depressurizing

the .

steam generators. To complete this activity, operations personnel will be dispatched to the main steam valve rooms to manually reposition the ARVs and reduce pressure in the steam generators to approximately 300 psig. The normal supply for the SG FLEX Pump will be from the CSTs (primary) and the alternate suction source will be from the

- _RMWST (alternate). The RMWST contains de-mineralized water with a minimum inventory of 148,000 gallons (Reference 3.14) that is capable of providing at least 30 additional hours of makeup after depletion of the CSTs (see Table 3).

Page 29 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 If circumstances dictate the need for an additional SG makeup source, inventory in the NSCW basins will be available. Each NSCW basin contains a nominal inventory of 3,670,000 gallons of water (Reference 3.24, Section 3.8.4.1.7). The inventory located in one (1) NSCW basin provides a minimum of 728 hours0.00843 days 0.202 hours 0.0012 weeks 2.77004e-4 months (30 days) for SG injection after exhausting the CSTs and RMWST (see Table 3 and Reference 3.14) for core cooling. Since the NSCW basin is over 80 ft deep, a portable submersible pump (FLEX .

Submersible Pump) will be used to supply the inventory from the NSCW basin.

2.4.7.2 RCS Analysis The use of the new safe shutdown/low leakage seal design for the Reactor Coolant Pumps will delay the need for RCS makeup to prevent core uncovery to well beyond 7 days following an ELAP event (Reference 3.23). The coping strategy credits use of the Westinghouse SHIELD Passive Shutdown Seal as described in the vendor's technical report (Reference 3.27) subject to the. limitations and *conditions endorsed by the NRC (Reference 3.8). The Westinghouse RCS makeup evaluation for VEGP (Reference 3.19) demonstrates that RCS makeup at 10 gpm will be required at 46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months to maintain single phase RCS core cooling using the steam generators with no credit taken for boration. If credit is taken for two-phase RCS core cooling using the steam generators, RCS makeup would not be required until after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with no credit taken for boration. The Boron Injection FLEX pump will be available for RCS makeup as needed (but well in advance of 46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months ) with suction available from either the BAST or the RWST.

2.4.8 Recirculation Pump Seal Leakage The SHIELD low leakage seals are credited in the FLEX strategies in accordance with the four conditions identified in the NRC's endorsement letter from J. Davis, NRC, to J. A. Gresham, Westinghouse Electric Company, LLC, dated May 28, 2014 (Reference 3.8). That NRC letter endorsed Westinghouse Technical Report TR-FSE-14-1-P (Reference 3.27) and supplemental information provided by Westinghouse letters dated March 19, 2014, and April 22, 2014 Page 30 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 (References 3.28, 3.29). The May 28, 2014 NRC letter documented the staff's conclusion that the Westinghouse Technical Report and supplel'l)ental information is acceptable for use in ELAP evaluations for NRC Order EA-12-049 subject to four limitations and conditions. Each of these four limitations and conditions is restated below followed by a description of VEGP Unit 1 and Unit 2 compliance.

1) Credit for the SHIELD seals is only endorsed for Westinghouse RCP Models 93, 93A, and 93A-1. Additional information would be needed to justify use of SHIELD seals in other RCP models.

VEGP Unit .1 and 2 compliance: The VEGP Unit 1 and 2 RCPs are Model 93A-1. Therefore, VEGP Unit 1 and Unit 2 comply with this limitation/condition.

2) the maximum steady-state reactor coolant system (RCS) cold-leg temperature is limited to 571°F during the ELAP (i.e., the applicable main steam safety valve setpoints result in an RCS cold-leg temperature of 571°F or less after a brief post-trip transient). Nuclear power plants that predict higher cold-leg temperatures shall demonstrate the following:

a. The polymer ring and sleeve 0-ring remain at or below the temperature to which they have been tested, *as provided in TR-FSE-14-1-P, Revision 1; or,

b. The polymer ring and sleeve 0-ring 'shall be re-tested at the higher temperature.

VEGP Unit 1 and 2 compliance: The maximum steady-state RCP seal temperature during an ELAP response is expected to be the Tcold corresponding to the lowest SG safety relief valve setting of 1185 psig. This corresponds to a Tcold value of 567°F to 569°F. Therefore VEGP Unit 1 and 2 comply with this limitation/condition.

3) The maximum RCS pressure during the ELAP (notwithstanding the brief pressure transient directly following the reactor trip comparable to that predicted in the applicable analysis case from WCAP-17601-P) is as follows: For Westinghouse Models 93 and 93A-1 RCPs, RCSpressure is limited to 2250 psia; for Westinghouse Model 93A RCPs, RCS pressure is to

remain bounded by Figure 7. 1-2 of TR-FSE-14-1-P, Revision 1.

Page 31 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May2016 Units 1 and 2 VEGP Unit 1 and 2 compliance: Nominal Unit 1 and 2 operating pressure is 2250 psia. Therefore, VEGP Unit 1 and Unit 2 comply with this limitation/condition.

4) Nuclear power plants that credit the SHIELD seal in an ELAP analysis shall assume the normal seal leakage rate before SHIELD seal actuation, and a constant seal leakage rate of 1.0 gallon per minute for the leakage after SHIELD seal actuation.

VEGP Unit 1 and 2 compliance: A constant Westinghouse SHIELD RCP seal package leak rate of 1 gp_m per RCP was assumed in the applicable analysis, Westinghouse letter LTR-FSE-12-26, Rev. 2 (Reference 3.19). As stated in Westinghouse letter LTR-FSE-14-29, Rev 0 (Reference 3.30): "Although seal leakage may be higher than 1 gpm/pump before shutdown seal actuation, the total integrated inventory Joss expected during that time period is negligible when compared to the total RCS mass because the time period before actuation is on the order of 10 minutes compared to the 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months duration of the ELAP event." Therefore, VEGP Unit 1 and Unit 2 meet the intent of this limitation/condition,*

2.4.9 Shutdown Activity Analysis Vog~le will provide sufficient negative reactivity by injecting borated water into the RCS using the Boron Injection FLEX Pump to ensure that shutdown margin (1 %) is maintained following cooldown and xenon decay. To ensure adequate boric acid concentration is provided to the RCS, injection for reactivity control is provided at approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following the loss of power and a reactor trip from full power.*.

The primary borated water source for reactivity control in Phase 2 is the BAST. As an alternate, injection will be from the RWST. The analysis determined that subcriticality would be maintained from either source, however a head vent letdown path may need to be established to allow for injection if the source of the borated water is the RWST to accommodate the additional inventory due its lower concentration (See Section 2.4.4.5 for a description of the head vent letdown path).

Reference 3.19 shows that injection of approximately 5,000 gallons of borated water from the BAST (7000 ppm) or 13,800 gallons of borated water from the RWST (2400 ppm) will be adequate to meet shutdown reactivity requirements at limiting cycle conditions an.d the RCS average temperature as low as 425°F. Note that the BAST volume Page 32 of 93

FINAL 1NTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

\

required will provide adequate shutdown margin. No credit is taken for boron addition from the SI accumulators.

With a 10 gpm boron injection flowrate from the BAST, commencing makeup by 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months will provide adequate shutdown margin by the time at which xenon is no longer maintaining greater than 1000 pcm (1 % or Kett<0.99) shutdown margin (approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

Sufficient shutdown margin is achieved in less than 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months using the BAST as RCS makeup source (Reference 3.20). The Boron Injection FLEX Pumps are capable of delivering a flowrate of 20 gpm from the BAST, however a 10 gpm flowrate is assumed based on the evaluations performed to support FLEX strategies (Reference 3.19).

The 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months includes a mixing delay period of 60 minutes following the addition of the targeted quantity of boric acid to the reactor coolant system. The time sensitive action for reactivity control must be completed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event. The Vogtle strategy begins RCS injection at hour 12 at a rate of 10 gpm from the BAST. At this rate of injection the required amount of boric acid injected into the RCS will be completed by hour 22, which ensures sufficient time for complete mixing of injected borated water throµghout the RCS.

Therefore, Vogtle complies with the August 15, 2013 Westinghouse position paper on boric acid mixing~ including the conditions imposed in the NRC staff's corresponding endorsement letter (References 3.21 and 3.22).

2.4.10 FLEX Pumps and Water Supplies

2.4.10.1 SG FLEX Pumps Throughout Phase 2, it *is expected that either the TDAFW pump with suction from the CST, or the diesel driven SG FLEX Pump, with suction from either the CST , or the RMWST, will be in operation and aligned to discharge to the SGs (see Figure 1 and Figure 3). The diesel driven SG FLEX Pump is deployed and ready for operation at approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months into the event. The discharge of the SG FLEX Pump will be direCted to all four steam generators via hose and adapters connected to either of two injection points (primary and alternate) located in the AFW pump house (see Sections 2.4.5.1 and 2.4.5.2). The SG FLEX Pump is sized based on the decay heat removal Page 33 of 93

FINAL INTEGRATED PLAN Vogtle Electric. Generating Plant May 2016 Units 1 and 2 requirements at one hour after reactor shutdown. This

_ corresponds to a minimum flow rate of approximately 300 gpm at a discharge pressure sufficient to feed a SG at a pressure of 300 psig (Reference 3.31 ).

The bounding case used to size the SG FLEX pump is the SG FLEX pump taking suction from the RMWST. A minimum pump head of 864.0 ft is required to ensure a minimum flow rate of 300 gpm can be provided for Steam Generator injection when the SG FLEX pump is aligned to 1 .

the RMWST. At this flow rate, the minimum Net Positive Suction Head Available (NPSHa) is 24.6 ft which exceeds the. NPSH required (NPSHr) of 10 ft. At the minimum RMWST water level, the NPSHa is 17.5 ft at a flow rate of approximately 218 gpm which exceeds the NPSHr of 10 ft.

With the SG FLEX Pump suction aligned to the CST at minimum CST water level, the NPSHa is 19.8 ft at a flow rate of approximately 300 gpm which exceeds the NPSHr of 10 ft. (Reference 3.31) 2.4.10.2 Makeup FLEX Pumps Prior to depletion, makeup to the CSTs can be provided from the RMWST (primary) or one of the Nuclear Service Cooling Water (NSCW) basins (alternate). Makeup from the RMWST requires the use of on-site equipment including a portable pump (diesel driven Makeup FLEX Pump). The diesel driven Makeup FLEX Pump suction will be aligned to the RMWST via a connection located in the moat adjacent to the RMWST valve gallery. The diesel driven .Makeup FLEX Pump discharges to either of the CSTs (two per unit) via diverse fill connection points or the cross-tie which is connected to the CST drain lines. Hoses will be used for these supply and discharge connections. (See Figure 1 and Figure 3)

I A minimum pump head of 171.3 ft is required to ensure a minimum flow rate of 130 gpm can be provided for CST makeup at any RMWST water level, which is higher than the minimum required of 120 gpm (120 gpm exceeds the flowrate necessary to maintain CST at the time makeup would be required (References 3.14, 3.32)). At this flow rate, the minimum NPSHa is 15.7 ft (Reference 3.32) which Page 34 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 exceeds the NPSHr of 10 ft (Reference 3.33). With the diesel driven Makeup FLEX Pump taking suction from the RMWST, air entraining vortices are prevented from forming by the RMWST diaphragm, and the entire water volume in the RMWST is available for CST make-up. (Reference 3.32) 2.4.10.3 FLEX Submersible Pumps When the RMWST inventory is depleted as a CST makeup source, then the portable self-powered FLEX Submersible Pump will be used to supply makeup from one of the NSCW Basins. The discharge from the pump will be connected by hose to any of the available CST fill connections. (See Figure 1 and Figure 3)

A minimum pump head of 145.8 ft is required to ensure a minimum flow rate of 130 gpm can be provided for CST makeup at any NSCW water level which is higher than the minimum required of 120 gpm (120 gpm exceeds the flowrate necessary to maintain CST at the time makeup would be required (References 3.14, 3.34).

2.4.10.4 Boron Injection FLEX Pumps Evaluation for VEGP indicates that it will be necessary to initiate supplemental boron injection (with letdown as necessary) to maintain sub-criticality margin. The addition of borated water is accomplished by a Boron Injection FLEX Pump. This pump will be powered by a 480V FLEX DG and is sized to provide sufficient borated water at the RCS injection point to meet the makeup needs associated with both primary inventory control and subcriticality requirements. Diverse connections (primary and alternate) for discharge of the Boron Injection FLEX Pump are located downstream of each RHR pump on the piping that discharges to the RCS cold legs. The Boric Acid Storage Tank (BAST) is the primary suction source for the Boron Injection FLEX Pump. The RWST is also available as a source of borated water for boron injection if needed. (See Figure 1)

The limiting minimum pump head of 1213.9 ft is required to ensure a flow rate of 20 gpm can be provided for boron Page 35 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 injection with suction from the BAST or RWST for MODES 1-

4. At this flow rate, the minimum NPSHa is 25.5 ft (Reference 3.35) which exceeds the NPSHr of 14 ft (Reference 3.36).

2.4.10~5 AFW Water Supplies Condensate Storage Tanks The Seismic Category 1 CSTs, are also protected from tornado missiles (Reference 3.12). Each unit has two (2)

CSTs, each with a credited inventory equal to 340,000 gallons of de-mineralized water (Reference 3.13, Bases 3.7.6). Based on the minimum volume of water available, the credited volume in the CSTs can support core cooling and

.heat removal requirements in MODES 1 through 4 for a minimum of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (see Table 3 and Reference 3.14).

Reactor Makeup Water Storage Tank The RMWST is a Seismic Category 1 source of water. The preferred source of makeup to the CSTs for SG injection prior to exhausting the inventory of the CSTs _is the RMWST.

The RMWST contains de-mineralized water with a minimum inventory of 148,000 gallons that is capable of providing at least 30 additional hours of makeup after depletion of the initial inventory of the *csTs (see Table 3 and Reference 3.14).

Nuclear Service Cooling Water Basins If circumstances dictate the need for an alternative SG makeup source, inventory in the NSCW basins will be available. Each NSCW basin contains a nominal inventory of 3,670,000 gallons of water (Reference 3.24, Section

3.8.4.1.7). The NSCW basins are concrete structures, deeply embedded, and are identical. The water inventory is located within the. basin, which is a large cylindrical shell that extends 81 ft below the grade elevation. The Technical Specifications (Reference 3.13, SR 3.7.9.1) require a minimum inventory of at least 80.25 ft of water. The inventory located in one (1) NSCW basin provides a minimum of 728 hours0.00843 days 0.202 hours 0.0012 weeks 2.77004e-4 months (30 days) for SG injection after Page 36 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 exhausting the CSTs and RMWST for core cooling (see Table 3). Since the N~CW basin is over 80 ft deep, the portable FLEX Submersible Pump will be used to supply the inventory from the NSCW basin.

Savannah River The ultimate source of water for VEGP is the Savannah River, which is located approximately 3,600 ft from the Unit 1 reactor and 3,900 ft from the Unit 2 reactor (Reference 3.37).

When supplemented by portable equipment delivered from off-site, water from the Savannah River can be used to replace depleted on-site Seismic 9ategory 1 water inventories. See Table 2 for a list of equipment that will be delivered to the site by the NSRC after notification by the plant; refer to Section 2.11 for. a discussion on NSRC supplied equipment. In addition, the plant is on high ground with entrance to the power block structures at grade El 220 ft, approximately 140 ft above the minimum Savannah River level (Reference 3.38).

2.4.10.6 Borated Water Supplies Boric Acid Storage Tank

The B.oric Acid Storage Tank (BAST) is the primary source for supplemental boron addition. The BAST has a minimum required volume of 36,674 gallons (Reference 3.25 TRS 13.1.7.4) providing shutdown margin necessary to maintain the core in a subcritical state.

RWST The borated water inventory in the RWST will remain

available (Technical Specifications minimum of 686,000 gallons) as a backup source for RCS injection. This availability is* due to the preferred use of other sources of water* inventory (BAST, CSTs, RMWST, and NSCW basins) during Phases 1 and 2 for core reactivity and SFP cooling strategies.

Page 37 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.5 Spent Fuel Pool Cooling/Inventory In an ELAP event, the SFPs will initially heat up due to the unavailability of the normal cooling system. Unit 1 SFP heat loads and temperatures are bounded by Unit 2 values due to the larger capacity for fuel assembly storage in the Unit 2 SFP. The basic FLEX strategy for maintaining SFP cooling is to monitor SFP level utilizing the SFP level instrumentation and initiating SFP makeup as soon as resources are available but prior to adequate shielding being lost. Deployment of hoses and equipment inside the Fuel Handling Building (FHB) will t;>egin no later than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months prior to the SFP reaching 200°F. The Control Room Staff maintains the time to 200°F at all times.

Gravity feed to the SFPs from the RWST in MODES 1-5 will be available and can be established immediately following an ELAP event using existing plant procedures (see Figure 1). The makeup flow rate using the RWST will be approximately 75 gpm if the RWST is near its Technical Specifications minimum volume of 686,000 gallons (Reference 3.13, SR 3.5.4.2). In MODE 6, gravity feed may not be available if the contents of the RWST have been transferred to the Refueling Cavity. As such, the RWST isn't credited for SFP makeup during Phase 1 during MODE 6 but is included as an option in plant procedures.

For Phase 2, the FLEX Submersible Pump drawing water from the NSCW basins will be aligned and used to add water to the SFPs of both units to maintain level. Three paths will be available for SFP makeup; via hoses directly discharging into the pools; via connections to the existing SFP makeup lines; or via hoses directed to portable spray monitors positioned around the SFPs (see Figure 1). Deployment of hoses inside the FHB will begin no later than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months prior to the SFP reaching 200°F. This will maintain a sufficient amount of water above the top of the fuel assemblies for cooling and shielding purposes. The long term strategy for SFP cooling is to continue the strategies described abov~. When supplemented by portable equipment delivered from off-site (NSRC), water from the Savannah River can be used to replace depleted on-site Seismic Category 1 water inventories. However, the associated actions for the long term strategy are not relied upon in the FLEX strategy during the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following ELAP.

2.5.1 Phase 1 Strategy No specific operator actions are required in Phase 1.

Requirements for SFP makeup (which are not required by the strategy until SFP water level reaches 15 feet above the top of the spent fuel Page 38 of 93

FINAL INTEGRATED PLAN . Vogtle Electric Generating Plant May 2016 Units 1 and 2 racks) are based on the design basis heat loads applicable to specific operating MODES as described below.

MODES 1 through 5 For an ELAP event initiated during MODES 1-5, the SFP makeup flow rate is based on the maximum normal design basis heat load limit for power operation immediately following startup from a refueling outage.

On a loss of cooling, water in the SFP (normally less than 100°F) would reach 212°F in 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months . Without makeup, the time to reach 15 feet above the top of irradiated fuel is greater than 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months . Total required flow to make up for losses due to boil off is less than 62 gpm per pool (Reference 3.14).

MODE6 For an ELAP event initiated during MODE 6, the SFP makeup flow rate is based on the SFP cooling system design basis heat load for the emergency condition in which all fuel has been transferred from the reactor to the SFP shortly after shutdown (i.e., full-core offload). The time to 212°F is approximately 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . Without makeup, time to reach 15 feet above the top of irradiated fuel is approximately 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months . Total required flow to make up for boil off is less than 125 gpm per pool (Reference 3.14).

2.5.2 Phase 2 Strategy This spray capability flow rate is bounding for all SFP cooling baseline capabilities (i.e., the three methods described below). Based on needs identified for Phase 2, makeup or spray may be chosen by alignment of the appropriate hose to the discharge of a pump capable of providing the minimum flow rate with enough discharge pressure to provide the appropriate spray pressure from the monitor nozzles and to overcome head losses associated with discharge hoses and any other discharge connections. Since the SFP is designed so that it does not require borated water to maintain subcritical conditions, the NSCW basins are the credited sources of makeup in this scenario. The RMWST and the CSTs are available as backup sources. The inventory of each NSCW basin (approximately 3,600,000 gallons based on the Technical Specifications minimu_m level of 80.25" ft, Reference 3.13 SR

3. 7 .9.1) is .capable of providing spray for both SFPs (500 gpm total flow) for approximately 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months (Reference 3.43). Since the NSCW basin is over 80 ft deep, the FLEX Submersible Pump will be used to Page 39 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 provide the required lift so the inventory from the NSCW basin may be accessed. Separate sets of hoses and the necessary makeup equipment (tools, spray monitor nozzles, wyes, etc.) for hose spray and makeup will be stored in both the SFP area and in the FLEX Storage Building. (See Figure 1 and Figure 3)

Prior to the spent fuel pool reaching 200°F, staging hoses for makeup inside the FHB will be accomplished. Hoses outside the FHB will be staged prior to makeup being required. This strategy consists of installing hoses for makeup and spray on each unit. A manifold is provided to connect three hoses: one that discharges directly into the SFP (Method 1), one that can provide makeup to the SFP from the Reactor Makeup Water (RMW) system that does not require access to the SFP (Method 2), and one that can supply the monitor spray nozzles (Metllod 3).

Makeup Strategv Method 1 - Spent Fuel Pool makeup via hoses directly into the spent fuel pool Direct makeup to the SFP will be accomplished by hoses staged on the refuel floor. This makeup strategy employs hoses for each SFP.

Since the SFP area (Level 1 of the Fuel

Handling and Auxiliary Buildings) may become inaccessible as Phase 2 progresses, hoses inside the FHB will be deployed prior to the SFP reaching 200°F to minimize the need for personnel access to the SFP area following degraded environmental conditions in the SFP area following the ELAP event.

Makeup Strategy Method 2 - Spent Fuel Pool makeup via a connection to SFP cooling piping An adapter will be used for connecting to an existing valve located on the SFP makeup line from the RMW system (see Figure 1). The isolation valves for makeup are located in the Auxiliary Building (a Seismic Category 1 structure) with accessibility from the yard (i.e.,

personnel access to the SFP area will nc:>t be required). This injection source requires operator action to isolate other valves (all located in the Auxiliary Building) in the RMW system and other interfacing systems.

Page 40 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Makeup Strategy Method 3 - spray capability via portable monitor nozzles To assure spent fuel cooling in the event that methods described above prove insufficient, spray capability with portable monitor nozzles from the refueling floor will be provided. The monitor nozzles are deployed prior to the SFP reaching 200°F to minimize the need for personnel access to the SFP area following degraded environmental conditions in the SFP area following the ELAP event. The spray strategy consists of deploying a hose to a pre-determined location in the SFP area, splitting flow into two separate hoses for each SFP which connect to spray monitors located in the two most accessible corners of each SFP (see Figure 1).

2.5.3 Phase 3 Strategy The long-term strategy for SFP cooling is to continue the Phase 2 strategy. When supplemented by portable equipment delivered from off-site, water from the Savannah River can be used to replace depleted on-site Seismic Category 1 water inventories. See Table 2 for a list of equipment that will be delivered to the site by the NSRC after notification by the plant; refer to Section 2.11 for a discussion on NSRC supplied equipment.

As resources become available, actions can be taken to transition away from extended Phase 2 coping strategies. Since no time sensitive Phase 3 actions have been identified, instructions for connection and utilization of NSRC equipment for long term coping or recovery will be provided by TSC personnel who will have assessed the condition of the plant and infrastructure, plant accessibility, and additional available offsite resources (both equipment and personnel) following the BDBEE.

2.5.4 Structures, Systems, and Components 2.5.4.1 Primary Connection Makeup Strategy Method 1 (Hose)

Direct makeup from the FLEX Submersible Pump in the NSCW basin to the SFP will be accomplished by hoses staged on the refuel floor. Therefore, there are no connections associated with the Method 1 strategy; all Page 41 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units. 1 and 2 equipment is portable and does not require any physical connections to permanent plant equipment. (See Figure 1)

Makeup Strategy Method 2 (SFP cooling piping)

An adapter will be used for connection to an existing valve located on the SFP makeup line from the RMW system. The isolation valve is 1-1228-U4-039 for Unit 1 and 2-1228-U4-039 for Unit 2 (References 3.42 and 3.44). These valves are located in the Auxiliary Building (a Seismic Category 1 structure) with accessibility from the yard (i.e., personnel access to the SFP area is not required). (See Figure 1)

Makeup Strategy Method 3 (Spray)

Direct makeup from the FLEX Submersible Pump in the NSCW basin to the SFP will be accomplished by hoses staged on the refuel floor. All equipment is portable and does not require any *physical connections to permanent plant equipment . Therefore, there are no connections associated with the Method 3 strategy. (See Figure 1) 2.5.4.2 Alternate Connection As an alternate to the NSCW basins as a source of makeup to the SFP, the RMWST, RWST and the CSTs are*available.

Due to the diverse makeup methods available, alternate connections in addition to those described in the Primary Connections are not required.

2.5.4.3 Ventilation SFP bulk boiling will create adverse temperature, humidity, and condensation conditions in the SFP area which requires a ventilation vent pathway to exhaust the humid atmosphere from SFP area. The primary pathway will be established by manually opening the personnel door on the south wall of the Auxiliary Building. An alternate ventilation path can be established by opening doors that allow steam to escape through the hot machine shop and adjacent corridor and passage to outdoors. Either vent path will be sufficient for the initial coping efforts due to the relatively large openings provided. Establishing the vent path will occur no later than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months prior to boiling in the SFP.

Page 42 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

2.5.5 Key Reactor Parameters The key parameter for the SFP make-up strategy is the SFP water level. The SFP water level is monitored by the instrumentation that was installed in response to Order EA-12-051, Reliable Spent Fuel Pool level Instrumentation (Reference 3.5).

2.5.6 Thermal-Hydraulic Analyses An analysis* was performed that determined with the maximum expected SFP heat load immediately following a full-core offload, the SFP will reach a bulk boiling temperature of 212°F in approximately 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and boil off to a level 15 feet above the top of fuel in 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months unless additional water is* supplied to the SFP. Total required flow for the most limiting case (full-core offload) to make up for boil off is less than 125 gpm per pool (Reference 3.14) ..

2.5.7 FLEX Pump and Water Supplies 2.5.7.1 FLEX Submersible Pump Makeup to the SFP is supplied by either gravity feed from the RWST or from the NSCW basin using the portable self-powered FLEX Submersible Pump. Since the NSCW basin *

. is over 80 ft deep, the self-powered FLEX Submersible Pump will . be used to provide the required lift so the inventory from the NSCW basin may be accessed. The pump is sized to provide required flow* and pressure for all three makeup strategies . discussed in section 2.5.2.

(Reference 3.43) 2.5.7.2 Ultimate Heat Sink The inventory of each NSCW basin .(minimum of 3,600,000 gallons based on Technical Specifications minimum level) is capable of providing spray for both SFPs (500 gpm total flow) for approximately 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months (Reference 3.43) 2.5.8 Electrical Analysis The ~FP level will be monitored by instrumentation installed by Order EA-12-051 . The power for this equipment has a backup battery; a minimum battery life of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is provided to allow for power restoration from the 480V FLEX DG. (References 3.45, 3.46)

Page 43 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.6 Containment Integrity MODES 1-4 and MODE 5 with Steam Generators Available Vogtle has a large dry containment building. During a BDBEE, containment integrity is maintained by normal design features of the containment. Vogtle utilizes low-leakage seals on the reactor coolant pumps. Utilizing the low leakage seals will limit the leakage inside the containment, resulting in containment pressure and temperature remaining within design limit without active containment cooling until well beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; at which time availability of the NSRC equipment will allow implementation of long-term strategies to control containment pressure and temperature.

2.6.1 Phase I Following a BDBEE event, with the reactor tripped and containment isolated, containment pressure and temperature will slowly increase due to reactor coolant leakage and direct heat transfer from the RCS.

Analysis (Reference 3.47) demonstrates that containment response following a postulated ELAP event does not challenge containment design limits. As a result, no coping strategy is required for maintaining containment integrity during Phase 1 beyond monitoring containment pressure.

2.6.2 Phase 2 Phase 2 coping strategies remain the same as Phase 1. No additional strategies are required for maintaining containment integrity. In Phase 2, the onsite 480V FLEX DG will be employed to charge sfation batteries which will maintain DC bus voltage for continued availability of instrumentation needed to monitor containment pressure.

2.6.3 Phase 3 Calculations (Reference 3.47) determined that the MODES 1-4 containment pressure at 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months is 5.7 psig and the peak containment temperature at 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months is 213.2°F. It is expected that containment temperature and pressure will remain below the design basis limits beyond 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months , because of the significant margin to the design basis limits. Since the containment design limits are not exceeded, then the equipment in containment is expected to remain operable. Containment coolers, when supplemented by portable equipment delivered from off-site, can be aligned to maintain containment integrity. See Table 2 for a list of equipment that will be Page 44 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 . Units 1 and 2 delivered to the site by the NSRC after notification by the plant; refer to Section 2.11 for a discussion on NSRC supplied equipment.

As resources become available, actions can be taken to transition away from extended Phase 2 coping strategies. Since no time sensitive Phase 3 actions have been identified, instructions for connection and utilization of NSRC equipment for long term coping or ,

recovery will be provided by TSC personnel, who will have assessed the condition of the plant and infrastructure, plant accessibility, and additional available offsite resources (both equipment and personnel) following the BDBEE.

2.6.4 Structures, Systems, Components 2.6.4.1 Containment During the BDBEE which results in an ELAP and LUHS, containment integrity is maintained by normal design features of the containment. The containment design pressure is +52 psig/-3 psig and the containment atmospheric design temperature is 381°F (Reference 3.24, Table 6.2.1-1). Refer to VEGP FSAR (Reference 3.~4)

Section 6.2.1 for a description and discussion of design capabilities of the containment.

2.6.4.2 Containment Coolers No time sensitive actions have been identified for maintaining containment integrity; however, containment coolers, when supplemented by portable equipment (i.e.,

pumps for cooling water and 4kV generator for powering the fans) delivered from off-site (NSRC), can be aligned to maintain containment integrity long term. Refer to VEGP FSAR (Reference 3.24) Section 6.2.2 for a description and discussion of design capabilities of the containment coo_lers.

The Containment Coolers are Seismic Category 1 components which are also protected from the effects due to the design basis tornado (Re!erence 3.24, Table 3.2.2-1, Section 3.5.1.4).

Page 45 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.6.5 Key Containment Parameters The instruments monitoring containment pressure remain available following specified load shed actions outlined in plant procedures.

Analysis ,(Reference 3.15) indicates this strategy provides a minimum of two channels of instrumentation for a minimum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from Station batteries, which allows for the installation of the 480V FLEX DGs by 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after the start of the event. Only a single channel is needed for FLEX strategy.

The containment pressure instrumentation credited in the strategy are:

CTMT Pressure Pl-937 A-Train Battery Pl-936 B-Train Battery Contingencies for alternate instrumentation monitoring are provided to the control roo'!l team following a BDBEE. Procedural guidance is provided for establishing alternate indications for essential instrumentation.

2.6.6 Thermal-Hydraulic Analyses Analysis (Reference 3.47) demonstrates that containment response following a postulated ELAP event does not challenge design limits until well after availability of off-site equipment and implementation of strategie_s to control pressure and temperature. Two methodologies were used in the analysis. _The first is use of the Modular Accident Analysis Program (MAAP) PWR Version 4.0.5 analysis software for the containment analysis (Reference 3.78). The MAAP PWR Version 4.0.5 analysis software was employed to analyze the specified FLEX scenarios during a LUHS and ELAP. MAAP4 is an EPRI sponsored computer code that simulates the response of light water nuclear power plants during severe accident sequences, including actions taken as part of the severe accidents. MAAP4 can predict the progression of hypothetical accident sequences from a set of initiating events to either a safe, stable, coolable state or to an impaired containment and depressurization. The guidance provided in the position paper entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (R~ference 3.48) as endorsed by the NRC (Reference 3.49) was used to support the performance of ELAP containment analyses. The second was the use of the modified Darcy equation for compressible flow to determine the Page 46 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 pressu-re drop in the containment vent line for MODES 5 & 6 with SGs not Available.

2.6.7 FLEX Pump and Water Supplies No FLEX pump or water supplies are credited for containment integrity coping strategies.

2.6.8 Electrical Analysis Power requirements for the containment critical instrumentation is provided by the station batteries. 480V FLEX portable DGs are used to repower station battery chargers and to repower ac powered instrumentation. See additional discussion in Section 2.3.2.

2. 7 Characterization of External Hazards In accordance with NEI 12-06 sections 4 through 9, the applicable extreme external hazards at Vogtle Unit 1 and 2 are seismic, high wind, extreme _cold with ice and high temperature.

2.7.1 Seismic Per the Vogtle Unit 1 and 2 Final Safety Analysis Report (FSAR), the seismic criteria for VEGP include two design basis earthquake spectra:

Operating Basis Earthquake (OBE) and the Safe Shutdown Earthquake (SSE). The OBE and the SSE are 0.12g and 0.20g, respectively; these val_ues constitute the design basis of VEGP (Reference 3.24 Sections 2.5.2.7 and 2.5.2.6).

For Diverse and Flexible Coping Strategies (FLEX), the earthquake is assumed to occur without warning and result in damage to non-seismically designed structures and equipment. A debris assessment for the site was performed, including debris generated by seismic events, to determine debris removal tool requirements; see Section 2.9.1 for a discussion of debris removal capability.

2.7.2 External Flooding Vogtle is built above the design basis flood level. The_ limiting design basis flood causing mechanism for Plant Vogtle is dam failures. As stated in the Vogtle Updated Final Safety Analysis Report (UFSAR)

Chapter 2 (Section 2.4.2), the flood elevation for dam failures is 168 ft msl while the elevation of the VEGP control building, containment buildings, diesel generator buildings, and all safety-related structures is approximately 220 ft msl.

Page 47 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Contours and grading in the Units 3 and 4 construction area are controlled to prevent impact on flooding analysis. The site is not adjacent to a large, enclosed, or partially enclosed body of water (Reference 3.24, Chapter 2). In accordance with NEI 12-06 (Section 6.2.1) Vogtle is considered a dry site and would not be adversely affected by external flooding (Reference 3.3).

2.7.3 Severe Storms with High Wind Current plant design bases address the storm hazards of hurricanes, high winds and tornados.

VEGP is located at approximately 33°09' N latitude and 81°46' W longitude (Reference 3.24, Section 2.1.1.1 ). The location of Vogtle is situated between the 160 mph and 170 mph contours shown in Figure 7-1 of NEI 12-06 (Reference 3.3); therefore hurricanes are applicable to Vogtle. Per Figure 7-2 of NEI 12-06, the recommended tornado design wind speed for the 10-6/yr probability level for the 2 latitude/longitude block where Vogtle is located is 172 mph. Therefore, tornado hazards are applicable to Vogtle.

For hurricanes, the VEGP UFSAR (Reference 3.24, Section 2.3.1.2.5) indicates that the site is located approximately 100 miles inland from the Atlantic coast; . so the effects from hurricanes or tropical depressions are considerably diminished.

The design basis tornado has a probability of occurrence of about 10-7

per year. For the site region, the 10-7 probable tornado would have a maximum wind speed of about 360 mph, which is considered 290 mph rotational and 70 mph translational (Regulatory Guide 1.76, 1974, Reference 3.51). Safety-related systems and components are protected by missile barriers.

Protection of FLEX equipment is ensured by ensuring that the characteristics of the storage locations meet the requirements in NEI 12-06. At Vogtle the storage location is in the Owner Controlled Area (OCA). By providing a storage building designed to withstand hurricane and tornado high wind hazards, sufficient FLEX equipment to supply both units will be protected from all high wind hazards including high wind missiles.

FLEX equipment will remain deployable for high wind hazards such as a tornado or hurricane. Potentially downed trees and flooded roads Page 48 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 will have an impact on the time it takes to deploy FLEX equipment.

Debris removal capabilities are provided for by the onsite FLEX equipment (e.g., wheeled loader). The tow vehicles for the FLEX equipment* are also stored in the FLEX Storage Building; see Section 2.9.1 for additional discussion of debris removal capability.

2. 7.4 Ice. Snow and Extreme Cold Per NEI 12-06 Section 8.2.1 guidance, extreme snowfall is not a concern for VEGP which is located in the southeastern U.S. Snow is infrequent In the site region and heavy snow is very rare. The highest 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months snowfall on* record was i 3.7 inches in February. of 1973 (Reference 3.24, Section 2.3.1.2.3). The average annual snowfall is only about 1 inch and the maximum probable winter precipitation is 19 inches over a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period. Thus, even iii the unlikely scenario of an ELAP coincident with a maximum probable snowfall, snow .removal could be easily accomplished with the normal debris removal equipment (e.g., wheeled loader).

'The Vogtle site is located within the region characterized by EPRI as ice severity level 5 (NEI 12-06, Figure 8-2, Reference 3.3). As such, the Vogtle site is subject to severe ic;:ing conditions that could also cause catastrophic destruction to electrical transmission lines .. While freezing .rain resulting in heavy ice loading in the Vogtle site region is considered rare (Reference 3.24, Section 2.3.1.2.4), NEI guidelines.

still dictate that the storage and deployment of Vogtle FLEX equipment must consider the impact of severe icing due to the EPRI study. Thus, the storage of FLEX equipment, including transport equipment, has been designed to protect it from extreme weather. The design criteria

for the storage buildings meet the site design basis weather effect$ in accordance with the requirements of ASCE 7-10, Minimum Design Loads for Buildings and Other Structures. Debris removal equipment is stored in the FLEX Storage Building; see Section 2.9.1 for additional discussion of debris removal capability. Because advance warning of freezing weather would be available, actions can be taken in advance to prepare for adverse conditions. (including personnel actions).

The normal daily minimum temperature ranges from 34°F in December and January to 70°F in July (Reference 3.24, Section 2.3.2.1.2). An extreme minimum temperature of 3°F was recorded in February 1899.

Based on historical records, the temperature. remains below freezing all day on the average of only 1 day each January. About one-half of Page 49 of e3

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 the days in December, January, and. February have minimum temperatures below freezing.

Icing does not occur on the lower reaches of the Savannah River based on records of minimum temperature from 1961 to 1980 (Reference 3.24, Section 2.4.7) Therefore, there is no risk of ice blockage of the Savannah River, frazil ice, or freezing of the below-grade UHS water source in the NSCW basins.

The storage of FLEX equipment considers the minimum temperature specified by the manufacturers. The FLEX pumps and generators have additional operating requirements when temperatures fall below 32°F. Freeze protection of idle but primed portable pumps and hoses considers the possibiiity of freezing when conditions warrant action. It should not be necessary to thaw the relatively short connections at the outdoor water tanks due to the large thermal mass of water .in the tank.

2.7.5 High Temperatures The Vogtle site normal daily maximum temperature ranges from 58°F in January to 91°F in July. An extreme maximum of 106°F was recorded in July 1952.- Based on a 14-year record, the average number of days in a year on which temperatures of 90°F and above occur is 62, ranging *to approximately two-thirds of the days in July (Reference 3.24, Section 2.3.2.1.2).

The FLEX pumps can operate in hot weather well in excess of 100°F.

Similarly, the 480V FLEX portable DGs can operate in ambient air up to 113°F based on information from the equipment vendor. The FLEX Storage Building is ventilated to maintain equipment functional. Active cooling systems are not required as normal room ventilation will be utilized.

Extreme high temperatures are not expected to impact the ability of personnel to implement the required FLEX strategies. Site industrial safety procedures currently address activities with a potential for heat stress to prevent adverse impacts on personnel.

2.8 Protection of FLEX Equipment 2

FLEX equipment is stored in a single 12,000 ft concrete, tornado-missile protected structure that meets the plant's design basis for the Safe Shutdown 2

Earthquake (SSE) (Reference 3.52). Additionally, it has a 5,200 ft (4750 ft 2 usable) mezzanine which is seismically robust (Reference 3.53). The VEGP Page 50 of 93 .

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 FLEX Storage Building is located outside of the Protected Area but within the Owner Controlled Area (see Figure 3). This location is significantly above the upper-bound flood stage elevation. The FLEX Storage Building was designed and constructed to prevent water intrusion and built to protect the equipment from other hazards identified in Section 2.7.

Large portable FLEX equipment such as pumps and power supplies are secured, as required, inside the FLEX Storage Building to protect them during a seismic event. The FLEX Storage Building has tie downs integrated into the floor slab for this purpose. These tie downs are used to secure any equipment that is not considered stable to ensure the stored FLEX equipment remains protected from damage during a seismic event. Additionally, fire pipin~ and HVAC were designed and installed to meet the FLEX Storage Building specifications (seismic, wind, etc.). The lighting, conduits, electrical, and fire detection components were not seismically installed because they are considered insignificant and not able to damage FLEX equipment and only required functional before the event.

Debris removal equipment is also stored inside the FLEX Storage Building in order to reasonably protect it from the applicable external events such that the equipment remains functional and deployable to clear obstructions f~om the pathway between the FLEX equipment's storage location and its

deployment location(s). See Section 2.9.1 for additional discussion of debris removal capability.

Deployments of the FLEX and debris removal equipment from the FLEX Storage Building are not dependent on off-site power.

The logistics of equipment removal for maintenance and after a BDBEE was considered in the design of the building. Two tornado missile-resistant equipment doors are provided and located 180° around the perimeter of the building from each other. The door opening size provides a minimum clearance for equipment of 14 ft in height and 16 ft in width. The design also includes two personnel entry/exit doors. The tornado-resistant doors are designed to resist, and be operational during and after tornado wind pressure loads and tornado-missile loads. All tornado missile-resistant equipment access and personnel access doors have the ability to be operated manually in the case of a loss of power. The HVAC systems are designed to maintain the following indoor conditions: Heating: minimum indoor temperature of 50°F; Cooling: maximum indoor temperature of 100°F.

Page 51 of 93

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Figure 1 - Flow Diagram for FLEX Strategies Page 52 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 r~~;i~~l,_~r _-_- _-_ -_-_-_-_-_- _-_-_-_- _-_-

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..cR LIGHTllC I CNJT£ DJ INFORMATION 1.0 Figure 2 - Electrical Diagram for FLEX Strategies Page 53 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 FLEX EQU IPMENT STAGING AREAS:

A -SC Fl.EX PUM P S (ONE PER UNIT)

B - FLEX SUBM ER SIBLE P UMP HYDRAULIC UNIT (200" CAPACITY)

C -MAKEUP FLEX: PUt.ilPS (ONE PER UNIT; ALT F OR MODE 5 SFP MAKEUP) 0 - Fl.EX SUBMERS IBLE P U MPS (ONE PER UNI ....; RE- LOCATE AS BASINS DEP LETE)

E - 480V FLEX DIESEL GENERATOR (ONE PER UNIT)

F -NSRC PUMPS (ONE PER UN IT)

A UX.

TURBINE BUILDING

~

~ M AINTENANCE BLD G.

G -NSRC 4160 VO L T GEN !:RATORS (ON~ P !:R UN IT)

H -NSRC MOBILE BORATION SKID (ONE PER UNIT)

FEEOWATER t -Fl.EX FUEL TANKER (ON E SERVES BOTH U NITS ;

PU MPH OUSE RE - L OCATE AS DIESEL F UEL OIL STORAGE TANKS DEPLETE)

J -NSRC WATER TREATM ENT SKID (ONE PER UN l n CON TROL BU ILD ING FU E L HANDLING BU ILD ING AUX. BUILDING M A I NTENANCE SH OP WAREHOUSE BLDG F IELO SUPPORT BLOC FLEX STORAGE FACILITY LEGENP*

(prl) PRIMARY DEPLOYM EN T LOCATIONS CAN BE AD JUSTED WITHIN LI MI TA TIONS (cit) A L TERN A TE / OPTION GIVEN IN F LEX PORTABLE SYSTEMS DOCU M ENTS AS DETERMIN ED Fl.£)( EQU IPM ENT H AU L ROUTES BY FIELD.

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~~ '""""'1~;£:Ult l . "'1"£11 l ~~;r!Ull.T Figure 3 - VEGP Overall Site Plan Page 54 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.9 Deployment of FLEX Equipment 2.9.1 Haul Paths and Accessibility Multiple haul routes will be available from the FLEX Storage Building to any staging area. The appropriate haul routes have been evaluated for access per NEI 12-06, Section 5.3.2 (including liquefaction).

The equipment being transported for Phase 2 strategies will be towed by a heavy duty pickup truck and a small semi-tractor. The wheeled loader can also be used to tow equipment. The tires for these vehicles and trailers are designed to withstand small debris punctures and razor wire cuts/penetration (i.e., large commercial/military grade, run-flat, non-pneumatic tires). Debris clearing equipment is stored in the FLEX Storage Building. This provides the equipment with direct access to the critical. travel paths providing timely debris removal.

It was determined through walk downs that all haul paths can support a minimum of two lanes of normal vehicular traffic. This will decrease the likelihood of a path being completely blocked, as well as reduce the time it will take to clear any debris. The possibility exists to move off of the roadway to avoid debris along a majority of .the deployment route paths. Alternative routes into the power block area exist on the north and west sides of the plant that could be utilized.

A debris assessment for .the site was performed to determine debris

' equipment requirements.

removal .

It was determined that the debris removal equipment should be capable of moving large debris such as automobiles; trees, pieces of buildings, switchyard structures, and perhaps concrete barriers, in addition to general assorted small debris such as limbs. Based on this assessment, it was determined that a medium wheeled loader with the appropriate blade and horsepower can move the postulated debris in a single maneuver which simplifies and speeds the debris removal effort. This is because of its articulated steering and the capability of using a variety of tools which can be specific to the task. Multiple functions afforded the wheeled loader because of its various tools make this machine: a fork lift; a hoist; a modified version of a bulldozer; or a bucket lift. All tools are stored in the FLEX Storage Building.

For the travel paths, analyses indicate that there are potentially liquefiable soils below the design groundwater level, and that some settlement may occur along the travel paths following an earthquake.

Page 55 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 The magnitude of the settlement expected to occur is not anticipated to make the road impassable for the selected haul vehicles and wheeled loader (Reference 3.54).

2.10 Fueling of Equipment The four underground diesel fuel oil storage tanks (DFOSTs) at Vogtle are

./ seismically qualified and have a nominal capacity of 80,000 gallons each. The VEGP Technical Specifications (Reference 3.13, SR 3.8.3.1) require that each DFOST contains at least 68,000 gallons of fuel. The stored quantity of fuel in any selected DFOST will meet the fuel demand for all of the diesel driven FLEX equipment well past 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (References 3.56, 3.57). The Phase 2 support strategy includes repowering an existing diesel fuel oil transfer pump to refill a FLEX Fuel Tanker from the chosen DFOST. Hoses are connected to vent connections in the existing pump discharge piping.

Temporary FLEX cables with quick connect terminations will supply power from a 480V FLEX DG to the existing pump motor cables. A FLEX Fuel Tanker will be towed to each diesel-driven FLEX component that needs refueling. An on board DC powered pump will dispense fuel oil from the tanker. The haul routes for transporting fuel are the same haul routes for deployment of the FLEX equipment, which are evaluated for accessibility following screened in external hazards.

All four Diesel Fuel Oil Storage Tanks (DFOST) have been sampled to determine sulfur content and all were found to be in excess of 200 ppm. At the current usage rate of fuel oil it will be years before the sulfur content in the DFOSTs reaches 15 ppm (Ultra Low Sulfur Diesel fuel). The debris removal equipment, tow vehicles and diesel lights are the only FLEX equipment that require ultra-low sulfur diesel. Because of how long it will take to reduce the sulfur content in the DFOST's a sufficient quantity. of ultra-low sulfur fuel oil

will be maintained to operate the equipment listed above for a minimum of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

A fixed fuel tanker, that is stored in the FLEX Storage Building, is used to keep the equipment requiring ultra-low sulfur fueled. The 500 gallon capacity fuel tanker is sufficient to keep the FLEX equipment requiring ultra-low sulfur fueled for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Page 56 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.11 Offsite Resources 2.11.1 National SAFER Response Centers The industry has established two (2) National SAFER Response Centers (NSRCs) to support utilities during BDBEEs. SNC has established contracts with the Pooled Equipment Inventory Company (PEICo) to participate in the process for support of the NSRCs as required. Each* NSRC holds five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. In addition, on-site FLEX equipment hose and cable end fittings are standardized with the equipment supplied from the NSRC. In the event of a BDBEE and subsequent ELAP/LUHS condition, equipment will be moved from an NSRC to a local assembly area established by the Strategic Alliance for FLEX Emergency Response (SAFER) team. FLEX Strategy requests to the NSRC will be directed by FLEX Procedures.

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 and required equipment moved to the site as needed. First *arriving equipment 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 order at which equipment is delivered is identified in the Vogtle "Site 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. Typically deliveries will go by truck using preselected routes and with any necessary escort capabilities to ensure timely arrival at the plant site staging area or to an intermediate staging area approximately 25 miles from the site. The delivery of equipment from the intermediate staging area will use the same methodology. These areas are designed to accommodate the equipment being delivered from the NSRC.

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.

Page 57 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Multiple pre-selected routes are one method to circumvent the effects of seismic events, floods, etc. and these routes will take into account 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.

2.11.2 Equipment List The equipment stored and maintained at the NSRC for transportation to the local assembly area to support the response to a BDBEE at VEGP is listed in Table 2.

See Reference 3.55 for descriptions and capabilities of equipment maintained by the NSRC.

Page 58 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 2 PWR Portable Equipment From NSRC Use and (Potential I Flexibility) Diverse Uses Qty Qty Core Cont. Performance Criteria Notes List Portable lnstrumen RCS Req'd Provided Power Cool- Cooling/ Access Equipment -tation Inventory

/Unit I Unit ing Integrity Mobile Boration Skid 1 1 Diesel x 1000 gal 1 and Boric Acid Water Treatment 1 1 Diesel x x 250 gpm 1 Systems Water Treatment 1 1 Diesel 480V 150 kW 1 Generators Ventilation Fans 0 1 120 v x 3000 cfm 1 Portable Air 0 1 Diesel 150 psi 300 scfm 1 Compressor Suction Lift Booster 1 1 Diesel x x 26 ft lift 5000 gpm 1 Pumps Medium Voltage 1 2 Turbine x x x 4160 v 2MW 3 Generator Low Voltage 0 1 Turbine x x x 480V 1000 kW 2 Generator Cable I Electrical 0 Various N/A x x x x 4160 v 2 480V High Pressure 0 1 Diesel x 2000 psi 60 gpm 2 Injection Pump SG/RPV Makeup 0 1 Diesel x x 500 psi 500 gpm 2 Pump Low Pressure I 1 1 Diesel x 300 psi 2500 gpm 2 Medium Flow Pump Low Pressure I High 0 1 Diesel x 150 psi 5000 gpm 2 Page 59 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 2 PWR Portable Equipment From NSRC Use and (Potential I Flexibility) Diverse Uses Qty Qty Core Cont. Performance Criteria Notes List Portable lnstrumen RCS Req'd Provided Power Cool- Cooling/ Access Equipment -tation Inventory I Unit I Unit ing Integrity Flow Pump Hose I Mechanical 0 Various N/A x x x Various Various 2 Connections Lighting Towers 0 3 Diesel x . 440,000 (minimum) 2 lumens Diesel Fuel Transfer 0 1 N/A x x x x 500 gallon air-lift 2 container Diesel Fuel Transfer 0 1 Motor x x x x 264 gallon tank, with 2 Tank mounted AC/DC pumps Portable Fuel 0 1 Diesel x x x x 60 gpm after filtration 2 Transfer Pump Electrical 0 1 N/A x x x 4160 v 250 MVA, 2 Distribution System 1200 A Note 1 - NSRC Non-Generic Equipment - Not required for FLEX Strategy- Provided as Defense-in-Depth (Reference 3.55, Table 9-1 ).

Note 2 - NSRC Generic Equipment - Not required for FLEX Strategy- Provided as Defense-in-Depth (Reference 3.55, Table 7-1 ).

Note 3 - 1 MW is the individual generator output, and 2 MW is the total standard output to be supplied by the Phase 3 MV generators to satisfy identified load demands. The total output is created by connection of several smaller generators in parallel (Reference 3.. 55, Table 7-1 ).

Page 60 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.12 Habitability and Operations 2.12.1 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 to ensure the environmental conditions remain acceptable for personnel habitability or accessibility and within equipment limits.

The key areas identified for all phases of execution of the FLEX strategy activities are the MCR, TDAFW Pump Room, 'and Battery and Switchgear Rooms.

2.12.1 .1 Main Control Room Accessibility in the MCR must be maintained for the duration of the extended loss of all AC power (ELAP). During the ELAP, some control room vital electronics, instrumentation and emergency lighting remain energized from emergency DC power sources. An ELAP event disables all trains of control room HVAC for both units simultaneously.

Under ELAP conditions with no mitigating actions taken, analysis (Reference 3.58) projects the control room temperature to surpass 110°F (the assumed maximum temperature for efficient human performance as described in NUMARC 87-00 (Reference 3.10)) in less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The Phase 1 FLEX strategy will be to block open the MCR

access doors on the Unit 2 side within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . This strategy will open the MCR to the structure exterior at plant grade level and provide enough ventilation to keep MCR temperature below 110°F until power can be provided for a portable fan. By 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months , actions to deploy portable ventilation and block open additional doors on the Unit 1 side Page 61 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 of the MCR (to complete a flow path for outdoor through the MCR) are complete. Per NUMARC 87-00, the equipment in the MCR can be exposed to thermal environments of 120°F (Reference 3.10). Since the temperature in the MCR will be maintained less than 110°F the electrical equipment is expected to remain operable.

During cold weather, the ventilation flow can be limited to keep the MCR at a habitable temperature. If the outside temperature is above 98°F, then the doors will not be opened until the MCR temperature is in excess of the outside temperature. Note that on the infrequent days when the peak daily outside temperature is above 98°F, this temperature is normally only exceeded for a limited time during the afternoon hours. In addition, there is on average a 20°F difference between the daily high and low temperatures. (Reference 3.24, Section 2.3.2.1.2 and Table 2.3.2-1) 2.12.1 .2 TDAFW Pump Room During operation, there will be a considerable heat load within the room from the steam turbine and associated piping. Operation of TDAFW without forced ventilation was evaluated for the ELAP/LUHS condition (Reference 3.59).

This conservative calculation determined that with no supplemental ventilation, the room would heat up to a maximum of 116°F during the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of operation.

The temperature rise in this room is mitigated by natural circulation. A fail open installed damper provides air flow via heat-induced natural circulation. It is sufficient to maintain accessibility of the room for manual operation if required and to maintain equipment temperatures within operating limits.

A temperature of 116°F is deemed acceptable for infrequent occupancy to allow local operation of pumps as required.

The acceptance criteria for personal habitability for short intervals of exposure is 150°F, which is derived from an aero medical laboratory report titled "Human Tolerance for Short Exposures to Heat" (Serial No. TSEAL-3-695-49A)

(Reference 3.63).

Page 62 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.12.1.3 Battery and Switchgear Rooms During the ELAP event, the 125V de and inverter-fed 120V ac electrical distributions are energized and maintain power to instrumentation and controls for core cooling, containment, and SFP cooling functions.

Analysis (Reference 3.60) determined that the maximum temperature in the switchgear and battery rooms over a period of 7 days from the start of the BDBEE is 108°F and 95°F respectfully. This requires that the doors to the switchgear and battery rooms be propped open within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from the start of the event. Although not required for equipment protection, fans are available to allow for additional mixing of air from the switchgear and. battery rooms with the large volume of the adjacent non-train switchgear room on Level "B" in the Control Building .

.Operators are procedurally directed to open the switchgear and battery room doors within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to stage and start room fans as part of the FLEX Switchgear energization. An evaluation of equipment in the switchgear and bp.ttery rooms.

determined that this equipment will operate with no perceptual change in life expectancy when operating at the maximum temperatures for up to 7 days.

Since temperatures in and around the switchgear and battery rooms will remain less than 110°F, no specific action is needeq to address habitability. Since continuous occupation is not needed for operation of this equipment, operators can withdraw to a cooler area between equipment checks.

During subsequent battery charging operations, hydrogen will be released into the battery rooms. ~ith no mitigating action taken, the limiting time to 2% hydrogen concentration in the battery rooms is 86 hours9.953704e-4 days 0.0239 hours 1.421958e-4 weeks 3.2723e-5 months from the start of the event (Reference 3.61 ). Propping the battery room doors open at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ensures that the time to 2% hydrogen concentration in the battery rooms is well beyond 30 days (Reference 3.61).

Page 63 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.12.1.4 Aux. Bldg. "D" Level Corridor The Phase 2 strategy includes supplying the electrical distribution for RCS inventory strategies that rely on the portable Boron Injection and RCS Makeup FLEX Pumps located in the Aux. Bldg. "D" Level corridor from the 480V FLEX DG. Analysis (Reference 3.62) confirms that by propping open a door between corridors by 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , temperature in these areas will remain low enough (i.e., less than 104°F for the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of operation) so as to not impact accessibility or equipment operation given the heat load and building size. The Boron Injection and RCS Makeup FLEX pumps can provided design flow rates at a maximum ambient temperature of 104°F (Reference 3.62).

Since temperatures around the pumps will remain less than 110°F, no specific action is needed to address habitability.

Sine~ continuous occupation is not needed for operation of this equipment, operators can withdraw to a cooler area between equipment checks.

2.12.1.5 Containment Analysis (Reference 3.4 7) determined that the* MODES 1-4 containment pressure at 120 hou.rs is 5. 7 psig and the peak containment temperature at 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months is 213.2°F. It is .

expected that containment temperature and pressure will remain below the design basis Hmits. beyond 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months , because of the significant margin to the design basis limits.

An .additional analysis (Reference 3.64) determ.ined that the instrumentation in* containment needed in Modes 1-4 would be avaJlable throughout a BDBEE for the first 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months .

Analysis (Reference 3.47) demonstrates that containment response in MODES 5 & 6 following .a postulated ELAP event does not challenge design limits. To maintain containment parameters within design limits, local manual

actions are requi,red to establish a vent flow path through one of the two installed lines provided for Integrated Leak Rate Testing (ILRT}. Either ILRT penetration provides an adequate containment vent path. A_n additional analysis (Reference 3.64) determined that the instrumentation in

Page 64 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 containment needed in Modes 5 & 6 would be available throughout a BDBEE for the first 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months .

2.12.1 .6 FLEX Switchgear During the ELAP event, the FLEX Switchboard distributes power to one battery charger for each 125V DC Switchgear and other critical loads (See Section 2.3.2). The FLEX Switchboards are located on Level "B" of the Control Building immediately outside the 125V DC Switchgear and Battery rooms. Analysis (Reference 3.60) determined that the maximum temperature in the FLEX switchgear rooms .

over a period of 7 days from the start of the BDBEE is 96°F:

The FLEX Switchboards are designedto operate up 104°F.

Since temperatures around the FLEX Switchboards will remain 1.ess than 110°F, no specific action is needeo to address habitability. Since continuous occupation is not needed for operation of this equipment, operators can withdraw to a cooler. area between equipment checks, 2.12.2 Heat Tracing For the VEGP site, the normal daily minimum temperature ranges from 34°F in December and January to 70°F in July (Reference 3.24, Section 2.3.2.1.2). An extreme minimum temperature of 3°F was recorded in February 1899. Based on historical records, the temperature remains below freezing all day on the average of only 1 day each January. About one-half of the days in December, January, and February have minimum temperatures below freezing. Therefore, extreme cold is not considered to be a significant concern for the site.

During *normal. plant operation, the RMWST tank nozzles and level instrument piping are maintained above freezing temperature by heat tracing. During a BDBEE, the RMWST can supply makeup water to the CSTs when their initial inventories are depleted via the FLEX Makeup pump. The CST will be the initial source of water and in continuous use so there is no need for heat tracing. The need for a backup supply is not anticipated prior to 89 hours0.00103 days 0.0247 hours 1.471561e-4 weeks 3.38645e-5 months into the BDBEE due to the capacity of the CSTs (see Table 3). Additionally, the NSCW basins serve as alternate supplies of makeup water to the CSTs. When heat tracing is lost during cold weather events, it should not be necessary to thaw the relatively short connections at the outdoor water tanks due to the large Page 65 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 thermal mass of water in the tank. Because of the length of time available to address freezing concerns (i.e., 89 hours0.00103 days 0.0247 hours 1.471561e-4 weeks 3.38645e-5 months ) and the availability of the NSCW basins (which are not susceptible to freezing) as backup to the RMWST, heat tracing is not required to be maintained following a BDBEE.

During normal plant operation, the RWST lines and appurtenances to the RWST are heat traced as necessary to prevent freezing. During a BDBEE, the RWST is a secondary source of borated water for boron injection to maintain sub-criticality (the BAST is the primary source).

When heat tracing is lost during cold weather events, it should not be necessary to thaw the relatively short connections at the outdoor water tanks due to the large thermal mass of water in the tank. Because of the length of time available to addre.ss freezing concerns (i.e., greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) and the availability of the NSCW basins (which are not susceptible to freezing) as backup to the RMWST, heat tracing is not required to be maintained following a BDBEE.

The storage of FLEX equipment considers the minimum temperature specified by the manufacturers (see Section 2.8). The FLEX pumps and generators have special operating requirements when

temperatures fall below 32°F. Freeze protection of idle but primed portable pumps and hoses considers the possibility of freezing.

2.13 Personnel Habitability Personnel habitability was evaluated in Section 2.12.1 and determined to be acceptable.

2.14 Lighting In order to validate the adequacy of supplemental lighting and the adequacy and practicality of using portable lighting to perform FLEX strategy actions it was confirmed that all operators are required to have flashlights. 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.

The majority of areas for ingress/egress and deployment of FLEX strategies contain emergency lighting fixtures (Appendix "R" lighting) consisting of a battery, battery charger and associated light fixtures. These emergency lights are designed and periodically tested to insure the battery pack will provide a minimum of eight (8) hours of lighting with no external AC power sources.

Page 66 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Therefore, these currently installed emergency lighting fixtures provide lighting to light pathways for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Prior to the depletion of the Appendix "R" lighting, portable battery powered lighting could be deployed to support the FLEX strategy tasks.

There are no emergency lighting fixtures in the yard outside of the protected area to provide necessary lighting in those areas where portable FLEX equipment is to be deployed. Therefore, the large FLEX pumps and diesel generators are, outfitted with light plants that are powered from either their respective diesel generators or batteries in order to support connection and operation. In addition to the lights installed on the FLEX equipment, portable light plants are available to be deployed from the FLEX Storage Building as needed to support night time operations.

Installed ballasts on MGR light fixtures provide reduced illumination for 90 minutes. The strategy calls for operator action to align MGR lighting in the "Horseshoe" area to the associated unit's D Battery. Analysis indicates that execution of specified load shed actions directed in plant procedures ensures a continued reliable source of illumination for a minimum of 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months until the 480V FLEX DG will be available to repower the battery charger that supplies the D Battery which powers the MGR lighting (Reference 3.15). To align MGR lighting in the "Horseshoe" area to the associated Unit's D battery, operators man,ipulate breakers on a single 120V Instrument ac panel and position two control switches at readily accessible locations in the Control Building.

2.15 Communications The plant Public Address (PA) system will assist with initial notifications and directions to on-site personnel, the on-shift Emergency Response Organization (ERO) personnel, and in-plant response personnel. Battery operated handheld satellite phones will assist with initial notifications and directions to off-site Emergency Response Organization (ERO) personnel and other personnel.

As discussed in the VEGP communications assessment (Reference 3.65),

provisions have been made for battery backup for the plant public address system to allow for extended operation following a loss of power, as necessary, to support plant operations until AC. power is restored or alternative communications are available. A rapidly deployable communications kit (RAPIDCASE) and a mobile communications system (RAPIDCOM) will be utilized to support satellite communications for the ERO.

The RAPIDCOM is self-powered via a generator located on board and it can support radio communications. The RAPIDCASE is maintained in a charged Page 67 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 condition and requires a backup source of power before the batteries are depleted.

The RAPIDCASE is stored in the Equipment Building which is a seismically qualified structure and the RAPIDCOM is stored in the FLEX Storage Building.

The electrical strategy for Phase 2 includes the capability to enhance the Phase 2 onsite communications by repowering the Public Address system.

2.16 Water sources 2.16.1 Secondary Water Sources Table 3 provides a comprehensive list of onsite water sources considered for core cooling and SFP cooling coping strategies. This table considers each source's design robustness with respect to seismic events, high winds, and associated missiles. Only the Condensate Storage Tank (CST), Reactor Makeup Water Storage Tank (RMWST), Refueling Water Storage Tank (RWST), Nuclear Service Cooling Water (NSCW), and Savannah River meet 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 may be available for injection, depending on the cause of the event, and although these are not credited, they will be considered for use during an actual event.

Page 68 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 3 Water Sources Water sources an_d associated piping that fully meet ALL BDB external hazards, i.e., are FLEX qualified (See Reference 3.14 Attachment A for Calculated Times)

Qualified for Applicable Hazard? SG Makeup RCS Makeup SFP Makeup Usable Volume Time Based Cumulative MODES MODE5 MODE6 MODES 1-4 MODE5 MODE6 Water Sources High Low High (Gallons) Seismic on Decay Time Based on 1-4 (No SGs) (SGs Available) (No SGs) (Full-Core Winds Temp Temp Heat Decay Heat (SGs) Offload)

CST 1 (Ref. 3.13, SR 340,000 y y y y 29 hrs 29 hrs -- 47 hrs -- -- 45 hrs makeup 3.7.6.1) (one per unit) >22 hrs spray CST 2 (Ref. 3.13, SR 340,000 y y y y 60 hrs 89 hrs -- 47 hrs -- -- 45 hrs makeup 3.7.6.1) (one per unit) >22 hrs spray RMWST (Ref. 3.14) 148,000 y y y y 31 hrs 120 hrs -- >20 hrs -- -- 19 hrs makeup (one per unit) >9 hrs spray NSCW Basin A 3,361,500 y y y y 30 days >35 days -- -- -- -- 19 days makeup 9 days makeup (Ref. 3.14; Ref. 3.13, SR (one per unit) 112 hrs spray 112 hrs spray 3.7.9.1) (Note 2)

NSCW Basin B 3,361,500 y y y y -- -- -- -- -- 19 days Makeup 19 days makeup 9 days makeup (Ref. 3.14; Ref. 3.13, SR (one per unit) 112 hrs Spray 112 hrs spray 112 hrs spray 3.7.9.1) (Note 2)

RWST (Ref. 3.13, SR 686,000 y y y y -- -- >47 days 95 hrs 95 hrs -- -- --

3.5.4.2) (one per unit) (Note 3)

Savannah River Continuous Source y y y y Indefinite Indefinite

>35 days > 19 days makeup >38 days makeup >23 days makeup Totals -- (Indefinite)

>47 days >3.9 days 115 hours0.00133 days 0.0319 hours 1.901455e-4 weeks 4.37575e-5 months

>4.5 days spray >9 days spray > 11 days spray Water sources not credited in FLEX strategy (No analysis performed for the non-qualified water sources)

Condenser Hotwell (Note 1) 156,534 N -- -- -- -- -- -- -- -- -- -- --

(one per unit)

Demin. Water Storage Tank 250,000 N -- -- -- -- -- -- -- -- -- -- --

(Ref. 3.24, Table 2.4.12-2)

Fire Water Storage Tanks 600,000 N -- -- -- -- -- -- -- -- -- -- --

(Ref. 3.24, Table 2.4.12-2)

Makeup Well Water Storage 300,000 N -- -- -- -- -- -- -- -- -- -- --

Tank (Ref. 3.24, Table 2.4.12-2)

Potable Water Storage 25,000 N -- -- -- -- -- -- -- -- -- -- --

Tank (Ref. 3.24, Table 2.4.12-2)

Cooling Tower Basins 6,000,000 N -- -- -- -- -- -- -- -- -- -- --

(Ref. 3.24, Section (one per unit) 10.4.5.2.2) -

Note 1 - The condenser hotwell level was determined by multiplying the maximum water level in the condenser {which is 7.3 feet from the bottom) by volume of water per one foot rise in the condenser {which is calculated to be 21,443 gallons per foot). (Ref. 3.26)

Note 2 - SFP makeup and spray are based on submergence considerations for the submersible pump (Reference 3.43). Makeup values are conservatively based on submergence requirements for flow path through flexible hoses and permanent plant piping (Reference 3.43). The required SFP flow rates are doubled because a single basin is used for both units.

Note 3 - The majority of the contents of the RWST would already be in the refueling cavity in MODE 6; MODE 5 bounds MODE 6 requirements.

Page 69 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.17 Shutdown and Refueling Analysis VEGP abides by the Nuclear Energy Institute position paper entitled "Shutdown/Refueling MODES" (Reference 3.66) addressing mitigating st,rategies in shutdown and refueling MODES. This paper has been endorsed by the NRC Staff (Reference 3.67).

Vogtle has site-specific procedures for implementation of FLEX in shutdown MODES. The applicable procedure addresses all expected plant configurations expected in MODES 5 & 6. No pre-deployment of FLEX is required: Some FLEX equipment used for MODES 5 & 6 strategies is stored near containment inside protected structures such as the Equipmen.t Building.

FLEX mitigating strategies available during shutdown and refueling MODES are summarized below.

2.17.1 RCS Inventory and Reactivity Control MODE 5 without Steam Generators Available 2.17.1.1 Phase 1 In Phase 1 without the steam generators available, makeup to the RCS is provided via gravity* feed from the Refueling Water Storage Tank (RWST). Prior to filling the reactor cavity, the volume of water in the RWST is sufficient to provide gravity feed until a pressure of 35 psig is reached in the RCS. Establishing the gravity feed alignment will be accomplished via manual valve operation.

The gravity feed path will be from the RWST via the Safety Injection (SI) system flow path to the RCS cold legs.

Additional gravity feed paths from the RWST to the RCS are also available using the SI flow path to the RCS hot legs and flow paths in the Residual Heat Removal (RHR) System and the Chemical Volume and Control System (CVCS).

The required makeup flow rate to the RCS following a loss of RHR cooling is 120 gpm (Reference 3.19). Depending on the rate at which containment pressure rises and RWST level decreases, gravity feeding may not maintain the required flow rate necessary to makeup to the RCS, it is still a credited action that will mitigate core uncovery. The initial response of gravity feeding from the RWST will extend the Page 70 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 required Phase 2 response time to prevent or mitigate the consequences of the event.

2;17.1.2 Phase 2 and 3 The primary strategy for inventory and reactivity control will be to utilize an electric motor driven RCS Makeup FLEX Pump, powered by a 480V FLEX DG, taking a suction on the RWST with its discharge aligned to a connection in the RHR system.

The Westinghouse RCS makeup evaluation (Reference 3.19) indicates that a flow rate of 120 gpm is sufficient to remove the decay heat for MODES 5 events that occur beyond 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after plant shutdown. Diverse connections (primary and alternate) for suction from the RWST are provided upstream of each RHR pump. Diverse connections for discharge of the pump are located downstream of each RHR pump on the piping that discharges to the RCS cold legs. No venting of the RCS will be required since the Pressurizer Safety Valves are removed* from the pressurizer during the limiting shutdown condition (i.e., in 'MODE 5 with the reactor vessel head installed).

A minimum RCS Makeup FLEX Pump head of 449.6 ft is required to ensure a minimum flow rate of 120 gpm can be provided for boron injection with suction from the RWST for MODES 5-6. At this flow rate, the minimum NPSHa is 86.8 ft (Reference 3.35) which exceeds the NPSHr of 8 ft (Reference 3.36).

2.17.2 RCS Inventory and Reactivity Control MODE 6 2.17.2.1 Phase 1 In MODE 6, the RWST inventory is available in the reactor refueling cavity and no Phase 1 actions will be required.

2.17.2.2 Phase 2 and 3 The Westinghouse RCS makeup evaluation (Reference 3.19) indicates that a flow. rate of 120 gpm is sufficient to remove the decay heat for MODES 6 events that occur beyond 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after plant shutdown. The strategy for Page 71 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 inventory control for MODE 6 will be established by using the SG FLEX Pump to make up demineralized water, from any available makeup source (i.e., CST or RMWST) to the top of the refueling cavity (Reference 3.19). Makeup to the refueling cavity is through one of two available containment penetrations.

2.17.3 Spent Fuel Pool Cooling/Inventory For SFP cooling considerations, refer to Section 2.5 .

. 2.17.4 Containment Integrity, MODES 5 & 6 To maintain containment parameters within design limits, local manual actions are required (Reference 3.47) to establish a vent flow path

through one of the two installed lines provided for Integrated Leak Rate Testing (ILRT). The coping strategy for maintaining containment integrity includes monitoring containment pressure 2.17.4.1 Thermal-Hydraulic Analyses Analysis (Reference 3.47) demonstrates that containment response following a postulated ELAP event does not challenge design limits as long as an adequate vent is established. *Either ILRT penetration provides _an adequate containment vent path.

Two methodologies were used in the analysis. The first is use of the Modular Accident Analysis Program (MAAP) PWR Version 4.0.5 analysis software for the containment analysis (Reference 3.78). The second was the use of the modified Darcy equation for compressible flow to determine the pressure drop in the containment vent line for MODES 5 & 6, SGs not Available, and mid loop conditions. See Section 2.6.6 for additional discussion on the utilization of the MAAP4 analysis software.

Page 72 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.18 Sequence of Events Table 4 below presents a Sequence of Events (SOE) Timeline for an ELAP/LUHS event at VEGP. Validation of each of the FLEX time constraint actions has been completed in accordance the FLEX Validation Process document issued by NEI (Reference 3.82) and includes consideration for staffing (References 3.74 and 3.75). Time to clear debris to allow equipment deployment is assumed to be up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months from the start of the event (Reference 3.75). This time is considered to be conservative based on site reviews and the locatio'n of the FLEX Storage Building. Debris removal equipment is stored in the FLEX Storage Building.

Additional technical basis details regarding the identified time sensitive actions (i.e., Actions which have a "Y" in the ELAP Time Constraint column in Table 4) follow the table.

Table 4 Sequence of Events Timeline ELAP Action Elapsed Action Time Remarks Number Time Constraint 0 Event Initiation N/A Unit Operator (RO) verifies 1 60 sec TDAFW Pump Starts N initiation of TDAFW and that SG levels are increasing Attempt to establish DG RO attempts to start EOG from emergency power from MCR and dispatches System 2 10 min N MCR and attempt local Operator (SO) to start locally.

diesel start Evaluate off site power Shift Manager determines with off- site PSCC and availability of off-site power 3 15 min N attempt Plant Black Start.

Time sensitive at a time greater than 45 minutes. DC buses are readily available for operator access and 4 30 min DC load shed complete y breakers/control switches at the DC switchgear are appropriately identified (labeled) to show which are required to be opened.

Time sensitive at a time Attempts to start EDGs greater than1 hour. Entry into have been y 5 30 min ELAP provides guidance to

unsuccessful. Enter operators to perform ELAP ELAP procedure actions.

Page 73 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 4 Sequence of Events Timeline ELAP Action Elapsed Action Time Remarks Number Time Constraint Installed ballasts on emergency MGR light fixtures provide reduced illumination for 90 minutes. To align MGR lighting in the "Horseshoe" to Transfer MOR lighting the associated Unit's D 6

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to the associated unit's N battery, operators manipulate D battery 12 breakers on a single 120V Instrument AC panel and position two control switches at readily accessible locations in the Control Building.

A time constraint of 60 minutes was established for this action.

Opening the doors is procedurally performed during the battery load shed. The 125V DC and inverter-fed Open doors to the main 120V AC electrical battery rooms and y distributions remain energized 6A 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months adjacent switchgear and generate heat in these rooms rooms. With doors opened, natural mixing of air in these rooms with large adjacent spaces will maintain adequate temperatures prior to availability of forced ventilation.

Time sensitive at a time greater than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

Command and control I

c functions require continued personnel accessibility to the Open access doors on y MGR. With these doors 6B 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Unit 2 side of the MGR opened, natural mixing of air in the MGR with the outdoor environment will maintain adequate temperatures prior to availability of forced ventilation.

Time sensitive at a time greater than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months . RCS cooldown occurs at the same Initiate depressurization y time as the secondary side 7 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the SGs via local operation of the ARVs depressurizes. This enables boration via accumulators and Boron Injection FLEX pump orior to net xenon decay (i.e.,

Page 74 of 93

FINAL INTEGHATED PLAN

Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 4 Sequence of Events Timeline ELAP Action Elapsed Action Time Remarks Number Time Constraint within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

Stage and connect the Time sensitive after 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 480V FLEX DG to 8 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months battery chargers and y Boron Injection FLEX Pump Battery charging operations generate additional heat in these spaces and release hydrogen into the battery rooms. Forced ventilation is not required for maintaining Establish forced acceptable room temperatures 8A 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ventilation for battery N and battery room hydrogen and switchgear rooms concentration levels.

Deploying portable fans to circulate air between these rooms and the. large adjacent spaces will provide additional operating margin.

Stage and connect The SG FLEX Pump will be portable SG FLEX staged beginning at

9 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months N Pump in the event the approximately 8-1 O hours TDAFW Pump fails Time sensitive after at a time Initiate supplemental greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

boration (with letdown Operator starts the transfer of 10 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months as necessary) using y water from the BASTs to the portable Boron Injection RCS to ensure adequate FLEX Pump boration and maintain sub-criticality Time sensitive at a time greater than approximately 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . During the ELAP event, command and control Open access doors on functions require continued

'- the Unit 1 side of the y personnel accessibility to the 10A 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months MCR and establish MCR. Deploying a portable fan forced ventilation to ventilation provide forced ventilation through the MCR will maintain acceptable temperatures for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Begin makeup to SFP SFP area venting and hose as necessary to N deployment will begin at 11 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months maintain adequate level approximately 5-6 hour time in the SFP. (Under frame. Boil-off rate is slow Page 75 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 4 Sequence of Events Timeline ELAP Action Elapsed Action Time Remarks Number Time Constraint design basis conditions, with a large volume of water in boiling begins at - 7 the SFP. Times shown hours; without makeup, assume worst case SFP level falls to 15 emergency full-core off load feet above the active heat load in both units' SFPs.

fuel in -27 hours.) Vent the spent fuel pool area by opening doors to minimize condensation during pool boiling Time sensitive at a time greater than 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months . To Align second CST for transfer source of water to the 12 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SG Makeup and install y second CST before the first CST crosstie. CST inventory will be exhausted (initial selection of CST 1 assumed)

Action added because it requires significant coordination. An elapsed time Power DFOST pump was developed based placing 13 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months from 480V FLEX DG N the SG FLEX pump in and fill lrans Cube.

operation at 6 hrs. The SG FLEX pump has a refuelin.g

. time of 11 hrs .

Discussion of time constraints identified in Table 4.

30 minutes, de extended load shed complete (Table 4 item 4) - Time sensitive at a time greater than 45 minutes. To ensure that all saJety-related station batteries can maintain de bus voltages above minimum required voltage for a minimum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following a loss of AC power, de load shed is required to be completed by 45 minutes after loss of AC power. Station procedures will require a de load shed following a loss of all AC power even if an ELAP has not been declared at about 15 minutes after the start of the event. The Verification &

Validation (V&V) performed determined that the load shed can be performed in 16 minutes. Battery chargers are assumed to be operating no later than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months via the 480FLEX DG after the start of the event (Table 4 item 8); therefore, there is sufficient conservatism in the life of the de power source. The ac & de distribution panels are primarily located in Switchgear Rooms on the 8 level of the control Page 76 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 building and are readily accessible to the operator. One distribution panel is located on level 1 of the Auxiliary Building. It too i~ readily accessible to the operator. As an operator aid, the breakers are appropriately identified (labeled) to show which are required to be opened to facilitate an extended load shed.

30 minutes, Entry into Extended Loss of ac Power (Table 4 item 5) -

Time sensitive af a time greater than1 hour. Time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is selected conservatively to ensure that ELAP entry conditions can be verified by control room staff and it is validated that emergency diesel generators (EOG) are not available. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is a reasonable assumption for system operators to perform initial evaluation of the EDGs. Entry into ELAP provides guidance to operators to perform ELAP actions.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Open doors to main battery rooms and associated switchgear

. rooms (Table 4 item 6A). Analysis (Reference 3.60) indicates that this action allows mixing of air from the main battery rooms and associated

switchgear rooms with the large volume of the adjacent non-train switchgear room on Level "B" in the Control Building .. Opening the doors to these spaces during the. first hour following ELAP-which operators will be doing to accomplish credited load ~hedding actions-will provide enough natural mixing to keep temperatures below 108°F

. in the switchgear rooms and 94 °F in the battery rooms.

3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , Open access doors on- Unit 2 side of the Main Control Room (MCR) (Table 4 item 6B) - Time sensitive at a time greater than. 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Opening the MCR to the structure exterior at plant grade level within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months provides enough ventilation to* keep MCR temperature be.low 110°F until power can be provided for a portable fan (Reference 3.58). During cold weat.her, the ventilation flow can be limited to keep

ttie MCR at a .habitable temperature. If the outside temperature is above 98°F, then the doors will not be opened until the MCR temperature is in excess of the outside temperature.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , Depressurize steam generators (SGs) .via local operation of Atmospheric Relief Valves (ARVs) (Table 4 item 7) - Time"sensitive at 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months . Initiating cooldown at 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months allows sufficient time for RCS co9ldown and depressurization (estimate 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) prior to when borated makeup must be started (Table 4 item 1.0) for maintaining sub-critiqality at the most limiting core conditions (Reference 3.19).

Page 77 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , Energize 480V FLEX switchboard (Table 4 item 8) - Time sensitive at a time greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Current battery calculations demonstrate that battery capacity is sufficient to provide three trains of critical loads for greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Reference 3.15). The 480V FLEX DG will be available for service no later than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after the start of the event. Thus, the 480V FLEX DGs will be available to restore power to one battery charger on each Class 1E 125V de distribution bus and a portable FLEX pump (Boron Injection or RCS Makeup as needed-dependent on ELAP initial conditions). The 480V FLEX DGs will be maintained in the on-site FLEX Storage Building.

The 480V FLEX DG will be transferred and staged via haul routes and staging areas evaluated for impact from external hazards. Diverse connection points for the 480V FLEX DG are provided outside and inside the Control Building (primary and alternate, respectively) to facilitate the connections and operational actions required to supply the battery chargers and portable FLEX pumps from the 480V FLEX DG.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , Begin supplemental boron injection from the Boric Acid Storage Tank (BAST) using portable Boron Injection FLEX pump (Table 4 item tO) - Time sensitive after at a time greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Westinghouse RCS makeup evaluation for VEGP (Reference 3.19) determined that injecting from the BAST provides sufficient shutdown margin for the worst case boration requirements. Initiating makeup from the* BAST at 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures adequate boration (with one hour for mixing) . to maintain long-term sub-criticality is accomplished within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with injection rate limited by letdown through the upper head vent flowpath (Reference 3.19).

15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months , Open access doors on Unit 1 side of the MCR and establish forced ventilation (Table 4 item 1OA) - Time sensitive at a time greater than approximately 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . Opening additional doors on the Unit 1 side of the MCR establishes a flow path through the MCR to the outdoor atmosphere. Deploying a portable fan at 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months will keep MCR temperatures below 110°F for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Reference 3.58).

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , Align second CST for SG injection and rnstall CST crosstie (Table 4 item 12) - Aligning to the second CST is time sensitive at a time greater than 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months . The inventory of one CST is capable of removing decay heat and RCS stored energy for a minimum of 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months (see Table 3 and Reference 3.14). Prior to depletion of the first CST, the TDAFW pump (or SG FLEX Pump, as applicable) will require makeup from the second CST. Cross tying the CSTs is not time Page 78 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 sensitive. The CSTs have the capability to be cross-tied removing the need to realign to the second CST for injection and to add an alternate flowpath for CST makeup. V&V of the cross-tie was added because it requires significant coordination.

2.19 Programmatic Elements 2.19.1 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 (NMP-GM-038, Reference 3.69),

and a program document specific for each of the SNC sites (NMP-GM-038-003 for VEGP, Reference 3.70). Together, the two documents describe the FLEX program for VEGP.

Key elements of the VEGP FLEX program include:

A summary of FLEX strategies including validation methods

A description of FLEX equipment including:

o Quality attributes o Maintenance and testing o Availability tracking o Storage o Requirements for deployment

A description of SNC's FLEX procedure development including:

o The interface between design basis and beyond design basis procedures o Procedure maintenance o Application of procedures during emergencies

Plant Configuration Control:

o Changes to FLEX strategies o Configuration Management Page 79 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 o Activities that Potentially Affect FLEX Strategies o Plant qonfiguration Control Processes during Emergencies

A summary of personnel related items including staffing and training 2.19.2 Procedural Guidance The overall plant response to an ELAP and LUHS is accomplished through normal plant command and control procedures and practices.

The inability to predict plant conditions following an extreme external event has prompted the creation of a new set of procedures. These procedures; FLEX Support Guidelines (FSGs), provide guidance for deployment of FLEX equipment. FSGs are written such that they can be implemented during a variety of post event conditions. When the use of FLEX equipment is required for response to a FLEX stylized BDBEE, EOPs or, AOPs, will direct the entry into and exit from the appropriate FSG. This procedure approach conforms to NEI 12-06, Section 11 .4 guidance for the relationship between FLEX procedures and other relevant plant procedures.

FSGs were developed, from the PWROG procedure guidelines to provide pre-planned strategies for accomplish.ing specific tasks associated with implementation of FLEX strategies. The FSGs satisfy

the criteria specified in Section 11.4 of NEI 12-06.

Strategy Implementation Guides (SIGs) were developed to have operator actio""s in the field included in a separate "operator friendly" procedure format. The FSGs and SIGs together are equivalent to the PWROG generic FSGs.

Procedural Interfaces have been incorporated into ECA-0.0, "Loss of AH AC Power (Reference 3. 71) to the extent necessary to include appropriate reference to FSGs and provide command and control for the ELAP. Additionally, procedural interfaces have been incorporated into the AOPs for MODES 5 & 6 to include appropriate reference to

.FSGs.

FSGs and SIGs are reviewed, approved, and maintained iri accordance with existing procedure control procedures.

Changes to plant procedures including FSGs and SIGs are screened using existing procedural guidance which incorporates the aspects of Page 80 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 NEI 96-07, Revision 1 (Reference 3.68), and NEI 97-04, Revision 1 (Reference 3.72).

2.19.3 Staffing Using the methodology of NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities (Reference 3.73), assessments of the capability of the Vogtle 1 & 2 on-shift staff and ERO to respond to a BDBEE were performed for Phase 1 and for Phase 2. (References 3.74 and 3.75) 2.19.4 Training Training has been developed and delivered to the target populations (Operations, Maintenance, Security, and ERO staff) using the systematic approach to training (SAT) process. The training conducted by SNC satisfies the applicable requirements of NEI 12-06, Section 11.6.

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.

SNC Staff responsible for the implementation of the FSGs also complete additional NANTeL training provided by the ERTD working group.

ERO Decision Makers receive additional training on directing actions and implementing strategies following a BDBEE.

2.19.5 FLEX Equipment List The equipment necessary for the implementation of the FLEX strategies in response to a BDBEE at VEGP is listed in Table 5. The table includes the quantity, applicable strategy, and equipment performance criteria for the required FLEX equipment. FLEX equipment is primarily stored in the FLEX Storage Building (FSB).

Some equipment (Boron Injection FLEX Pumps, and RCS Makeup FLEX Pumps) are stored near their staging areas in the Auxiliary Building.

Page 81 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.19.6 N+ 1 Equipment Requirement NEI 12-06 invokes an N+ 1 requiremeht for the FLEX equipment that directly performs a FLEX mitigation strategy for core cooling, containment, or SFP cooling in order to assure reliability and availability of the FLEX equipment required to meet the FLEX

. strategies. Sufficient equipment is available to address all functions at all units on-site, plus one additional spare, i.e., an N+1 capability, where "N" is the number of equipment required by FLEX strategies for all units on-site. Where a single resource is sized to support the required function of both units a second resource is available to meet the + 1 capability. In addition, where multiple strategies to accomplish a function have been developed, the equipment associated with each strategy does not require N+ 1 capability.

The N+ 1 requirement does not apply to the FLEX support equipment, vehicles, and tools. However, these items are subject to inventory checks, requirements, and any associated maintenance and testing.

Page 82 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 5 PWR Portable Equipment Stored On-Site Use and (Potential I Flexibility) Diverse Uses Performance Criteria List Portable Equipment Qty Core Containment SFP Instrumentation Accessibility Medium Wheeled Loader - 1 x x x x x Can also be used as a tow Debris Removal vehicle Tow Vehicles - 1 large, 1 2 x x x x x Towing Pumps and Diesel Generators small 480V FLEX Diesel Generator 3 x x Provide 480V AC power to FLEX Switchboard SG FLEX Pump 3 x Provides injection into the SGs to remove decay heat from the core.

Makeup FLEX Pump 2 x Provide CST Makeup - Godwin HL 11 OM Makeup FLEX Pump 1 x Provide CST Makeup - Godwin HL-4M SFP FLEX Submersible 2 x x Provides the hydraulic motive force to drive Pump Hydraulic Unit the submersible pump SFP FLEX Pump 4 x x Pump unit placed in the NSCW Basin for Submersible Pumps access to entire water volume Sets of Monitor Spray 6 x Nozzles for SFP Spray and Provides 250 gpm of spray water for each unit required hoses Boron Injection FLEX Pump 3 x Provides Borated Water from the BAST or RWST for injection to the RCS in MODES with SGs available for decay heat removal RCS Makeup FLEX Pump 3 x Provides borated water from the RWST for injection to the RCS during MODES with SGs not available for decay heat removal FLEX Fuel Tanker 3 x x x x Provide fuel to diesel powered FLEX equipment.

Page 83 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 Table 5 PWR Portable Equipment Stored On-Site Use and (Potential I Flexibility) Diverse Uses Performance Criteria List Portable Equipment Qty Core Containment SFP Instrumentation Accessibility 20 kW FLEX Diesel 3 Not credited in FLEX strategies Generator DC Equipment Room FLEX 10 x x x x x Not credited in FLEX strategies. Portable Fan ventilation for equipment operability.

Battery Room FLEX Fan 10 Not credited in FLEX strategies. Portable ventilation fans available for long term cooling.

FLEX Ventilation Fan 2 x x x x x For MCR Ventilation Diesel Powered Lights 4 Misc. lighting. Not credited in FLEX strategies Air Compressors 2 Air as needed. Not credited in FLEX strategies Rapidly Deployable 2 x x x x x Does not rely on the availability of either on-Communications Kit site or off-site infrastructure other than satellites Page 84 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 2.19. 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, to verify proper function.

The standard EPRI industry 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 2.19.8 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.

Page 85 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 The unavailability of FLEX equipment and connections is controlled using the tracking application in the Shift Operations Management System (eSOMS) per NMP-OS-019-013, Beyond Design Basis Equipment Unavailability Tracking (Reference 3.76).

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 NMP-OS-019-013.

FLEX equipment and resources may be allocated when requested to support a beyond design basis emergency event at another nuclear site provided the following requirements are met:

Permission is received from the Site Duty Manager per NMP-GM-036, Duty Manager (Reference 3. 77)

The status of the allocated equipment is tracked and unavailability actions implemented per NMP-OS-019-013.

Page 86 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2

3. References 3.1 SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan," dated July 12, 2012 (ADAMS Accession No. ML11186A950) 3.2 NRG Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated March 12, 2012 (ADAMS Accession No. ML12056A045) 3.3 Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 2, dated December 2016 (ADAMS Accession No. ML15348A015) 3.4 NRG Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174) 3.5 NRG Order Number, EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ADAMS Accession No. ML12054A682) 3.6 Nuclear Energy Institute (NEI) 12-02, Industry Guidance for Compliance with NRG Order EA-12-051, To Modify Licenses with Regard to Reliable SFP Instrumentation, Revision 1, dated August 2012 (ADAMS Accession No. ML12240A307)

. 3.7 NRG Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable SFP Instrumentation, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339) 3.8 United States NRG Endorsement Letter for Westinghouse Electric Company Technical Report TR-FSE-14-1-P, Revision 1 and TR-FSE 1-NP, Revision 1 "Use of Westinghouse Shield Passive Shutdown Seal for FLEX Strategies," May 28, 2014 (ADAMS Accession Number ML14132A128) 3.9 AX3DT120, FLEX Portable System, Units 1 & 2 480V Diesel Generator Sizing Calculation, Version 1.0 3.10 NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, Revision 1 Page 87 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 3.11 VEGP Design Criteria DC-1302, Auxiliary Feedwater System, Version 15.0 3.12 VEGP Design Criteria DC-2130, Condensate Storage Tanks and Valve Houses, Revision 5 3.13 Vogtle Units 1 and 2 Technical Specifications and Bases, Amendment No.

177 (Unit 1) and Amendment No. 158 (Unit 2) 3.14 X4CPS0173, Required Makeup Flows and Water Availability for a Beyond Design Basis External Event at Vogtle Electric Generating Plant, Version 2.0 3.15 X3CF14, Class 1E Battery Station Blackout Extended Coping Time Study, Version 2.0, dated May 27, 2015 3.16 X3CF15, TSC Battery capability evaluation after Beyond Design Basis External Event (BDBEE),*Version 1.0 3.17 VEGP Design Criteria DC-1007, Environment- lnterdiscipline, Version 34.0 3.18 Westin~hous~ Letter LTR-PSCA-12-78, PA-PSC-0965 Core Team PWROG Core Cooling Management Interim Position Paper, Revision 0, November 2012

-3.19

Westinghouse Letter LJ"R-FSE-12-26 Revision 2, "Evaluations to Support SNC FLEX Strategies for Vogtle Electric Generating Plant," March 4, 2013 3.20 CN-PCSA-14-6, Westinghouse Calculation, \(ogtle Unit 1 and .Unit 2 EOP Setpoints for ELAP, Revision b 3.21 Westinghouse Letter LTR-FSE-13-46, Rev. 0, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG),

dated August 15, 2013.

3.22 United States NRC Endorsement Letter for Boron Mixing in Regards to Mitigation Strategies Order EA-12-049, January 8, 2014 (ADAMS

Accession Number ML13276A183) 3.23 WCAP-17601-P, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, and Babcock & Wilcox NSSS Designs," Revision 1, dated January 2013 Page 88 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 201.6 Units 1 and 2 3.24 Vogtle Electric Generating Plant Final Safety Analysis Reports Update, Rev20 3.25 Vogtle Electric Generating Plant Technical Requirements Manual, Rev 42

. 3.26 X4C1305S28, Condenser Water Level, Version 2.0 3.27 Westinghouse White PaperTR-FSE-14-1-P, Use of Westinghouse SHIELD Passive Shutdown Seal for FLEX Strategies, Rev. 1, March 2014

. 3.28 Westinghouse Letter LTR-NRC- 14-16, Submittal of TR-FSE-14-1-P, Revision 1 andTR-FSE-14-1-NP, Revision 1, "Use of Westinghouse SHIELD Passive Shutdown Seal for FLEX Strategies" (Proprietary/Non-Propriet~ry), dat.ed March 19, 2014 (ADAMS Accession No. ML14084A497) 3.29 Westinghouse Letter LTR-NRC- 14-24, Submittal of LTR-FSE-1 4-29, Revision 0, "Acceptance Criteria and Applicability of the Westinghouse

~ SHEILD Passive Shutdown Seal for FLEX Strategies" (Non-Proprietary),

dated April 22, 2014 (ADAMS Accession No ML14129A353) 3.30 Westinghouse Letter LTR-FSE-14-29, Acceptance Criteria and Applicability of the Westinghouse SHEILD Passive Shutdown Seal for FLEX Strategies, Rev. 0, April 22, 20f4 3.31 AX4DT108, FLEX Portable System, Sizing Criteria for the Steam Generator FLEX Pump Calculation, Version 2.0 3.32 AX4DT112, FLEX Portable System, CST Makeup Sizing Criteria for the Makeup FLEX Pump, Version 1.0 3.33

AX4DT011,, FLEX Portable System Tank Makeup Subsystem P.hase 2,

Version 1.0 3.34 AX4DT113, FLEX Portable System, CST Makeup Sizing Criteria for the NSCW Sump Pump, Version 2.0 3.35 AX4DT100, FLEX Portable System, Boron Injection Pump Sizing Calculation, Version 2.0 3.36 AX4DT007, FLEX Portable System Boron Injection Subsystem, Version 1.0 3.37 CX2D45V002, Location and Vicinity Map, Version 18.0

Page 89 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 3.38 CX2D45V004, System Area Key Plan, Version 4.0 3.39 Nuclear Energy Institute (NEI) White Paper entitled "Battery Life Issue,"

dated August 27, 2013 (ADAMS Accession No. ML13241A186) 3.40 United States NRC Endorsement Letter of the Nuclear Energy Institute (NEI) White Paper entitled "Battery Life Issue," dated September 16, 2013 (ADAMS Accession No. ML13241A188) 3.41 AX3DT004, FLEX Portable System, Phase 2 480V Alternate Power Subsystem, Version 1.0 3.42 1X4DB184, Reactor Make-up Water Storage Tank and De-Gasifier System, Version 32.0 3.43 AX4DT009, FLEX Portable System, Spent Fuel Pool Subsystem, Version 1.0.

3.44 2X4DB184, Reactor Make-up Water Storage Tank and De-Gasifier System, Version 27.0 3.45 SNC Letter NL-15-1777, Vogtle Electric Generating Plant -Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation, Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool level instrumentation, dated November 20, 2015 (ADAMS Accession No. ML15324A243) 3.46 SNC Letter NL-14-1745, Vogtle Electric Generating Plant -Unit 2 Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool level instrumentation, dated December 1, 2014 (ADAMS Accession No. ML14336A587) 3.47 X4CPS0175, Containment Integrity Analysis for FLEX Coping Strategies, Version 2 3.48 EPRI Report 3002001785, Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications, June 2013 (ADAMS Accession Number ML13190A201) 3.49 United States NRC Endorsement Letter for Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications, October 3, 2013 (ADAMS Accession Number ML13275A318)

Page 90 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 3.50 SNG Letter NL-13-0117, "Vogtle Electric Generating Plant - Units 1 and 2 Flooding Recommendation 2.1 Hazard Reevaluation Report Requested by NRG Letter, Request for Information Pursuant to Title 10 of the Gode 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 Daiichi Accident, dated March 12, 2012," letter dated March 5, 2013 3.51 U.S. Nuclear Regulatory Commission, "Design Basis Tornado for Nuclear Power Plants," Regulatory Guide 1.76, 1974 3.52 FHG-S-13-001 I X1AR50 Procurement Specification for FLEX Equipment Storage Building, Version 2.0 3.53 RE.R NMP-ES-050-F01, FLEX Building Ground Prep and Infrastructure, Version 2.0, Worksheet SNG528260G016 3.54 SNG 528260-02, FLEX Building Ground P~ep and Infrastructure, Version 1.0 3.55 AREVA Document No. 51-9199717-013, National SAFER Response Genter Equipment Technical Requirements 3.56 AX4DT010, FLEX Portable System Fuel Transfer Subsystem Phase 2, Version 2.0 3.57 AX4DT106, FLEX Portable System Evaluation For On-Site Flex Equipment Fuel Consumption, Version 2.0 3.58 X4G1531S05, Main Control Room Heatup During an Extended Loss of AG Power, Version 1.0 3.59

X4G1593S03, Vogtle Auxiliary Feedwater Pump House Heatup Evaluation During an Extended Loss of all AG Power, Version 1.0 3.60 X4G1533V02, Vogtle DG Equipment Rooms Heat Up after an Extended Loss of All AG Power, Version 2.0 3.61 X3GF16, Glass 1E Battery Hydrogen Generation after an Extended Loss of AC Power (ELAP), Version 3.0 3.62 X4G1553V02, Vogtle Auxiliary Building Level D Heat Up After an Extended Loss of All AG Power, Version 2.0 3.63 TSEAL-3-695-49A, Human Tolerance for Short Exposures to Heat Page 91 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 3.64 AX4DT123, Evaluation of Operability of Electrical Equipment in Containm*ent Relied Upon For a BDBEE (FLEX Event), Version 1.0 3.65 SNC Letter NL-12-2070, "Vogtle Electric Generating Plant Units 1 and 2 1

Emergency Preparedness Information 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 ifask Force Review of Insights from the Fukushima Dai-ichi Accident Dated March 12, 2012," letter dated October 31, 2012 3.66 Nuclear Energy Institute position paper*entitled "Position Paper:

Shutdown/ Refueling Modes:* dated September 18, 2013 (ADAMS Accession No. ML13273A514) 3.67 United States NRC Endorsement Letter of the Nuclear Energy Institute (NEI) Position Paper entitled "Position Paper: Shutdown/ Refueling Modes," dated September 30, 2013 (ADAMS Accession No. ML13267A382) 3.68 Nuclear Energy Institute (NEI) 96-07, Revision 1, Guidelines For 10 CFR 50.59 Implementation, dated November 2000 3.69 NMP-GM-038, Diverse and Flexible Coping Strategies (FLEX) Program, Version 1.1 3.70 NMP-GM-038-003, Vogtle Electric Generating Plant Diverse and Flexible Coping Strategies (FLEX) Program Document, Version 1.1 3.71 19100-C,ECA-O.O, Loss of.All AC Power, Version 39 3.72 Nuclear Energy Institute (NEI) 97-04, Revision 1, Design Bases Program Guidelines, dated February 2001 3.73 Nuclear Energy Institute (NEI) 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, dated May 3, 2012 (ADAMS Accession No. ML12125A410) 3.74 SNC Letter NL 13-0765, Vogtle Electric Generating Plant - Units 1 and 2 Emergency Preparedness. Information Requested by NRC Letter, Request for Information Pursuant to Title 1O 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 Daiichi Accident, -letter dated April 30, 2013 [VEGP Phase 1 Staffing Assessment], Version 1.0 Page 92 of 93

FINAL INTEGRATED PLAN Vogtle Electric Generating Plant May 2016 Units 1 and 2 3.75 SNC letter NL 14-0585, Vogtle Electric Generating 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, letter dated May 16, 2014 [VEGP Phase 2 Staffing Assessment], Version 1.0 3.76 NMP-OS-019-013, Beyond Design Basis Equipment Unavailability Tracking, Version 1.0 3.77 NMP-GM-036, Duty Manager, Version 1.0 3.78 MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1020236),

July 2010 3.79 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(ML12053A340) 3.80 NRC Letter from J. Davis, NRC, to J. A. Gresham, Westinghouse Electric Company, LLC, dated May 28, 2014(ML14132A128) .

~

3.81 *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 BDBEEs, Revision 1, dated January 22, 1016, (ADAMS Accession No. ML15357A163) 3.82 Nuclear Energy Institute letter to Administrative Points of Contact (APC 14-17), Validation Document for FLEX Strategies, dated July 18, 2014.

Page 93 of 93

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY 1 May 23, 2016 Docket No.: 50-424 NL-16-0228 50-425 U. S. Nuclear Regulatory Commission .

ATTN: Document Control Desk Washington, D. C. 20555-0001 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 Ladies and Gentlemen:

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, to Southern Nuclear Operating Company (SNC). This Order 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. This letter provides the notific;:ation required by Item IV.C.3 of Order EA-12-049 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for both VEGP Units 1 and 2 on March 27, 2016 as Unit 2 completed refueling outage U2R18. SNC previously notified the NRC of the Unit 1 compliance with the Order on November 20, 2015. summarizes VEGP Units 1 and 2's compliance with Order EA-12-049. Enclosure 2 contains the VEGP Units 1 and 2 Final Integrated Plan (FIP) which provides strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design basis external event. Prior to the issuance of Order EA-12-049, the Nuclear Energy Institute notified the NRC of an industry initiative on procurement of equipment for the diverse and flexible coping strategy (letter dated February 24, 2012). The VEGP Units 1 and 2 FIP includes a list of equipment used for implementation of this Order wnich is more refined and supersedes the list which was procured for the 2012 initiative.

The VEGP FIP is based on NEI 12-06, Rev. 2 with the exception of Appendix E which was finalized after the validation process was completed. Other aspects of NEI 12-06, Rev. 2, while not applicable to this Order compliance, will be utilized for upcoming submittals (e.g., use of re-evaluated hazards, Appendix G and Appendix H) and rulemaking (e.g., references to NEI 13-06 and NEI 14-01).

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

U.S. Nuclear Regulatory Commission NL-16-0228 Page 2 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.

Rec.e~lyp;:ed,

.,': ~-

C.R. Pierce Regulatory Affairs Director *'

CRP/JMG/MRE

.d-Sw rn to and sub cribed before me this Z:J day of /YI CJ f '2016.

My commission expires: 1/z/zofg.

I I

Enclosures:

1. Compliance with Order EA-12-049

2. Vogtle Electric Generating Plant Final Integrated Plan cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President - Vogtle 1& 2 Mr. M. D. Meier, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Vogtle 1 & 2 Mr. A. M. Alen Resident Inspector - Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director - Environmental Protection Division

Vogtle Electric Generating Plant - Units 1 and 2 Notification of Full Compliance of for NRG Orders EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 1 Compliance with Order EA-12-049 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 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 effective immediately and directed the Vogtle Electric Generating Plant (VEGP) - Units 1 and 2 to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049. SNC developed an Overall Integrated Plan (OIP) (Reference 2 and revised in Reference 11) to provide FLEX. The information provided herein, as well as the implementation of the OIP, documents full compliance for VEGP Units 1 and 2 in response to the Order (Reference 1).

Open Item Resolution Following issuance of the NRC Audit Report (Reference 13), there were no open items from either it or the NRC Interim Staff Evaluation (ISE) (Reference 7). All identified items in the audit have been addressed and documented in the site CAP program.

Interim Staff Evaluation (ISE) Open Items - VEGP Units 1 and 2 has no open or pending items

Licensee Identified Open Items - VEGP Units 1 and 2 has no open or pending licensee identified open items

Audit Questions/Audit Report Open Items - VEGP Units 1 and 2 FLEX has no open or pending items Milestone Schedule - Items Complete VEGP Unit 1 & 2 Milestone Completion Date Submit 20 Day Letter Acknowledging Receipt of Order March 2012 Submit Overall Integrated Plan February 2013 1*t 6 Month Update August 2013 2nd 6 Month Update February 2014 Unit 1 - 1st Refueling Outage April 2014 3rd 6 Month Update August 2014 Unit 2 - 1st Refueling Outage October 2014 4th 6 Month Update February 2015 Develop Modifications March 2015 Develop Training Material June 2015 Develop Strategies (Vogtle Response Plan) with June 2015 National SAFER Response Center 5th 6 Month Update August 2015 Develop Operational Procedure Changes October 2015 Unit 1 Walk-throughs or Demonstrations October 2015 E1-1 to NL-16-0228 Vogtle Electric Generating Plant - Units 1&2 Compliance with Order EA-12-049 VEGP Unit 1 & 2 Milestone Completion Date Implement Training October 2015 Unit 1 - 2nd Refueling Outage/ Implementation Complete October 2015 Phase 2 Equipment Procurement Complete December 2015 61h 6 Month Update February 2016 Develop FSGs February 2016 Issue FSGs February 2016 Unit 2 Walk-throughs or Demonstrations February 2016 Unit 2 - 2nd Refueling Outage/ Implementation Complete March 27, 2016 Order EA-12-049 Compliance Elements Summary The elements identified below for VEGP Units 1 and 2 are included in the Final Integrated Plan (FIP) (Enclosure 2) and demonstrate compliance with Order EA-12-049.

Strategies - Complete

VEGP Units 1 and 2 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit

Questions/Audit Report Open Items.