NOC-AE-15003287, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

ML15251A208
Person / Time
Site:	South Texas
Issue date:	08/26/2015
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NOC-AE-15003287, STI: 34178368, TAC MF0825, TAC MF0826
Download: ML15251A208 (8)

Text

Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, Texas 77483 pNA* -

August 26, 2015 NOC-AE-1 5003287 10 CFR 2.202 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units I & 2 Docket Nos. STN 50-498, STN 50-499 STPNOC Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies For Beyond-Desiqn-Basis External Events (Order EA-12-049) (TAC Nos. MF0825 and MF0826)

References:

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", March 12, 2012 (ML12073A195)

2. Letter from D.W. Rencurrel, STPNOC, to NRC Document Control Desk, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", October 24, 2012 (ML12310A389) (NOC-AE-1 3002909)

3. Letter from D.L. Koehl, STPNOC, to NRC Document Control Desk, "STPNOC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", February 28, 2013 (ML13070A011) (NOC-AE-13002963)

4. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "STPNOC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049)", August 26, 2013 (ML13249A060) (NOC-AE-1 3003027)

5. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "STPNOC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049)", February 27, 2014 (ML14073A458) (NOC-AE-1 4003089)

6. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "STPNOC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049)(TAC Nos. MF0825 and MF0826)", August 27, 2014 (ML14251A029)

(NOC-AE-1 4003162)  : / _

STI: 34178368

NOC-AE-1 5003287 Page 2 of 4

7. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "STPNOC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049)(TAC Nos. MF0825 and MF0826)", February 26, 2015 (ML15075A019)

(NOC-AE-1 5003224)

8. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "Notification of Compliance with Orders EA-12-049 for Mitigation Strategies for Beyond-Design-Basis External Events and EA-12-051 for Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0826 and MF0828)", July 2, 2015 (ML15196A031 ) (NOC-AE-1 5003257)

9. Nuclear Energy Institute (NEI) Guidance 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, August 21, 2012 (ML12242A378)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to South Texas Project Nuclear Operating Company (STPNOC) 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. The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, of EA-12-049 delineating progress made in implementing the requirements of EA-12-049.

The Attachment included with this letter provides updates to milestone accomplishments since the last status report including any changes to the compliance method, schedule, or need for relief and the associated basis.

Per the requirements of Reference 1, STPNOC submitted an initial status report (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C of the Order (Reference 3). STPNOC has submitted four status updates to the Overall Integrated Plan (References 4-7) as well as a notification of compliance with Order EA-12-049 for STP Unit 2 (Reference 8).

There have been no significant changes to the STP FLEX strategies since the submittal of the last six-month status report and the Unit 2 compliance letter (References 7-8).

Direction regarding the content of the status reports is provided in NEI 12-06 (Reference 9).

NOC-AE-1 5003287 Page 3 of 4 This letter contains no new regulatory commitments.

If there are any questions regarding this letter, please contact Wendy Brost at (361) 972-8516 or me at (361) 972-7566.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:"'/-/Ž*"/. Z*vS G. T. Powell Site Vice President web

Attachment:

STP Nuclear Operating Company (STPNOC) Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

NOC-AE-1 5003287 Page 4 of 4 CC:

(paper copy) (electronic copy)

Regional Administrator, Region IV Morgqan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission Steve Frantz, Esquire 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regqulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission NRG South Texas LP One White Flint North (MS 08 H04) John Ragan 11555 Rockville Pike Chris O'Hara Rockville, MD 20852 Jim von Suskil NRC Resident Inspector City Public Service U. S. Nuclear Regulatory Commission Kevin Polio P. O. Box 289, Mail Code: MN116 Cris Eugster Wadsworth, TX 77483 L.D. Blaylock William Dean Cramn Caton & James, P.C.

Director, Office of Nuclear Reactor Regulation Peter Nemeth U.S. Nuclear Regulatory Commission One White Flint North (MS 13 H 16) 11555 Rockville Pike City of Austin Rockville, MD 20852 C. Mele John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free

Attachment NOC-AE-1 5003287 Page 1 of 4 STP Nuclear Operating Company (STPNOC) Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction There have been no significant changes to the STP FLEX strategies since the submittal of the last six-month status report and the Unit 2 compliance letter (References 4-5).

STP Unit 2 came in to full compliance with Order EA-12-049 on May 7, 2015. Plant modifications are ongoing for STP Unit 1 and will be completed prior to the startup from refueling outage 1 RE19.

2. Milestone Accomplishments

• STP Unit 2 came into full compliance with Order EA-1 2-049 on May 7, 2015.

• The Order EA-12-049 compliance letter for STP Unit 2 was submitted July 2, 2015 (Reference 5). The compliance letter includes a response to each of the open and pending issues listed in the NRC tracking system for STP.

• Plant modifications for FLEX strategies have been completely evaluated and field installations are ongoing for STP Unit 1.

3. Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 1).

It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Items in bold have been changed since the last status update.

Milestone Target Activity Revised Target Completion Date Status Completion Date Submit 60 Day Status Report October 2012 Complete None Submit Overall Integrated Plan February 2013 Complete None Submit 6 Month Updates:

Update 1 August 2013 Complete None Update 2 February 2014 Complete None Update 3 August 2014 Complete None Update 4 February 2015 Complete None Update 5 August 2015 Complete None

Attachment NOC-AE-1 5003287 Page 2 of 4 Milestone "rarget Activity Revised Targqet Completion Date Status Completion Date Update 6 February 2016 Not Started Update 7 August 2016 Not Started FLEX StrategyEvaluation September 2013 Complete None Walk-throughs or Demonstrations December 2014 Started *A"*"

November 2015 Perform Staffing Anaiysis December 2013 Complete July201 Modifications:

Modifications Evaluation September 2013 Complete None Unit 1 Design Engineering January 2014 Started October 2015 Unit 1 Implementation Outage October 2015 Not started Unit 2 Design Engineering January 2014 Complete April 2015 Unit 2 Implementation Outage April 2015 Complete None Storage (outside Protected Area):

Storage Design Engineering September 2013 Complete May 2014 Storage Implementation Api 05 Complete None FLEX Equipment:________

Procure On-Site Equipment January 2014 Complete June 2015 Develop Strategies with Regional October 2013 Complete April 2015 Response Center Procedures:

PWROG 1 issues NSSS 2 -specific April 2015 Complete None guidelines______ ____

Create Site-Specific FSGs 3 April 2015 Started November 2015 Create Maintenance Procedures May 2014 Complete April 2015 Training: _________

Develop Training Plan May 2014 Complete Jan 2015 Trainng CopleteSeptmber 014 Cmplet W2r1-25M TraiingComlet Setembr 214 ompete March 2015 Unit I FLEX Implementation October 2015 Started Unit 2 FLEX Implementation April 2015 Complete May 2015 Submit Completion Report and Final Started Otbr21 Integrated Plan ________ ______ January 2016 1PWROG - Pressurized Water Reactor Owner's Group 2 NSSS - Nuclear Steam Supply System 3 FSG -FLEX Support Guidelines

Attachment NOC-AE-1 5003287 Page 3 of 4 4, Changes to Compliance Method There have been no changes to the compliance method since the submittal of the last six-month status report and the Unit 2 compliance letter (References 4-5).

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation STPNOC expects to comply with the Order implementation date and no relief/relaxation is required at this time.

6. Open Items from Overall Integrated Plan, the Draft Safety Evaluation and the Mitigating Strategies Audit The Order EA-1 2-049 compliance letter for STP Unit 2 was submitted July 2, 2015 (Reference 5). The compliance letter includes a response to each of the open and pending issues listed in the NRC tracking system for STP.

7. Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Attachment NOC-AE-1 5003287 Page 4 of 4

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

1. Letter from D.L. Koehi, STPNOC, to NRC Document Control Desk, "STPNOC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", February 28, 2013 (ML13070A011 )

(NOC-AE-1 3002963)

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12, 2012. (ML12054A735) (AE-NOC-1 2002268)

3. Letter from J.S. Bowen, NRC, to D.L. Koehl, STPNOC, "South Texas Project, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)", January 29, 2014.. (ML13339A736) (AE-NOC-1 4002494)

4. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "STPNOC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)(TAC Nos. MF0825 and MF0826)",

February 26, 2015 (ML15075A019) (NOC-AE-1 5003224)

5. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "Notification of Compliance with Orders EA-12-049 for Mitigation Strategies for Beyond-Design-Basis External Events and EA-12-051 for Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0826 and MF0828)", July 2, 2015 (ML15196A031 ) (NOC-AE-1 5003257)