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| issue date = 01/13/2016
| issue date = 01/13/2016
| title = Edwin I Hatch Nuclear Plant, Units 1 and 2- Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051
| title = Edwin I Hatch Nuclear Plant, Units 1 and 2- Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051
| author name = Paige J C
| author name = Paige J
| author affiliation = NRC/NRR/JLD
| author affiliation = NRC/NRR/JLD
| addressee name = Pierce C R
| addressee name = Pierce C
| addressee affiliation = Southern Nuclear Operating Co, Inc
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000321, 05000366
| docket = 05000321, 05000366
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295 /BIN B038 Birmingham, AL 35201-1295 January 13, 2016
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 13, 2016 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
P.O. Box 1295 /BIN B038 Birmingham, AL 35201-1295


==SUBJECT:==
==SUBJECT:==
EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 -REPORT FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0712, MF0713, MF0721, AND MF0722)  
EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 - REPORT FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0712, MF0713, MF0721, AND MF0722)


==Dear Mr. Pierce:==
==Dear Mr. Pierce:==
On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, respectively).
 
The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.
On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of of each order will be achieved.
By letter dated February 27, 2013 (ADAMS Accession No. ML 13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049.
By letter dated February 27, 2013 (ADAMS Accession No. ML13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049. By letters dated August 27, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A238, ML14057A776, ML14239A650, ML15057A315. and ML152398301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28. 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit.
By letters dated August 27, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML 13240A238, ML 14057A776, ML 14239A650, ML 15057A315.
 
and ML 152398301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28. 2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).
C. Pierce                                         By letter dated February 27, 2013 (ADAMS Accession No. ML13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051. By letter dated August 1, 2013 (ADAMS Accession No. ML13203A118), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A236, ML13242A293, ML14057A778, ML14239A298, ML15057A273, and ML15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML13294A529). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.
This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML 13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit.
The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents/Final Integrated Plans while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.
C. Pierce By letter dated February 27, 2013 (ADAMS Accession No. ML 13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051.
In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 - 29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML15266A345). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
By letter dated August 1, 2013 (ADAMS Accession No. ML 13203A 118), the NRC staff sent a request for additional information (RAI) to the licensee.
The enclosed audit report provides a summary of the activities for the onsite audit portion.
By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML 13240A236, ML 13242A293, ML 14057A778, ML 14239A298, ML 15057A273, and ML 15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML 13294A529).
Additionally, this report contains attachments listing the attendees and documents reviewed by the staff while onsite.
By letter dated March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above. The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions.
 
Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents/Final Integrated Plans while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.
C. Pierce                                   If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.
In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 -29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML 15266A345).
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The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
The enclosed audit report provides a summary of the activities for the onsite audit portion. Additionally, this report contains attachments listing the attendees and documents reviewed by the staff while onsite.
C. Pierce If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.
Docket Nos. 50-321 and 50-366  


==Enclosure:==
==Enclosure:==


Audit report cc w/encl: Distribution via Listserv Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS AND RELIABLE SPENT FUEL POOL INSTRUMENTATION SOUTHERN NUCLEAR OPERATING COMPANY EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation,'' (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, respectively).
Audit report cc w/encl: Distribution via Listserv
The orders require holders of operating reactor licenses and construction permits issued under Title 1 O of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how complian.ce with the requirements of Attachment 2 of each order will be achieved.
 
By letter dated February 27, 2013 (ADAMS Accession No. ML 13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049.
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS AND RELIABLE SPENT FUEL POOL INSTRUMENTATION SOUTHERN NUCLEAR OPERATING COMPANY EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation,'' (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 1O of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how complian.ce with the requirements of of each order will be achieved.
By letters dated August 27, 2013, February 26, 2014, August 26. 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML 13240A238, ML 14057A776, ML 14239A650, ML 15057A315, and ML 15239B301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).
By letter dated February 27, 2013 (ADAMS Accession No. ML13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049. By letters dated August 27, 2013, February 26, 2014, August 26. 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A238, ML14057A776, ML14239A650, ML15057A315, and ML15239B301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit.
This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML 13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit. Enclosure   By letter dated February 27, 2013 (ADAMS Accession No. ML 13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051.
Enclosure
By letter dated August 1, 2013 (ADAMS Accession No. ML 13203A 118), the NRC staff sent a request for additional information (RAI) to the licensee.
 
By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML 13240A236, ML 13242A293, ML 14057 A778, ML 14239A298, ML 15057 A273, and ML 15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML 13294A529).
By letter dated February 27, 2013 (ADAMS Accession No. ML13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051. By letter dated August 1, 2013 (ADAMS Accession No. ML13203A118), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A236, ML13242A293, ML14057A778, ML14239A298, ML15057A273, and ML15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML13294A529). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.
By letter dated March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above. The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions.
The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs) while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.
Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs) while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.
In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 - 29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML15266A345). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 -29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML 15266A345).
Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML12242A378), as endorsed, by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) 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"' (ADAMS Accession No. ML12229A174) as providing one acceptable means of meeting the order requirements. For Order EA-12-051, the staff will make a safety determination regarding order compliance using the NEI guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12221A339) as providing one acceptable means of meeting the order requirements. Should the licensee propose an
The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
 
Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML 12242A378), as endorsed, by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) 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"' (ADAMS Accession No. ML 12229A174) as providing one acceptable means of meeting the order requirements.
alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate if the alternative strategy complies with the applicable order.
For Order EA-12-051, the staff will make a safety determination regarding order compliance using the NEI guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML 12240A307), as endorsed, with exceptions and clarifications, by NRC JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML 12221A339) as providing one acceptable means of meeting the order requirements.
AUDIT ACTIVITIES The onsite audit was conducted at the Hatch facility from October 26, 2015, through October 29, 2015. The NRC audit team staff was as follows:
Should the licensee propose an   alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate if the alternative strategy complies with the applicable order. AUDIT ACTIVITIES The onsite audit was conducted at the Hatch facility from October 26, 2015, through October 29, 2015. The NRC audit team staff was as follows: Title Team Member T earn Lead I Project ManaQer Jason PaiQe Technical Support Garry Armstrong Technical Support Matthew McConnell Technical Support Joshua Miller Technical Support Due NQuven Technical Support Bruce Heida The NRC staff executed the onsite portion of the audit per the three part approach discussed in the September 29, 2015, plan, to include conducting a tabletop discussion of the site's integrated mitigating strategies compliance program, a review of specific technical review items, and discussion of specific program topics. Activities that were planned to support the above included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
Title                                       Team Member Tearn Lead I Project ManaQer                               Jason PaiQe Technical Support                                   Garry Armstrong Technical Support                                 Matthew McConnell Technical Support                                     Joshua Miller Technical Support                                     Due NQuven Technical Support                                     Bruce Heida The NRC staff executed the onsite portion of the audit per the three part approach discussed in the September 29, 2015, plan, to include conducting a tabletop discussion of the site's integrated mitigating strategies compliance program, a review of specific technical review items, and discussion of specific program topics. Activities that were planned to support the above included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.
AUDIT  
AUDIT  


==SUMMARY==
==SUMMARY==


===1.0 Entrance===
1.0     Entrance Meeting (October 26. 2015)
Meeting (October 26. 2015) At the audit entrance meeting, the NRC staff audit team introduced itself followed by introductions from the licensee's staff. The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule.  
At the audit entrance meeting, the NRC staff audit team introduced itself followed by introductions from the licensee's staff. The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule.
2.0    Integrated Mitigating Strategies Compliance Program Overview Per the audit plan and as an introduction to the site's program, the licensee provided a presentation to the NRC audit team titled "Hatch FLEX Presentation." The licensee provided an overview of its strategy to maintain core cooling, containment, and SFP cooling in the event of a beyond-design-basis external event (BDBEE), and the plant modifications being done in order to implement the strategies. Also presented was the design and location of the FLEX equipment storage facility, the FLEX equipment that would be stored there, the interface with the National SAFER Response Centers (NSRCs), and the spent fuel pool level indication modification.
3.0    Onsite Audit Technical Discussion Topics Based on the audit plan, and with a particular emphasis on the Part 2 "Specific Technical Review Items," the NRC staff technical reviewers conducted interviews with licensee technical staff, site walk-downs, and detailed document review for the items listed in the plan.


===2.0 Integrated===
3.1  Reactor Systems Technical Discussions and Walk-Downs The NRC staff reviewed the licensee's modeling of an extended loss of all alternating current (ac) power (ELAP) for Hatch and its ability to mitigate the event, including the computer code Modular Accident Analysis Program (MAAP) used and input parameters assumed to generate the results of the analysis. The licensee noted that the MAAP analysis was carried out in accordance with EPRI 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications," dated June 2013. In addition, the licensee indicated that EPRI later released the BWR (boiling water reactor] roadmap EPRI 3002002749, "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4." The licensee followed the BWR template for Hatch using site specific information. The licensee's analysis confirmed that the collapsed vessel level would not fall below the top of active fuel, and confirmed that the cooldown rate for the primary system would remain within the technical specification limits.
3.2  Electrical Technical Discussions and Walk-Downs The NRC staff reviewed Hatch's load shedding procedures, FLEX diesel generator (DG) sizing calculations, manufacturer's specifications, and FLEX Support Guidelines (FSGs) to confirm that they are of sufficient capacity to supply the expected loads. The licensee calculated that the direct current system can provide power to the required BDBEE loads for at least 13 hours given that load shedding is completed within 75 minutes of an ELAP being declared. The licensee plans to connect the FLEX DGs within 1O hrs. The licensee indicated that Hatch's Phase 2 electrical strategy is to connect the FLEX DGs directly to the 600 V busses. The alternate strategy is to connect directly to the battery charger disconnects using cables. For Phase 3, the licensee can connect the NSRC DGs to the 4160 V busses 1E and 2E. The alternate strategy is to connect the DGs to the 4160 V busses 1G and 2G. The licensee noted that the Phase 2 DGs have been checked for phase rotation in comparison to plant typical rotation. In addition, color coding of the extension cables has been used to ensure that proper phase rotation will be achieved when cables are connected from the pigtails supplied on the generator to the connections at the breaker into the plant electrical supply. Lastly, the licensee generated a corrective action to enhance or verify that any and all procedures developed for connecting a DG received from the NSRCs will be checked for proper phase rotation prior to being placed in service to supply plant electrical loads during an ELAP event.
3.3  SFPI Technical Discussions and Walk-Downs The NRC staff walked down the SFP area, SFPI locations, and related equipment mounting areas. No concerns were identified during the walk-downs. The staff also reviewed the associated calibration, maintenance, and test procedures for the SFP level instrumentation.


Mitigating Strategies Compliance Program Overview Per the audit plan and as an introduction to the site's program, the licensee provided a presentation to the NRC audit team titled "Hatch FLEX Presentation." The licensee provided an overview of its strategy to maintain core cooling, containment, and SFP cooling in the event of a beyond-design-basis external event (BDBEE), and the plant modifications being done in order to implement the strategies.
3.4    Other Technical Discussion Areas and Walk-Downs
Also presented was the design and location of the FLEX equipment storage facility, the FLEX equipment that would be stored there, the interface with the National SAFER Response Centers (NSRCs), and the spent fuel pool level indication modification.  
: a. The staff reviewed design documents of the FLEX equipment storage location to verify that adequate capability would exist to mitigate a BDBEE. In addition, the staff walked down the storage location of the FLEX equipment. The licensee indicated that the storage location for the FLEX portable equipment will be the new FLEX dome, which is designed to protect the equipment from all external hazards as described in NEI 12-06.
Originally, the licensee's strategy included two FLEX storage locations, therefore, the licensee stated that the evaluation for axis of separation for multiple locations is no longer needed with the new FLEX dome in place, which can protect from tornado missiles and design basis high wind events.
: b. The staff reviewed the FLEX connection points to verify that at least one connection point is accessible through a seismically robust structure. The water source (i.e.,Altamaha River) for the core cooling and SFP cooling strategies is supplied by the FLEX pumps to the seismically qualified residual heat removal service water (RHRSW) piping via FLEX connections within the intake structure valve pit. The existing missile shield grating protects these connections and the associated piping. A new permanent platform is provided to allow plant personnel to access the new FLEX inlet valves in the intake structure valve pit. In addition, a new ladder is installed to allow plant personnel access to the new FLEX connections. The new platform and ladder are installed in a seismic Category I structure (Intake Structure), as well as in the vicinity of existing safety-related piping and valves. Permanent conduits are installed and routed from the 600 V bus inside the control building to a seismically mounted FLEX connection box (one per unit) in the west cableway. Two seismically robust, wind-rated, missile-protected penetrations (one per division) have been installed to provide protection to the new connection box located inside the west cableway, near the penetration.
: c. The staff walked down the deployment routes and the debris removal equipment. The licensee indicated that the primary and alternate routes for transporting FLEX equipment have been established. Debris removal will be accomplished using a front loader. The licensee evaluated the potential obstacles to ensure that the front loader is capable of removing all potential debris. Four hours has been allocated for debris removal as documented in the Hatch Phase 2 staffing study. The front loader will be stored in the FLEX Dome along with a freightliner truck and an additional truck to haul vehicles.
: d. The staff reviewed the hydraulic analysis for the FLEX pumps and hoses used for all areas for makeup after an ELAP. The licensee provided the calculations for the primary and alternative connections and hydraulic analyses for the hose runs for reactor pressure vessel (RPV) and SFP makeup. The licensee intends to use the FLEX pump for condensate tank makeup after the 7.5 hour timeframe for makeup to the RPV via RCIC. Alternatively, the FLEX pump can be staged near the Intake Structure in order to take suction from the Altamaha River for injection into the RPV via RHRSW piping to RHR.. In the hydraulic analysis, the licensee concluded that the FLEX pump is capable of satisfying the minimum required flow to both units for makeup to the RPV and SFP during an ELAP event. The licensee also provided the hose lengths needed to maintain the minimum flow requirement, since the strategy accounts for both makeup functions to occur together when the RHRSW is the makeup source.
: e. The staff reviewed the robustness of the condensate storage tanks (CSTs). The licensee stated that the CSTs are credited for the use of the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) suctions for injection due to the tanks being protected from tornado missiles and seismic hazards. The enclosure walls surrounding the tanks provide protection from tornado missiles and are designed as seismic Category I structures. The CST is designed to prevent the usage of a credited amount of water in the tank by systems other than RCIC and HPCI.
Instrumentation and controls, system piping and valves associated with the RCIC and HPCI suction swap-over function are safety grade and seismic, and are qualified for all potential ELAP events. The suction valves will be aligned according to existing procedures, either from the main control room or a remote control panel. The licensee noted that although other water sources are available for CST makeup, the Altamaha River would be the primary source of makeup utilizing the FLEX pumps once the CST inventory is depleted after 10 hours.
: f. The licensee plans to replenish water supplies by using portable FLEX pumps taking suction from the Ultimate Heat Sink (Altamaha River). The staff verified that the FLEX pumps and hoses will remain unhindered and clear of debris accumulation due to the pumps taking suction from an untreated water source. The licensee described the FLEX pump as being designed with two submersible pumps, in which both submersible pumps operate during the operation of the main pump. Each submersible pump is encased in a mesh screen cage, thereby limiting the size of debris that can be sucked into the pump.
Each submersible pump supplies enough flow for both units' FLEX needs, therefore, if one submersible pump becomes completely clogged, the other is sufficient to supply the main pump with the necessary flow. These pumps are required to be in service at 10 hours after the initiation of the ELAP. Supplemental personnel begin arriving at 6 hours after the start of the ELAP, which allows for adequate manpower to remove a submersible pump from the river and clean the pump casing and return it to the river.
Each submersible pump has individual hydraulic lines used to power the pump and each pump has two discharge pipes supplying the main pump. The licensee noted that the design of pumps prevents an issue with one pump from debilitating the other.
4.0      Exit Meeting (October 29. 2015)
The NRC staff audit team conducted an exit meeting with the licensee staff following the closure of onsite audit activities. The NRC staff highlighted items reviewed and noted that the results of the onsite audit trip will be documented in this report.
CONCLUSION The NRC staff completed all three parts of the September 29, 2015, onsite audit plan. Each audit item listed in Part 2 of the plan was reviewed by NRC staff members while on site. In addition to the list of NRC and licensee onsite audit staff participants in Attachment 1,  provides a list of documents reviewed during the onsite audit portion.
In support of the continuing audit process as the licensee proceeds towards orders compliance for this site, the NRC staff is evaluating the audit items listed below in anticipation of issuance of a combined safety evaluation for both the Mitigation Strategies and Spent Fuel Pool Level Instrumentation orders.
: a.      Interim Staff Evaluation (ISE) Open Items (Ols) and Confirmatory Items (Cls)
: b.      Audit Questions (AQs)
: c.      Licensee-identified Overall Integrated Plan (OIP) Open Items (Ols)
: d.      Spent Fuel Pool Level Instrumentation Requests for Additional Information (RAls)
: e.      Additional Safety Evaluation (SE) needed information The attachments provide audit information as follows:
: a.      Attachment 1: List of NRC staff and licensee staff audit participants
: b.      Attachment 2: List of documents reviewed during the onsite audit While this report notes the completion of the onsite portion of the audit per the audit plan dated September 29, 2015, the ongoing audit process continues as per the letters dated August 28, 2013, and March 26, 2014, to all licensees and construction permit holders for both orders.
Additionally, while this audit report provides a progress snapshot of the NRC staff's review of the licensee's OIPs, as supplemented, and as augmented in the audit process, the status and progress of the NRC staff's review may change based on licensee plan changes, resolution of generic issues, and other NRC staff concerns not previously documented. Changes in the NRC staff review will be communicated in the ongoing audit process.
Lastly, the licensee has identified open items that need to be completed to implement orders EA-12-049 and EA-12-051, and the staff expects that the licensee continue to provide updates on the status of the licensee identified open items in their 6-month updates or on the ePortal.
Attachments:
: 1. NRC and Licensee Staff Onsite Audit Participants
: 2. Onsite Audit Documents Reviewed
 
Onsite Audit Participants NRC Staff:
Jason Paige          NRR/JLD/JOMB                  Josh Miller        NRR/JLD/JERB Garry Armstrong      NRR/JLD/JCBB                  Due Nguyen        NRR/JLD/JERB Matthew McConnell    NRR/JLD/JERB                  Bruce Heida        NRR/JLD/JCBB Hatch Staff:
David R. Vineyard            Site Vice President Richard A. (Tony) Spring    Plant Manager Robert J. Anderson          Radiation Protection Manager Andy Belcher                Nuclear Oversight Manager - Site Anthony D. Giancatarino      Engineering Director Greg L. Johnson              Site Regulatory Affairs Manager Daniel Adam Komm            Operations Director Keith D. Long                Work Management Director Jonathan M. Merritt          Site Security Management Pat Swinson                  IT Manager Al M. Wheeler                Site Project Manager J. Derwood Tootle            Severe Accident Management Manager Randy C. Bunt              Corporate Severe Accident Management Manager John M. Giddens            Corporate Licensing Manager Matthew R. Euten            Licensing Engineer Deep Ghosh                  Lead Engineer Brad Osterbuhr              Senior Engineer John Cole                    Senior Engineer Frank D. Sellers            Security Shift Lieutenant Blake Bolt                  Work Week Manager Lee S. Williams              Flex PM Writer/Contractor David H. Giddens            Flex Procedure Writer/ X-SRO/Contractor Ronnie D. Musgrove          Flex Procedure Writer/X-SRO/Contractor Rob Brixey                  Training Procedure Writer/Contractor April Perkins                Senior Engineer Bryan Hess                  Bechtel/ Mechanical Design Supervisor Josef Barrick                Enercon/ Electrical Engineer Stacey Fredenberg          Enercon/Lead Mechanical Engineer Norman Good                Sargent &Lundy/ l&C Engineer Michael Hopman              Bechtel/ Mechanical Design Engineer Attachment 1


===3.0 Onsite===
Audit Technical Discussion Topics Based on the audit plan, and with a particular emphasis on the Part 2 "Specific Technical Review Items," the NRC staff technical reviewers conducted interviews with licensee technical staff, site walk-downs, and detailed document review for the items listed in the plan. 3.1 Reactor Systems Technical Discussions and Walk-Downs The NRC staff reviewed the licensee's modeling of an extended loss of all alternating current (ac) power (ELAP) for Hatch and its ability to mitigate the event, including the computer code Modular Accident Analysis Program (MAAP) used and input parameters assumed to generate the results of the analysis.
The licensee noted that the MAAP analysis was carried out in accordance with EPRI 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications," dated June 2013. In addition, the licensee indicated that EPRI later released the BWR (boiling water reactor] roadmap EPRI 3002002749, "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4." The licensee followed the BWR template for Hatch using site specific information.
The licensee's analysis confirmed that the collapsed vessel level would not fall below the top of active fuel, and confirmed that the cooldown rate for the primary system would remain within the technical specification limits. 3.2 Electrical Technical Discussions and Walk-Downs The NRC staff reviewed Hatch's load shedding procedures, FLEX diesel generator (DG) sizing calculations, manufacturer's specifications, and FLEX Support Guidelines (FSGs) to confirm that they are of sufficient capacity to supply the expected loads. The licensee calculated that the direct current system can provide power to the required BDBEE loads for at least 13 hours given that load shedding is completed within 75 minutes of an ELAP being declared.
The licensee plans to connect the FLEX DGs within 1 O hrs. The licensee indicated that Hatch's Phase 2 electrical strategy is to connect the FLEX DGs directly to the 600 V busses. The alternate strategy is to connect directly to the battery charger disconnects using cables. For Phase 3, the licensee can connect the NSRC DGs to the 4160 V busses 1 E and 2E. The alternate strategy is to connect the DGs to the 4160 V busses 1 G and 2G. The licensee noted that the Phase 2 DGs have been checked for phase rotation in comparison to plant typical rotation.
In addition, color coding of the extension cables has been used to ensure that proper phase rotation will be achieved when cables are connected from the pigtails supplied on the generator to the connections at the breaker into the plant electrical supply. Lastly, the licensee generated a corrective action to enhance or verify that any and all procedures developed for connecting a DG received from the NSRCs will be checked for proper phase rotation prior to being placed in service to supply plant electrical loads during an ELAP event. 3.3 SFPI Technical Discussions and Walk-Downs The NRC staff walked down the SFP area, SFPI locations, and related equipment mounting areas. No concerns were identified during the walk-downs.
The staff also reviewed the associated calibration, maintenance, and test procedures for the SFP level instrumentation. 3.4 Other Technical Discussion Areas and Walk-Downs
: a. The staff reviewed design documents of the FLEX equipment storage location to verify that adequate capability would exist to mitigate a BDBEE. In addition, the staff walked down the storage location of the FLEX equipment.
The licensee indicated that the storage location for the FLEX portable equipment will be the new FLEX dome, which is designed to protect the equipment from all external hazards as described in NEI 12-06. Originally, the licensee's strategy included two FLEX storage locations, therefore, the licensee stated that the evaluation for axis of separation for multiple locations is no longer needed with the new FLEX dome in place, which can protect from tornado missiles and design basis high wind events. b. The staff reviewed the FLEX connection points to verify that at least one connection point is accessible through a seismically robust structure.
The water source (i.e.,Altamaha River) for the core cooling and SFP cooling strategies is supplied by the FLEX pumps to the seismically qualified residual heat removal service water (RHRSW) piping via FLEX connections within the intake structure valve pit. The existing missile shield grating protects these connections and the associated piping. A new permanent platform is provided to allow plant personnel to access the new FLEX inlet valves in the intake structure valve pit. In addition, a new ladder is installed to allow plant personnel access to the new FLEX connections.
The new platform and ladder are installed in a seismic Category I structure (Intake Structure), as well as in the vicinity of existing safety-related piping and valves. Permanent conduits are installed and routed from the 600 V bus inside the control building to a seismically mounted FLEX connection box (one per unit) in the west cableway.
Two seismically robust, wind-rated, protected penetrations (one per division) have been installed to provide protection to the new connection box located inside the west cableway, near the penetration.
: c. The staff walked down the deployment routes and the debris removal equipment.
The licensee indicated that the primary and alternate routes for transporting FLEX equipment have been established.
Debris removal will be accomplished using a front loader. The licensee evaluated the potential obstacles to ensure that the front loader is capable of removing all potential debris. Four hours has been allocated for debris removal as documented in the Hatch Phase 2 staffing study. The front loader will be stored in the FLEX Dome along with a freightliner truck and an additional truck to haul vehicles.
: d. The staff reviewed the hydraulic analysis for the FLEX pumps and hoses used for all areas for makeup after an ELAP. The licensee provided the calculations for the primary and alternative connections and hydraulic analyses for the hose runs for reactor pressure vessel (RPV) and SFP makeup. The licensee intends to use the FLEX pump for condensate tank makeup after the 7.5 hour timeframe for makeup to the RPV via RCIC. Alternatively, the FLEX pump can be staged near the Intake Structure in order to take suction from the Altamaha River for injection into the RPV via RHRSW piping to RHR.. In the hydraulic analysis, the licensee concluded that the FLEX pump is capable of satisfying the minimum required flow to both units for makeup to the RPV and SFP during an ELAP event. The licensee also provided the hose lengths needed to maintain the minimum flow requirement, since the strategy accounts for both makeup functions to occur together when the RHRSW is the makeup source. e. The staff reviewed the robustness of the condensate storage tanks (CSTs). The licensee stated that the CSTs are credited for the use of the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) suctions for injection due to the tanks being protected from tornado missiles and seismic hazards. The enclosure walls surrounding the tanks provide protection from tornado missiles and are designed as seismic Category I structures.
The CST is designed to prevent the usage of a credited amount of water in the tank by systems other than RCIC and HPCI. Instrumentation and controls, system piping and valves associated with the RCIC and HPCI suction swap-over function are safety grade and seismic, and are qualified for all potential ELAP events. The suction valves will be aligned according to existing procedures, either from the main control room or a remote control panel. The licensee noted that although other water sources are available for CST makeup, the Altamaha River would be the primary source of makeup utilizing the FLEX pumps once the CST inventory is depleted after 10 hours. f. The licensee plans to replenish water supplies by using portable FLEX pumps taking suction from the Ultimate Heat Sink (Altamaha River). The staff verified that the FLEX pumps and hoses will remain unhindered and clear of debris accumulation due to the pumps taking suction from an untreated water source. The licensee described the FLEX pump as being designed with two submersible pumps, in which both submersible pumps operate during the operation of the main pump. Each submersible pump is encased in a mesh screen cage, thereby limiting the size of debris that can be sucked into the pump. Each submersible pump supplies enough flow for both units' FLEX needs, therefore, if one submersible pump becomes completely clogged, the other is sufficient to supply the main pump with the necessary flow. These pumps are required to be in service at 10 hours after the initiation of the ELAP. Supplemental personnel begin arriving at 6 hours after the start of the ELAP, which allows for adequate manpower to remove a submersible pump from the river and clean the pump casing and return it to the river. Each submersible pump has individual hydraulic lines used to power the pump and each pump has two discharge pipes supplying the main pump. The licensee noted that the design of pumps prevents an issue with one pump from debilitating the other. 4.0 Exit Meeting (October 29. 2015) The NRC staff audit team conducted an exit meeting with the licensee staff following the closure of onsite audit activities.
The NRC staff highlighted items reviewed and noted that the results of the onsite audit trip will be documented in this report. CONCLUSION The NRC staff completed all three parts of the September 29, 2015, onsite audit plan. Each audit item listed in Part 2 of the plan was reviewed by NRC staff members while on site. In addition to the list of NRC and licensee onsite audit staff participants in Attachment 1, Attachment 2 provides a list of documents reviewed during the onsite audit portion. In support of the continuing audit process as the licensee proceeds towards orders compliance for this site, the NRC staff is evaluating the audit items listed below in anticipation of issuance of a combined safety evaluation for both the Mitigation Strategies and Spent Fuel Pool Level Instrumentation orders. a. Interim Staff Evaluation (ISE) Open Items (Ols) and Confirmatory Items (Cls) b. Audit Questions (AQs) c. Licensee-identified Overall Integrated Plan (OIP) Open Items (Ols) d. Spent Fuel Pool Level Instrumentation Requests for Additional Information (RAls) e. Additional Safety Evaluation (SE) needed information The attachments provide audit information as follows: a. Attachment 1: List of NRC staff and licensee staff audit participants
: b. Attachment 2: List of documents reviewed during the onsite audit While this report notes the completion of the onsite portion of the audit per the audit plan dated September 29, 2015, the ongoing audit process continues as per the letters dated August 28, 2013, and March 26, 2014, to all licensees and construction permit holders for both orders. Additionally, while this audit report provides a progress snapshot of the NRC staff's review of the licensee's OIPs, as supplemented, and as augmented in the audit process, the status and progress of the NRC staff's review may change based on licensee plan changes, resolution of generic issues, and other NRC staff concerns not previously documented.
Changes in the NRC staff review will be communicated in the ongoing audit process. Lastly, the licensee has identified open items that need to be completed to implement orders EA-12-049 and EA-12-051, and the staff expects that the licensee continue to provide updates on the status of the licensee identified open items in their 6-month updates or on the ePortal. Attachments:
: 1. NRC and Licensee Staff Onsite Audit Participants
: 2. Onsite Audit Documents Reviewed Onsite Audit Participants NRC Staff: Jason Paige NRR/JLD/JOMB Josh Miller NRR/JLD/JERB Garry Armstrong NRR/JLD/JCBB Due Nguyen NRR/JLD/JERB Matthew McConnell NRR/JLD/JERB Bruce Heida NRR/JLD/JCBB Hatch Staff: David R. Vineyard Richard A. (Tony) Spring Robert J. Anderson Andy Belcher Anthony D. Giancatarino Greg L. Johnson Daniel Adam Komm Keith D. Long Jonathan M. Merritt Pat Swinson Al M. Wheeler J. Derwood Tootle Randy C. Bunt John M. Giddens Matthew R. Euten Deep Ghosh Brad Osterbuhr John Cole Frank D. Sellers Blake Bolt Lee S. Williams David H. Giddens Ronnie D. Musgrove Rob Brixey April Perkins Bryan Hess Josef Barrick Stacey Fredenberg Norman Good Michael Hopman Site Vice President Plant Manager Radiation Protection Manager Nuclear Oversight Manager -Site Engineering Director Site Regulatory Affairs Manager Operations Director Work Management Director Site Security Management IT Manager Site Project Manager Severe Accident Management Manager Corporate Severe Accident Management Manager Corporate Licensing Manager Licensing Engineer Lead Engineer Senior Engineer Senior Engineer Security Shift Lieutenant Work Week Manager Flex PM Writer/Contractor Flex Procedure Writer/ X-SRO/Contractor Flex Procedure Writer/X-SRO/Contractor Training Procedure Writer/Contractor Senior Engineer Bechtel/ Mechanical Design Supervisor Enercon/ Electrical Engineer Enercon/Lead Mechanical Engineer Sargent &Lundy/ l&C Engineer Bechtel/ Mechanical Design Engineer Attachment 1
Documents Reviewed
Documents Reviewed
* Calculation A-47402, 600V FLEX Diesel Generator Sizing Calculation, Revision 0
* Calculation A-47402, 600V FLEX Diesel Generator Sizing Calculation, Revision 0
Line 101: Line 110:
* Calculation SMNH-14-001, FLEX Battery Room Hydrogen Generation, Revision 1
* Calculation SMNH-14-001, FLEX Battery Room Hydrogen Generation, Revision 1
* Calculation SENH-13-001, Station Battery Battery 1A SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-001, Station Battery Battery 1A SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-002, Station Battery Battery 1 B SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-002, Station Battery Battery 1B SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-003, Station Battery Battery 2A SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-003, Station Battery Battery 2A SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-004, Station Battery Battery 2B SBO Extended Coping Time Study, Revision 1
* Calculation SENH-13-004, Station Battery Battery 2B SBO Extended Coping Time Study, Revision 1
Line 110: Line 119:
* Procedure NMP-OS-019-281, Hatch Unit 2 SIG-1, 4160V Alternate Power, Revision 1
* Procedure NMP-OS-019-281, Hatch Unit 2 SIG-1, 4160V Alternate Power, Revision 1
* Procedure NMP-OS-019-222, Hatch Unit 2 SIG-2, 600V Alternate Power, Revision 1
* Procedure NMP-OS-019-222, Hatch Unit 2 SIG-2, 600V Alternate Power, Revision 1
* Document FHC-S-13-001 I X 1 AR50, Procurement Specification for the FLEX Equipment Storage Building for Edwin I. Hatch Nuclear Plant, Units 1 & 2, Revision 0
* Document FHC-S-13-001 I X 1AR50, Procurement Specification for the FLEX Equipment Storage Building for Edwin I. Hatch Nuclear Plant, Units 1 & 2, Revision 0
* Calculation SCNH-14-050, Qualification of FLEX Tornado Missile Protection for West Cableway Roof Slab Penetrations, Revision 0
* Calculation SCNH-14-050, Qualification of FLEX Tornado Missile Protection for West Cableway Roof Slab Penetrations, Revision 0
* Procedure NMP-OS-019-254, Hatch Unit C Sig-11 Critical Instrumentation, Draft
* Procedure NMP-OS-019-254, Hatch Unit C Sig-11 Critical Instrumentation, Draft
Line 118: Line 127:
* Document SNC476666, U1 FLEX CST Makeup, Revision O
* Document SNC476666, U1 FLEX CST Makeup, Revision O
* Document SNC467 489, U2 FLEX CST Makeup, Revision 0
* Document SNC467 489, U2 FLEX CST Makeup, Revision 0
* Vendor Document A-47460, FLEX Portable System -FLEX Pump Vendor Manual, Revision 0
* Vendor Document A-47460, FLEX Portable System - FLEX Pump Vendor Manual, Revision 0
* Vendor Document A-47462, FLEX Portable System -Phase 2 600V Diesel Generator Vendor Manual, Revision 0
* Vendor Document A-47462, FLEX Portable System - Phase 2 600V Diesel Generator Vendor Manual, Revision 0
* Calculation SMNH-13-002, RCIC Room Heat-Up Room Temperature During An Extended Loss of A/C Power, Revision 1
* Calculation SMNH-13-002, RCIC Room Heat-Up Room Temperature During An Extended Loss of A/C Power, Revision 1
* Document A-47429, On-Site FLEX Equipment Fuel Consumption, Revision 0
* Document A-47429, On-Site FLEX Equipment Fuel Consumption, Revision 0
* Calculation SNC467474 E003, "Edwin I. Hatch Nuclear Plant Unit No. 2 Single Line Diagram 600V Bus 2C & 2D," Proposed Revision 2 Attachment 2
* Calculation SNC467474 E003, "Edwin I. Hatch Nuclear Plant Unit No. 2 Single Line Diagram 600V Bus 2C & 2D," Proposed Revision 2 Attachment 2
C. Pierce If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.
 
Docket Nos. 50-321 and 50-366  
C. Pierce                                       If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.
Sincerely, IRA Michael Brown Acting for/
Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366


==Enclosure:==
==Enclosure:==


Audit report Sincerely, IRA Michael Brown Acting for/ Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation cc w/encl: Distribution via Listserv DISTRIBUTION:
Audit report cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC JOMB R/F RidsNrrDorllpl 2-1 Resource RidsNrrPMHatchResource RidsNrrLASLent Resource ADAMS Accession No. ML 15349A801 OFFICE NRR/JLD/JOMB/PM NAME JPaige* DATE 12/15/15 OFFICE NRR/JLD/JOMB/BC(A)
PUBLIC                                             RidsRgn2MailCenter Resource JOMB R/F                                           SBailey, NRR/JLD RidsNrrDorllpl 2-1 Resource                         MHalter, NRR/JLD RidsNrrPMHatchResource                             RidsAcrsAcnw_MailCTR Resource RidsNrrLASLent Resource ADAMS Accession No. ML15349A801                                *via email OFFICE NRR/JLD/JOMB/PM           NRR/JLD/LA               NRR/JLD/JCBB/BC(A)   NRR/JLD/JERB/BC NAME      JPaige*                Slent                   BTitus*             SBailey (Jlehning for)*
NAME MHalter* DATE 12/21/15 RidsRgn2MailCenter Resource SBailey, NRR/JLD MHalter, NRR/JLD RidsAcrsAcnw_MailCTR Resource *via email NRR/JLD/LA NRR/JLD/JCBB/BC(A)
DATE      12/15/15               12/15/15                12/17/15             1/5/16 OFFICE    NRR/JLD/JOMB/BC(A)      NRR/JLD/JOMB/PM NAME      MHalter*                JPaige (MBrown for)
NRR/JLD/JERB/BC Slent BTitus* SBailey (Jlehning for)* 12/15/15 12/17/15 1/5/16 NRR/JLD/JOMB/PM JPaige (MBrown for) 1/13/16 OFFICIAL AGENCY RECORD}}
DATE      12/21/15                1/13/16 OFFICIAL AGENCY RECORD}}

Latest revision as of 06:52, 5 February 2020

Edwin I Hatch Nuclear Plant, Units 1 and 2- Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051
ML15349A801
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 01/13/2016
From: Jason Paige
Japan Lessons-Learned Division
To: Pierce C
Southern Nuclear Operating Co
Paige, Jason NRR/JLD 415-3597
References
EA-12-049, EA-12-051, TAC MF0712, TAC MF0713, TAC MF0721, TAC MF0722
Download: ML15349A801 (13)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 13, 2016 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

P.O. Box 1295 /BIN B038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 - REPORT FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0712, MF0713, MF0721, AND MF0722)

Dear Mr. Pierce:

On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of of each order will be achieved.

By letter dated February 27, 2013 (ADAMS Accession No. ML13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049. By letters dated August 27, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A238, ML14057A776, ML14239A650, ML15057A315. and ML152398301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28. 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit.

C. Pierce By letter dated February 27, 2013 (ADAMS Accession No. ML13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051. By letter dated August 1, 2013 (ADAMS Accession No. ML13203A118), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A236, ML13242A293, ML14057A778, ML14239A298, ML15057A273, and ML15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML13294A529). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents/Final Integrated Plans while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 - 29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML15266A345). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.

The enclosed audit report provides a summary of the activities for the onsite audit portion.

Additionally, this report contains attachments listing the attendees and documents reviewed by the staff while onsite.

C. Pierce If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.

J:(\~ ~o~

Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosure:

Audit report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS AND RELIABLE SPENT FUEL POOL INSTRUMENTATION SOUTHERN NUCLEAR OPERATING COMPANY EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. 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" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 1O of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how complian.ce with the requirements of of each order will be achieved.

By letter dated February 27, 2013 (ADAMS Accession No. ML13059A385), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted its OIP for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), in response to Order EA-12-049. By letters dated August 27, 2013, February 26, 2014, August 26. 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A238, ML14057A776, ML14239A650, ML15057A315, and ML15239B301, respectively), SNC submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Hatch interim staff evaluation (ISE) (ADAMS Accession No. ML13364A202) on February 27, 2014, and continues with in-office and onsite portions of this audit.

Enclosure

By letter dated February 27, 2013 (ADAMS Accession No. ML13059A389), the licensee submitted its OIP for Hatch in response to Order EA-12-051. By letter dated August 1, 2013 (ADAMS Accession No. ML13203A118), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated August 27, 2013, August 29, 2013, February 26, 2014, August 26, 2014, February 26, 2015, and August 27, 2015 (ADAMS Accession Nos. ML13240A236, ML13242A293, ML14057A778, ML14239A298, ML15057A273, and ML15239B262, respectively), the licensee submitted its RAI responses and six-month updates to the OIP. The NRC staff's review of these submittals led to the issuance of the Hatch ISE and RAI dated October 28, 2013 (ADAMS Accession No. ML13294A529). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs) while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Hatch from October 26 - 29, 2015, per the audit plan dated September 29, 2015 (ADAMS Accession No. ML15266A345). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussion, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML12242A378), as endorsed, by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) 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"' (ADAMS Accession No. ML12229A174) as providing one acceptable means of meeting the order requirements. For Order EA-12-051, the staff will make a safety determination regarding order compliance using the NEI guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12221A339) as providing one acceptable means of meeting the order requirements. Should the licensee propose an

alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate if the alternative strategy complies with the applicable order.

AUDIT ACTIVITIES The onsite audit was conducted at the Hatch facility from October 26, 2015, through October 29, 2015. The NRC audit team staff was as follows:

Title Team Member Tearn Lead I Project ManaQer Jason PaiQe Technical Support Garry Armstrong Technical Support Matthew McConnell Technical Support Joshua Miller Technical Support Due NQuven Technical Support Bruce Heida The NRC staff executed the onsite portion of the audit per the three part approach discussed in the September 29, 2015, plan, to include conducting a tabletop discussion of the site's integrated mitigating strategies compliance program, a review of specific technical review items, and discussion of specific program topics. Activities that were planned to support the above included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.

AUDIT

SUMMARY

1.0 Entrance Meeting (October 26. 2015)

At the audit entrance meeting, the NRC staff audit team introduced itself followed by introductions from the licensee's staff. The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule.

2.0 Integrated Mitigating Strategies Compliance Program Overview Per the audit plan and as an introduction to the site's program, the licensee provided a presentation to the NRC audit team titled "Hatch FLEX Presentation." The licensee provided an overview of its strategy to maintain core cooling, containment, and SFP cooling in the event of a beyond-design-basis external event (BDBEE), and the plant modifications being done in order to implement the strategies. Also presented was the design and location of the FLEX equipment storage facility, the FLEX equipment that would be stored there, the interface with the National SAFER Response Centers (NSRCs), and the spent fuel pool level indication modification.

3.0 Onsite Audit Technical Discussion Topics Based on the audit plan, and with a particular emphasis on the Part 2 "Specific Technical Review Items," the NRC staff technical reviewers conducted interviews with licensee technical staff, site walk-downs, and detailed document review for the items listed in the plan.

3.1 Reactor Systems Technical Discussions and Walk-Downs The NRC staff reviewed the licensee's modeling of an extended loss of all alternating current (ac) power (ELAP) for Hatch and its ability to mitigate the event, including the computer code Modular Accident Analysis Program (MAAP) used and input parameters assumed to generate the results of the analysis. The licensee noted that the MAAP analysis was carried out in accordance with EPRI 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications," dated June 2013. In addition, the licensee indicated that EPRI later released the BWR (boiling water reactor] roadmap EPRI 3002002749, "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4." The licensee followed the BWR template for Hatch using site specific information. The licensee's analysis confirmed that the collapsed vessel level would not fall below the top of active fuel, and confirmed that the cooldown rate for the primary system would remain within the technical specification limits.

3.2 Electrical Technical Discussions and Walk-Downs The NRC staff reviewed Hatch's load shedding procedures, FLEX diesel generator (DG) sizing calculations, manufacturer's specifications, and FLEX Support Guidelines (FSGs) to confirm that they are of sufficient capacity to supply the expected loads. The licensee calculated that the direct current system can provide power to the required BDBEE loads for at least 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> given that load shedding is completed within 75 minutes of an ELAP being declared. The licensee plans to connect the FLEX DGs within 1O hrs. The licensee indicated that Hatch's Phase 2 electrical strategy is to connect the FLEX DGs directly to the 600 V busses. The alternate strategy is to connect directly to the battery charger disconnects using cables. For Phase 3, the licensee can connect the NSRC DGs to the 4160 V busses 1E and 2E. The alternate strategy is to connect the DGs to the 4160 V busses 1G and 2G. The licensee noted that the Phase 2 DGs have been checked for phase rotation in comparison to plant typical rotation. In addition, color coding of the extension cables has been used to ensure that proper phase rotation will be achieved when cables are connected from the pigtails supplied on the generator to the connections at the breaker into the plant electrical supply. Lastly, the licensee generated a corrective action to enhance or verify that any and all procedures developed for connecting a DG received from the NSRCs will be checked for proper phase rotation prior to being placed in service to supply plant electrical loads during an ELAP event.

3.3 SFPI Technical Discussions and Walk-Downs The NRC staff walked down the SFP area, SFPI locations, and related equipment mounting areas. No concerns were identified during the walk-downs. The staff also reviewed the associated calibration, maintenance, and test procedures for the SFP level instrumentation.

3.4 Other Technical Discussion Areas and Walk-Downs

a. The staff reviewed design documents of the FLEX equipment storage location to verify that adequate capability would exist to mitigate a BDBEE. In addition, the staff walked down the storage location of the FLEX equipment. The licensee indicated that the storage location for the FLEX portable equipment will be the new FLEX dome, which is designed to protect the equipment from all external hazards as described in NEI 12-06.

Originally, the licensee's strategy included two FLEX storage locations, therefore, the licensee stated that the evaluation for axis of separation for multiple locations is no longer needed with the new FLEX dome in place, which can protect from tornado missiles and design basis high wind events.

b. The staff reviewed the FLEX connection points to verify that at least one connection point is accessible through a seismically robust structure. The water source (i.e.,Altamaha River) for the core cooling and SFP cooling strategies is supplied by the FLEX pumps to the seismically qualified residual heat removal service water (RHRSW) piping via FLEX connections within the intake structure valve pit. The existing missile shield grating protects these connections and the associated piping. A new permanent platform is provided to allow plant personnel to access the new FLEX inlet valves in the intake structure valve pit. In addition, a new ladder is installed to allow plant personnel access to the new FLEX connections. The new platform and ladder are installed in a seismic Category I structure (Intake Structure), as well as in the vicinity of existing safety-related piping and valves. Permanent conduits are installed and routed from the 600 V bus inside the control building to a seismically mounted FLEX connection box (one per unit) in the west cableway. Two seismically robust, wind-rated, missile-protected penetrations (one per division) have been installed to provide protection to the new connection box located inside the west cableway, near the penetration.
c. The staff walked down the deployment routes and the debris removal equipment. The licensee indicated that the primary and alternate routes for transporting FLEX equipment have been established. Debris removal will be accomplished using a front loader. The licensee evaluated the potential obstacles to ensure that the front loader is capable of removing all potential debris. Four hours has been allocated for debris removal as documented in the Hatch Phase 2 staffing study. The front loader will be stored in the FLEX Dome along with a freightliner truck and an additional truck to haul vehicles.
d. The staff reviewed the hydraulic analysis for the FLEX pumps and hoses used for all areas for makeup after an ELAP. The licensee provided the calculations for the primary and alternative connections and hydraulic analyses for the hose runs for reactor pressure vessel (RPV) and SFP makeup. The licensee intends to use the FLEX pump for condensate tank makeup after the 7.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> timeframe for makeup to the RPV via RCIC. Alternatively, the FLEX pump can be staged near the Intake Structure in order to take suction from the Altamaha River for injection into the RPV via RHRSW piping to RHR.. In the hydraulic analysis, the licensee concluded that the FLEX pump is capable of satisfying the minimum required flow to both units for makeup to the RPV and SFP during an ELAP event. The licensee also provided the hose lengths needed to maintain the minimum flow requirement, since the strategy accounts for both makeup functions to occur together when the RHRSW is the makeup source.
e. The staff reviewed the robustness of the condensate storage tanks (CSTs). The licensee stated that the CSTs are credited for the use of the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) suctions for injection due to the tanks being protected from tornado missiles and seismic hazards. The enclosure walls surrounding the tanks provide protection from tornado missiles and are designed as seismic Category I structures. The CST is designed to prevent the usage of a credited amount of water in the tank by systems other than RCIC and HPCI.

Instrumentation and controls, system piping and valves associated with the RCIC and HPCI suction swap-over function are safety grade and seismic, and are qualified for all potential ELAP events. The suction valves will be aligned according to existing procedures, either from the main control room or a remote control panel. The licensee noted that although other water sources are available for CST makeup, the Altamaha River would be the primary source of makeup utilizing the FLEX pumps once the CST inventory is depleted after 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

f. The licensee plans to replenish water supplies by using portable FLEX pumps taking suction from the Ultimate Heat Sink (Altamaha River). The staff verified that the FLEX pumps and hoses will remain unhindered and clear of debris accumulation due to the pumps taking suction from an untreated water source. The licensee described the FLEX pump as being designed with two submersible pumps, in which both submersible pumps operate during the operation of the main pump. Each submersible pump is encased in a mesh screen cage, thereby limiting the size of debris that can be sucked into the pump.

Each submersible pump supplies enough flow for both units' FLEX needs, therefore, if one submersible pump becomes completely clogged, the other is sufficient to supply the main pump with the necessary flow. These pumps are required to be in service at 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the initiation of the ELAP. Supplemental personnel begin arriving at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the start of the ELAP, which allows for adequate manpower to remove a submersible pump from the river and clean the pump casing and return it to the river.

Each submersible pump has individual hydraulic lines used to power the pump and each pump has two discharge pipes supplying the main pump. The licensee noted that the design of pumps prevents an issue with one pump from debilitating the other.

4.0 Exit Meeting (October 29. 2015)

The NRC staff audit team conducted an exit meeting with the licensee staff following the closure of onsite audit activities. The NRC staff highlighted items reviewed and noted that the results of the onsite audit trip will be documented in this report.

CONCLUSION The NRC staff completed all three parts of the September 29, 2015, onsite audit plan. Each audit item listed in Part 2 of the plan was reviewed by NRC staff members while on site. In addition to the list of NRC and licensee onsite audit staff participants in Attachment 1, provides a list of documents reviewed during the onsite audit portion.

In support of the continuing audit process as the licensee proceeds towards orders compliance for this site, the NRC staff is evaluating the audit items listed below in anticipation of issuance of a combined safety evaluation for both the Mitigation Strategies and Spent Fuel Pool Level Instrumentation orders.

a. Interim Staff Evaluation (ISE) Open Items (Ols) and Confirmatory Items (Cls)
b. Audit Questions (AQs)
c. Licensee-identified Overall Integrated Plan (OIP) Open Items (Ols)
d. Spent Fuel Pool Level Instrumentation Requests for Additional Information (RAls)
e. Additional Safety Evaluation (SE) needed information The attachments provide audit information as follows:
a. Attachment 1: List of NRC staff and licensee staff audit participants
b. Attachment 2: List of documents reviewed during the onsite audit While this report notes the completion of the onsite portion of the audit per the audit plan dated September 29, 2015, the ongoing audit process continues as per the letters dated August 28, 2013, and March 26, 2014, to all licensees and construction permit holders for both orders.

Additionally, while this audit report provides a progress snapshot of the NRC staff's review of the licensee's OIPs, as supplemented, and as augmented in the audit process, the status and progress of the NRC staff's review may change based on licensee plan changes, resolution of generic issues, and other NRC staff concerns not previously documented. Changes in the NRC staff review will be communicated in the ongoing audit process.

Lastly, the licensee has identified open items that need to be completed to implement orders EA-12-049 and EA-12-051, and the staff expects that the licensee continue to provide updates on the status of the licensee identified open items in their 6-month updates or on the ePortal.

Attachments:

1. NRC and Licensee Staff Onsite Audit Participants
2. Onsite Audit Documents Reviewed

Onsite Audit Participants NRC Staff:

Jason Paige NRR/JLD/JOMB Josh Miller NRR/JLD/JERB Garry Armstrong NRR/JLD/JCBB Due Nguyen NRR/JLD/JERB Matthew McConnell NRR/JLD/JERB Bruce Heida NRR/JLD/JCBB Hatch Staff:

David R. Vineyard Site Vice President Richard A. (Tony) Spring Plant Manager Robert J. Anderson Radiation Protection Manager Andy Belcher Nuclear Oversight Manager - Site Anthony D. Giancatarino Engineering Director Greg L. Johnson Site Regulatory Affairs Manager Daniel Adam Komm Operations Director Keith D. Long Work Management Director Jonathan M. Merritt Site Security Management Pat Swinson IT Manager Al M. Wheeler Site Project Manager J. Derwood Tootle Severe Accident Management Manager Randy C. Bunt Corporate Severe Accident Management Manager John M. Giddens Corporate Licensing Manager Matthew R. Euten Licensing Engineer Deep Ghosh Lead Engineer Brad Osterbuhr Senior Engineer John Cole Senior Engineer Frank D. Sellers Security Shift Lieutenant Blake Bolt Work Week Manager Lee S. Williams Flex PM Writer/Contractor David H. Giddens Flex Procedure Writer/ X-SRO/Contractor Ronnie D. Musgrove Flex Procedure Writer/X-SRO/Contractor Rob Brixey Training Procedure Writer/Contractor April Perkins Senior Engineer Bryan Hess Bechtel/ Mechanical Design Supervisor Josef Barrick Enercon/ Electrical Engineer Stacey Fredenberg Enercon/Lead Mechanical Engineer Norman Good Sargent &Lundy/ l&C Engineer Michael Hopman Bechtel/ Mechanical Design Engineer Attachment 1

Documents Reviewed

  • Calculation A-47402, 600V FLEX Diesel Generator Sizing Calculation, Revision 0
  • Calculation A-47404, Phase 2 600V Alternate Power Subsystem Diesel Generator Cable Evaluation, Revision 0
  • Calculation A-47407, Phase 2 Switchgear Room and Battery Rooms Ventilation Subsystems Sizing for Portable Diesel Generator and Cables, Revision 0
  • Calculation A-47400, Pump Sizing Evaluation for Hatch Units 1 and 2 Core Cooling Phase 2, Revision 0
  • Calculation A-47406, Diesel Fuel Transfer and Pump Sizing, Revision 0
  • Calculation A-47429, On-site FLEX Equipment Fuel Consumption, Revision 0
  • Calculation SMNH-12-032, Containment Analysis of FLEX Strategies, Revision 3
  • Calculation SMNH-14-001, FLEX Battery Room Hydrogen Generation, Revision 1
  • Calculation SENH-13-001, Station Battery Battery 1A SBO Extended Coping Time Study, Revision 1
  • Calculation SENH-13-002, Station Battery Battery 1B SBO Extended Coping Time Study, Revision 1
  • Calculation SENH-13-003, Station Battery Battery 2A SBO Extended Coping Time Study, Revision 1
  • Calculation SENH-13-004, Station Battery Battery 2B SBO Extended Coping Time Study, Revision 1
  • Calculation 31 EO-TSG-003-1, Extended Loss of AC Power (ELAP), Revision 1
  • Calculation 31 EO-TSG-003-2, Extended Loss of AC Power (ELAP), Revision 1
  • Procedure NMP-OS-019-261, Hatch Unit 1 SIG-1, 4160V Alternate Power, Revision 1
  • Procedure NMP-OS-019-262, Hatch Unit 1 SIG-2, 600V Alternate Power, Revision 1
  • Procedure NMP-OS-019-281, Hatch Unit 2 SIG-1, 4160V Alternate Power, Revision 1
  • Procedure NMP-OS-019-222, Hatch Unit 2 SIG-2, 600V Alternate Power, Revision 1
  • Document FHC-S-13-001 I X 1AR50, Procurement Specification for the FLEX Equipment Storage Building for Edwin I. Hatch Nuclear Plant, Units 1 & 2, Revision 0
  • Procedure NMP-OS-019-254, Hatch Unit C Sig-11 Critical Instrumentation, Draft
  • Procedure 34AB-Y22-002, Naturally Occurring Phenomena, Revision 2
  • Document SNC476653, U1 FLEX Core Cooling, Revision O
  • Document SNC467488, U2 FLEX Core Cooling, Revision 0
  • Document SNC476666, U1 FLEX CST Makeup, Revision O
  • Document SNC467 489, U2 FLEX CST Makeup, Revision 0
  • Vendor Document A-47460, FLEX Portable System - FLEX Pump Vendor Manual, Revision 0
  • Vendor Document A-47462, FLEX Portable System - Phase 2 600V Diesel Generator Vendor Manual, Revision 0
  • Calculation SMNH-13-002, RCIC Room Heat-Up Room Temperature During An Extended Loss of A/C Power, Revision 1
  • Document A-47429, On-Site FLEX Equipment Fuel Consumption, Revision 0
  • Calculation SNC467474 E003, "Edwin I. Hatch Nuclear Plant Unit No. 2 Single Line Diagram 600V Bus 2C & 2D," Proposed Revision 2 Attachment 2

C. Pierce If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.

Sincerely, IRA Michael Brown Acting for/

Jason C. Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosure:

Audit report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsRgn2MailCenter Resource JOMB R/F SBailey, NRR/JLD RidsNrrDorllpl 2-1 Resource MHalter, NRR/JLD RidsNrrPMHatchResource RidsAcrsAcnw_MailCTR Resource RidsNrrLASLent Resource ADAMS Accession No. ML15349A801 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JCBB/BC(A) NRR/JLD/JERB/BC NAME JPaige* Slent BTitus* SBailey (Jlehning for)*

DATE 12/15/15 12/15/15 12/17/15 1/5/16 OFFICE NRR/JLD/JOMB/BC(A) NRR/JLD/JOMB/PM NAME MHalter* JPaige (MBrown for)

DATE 12/21/15 1/13/16 OFFICIAL AGENCY RECORD

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